Privacy Policy

Your privacy is of the utmost importance to us. We make every effort to protect the data of our patients, suppliers, employees and other contacts against loss, leaks, errors, unauthorised access or unlawful processing. This privacy policy applies to all services we provide and all activities we perform. We respect the General Data Protection Regulation (“AVG” or “GDPR”) and the Belgian regulations on the protection of personal data.

1. Who is responsible?

o2 Clinic (praktijk) BV is responsible for collecting, managing and processing the personal data that you have shared with us. Located at Ringlaan 51, 2600 Berchem, BE0607945322, hereinafter referred to as “o2 Clinic”, “we”, “us” or “controller”.

As data controller, we reserve the right to change this privacy policy at any time.

2. For what purpose do we process your data?

We collect various types of personal data for various purposes, primarily for the provision of health care, the follow-up of patient files, the optimal navigation of the website and certain marketing purposes.

We do this for our clinic, so that you can use our (online) services with pleasure and ease and in complete safety. Your privacy is guaranteed.

Personal data is processed on the basis of Article 9 of the GDPR:

• 9.2, a): with the express consent of the data subject;
• 9.2, h): for the provision of health care.

We further divide this data as follows:

• patient data (e.g. for medical records, planning for consultations and operations, post-operative aftercare, website content, vital interests, etc.)
• data from suppliers (e.g. third parties who support the clinic in the areas of logistics, IT, medical facilities and installations, etc.) in order to function organizationally and to do business.
• personnel data (e.g. for contracts, training, planning, pay slips, website content, etc.)
• other data (e.g. prospects, quotations, useful contacts, applicants, etc.)

We protect your data according to general standards that are common in the industry. Where possible, we try to anonymize your data or apply special technical measures so that this data cannot be traced back to you.

In the following necessary cases we will have to process your data in order to perform our services as well as possible:

1. When this is necessary to provide a service, e.g. in the context of your patient file, planning of operations, your operation itself, subsequent follow-up, etc.

2. When you have shared your data with us and given us permission to do so, e.g. in the following cases:

• Registration on our website and apps to facilitate use.
• Saving your settings to make using our services as pleasant as possible for you.
• Subscription to our email newsletters.
• Membership of our online communities (social media channels).

3. When the law obliges us to request and process your data. Depending on what you share with us, we can use the personal data for the following purposes:

• To determine your consumer profile and to be able to provide you with targeted offers based on this, e.g. by e-mail or by post.
• Marketing knowledge, improvement and optimization of our services.
• Targeted marketing campaigns and/or collaborations with third parties to develop promotions that match your interests.

3. What personal data do we collect and what is it used for?

Depending on what you share with us, we may store and process the following personal data:

• First and last name
• Email address
• Phone number
• Address
• Country
• Postal Code
• Street number
• Street
• Location
• Language
• Gender at birth
• Desired gender
• Date of Birth
• Payment details
• National registration number (in Belgium) or ID number (international)
• Profession
• Diet and eating habits
• Medical history
• Insurance information
• Medical tests
• Information about your family members (e.g. as emergency contact)
• Information about your online activities on our services
• Recordings as a supplement to your medical file (e.g. Skype consultations). This processing is necessary for the provision of health care.
• If you apply for a job with us: your CV and the information contained therein.

This data is used to create medical records, medical follow-up, invoicing, administration and/or communication.

In addition, we keep the personal data that you provide to us (in writing or verbally), that result from tests and that we collect ourselves, such as publicly available data on the internet or when checking references.

These personal data are processed, stored and used in various places within o2 Clinic in order to optimally perform our services.

3.1. In the clinic

You can share all of the above personal data with us yourself via email, telephone, when you use our tablet in the clinic, or by sharing it with our staff. Registration is not necessary when you fill out a form via the tablet or at the reception.

It is also possible that we ask you if you are interested in receiving our newsletter. After your approval, our employees can enter your details and register you as a newsletter subscriber or as a “member”. You can register yourself via our websites or apps, but as an additional service our employees will be happy to do this for you. When you register, you will always be the first to know about the latest news, offers and necessary information in and about the clinic. It is possible to unsubscribe from this newsletter at any time.

