Introduction

Your privacy is very important to us at FLUIDDA NV (Groeningenlei 132, 2550 Kontich (Belgium)) and we want to be transparent about the information we collect, why we collect it, and how the information is used.

Fluidda provides this Policy explaining our online information practices and the choices you can make about the way your information is collected and used. This also describes how we process any personal information relating directly or indirectly to you (“Personal Data”). This also explains how and why we collect your Personal Data, what we do with it, with whom we share it, how we protect it, how long we store it and we inform you of your rights. We strongly urge you to read this Policy and make sure you fully understand our practices in relation to your personal data, before you access or use any of our Services.

This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you might have under applicable data privacy laws.

Fluidda reserves the right at any time and without notice to change this Privacy Policy simply by posting such changes on our website. Any such change will be effective immediately upon posting.

Where you have read this Policy but would like further clarification, please contact us at privacy@fluidda.com.

Who is responsible for processing of your personal data?

Fluidda is responsible for the processing of your Personal Data and will act as the data controller. Contact details in case of queries about this Policy is provided in the last section of this Policy.

Which type of personal data do we collect?

Personal data includes any information relating to an identified or identifiable natural person (also known as a “data subject”).
Please note that we may process the following Personal Data:

  • Contact details like name, surname, email address, phone number
  • Contact details of medical institution/company such as name, address

We do not process any special categories of Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data or data concerning someone’s sexual activity. In this respect, we would like to clarify that the CT Scans including the age, gender and height that we receive from clinical trials or which are uploaded into Broncholab and other medical devices do not qualify as Personal Data since they cannot directly or indirectly be identified to a natural living person. If a data breach occurs, for example if an unanonymized scan is sent to Fluidda for processing, the sponsor shall be informed within 1 working day from when the scan is received. Only anonymized or pseudonymized scans are processed.

Why do we collect such information?

We use your personal data solely for the purposes of processing your requests, to conduct our business, recruitment-relating purposes or to correspond with you.

We will only process your Personal Data for specific purposes. Please note that we do not intend to further process your Personal Data for a purpose other than described below or via specific notification.

We will process your Personal Data in relation to your use of our services or Broncholab and other medical devices. In these respects, we will process your information for registration purposes allowing us to provide you with an account, all necessary log-in details, when required. We will process your Personal Data for all subsequent access to and (general) use of Broncholab and other medical devices. Moreover, we will process your Personal Data for all interactions you have with us regarding Broncholab and other medical devices. This includes but is not limited to administrative or technical purposes to ensure their full functionality.

Furthermore, we will process your Personal Data for other interactions we may have with you. For example, if you contact us with any questions, remarks, complaints or other inquiries we will process your Personal Data to respond to your inquiry. Your personal data might also be collected as part of a project, for business purposes, sales process, etc.

Legal grounds for processing

we process your Personal Data, we will always rely on one of the following processing grounds:

  • Performance of a contract with you: when the processing is necessary for the performance of a contract you are a party to or in order to take the steps at your request to enter into a contract. In particular for Broncholab, providing your Personal Data is necessary for the performance of a contract with us to give you access to Broncholab. If you do not provide your Personal Data, we, regrettably, cannot give you (any further) access to Broncholab;
  • Our legitimate interest: when processing is necessary for the purposes of our legitimate interest, except where our interests are overridden by your fundamental rights and freedoms. We will provide you with more information about our legitimate interest at the appropriate time of the processing operation;
  • Your consent: we may occasionally ask you for your specific permission to process some of your Personal Data, and we will only do so if you give your free, explicit and informed consent to us. Please note that you can withdraw your consent at any time;
  • Compliance with law: in some cases, we are required to process your Personal Data to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency.

Duration

We will only store your Personal Data as long as necessary while ensuring appropriate protection of your personal information. How long we keep your Personal Data depends on the purpose we use it for as described in this Policy. Your personal data is kept for no longer than is necessary in relation to the purposes for which it is collected. We will frequently review the information we hold and when there is no longer a legal or business need for us to store it.

We will remove or anonymize your Personal Data you have provided us with regarding your use of Broncholab when you have not used Broncholab (i.e. inactivity) for a period of two years.

In case you have submitted a complaint or enquiry, we will store your Personal Data relating to your request for a period of five years starting the day after we receive your complaint or enquiry, after which we will anonymize or delete all your Personal Data you have provided us within this context.

Sharing personal data with third parties

We may have to share your data with third parties.

FLUIDDA may share your Personal data with third parties (or otherwise allow them access to it) only in the following manners and instances:

  • Third Party Services
  • Law Enforcement, Legal Requests and Duties
    Where permitted by local data protection laws, FLUIDDA may disclose or otherwise allow others access to your Personal data pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.

If warranted, we may also allow access to this information in special emergencies where physical safety is at risk. We reserve the right to disclose any personal data or other information obtained from or about you, to third parties in connection with a merger, acquisition, bankruptcy or sale of all or substantially all of our assets, to the extent that this is necessary for the process.

We require third parties to respect the security of your data and to treat it in accordance with the law.

How do we protect your personal data?

We have a set of technical and organizational security measures in place to protect your Personal Data against unlawful or unauthorized access or use, as well as against accidental loss or damage to their integrity. These measures are been designed taking into account our IT infrastructure, the potential impact on your privacy and the costs involved and in accordance with current industry standards and practice. Your Personal Data will only be processed by a third party if that third party agrees to comply with those technical and organizational data security measures.

