Privacy Policy

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Subject of this document

This privacy policy (hereinafter the “policy”) provides more information regarding the processing of personal data by Procaryote, a company specialized in publishing web and mobile applications. Procaryote processes personal data in accordance with this privacy statement.

The privacy of users of websites and applications providing personal data to Procaryote is very important to Procaryote. Procaryote only uses all personal data provided by the user for the purposes specified in this policy and complies with the applicable data protection laws and regulations, including the European Regulation 2016/679 of April 27, 2016 (General Data Protection Regulation or GDPR).

By accessing and using our websites or applications, you expressly declare that you accept the following general terms.

Processing purposes

Procaryote collects and processes customers’ personal data for customer and order management purposes (e.g., customer administration, order follow-up and/or deliveries, invoicing, creditworthiness monitoring, profiling, and sending marketing and personalized advertising).

Furthermore, Procaryote may also anonymize the user’s personal data under its own responsibility, to enable further processing and transfer to third parties for scientific purposes. After this anonymization, the user’s identity can no longer be linked in any way to the data from this user, so that the user’s privacy is not compromised, and the GDPR no longer applies.

Procaryote may also process non-anonymized user personal data, under its own responsibility, to improve its own services. This will only be done with the user’s consent and after pseudonymization of the user’s data so that the Procaryote employee can no longer see the user’s name.

Confidential processing by Procaryote

Procaryote acknowledges that the user’s personal data is strictly confidential.

Except with the user’s informed consent and/or when necessary for a doctor or hospital in the context of treating a patient and/or in the context of legal authorizations or obligations and/or by court order and/or for the initiation, exercise, or justification of legal proceedings, Procaryote will not disclose personal data to any third party.

The persons who may have access to personal data as part of the service are:

• Procaryote employees and subcontractors responsible for collecting, processing, managing, and reviewing personal data;

• Procaryote employees and subcontractors in charge of quality and security management;

• Persons responsible at Procaryote for verifying the employees and subcontractors of Procaryote;

• Any party for whom a doctor or patient instructs Procaryote to release;

• Any other person authorized to access under applicable legislation.

Procaryote raises awareness among the aforementioned individuals about the importance of the confidential processing of personal data and has them sign, if necessary, a confidentiality statement in addition to the agreement concluded with them.

If necessary to achieve the set objectives, the user’s personal data will be shared with third parties within the European Economic Area directly affiliated with Procaryote or Procaryote partners;

Procaryote guarantees that these recipients will take all necessary technical and organizational measures to protect personal data.

Protection of personal data

Procaryote takes appropriate technical and organizational measures (such as pseudonymization) to protect personal data against loss or any type of unlawful processing or access. These measures ensure an appropriate level of security, considering the state of the art and associated costs.

Data storage

The user agrees that Procaryote stores users’ personal data in electronic archives and/or databases, created and managed by Procaryote, in the form in which this personal data is received or any other derived form used by Procaryote. Procaryote may use third-party service providers for personal data storage, which are in principle established within the European Economic Area. If Procaryote uses service providers established outside the European Economic Area, it will take the necessary measures to ensure an equivalent level of protection for personal data in accordance with articles 44 to 49 of the General Data Protection Regulation.

Procaryote will not retain personal data longer than necessary to provide the service and to improve this service. As soon as personal data is no longer needed or at the user’s request, Procaryote will delete personal data, unless the storage of personal data is or becomes mandatory.

Secure communication

The user agrees that the communication of personal data to Procaryote is done electronically, and that any form of communication carries the risk of interception, misdelivery, or loss. Procaryote is not responsible for communication errors that are not attributable to it.

Rights of doctors and patients regarding their personal data

The rights of doctors and patients related to the processing of their personal data by Procaryote are explained below.

The patient can always exercise their rights related to the processing of their personal data by Procaryote by contacting their attending physician on whose behalf Procaryote processes the personal data. As a doctor, you have the following rights vis-à-vis Procaryote.

If the patient has a request related to the processing of their personal data by Procaryote only for Procaryote’s own needs (service improvement or anonymization for scientific research), the patient should be aware that Procaryote only processes their personal data for these purposes in such a way that the patient concerned cannot be identified. If the patient wishes to exercise their rights over this personal data, Procaryote may ask the patient to provide additional personal data to identify the patient. After identification, you as the patient will have the following rights.

