Privacy Policy

Version: 27/07/2022 (The English version is the official version)

Thank you for visiting our website https://relu.eu/. We welcome your interest in our company.

The protection of your privacy and personal data is of utmost importance to us. We make every effort to protect your privacy and to ensure that you can safely entrust us with your personal data. As such, we always handle personal data securely and discreetly. Furthermore, appropriate security measures have been taken to avoid loss, alteration, access by unauthorised persons and/or any other unlawful processing of your personal data.

We aim to be transparent regarding how we process your personal data and what we do with your personal data. We provide you with more detail on those processes in this privacy policy.

Who are we?

Relu BV, a limited liability company incorporated under the laws of Belgium, having its registered office at 3001 Leuven, Kapeldreef 60 (Belgium), registered with the Belgian Crossroads Bank of Enterprises under company number 0735.997.002 (LRE Leuven) (hereinafter, "Relu", "we" or "us").

You can contact us via the following contact details:

Name: Data Protection Officer (DPO)

E-mail: privacy@relu.eu

We process your personal data in accordance with the applicable legal provisions regarding privacy and the protection of personal data, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter the "GDPR") and the applicable national implementing legislation.

Some definitions":

As far as this privacy policy is concerned, the term "personal data" refers to: all information about an identified or identifiable natural person (the ‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular through an identifier, such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. In other words, all the information which can be used to identify a person. These elements include, for instance, your surname, first name, date of birth, telephone number and email address, as well as your IP address.

The term "processing" is very broad and covers, among other things, collecting, recording, organising, storing, updating, modifying, retrieving, consulting, using, disseminating, combining, archiving and deleting data.

Entity responsible for the processing of your personal data (the "Controller").

Relu is responsible for the processing of your personal data. We are what the GDPR refers to as the “controller” of your personal data. In concrete terms, this means that Relu, possibly together with other entities, determines the purpose and means for the processing of your personal data.

What categories of personal data do we process, why, on what legal basis and for how long?

Relu is processing personal data of different data subjects. To facilitate the procedure of informing you about what types of your personal data we process we have created separate tables for each category of data subject. The tables are extracted from our register of processing activities.

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In the tables below you can read:

• column 1: what categories of personal data we process (the “Categories of personal data”);
• column 2: why we process your personal data (the “Purposes”);
• column 3: on what legal grounds the processing is based (the “Legal basis”); and
• column 4: for how long we process your personal data (the “Retention period”).

All processing activities involving your personal data take place for one or more specific purposes.

In addition, we only process your personal data when we can rely on a valid legal basis. The applicable legal basis, which you can find in the column ‘Legal basis’, means the following:

• 'Consent': you have given consent for the processing of personal data for one or more specific purposes;
• 'Agreement': the processing is necessary for the performance of an agreement to which you are a party;
• 'Legal obligation': the processing is necessary for compliance with a legal obligation to which we, as the controller, are subject;

'Legitimate interest': the processing is necessary to protect our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.

Table 1- Website visitors

Table 2-Job applicants

Table 3-Employees

Table 4-Clients (Virtual Patient Engine)

Table 5-Clients (Virtual Patient Creator)

Table 6-Suppliers

Table 7- Shareholders and Directors

Table 8-Patients

Table 9-General

Not covered

This Privacy Policy does not apply where we process data on behalf of our customers (i.e. where Relu acts as a processor). Relu’s customers either use the Virtual Patient Creator software (web application) to view, manage and process their patients’ personal data OR use the Virtual Patient Engine (API) software to process patients' personal data. In that case our customers using the web application or the API act as the sole controllers for the processing of your personal data, while Relu processes the data in accordance with our customers’ instructions. Therefore, any inquiry or complaint relating to the use of your personal data in this context should be addressed to the customer (controller) and not to Relu (processor).

Minors

We do not intend to collect any personal data from persons younger than 16 years old. These minors are not allowed to provide us with any personal data or a statement of consent without permission from the person who has parental authority.

Cookies

We also use cookies, primarily to permanently optimise our website for its users. For more specific information about the cookies we use, you can consult our cookie policy (relu.eu/cookie-policy)

Opt-out

We understand that you may not prefer for us to contact you any further with any offers, promotions or details of our products and services. In the event you opt-out, we may be required to maintain information such as first name and surname, email address, telephone number and the subscription(s) that you have opted out of to ensure compliance with your requests. Also, in the future, if you wish to hear from us, you may at any time, contact us to opt-in and we would be happy to keep you posted about our latest offers, promotions and/ or details of our products and services.