Job applications

FLUIDDA welcomes all qualified Applicants to apply to any of the open positions published by sending us their contact details and CV (“Applicants Information”) via the Job page on our Website, or through any other means provided by us [(e.g. by email or post)].

We understand that privacy and discreetness are crucial to our Applicants and are committed to keep Applicants Information private and use it solely for FLUIDDA’s internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).

Please note that FLUIDDA may retain Applicants Information submitted to it for no longer than two years after the applied position has been filled or closed. This is done so we could re‑consider Applicants for other positions and opportunities at FLUIDDA; so we could use their Applicants Information as reference for future applications submitted by them; and in case the Applicant is hired, for additional employment and business purposes related to his/her work at FLUIDDA.

If you previously submitted your Applicants Information to FLUIDDA, and now wish to access it, update it or have it deleted from FLUIDDA systems, please contact us at privacy@fluidda.com .

Your rights

You have the possibility to exercise your rights as described in the GDPR. As a data subject, you can exercise the following rights:

  • Right to information
    You may request access to all personal data collected (including processing purposes, categories of personal data, estimated retention period) for inspection
  • Right to rectification, erasure and restriction
    You have the right to have incorrect personal data corrected or amended and, under certain circumstances, the right to have your personal data removed from our files. You have the right to have any of your Personal Data erased (except in some cases, for example, to prove a transaction or when required by law). You acknowledge that, if you refuse to provide certain data or ask for the erasure of your personal data, we will no longer be able to provide certain services. You have the right to request a restriction of processing if we are not entitled to use your Personal Data (anymore) or if you contest its accuracy
  • Right to withdraw consent
    If the processing activity is based on consent, you have a right to withdraw this consent at any point. Please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
  • Right to object
    If you no longer wish to be informed about any updates or receive direct marketing, you are entitled to make such a request by mailing to privacy@fluidda.com. Please note that you are not entitled to object to the processing of your personal data if such personal data is necessary for the execution of the agreement between us or your company (for example: for invoicing the data subject or the data subject’s company for ordered services).
  • Right to data portability
    Under certain conditions, you have the right to receive your Personal Data, which you have provided to us, in a commonly used, structured machine readable format and to transmit your Personal Data to any third party of your choice.
  • Right to lodge a complaint
    If, at any time, you are of the opinion that we have infringed your privacy, you have the right to lodge a complaint with the supervisory authority which is responsible for the protection of personal data in the country where you reside.
  • Right to access and correction:
    You have the right to access your Personal Data. Before providing access, we may ask for proof of identity and sufficient information about your interactions with us for security purposes. If we agree that we are obliged to grant you reasonable access, we will do so free of charge but only for your first request. If the Personal Data we hold about you is incorrect, you may always ask us to correct any inaccuracies;

You can make a request or exercise these rights by contacting us and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards. To exercise the above rights, you can contact privacy@fluidda.com. After verifying your identity and data subject rights applicability criteria, we will do everything reasonably possible to comply with the request unless it will require completely unreasonable measures (e.g. technically or organizationally virtually impossible or extremely costly). We may refuse to process requests that are unreasonably repetitive or systematic.

How can you lodge a complaint?

If you do not agree with the way we process your Personal Data, you always have the right to lodge a complaint with the Belgian Data Protection Authority acting as the supervisory authority:

contact@apd-gba.be
Tel: +32 (0)2 274 48 00/Fax: +32 (0)2 274 48 35
Rue de la Presse 35, 1000 Brussels, BELGIUM

Cookies

As is now common with most websites, our website uses cookies to record certain information about your use of the website. Cookies may be considered as pieces of data that are sent by the webserver to your browser who writes these data to the hard disk of your computer. Any information obtained consequently is used on an anonymous, aggregated basis and you cannot be identified from it. You are not required to accept a cookie that we send to you and you can modify your browser’s settings so that it will not accept cookies

By using cookies, we may offer you a quicker and more efficient entry to Fluidda website and Broncholab. You can turn off the use of cookies in your browser settings. If you disable the use of cookies, the Fluidda website and Broncholab are still accessible, but you may not have access to all of the functionalities.

Internet browsers allow you to change your cookie settings, for instance to block certain kinds of cookies or files. You can therefore block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of the website, due to the fact that some may be functionality cookies. For further information about deleting or blocking cookies, please visit: http://www.allaboutcookies.org/manage-cookies/

We use the following cookies on our website:

Google Analytics: allow us to assess how you and other web users use this website, and this information is essential in helping us to continuously improve our website’s functionality. They can be preserved from 30 minutes to 2 years.
Facebook: these cookies allow web users to request to share content on social media. They are preserved for 2 years.

Changes to our Policy

We may modify this Policy from time to time to reflect our current privacy practices. We encourage you to periodically review this Policy to be informed on how we process and protect your Personal Data.

If we make any significant changes in the way we treat your Personal Data you will be notified.

This Policy was last updated on May 31, 2020.

Contact information

If you have any questions or remarks about this Privacy Policy or wish to exercise any of your rights, please contact us at privacy@fluidda.com or send a post to
FLUIDDA NV
Groeningenlei 132, 2550 Kontich, Belgium

We will attempt to resolve any complaints regarding the use of your Personal data in accordance with this Privacy Policy.