3.2. On our website

We also need a number of necessary personal data when you visit our website. It is good to know in advance that we use a secure SSL connection when you surf on our website. Your name, address and payment details are necessary for processing and handling your registration, quotation request or booking of an appointment, treatment or operation. We process your gender (both your gender at birth and your desired gender) in order to be able to correctly compile your file and to be able to address you personally. We use the date of birth to confirm whether or not you are a minor. We use the e-mail address and telephone number to inform you about your registration, appointment, operation, etc. Please always use the same name and e-mail address during your transition to avoid confusion or administrative problems. If you have given us permission, we will also periodically send you a newsletter by e-mail.

3.3. In our apps

For our clinic, we use a number of apps (e.g. Freshdesk, Little Hotelier, ScheduleOnce, Jotform, Infusion Soft, Trello etc.). Depending on the app, we ask you to share certain personal data with us.

This information is required to register your bookings (e.g. a consultation, an operation, your stay, etc.). Your name and email address are required to create your account. You can enter this information yourself on the website or in the app. Our employees at the clinic can also help you create an account and ask you for your details. After your permission, they will enter this information into our system. We use your date of birth to check that you are not a minor. When all the details have been entered, a unique identification number will be created for you. We also use this information to build a database on which we can perform analyses regarding our offered procedures and services. If you have given us permission, you will also receive personalized emails with information relevant to you based on your interests.

3.4. Through our social media channels

Our brands use various social media channels. We use these channels to contact our customers and for various marketing purposes. We can view certain personal data on a number of social media channels. We use the following social media channels:

• Facebook
• Twitter
• Pinterest
• Instagram
• YouTube
• LinkedIn

We do not store this personal data, and we are not responsible for it. You decide what you share with us. You can adjust your data yourself in the privacy settings of the social media platform in question. When using these platforms, you are not bound by our privacy policy, but by that of the social media platform.

3.5. Via our customer service

In most cases, our customer service is contacted regarding questions, complaints, payments and/or cancellation or adjustment of bookings. If you contact our customer service, we will ask you to share some personal data with us. Depending on your question, we can request information in addition to the data mentioned in point 3.

In order to serve you better, the information is needed to look up your details. In the case of a refund, we need your name and account number. We register the e-mail address and/or telephone number so that we can contact you if necessary. We can also use this information later to check whether you were helped satisfactorily during your contact with our customer service.

4. Automatically collected data

We automatically collect data when you use our website, apps and social media channels. If you use one of these (online) services, we can store data that may or may not be directly traceable to you, namely:

• IP address
• Domains of other sites you have visited to reach our websites
• Information about pages you visit on our website such as
• Program
• Time of day
• Duration of your visit
• Visited pages within our website and apps
• Information about the use of visited pages
• Your browser and version used
• We use the IP address to determine your geolocation (country). We use the other data to improve and optimize our services.

5. How do we protect your personal data?

We cannot disclose exactly how we protect your personal data to prevent misuse or targeted attacks. We implement both appropriate technical and organizational measures that comply with the current state of the art to protect your personal data. In doing so, we do what is necessary to ensure all these matters.

The following departments have access to your data:

• Management: to be able to follow up on bookings of treatments and payments, to keep the administration up to date
• Marketing: to optimize the user-friendliness of the website and to be able to offer marketing-oriented content, information or promotion if desired
• Customer care: to complete the patient file and provide medical guidance
• Medical team (doctors, surgeons, nurses, anesthetists): to support healthcare
• Reception: to plan and follow up bookings for treatments and payments, to create files, etc.
• Beauty team: to plan, carry out and follow up treatments
• IT: to optimize the user-friendliness of the website, the patient platform, mailboxes, etc., to be able to develop new features and to guarantee the necessary data security
• Academic team: to be able to set up medical reporting and research.
• Media team: collecting facts, figures and scientific articles to support documents and petitions

The list of persons concerned per category is maintained by the supervisory authority. Each employment contract includes the requirement that each person concerned respect the confidential nature of the data concerned.