Right of access and copy

• Access: You always have the right to freely access the personal data that Procaryote processes about you, unless such access is excluded by law. You also have the right to receive certain information about this processing. Specifically, you have the right to the following information:

• The existence or non-existence of the processing of your personal data;

• The personal data itself;

• The purposes of the processing of these personal data;

• The categories of personal data and their retention period;

• The categories of recipients to whom these personal data will be provided;

• Your rights regarding these personal data;

• The source of these personal data, if not collected from you directly.

• Copy: You also have the right to receive a free copy of your personal data, to the extent that you can access it in accordance with the GDPR. If you wish to receive multiple copies of the same information, Procaryote reserves the right to charge you an administrative fee for this.

Right to rectification

You also have the right to have any incorrect or incomplete personal data processed corrected or supplemented free of charge.

You may also request that your personal data be temporarily no longer processed (except in certain statutory cases) until the accuracy or completeness of your personal data has been verified and any inaccuracies/omissions have been corrected (except in certain legal cases - see also the “right to restriction of processing” section).

Right to portability

With regard to personal data processed automatically (by computer), you also have the right to request that Procaryote transfer a copy of your personal data in a machine-readable format (e.g., XML) and/or directly to another institution or person of your choice. This right only applies to the personal data you have provided yourself and only if the processing by Procaryote is based on your consent.

Right to withdraw consent

When Procaryote processes your personal data based on your consent, you always have the right to withdraw this consent. In that case, Procaryote will no longer process your personal data. However, this does not affect the lawfulness of the processing before the withdrawal of your consent. When you withdraw your consent, you can also request that your personal data be deleted at the same time. See also the “right to deletion” section.

Right to deletion

If you believe that your personal data can no longer be processed (e.g., because this data is no longer needed or because it is processed unlawfully), you can request that your personal data be permanently deleted from Procaryote’s files.

Instead of deletion, you may also request that your personal data remain stored but no longer processed (except in certain legally defined cases). See also the “right to restricted processing” section. However, Procaryote is not obliged to delete personal data if it can or must still be lawfully processed in accordance with the GDPR.

Right to object to processing

Even when your personal data is processed without your consent, you can in certain cases object to the processing of your personal data by Procaryote. However, insofar as the processing does not involve any form of direct marketing, Procaryote may continue to process your personal data if this is necessary for compelling and justified reasons. While awaiting the assessment of these reasons, you can still ask us to temporarily stop processing the personal data in question (except in certain statutory cases). See also the “right to restriction of processing” section.

Right to restriction of processing

In certain cases, you have the right to request that your personal data be stored by Procaryote but temporarily no longer processed. Apart from the cases mentioned with the right to rectification, objection, and deletion in this policy, you have this right when Procaryote no longer needs your personal data, but you still need it yourself in the context of legal proceedings.

In certain statutory cases, restricted processing does not apply, and Procaryote can continue to process your personal data. These cases are:

• If you have given your specific consent for a certain processing;

• If Procaryote needs your personal data in the context of legal proceedings;

• If your personal data must be processed to protect the rights of another natural or legal person; or

• For serious public interest reasons.

Retention period

Personal data processed for customer management purposes will be retained for the duration necessary to comply with legal requirements (e.g., accounting).

Rights of access, rectification, deletion, restriction, objection, and portability of personal data

You have the right to consult your personal data at any time and to rectify it (or have it rectified) if it is incorrect or incomplete, to have it deleted, to have its processing restricted, and to object to the processing of personal data concerning you, including profiling based on these provisions.

In addition, you have the right to receive a copy of your personal data in a structured, commonly defined format by Procaryote and to transfer this data to another company. To exercise the above rights, the customer will be invited to set their own account settings and/or send an email to the following email address: support@procaryote.com.

Direct marketing

You have the right to object, free of charge, to any form of processing of your personal data for direct marketing purposes.

Questions and complaints

• Questions: For requests to exercise your rights or any other questions regarding the processing of personal data by Procaryote, you can always contact us at support@procaryote.com or our data protection officer, free of charge.