Your privacy rights

To give you more control over the processing of your personal data, you have various rights at your disposal. These rights are laid down, inter alia, in articles 15-22 of the GDPR.

You have the following rights:

• The right to access the personal data we process about you (art. 15 GDPR):

You have the right to be informed by us at any time whether or not we are processing your personal data. If we are processing them, you have the right to access these personal data and to receive additional information about:

1. the purposes of the processing;
2. the categories of personal data concerned;
3. the recipients or categories of recipients (in particular, recipients in third countries);
4. the retention period or, if that is not possible, the criteria for determining that period;
5. the existence of your privacy rights;
6. the right to lodge a complaint with the supervisory authority;
7. the source of the personal data if we obtain personal data from a third party;
8. whether we are using automated decision-making in respect of you.

If we cannot give you access to your personal data (e.g. due to legal obligations), we shall inform you as to why this is not possible.

You can also obtain a free copy, in an understandable format, of the processed personal data in an understandable format. Please note that we may charge a reasonable fee to cover our administrative costs for any additional copy you may request.

• The 'right to be forgotten' (the right to request us to delete your personal data) (art. 17 GDPR):

In certain cases, you can request that we delete your personal data. In this event, however, please note that we shall no longer be able to offer you our services if you exercise this right. Please also note that your right to be forgotten is not absolute. We are entitled to continue to store your personal data if this is necessary for, among other things, the execution of the agreement, compliance with a legal obligation, or the establishment, execution or substantiation of a legal claim. We shall inform you of this in more detail in our response to your request.

• The right to rectification (art. 16 GDPR):

If your personal data is incorrect, out of date or incomplete, you can ask us to correct these inaccuracies or incomplete information.

• The right to data portability (art. 20 GDPR):

Subject to certain conditions, you also have the right to have the personal data that you have provided to us for the performance of the agreement or for which you have given your consent, transferred by us to another controller. Insofar as technically possible, we shall provide your personal data directly to the new controller.

• The right to restriction of processing (art. 18 GDPR):

If any of the following elements apply, you may request us to restrict the processing of your personal data:

1. you dispute the accuracy of those personal data (in this case, its use shall be limited for a period that allows us to verify the accuracy of the personal data);
2. the processing of your personal data is unlawful;
3. we no longer need your personal data for the its purposes, but you need them in establishing, exercising or substantiating a legal claim;
4. as long as no decision has been taken on exercising your right to object to the processing, you may request that the use of your personal data be restricted.

• The right to object (art. 21 GDPR):

You can object to the processing of your personal data on the basis of your particular situation, if we process your personal data on the basis of legitimate interests or on the basis of a task of general interest. In this event, we shall cease the processing of your personal data, unless we can demonstrate compelling and legitimate grounds for processing which outweigh your own, or if the processing of the personal data is related to establishing, exercising or substantiating a legal claim.

• The right not to be subject to automated decision-making (art. 22 GDPR):

You have the right not to be subject to a decision made exclusively on the basis of automated data processing that significantly affects you or has legal consequences and that is made without substantial human involvement.

You cannot exercise this right in following three situations:

1. when automated decision-making is legally permitted (e.g. to prevent tax fraud);
2. when automated decision-making is based on your explicit consent; or
3. when automated decision-making is necessary for entering into, or performance of a contract (please note: we always endeavour to use less privacy-intrusive methods for entering into or performing the contract).

• The right to withdraw your consent (Art. 7 GDPR):

If your personal data are processed on the basis of your consent, you may withdraw this consent at any time upon simple request.

Exercising your rights

To exercise these rights, you can contact us by using the contact details set out in Section – ‘Who are we’.

In order to verify your identity when you wish to exercise these rights, we may ask you to send us a copy of the front side of your identity card. The image on your electronic identity card shall not be retained by us. We strongly advise you to “blackline” the image before transmitting a copy of your electronic identity card to us.