6. Sharing with service providers and third parties

First of all, we are bound by Belgian, Dutch and European legislation regarding the sharing of personal data with service providers and third parties. We share your data with third parties that play a role in the execution of our services, for example processing your bookings, appointments, treatments and operations. In addition, we can also exchange your data with other parties that have been engaged by us to improve our services and our marketing activities.

We handle all personal data obtained confidentially and with the utmost care. We will only share personal data that is necessary for the service provision and/or the marketing objective with our partners. In order to no longer be able to trace this data back to you, we anonymize it for you where possible and sharing only takes place via secure channels. In this way, we guarantee your privacy.

7. Expiry date and inspection

Your personal data has an expiration date. We distinguish between different types of data and information. All data is only kept for as long as necessary for the processing purposes described above. The following retention periods apply:

We retain medical, fiscal, social or legal data (whether or not part of documents) for as long as legally required, plus a period of 1 year. This allows us to remove the data from our systems and archives in a correct manner.

• Patient file: 30 years
• Patient administration: 7 years
• Patient registration: for the period necessary to achieve the purposes of the patient registration.
• Social services: 30 years (such as patient file)
• Complaints: during the period necessary to handle the complaint.
• Scientific research: for at least 20 years after completion of the study
• Camera surveillance: the images are stored for 30 days. This does not apply to cameras without image storage (so no images are stored here).
• Wifi network: The collected data will be deleted after one year.
• Cookies: see section 11.
• If you apply to o2 Clinic or Clinic, we will keep your details in our database for a maximum of 24 months.

In some cases, e.g. when you ask us not to contact you anymore, we may store your core data in a “do not contact” file for 36 months, in order to avoid us contacting you during this period.

Data that is the subject of a dispute or that can reasonably be expected to be used in a dispute will be retained for as long as necessary to be used in that dispute.

8. Rights

You have the right at all times to access the data we have collected about you (right of access), you can have it improved, supplemented (right of rectification) or deleted (right to be forgotten), you can request a restriction of the processing of the data or oppose automated decision-making. If you wish, you can request to transfer your data to a third party (right to data portability). For this you can contact N. Hermans via officemanager@o2clinic.be.

After sharing the data with us, you have the right at all times to view, change, transfer, take with you or even delete this data if the law permits, as further explained elsewhere in this Privacy Policy. If you submit this request to us, we will try to realize this within one month of the request. We will contact you if this is not feasible and extend this period by a maximum of two additional months.

Finally, you always have the right to file a complaint with the data protection authority if you believe that we are not handling your data with sufficient care.

• For the Netherlands, you can file a complaint with the Dutch Data Protection Authority (authoritypersoonsgegevens.nl)
• For Belgium, you can contact the Data Protection Authority (https://www.gegevensbeschermingsautoriteit.be/burger), Rue de la Presse 35 – 1000 Brussels.
• For the UK: gov.uk/data-protection/make-a-complaint
• For Germany you can go here: https://www.bfdi.bund.de/DE/Datenschutz/datenschutz-node.html

9. Adjusting personal data

Should you decide to exercise your above right(s), you can do so via our websites and apps. Should you experience any problems here (for example, you can no longer access your data or you cannot change it yourself), please submit a request to our customer service. Here you indicate what you want to do with your personal data. You can take this up with N. Hermans via officemanager@o2clinic.be.

If you are registered for our newsletter, you can unsubscribe at any time. You will find the “unsubscribe” button at the bottom of the newsletter. If you click on this, you can easily unsubscribe. You will then no longer receive our newsletter, unless you register again.

10. Parental consent

We are obliged to only process personal data of minors after permission from a parent or guardian. If we find out that personal data of minors is nevertheless being processed, we will delete this data within one month of discovery, unless we are required by law to keep this data.

11. cookies

This website uses cookies to improve the browsing experience of our visitors. Cookies ensure that our website functions better and is better tailored to your preferences. If you continue browsing, you give us permission to use cookies.

11.1. What are cookies?

Cookies are small, simple text files that your computer or mobile device stores when you use our websites. You can accept or refuse certain cookies yourself when you visit our websites. We use cookies to offer you all functionalities. In addition, we use cookies to make it as easy as possible for you to place an order, for example. We also use cookies to analyse for marketing purposes. If you refuse the use of cookies, it is possible that a number of functions within the website will not be available. Cookies generally have an expiration date and are automatically deleted when they are no longer valid. Depending on the cookie, it is deleted immediately after the session, while another cookie can be stored on your computer for a longer period of time.