• Complaints: If you believe that the provisions of this privacy policy or the GDPR are not being complied with, you can always file a complaint with the Data Protection Authority. If you have a complaint, we ask that you first submit it to us so that we can seek a solution to your problem.

Use of cookies

When visiting our website, cookies may be placed on your computer’s hard drive. A cookie is a fragment of text that may be placed in your computer’s or mobile device’s browser by a website server when you visit that website. Cookies cannot be used to identify people; they can only identify machines.

• Proprietary cookies are technical cookies used by the website you visit. Their purpose is to allow the website to function optimally.

• Third-party cookies are cookies that do not originate from the website itself, but from third parties (e.g., a marketing or advertising plug-in on the website).

You can adjust your Internet browser settings to block cookies, send you a warning when a cookie is installed, or ensure that cookies are subsequently deleted from your hard drive. You can do this by adjusting your browser settings (via the help function). Please note that some graphical elements may not display correctly, or you may not be able to use certain applications.

By using our websites or applications, you consent to our use of cookies.

Google Analytics

Our websites or applications use Google Analytics, a web analytics service offered by Google Inc. (“Google”). Google Analytics uses “cookies” (text fragments placed on your computer) to help the website or application analyze how visitors use it. The information generated by the cookie about your use of the websites or applications (including your IP address) will be transferred to and stored by Google on servers in the United States. Google uses this information to evaluate your use of the websites or applications, compile reports on website activity for website operators, and provide other services relating to website activity and internet usage. Google may disclose this information to third parties if Google is legally obliged to do so, or to the extent that these third parties process the information on Google’s behalf. Google will not combine your IP address with other data held by Google. You can refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of these websites or applications. By using our websites or applications, you expressly consent to the processing of your information by Google in the manner and for the purposes described above.

Intellectual property rights

The content of our websites or applications, including all trademarks, logos, designs, data, product or company names, texts, images, etc., are protected by intellectual property rights and belong to Procaryote or entitled third parties.

Limitation of liability

The information on the websites or applications is of a general nature and has not been adapted to personal or specific circumstances. Therefore, it cannot be interpreted as any form of personal, professional, or legal advice provided to the user.

Procaryote will do its best to ensure that the information provided is complete, correct, accurate, and up-to-date. Despite these efforts, inaccuracies may still occur in the information provided on the websites or applications. If the information provided on the website or application contains inaccuracies or if specific information on or via the website or application is not available, Procaryote will make every effort to rectify this as soon as possible.

However, Procaryote cannot be held responsible for any damage, direct or indirect, resulting from the use of the information provided on these websites or applications.

We kindly ask you to report any inaccuracies in the information made available via this website or application to the website or application manager.

The content of our websites or applications (including any links) can be adapted, modified, or supplemented at any time without prior notice or announcement. Procaryote does not provide any guarantees regarding the proper functioning of the website or application and cannot be held responsible in any way for its malfunction or temporary unavailability, or for any form of loss or damage, direct or indirect, resulting from the use or access to the website.

Procaryote cannot, under any circumstances, directly or indirectly, specifically or otherwise, be held responsible for any damage attributable to the use of this site or any other site or application, including but not limited to any losses, interruptions of work, damage to programs or other data of the computer system, equipment, software, or any other element belonging to the user.

Our websites or applications may contain hyperlinks to websites or pages of third parties or refer to them indirectly. The inclusion of links to these websites or pages does not imply any implicit approval of their content.

Procaryote expressly declares that it has no control over the content or other features of these sites or applications and cannot be held responsible in any way for their content or features or any form of loss or damage resulting from their use.

Applicable law and competent courts

Our websites and applications are governed by Belgian law. Any dispute arising in connection with these websites or applications will be subject to the exclusive jurisdiction of the competent courts of the Brussels district, Belgium.

Changes to this privacy policy

This document is the latest version according to the version list below. We regularly review this document to ensure it is up to date and may modify it over time to reflect changes in our services and data processing activities. If we do so, we will post an update on this webpage. Please check this document for any changes, as any revised version will apply upon publication by Procaryote.

Version summary

• • V1.0 - April 10, 2021: First version.

Contact

For more information, questions, or comments regarding our privacy policy, please contact Procaryote’s Data Protection Officer via dpo@procaryote.com – 78 Boulevard du Souverain, 1170 Brussels, Belgium.