You can exercise the above mentioned rights free of charge, unless your request is manifestly unfounded or excessive (for instance due to its repetitive nature). In such cases, we shall be entitled to charge you a reasonable fee or to refuse to respond to your request.

Retention of your personal data

We shall only retain your personal data for as long as necessary to achieve the intended purpose. You should take into account that numerous (legal) retention periods result in the fact that personal data (must) remain stored. Where there is no obligation to retain the data, it shall be routinely deleted once the purpose for which it was collected has been fulfilled.

In addition, we may store your personal data if you have given us your consent to do so or if we may require this data in the context of a legal claim. In the latter case, we need to use certain personal data as evidence. To this end, we store certain personal data, in accordance with the applicable statute of limitations, which may be up to thirty years; however, the usual statute of limitations in relation to personal claims is ten years.

Sources of your personal data

We may obtain personal data relating to you through the following sources:

1. Online appointment scheduling software, when you book a discovery session meeting with us;
2. Other sources: we may obtain your personal data from other sources, including but not limited to social media networks, our promotional partners or public sources.

Categories of recipients

We shall only disclose your personal data to third parties in accordance with the applicable legal framework, if you have given your consent, if such transfer is necessary for the performance of our services, for example transfers of your personal data to the suppliers who assist us in processing your personal data (based on our legitimate interest) or when we are legally obliged to do so (e.g. disclosure to governmental bodies, such as supervisory or law enforcement bodies).

In certain cases, our employees and associates may be assisted in their work by external service providers. With regard to data protection, an agreement has been concluded with all these service providers to ensure that they manage your personal data securely, with respect and with due care and diligence.

In particular, we may share your personal data with the following categories of recipients:

1. We may use carefully selected third parties to perform services on our behalf or to assist us with the provision of services to you. For example, we may engage cloud service providers, IT service providers and other third parties to provide legal, accounting, insurance, audit, and other professional services;
2. We may share your personal data with governmental or regulatory agencies upon their request to comply with any court order, law, regulation, norm or legal proceedings.

Transfer to third countries outside of the European Economic Area (“EEA”)

We shall only transfer your personal data to processors or controllers in third countries to the extent we are legally entitled to do so. Insofar as such transfers are necessary, we take the necessary measures to ensure that your personal data are highly protected and that all transfers of personal data outside the EEA take place lawfully. If a transfer takes place to a country outside the EEA for which the European Commission has not determined that it offers an adequate level of protection, this transfer shall always be subject to an agreement that complies with all requirements for transfers to third countries, such as the relevant safeguards and standard contractual clauses on data protection approved by the European Commission.

Security of your personal data

The security of your personal data is an important concern for us. We have taken all reasonable and adequate technical and organisational security measures to protect your personal data as best as possible against accidental or intentional manipulation, loss, destruction or access by unauthorised persons.

We aim to ensure secure transmission of your personal data from your computer, smartphone, and other electronic devices to our servers. We use industry security standards to safeguard the confidentiality of your information. All information you provide to us is stored on our secure servers behind firewalls. Furthermore, we have taken the following measures:

• We have imposed confidentiality requirements on our staff and service providers;
• We restrict access to your personal data to employees and third parties strictly on a need-to-know basis, for example in case we need to respond to your enquiry or request;
• We destroy or anonymize your personal information if it is no longer needed for the purposes for which it was collected; and
• We use secure communication channels for transmitting your personal data.

The security of your personal data also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping such password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.

Complaints?

We make every effort to securely protect your privacy and personal data. If you have a complaint about the way in which we process your personal data, you can notify us thereof via our contact details, as mentioned at the beginning of this privacy policy, so that we can deal with it as quickly as possible.

You can also lodge a complaint with the competent supervisory authority. In Belgium, the competent supervisory authority is the Data Protection Authority, with the following contact details:

Website:

https://www.dataprotectionauthority.be

Contact details:

Data Protection Authority
Drukpersstraat 35, 1000 Brussels, Belgium

+32 (0)2 274 48 00

+32 (0)2 274 48 35

contact@apd-gba.be

Do you have any questions?

You can always contact us by using the contact details set out in Section – ‘Who are we’. We are happy to answer any of your questions.

Amendments?

In response to feedback, or to reflect changes in our processing activities, we may amend this privacy policy from time to time. We therefore invite you to always consult the latest version of this privacy policy on our website.

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