For example, by using cookies and other techniques, we ensure that:

• Visiting our websites becomes easier.
• You do not receive or have to fill in the same information every time you visit our website.
• We can offer you functionalities such as the patient platform.
• We can measure how our website is used and where we can improve it.
• We can show you a more relevant website through 'personalization' techniques such as product recommendations and whether or not to show certain blocks or items on the website.
• To better tailor advertisements to your needs and interests and prevent you from seeing a particular advertisement too often.

11.2. What kind of cookies do we use?

There are mandatory, functional and analytical or statistical cookies, as well as advertising and social media cookies. You can indicate whether you only want to use mandatory cookies, or also the other types.

We use Google Analytics (anonymous) to keep track of the statistics of our website, a web analysis service offered by Google. Our website uses YouTube, Instagram, Facebook and other external services. These external services can place cookies to record certain data, for example to analyze the click behavior of visitors.

11.2.1. Functional and analytical cookies

These cookies are necessary to provide you with a working website. For example, they help you navigate and search the website. These are cookies that are only stored during a specific visit.

Functional cookies ensure that our website functions correctly. With analytical cookies we collect statistics of the users of our websites. By measuring usage, we can continue to improve and optimize our websites.

Examples of functional cookies on our website:

• The browser settings are saved so that you can view our websites perfectly on your desktop, laptop, tablet or mobile.
• Login details are saved so you don't have to enter them every time.
• The websites are loaded evenly, so they remain functional and accessible.
• Detecting possible abuse or potential problems on our websites (consecutive failed login attempts are recorded).

Our cookies:

• October (Session)
• ContactId
• cookie_consent_set
• cookie_consent_ga
• cookie_consent_ma

Examples of analytical or statistical cookies on our websites:

• The IP address, which is made anonymous.
• Technical features such as the browser you use and the resolution of your computer, tablet or mobile screen.
• The page from which you came to our website.
• When and for how long you visit or use our website.
• Whether you use our functionalities (placing an order).
• Which pages you visit within our website.

Our cookies:

• Crazy Egg
• Google Analytics
• Google Tag Manager

11.2.2. Advertising cookies

With advertising cookies we are able to show you (via third parties) a relevant advertisement / offer at the right time. With the help of these cookies we also ensure that you do not see an advertisement too often. We strive to only show advertisements if we think they are interesting to you.

Examples of advertising cookies on our websites:

• We can keep track of which advertisements you have seen and prevent you from seeing the same advertisement more than once.
• We can track how many visitors click on a particular advertisement.
• We may keep track of how many orders are placed through a particular advertisement.

11.2.3. Social media cookies

Social media cookies make it possible to share items/products on social media, to follow or like our pages and allow our customer service to chat with you if you wish.

The social media cookies are applied when you click on one of the social media icons.

Examples of social media cookies on our website:

• You can share certain pages within your social media channel.
• You can “follow” our brands.
• You can “like” our brands.

Examples:

• tracking pixels

11.3. Delete cookies?

Most internet browsers offer the possibility to remove cookies from your hard drive. You can also refuse cookies in advance or you can indicate that you want to receive a warning before they are placed. Consult the instructions or the help function of your internet browser for more details. Please note that blocking certain cookies will prevent the correct functioning of our websites.

12. Camera surveillance

Our clinic uses camera surveillance. The cameras are used to ensure the safety of our clients, staff and goods. For this purpose, it may happen that you are filmed, that images are recorded and temporarily stored.

The retention period is never longer than one month, unless the recorded images can contribute to proving a crime, damage or nuisance or to identifying a perpetrator, a disturber of public order, a witness or a victim.

13. Changes to the privacy policy

We will update the privacy policy when changes occur in our services and/or based on feedback from our customers. The version date on which the policy was last updated can be found at the end of this document. We recommend that you periodically review this policy so that you remain informed about how we handle your personal data. If we make significant changes to our Privacy Policy, we will inform you about this in due time.

Version: 22.02.2022