Health.be BV (hereinafter “Health.be”, “we” or “us”), having its registered office at A. Servaesdreef 1, 9830 Sint-Martens-Latem, and registered with the Crossroads Bank for Enterprises under number 1019.972.222, attaches great importance to the protection of personal data.

This Privacy Policy describes how personal data are processed when using the digital platform Health.be (the “Platform”), including the web application at app.health.be and our website.

This policy has been drawn up in accordance with:

• the General Data Protection Regulation (EU) 2016/679 (“GDPR”);
• the applicable Belgian data protection legislation.

The Platform is not a substitute for medical advice, diagnosis or treatment. Always consult your doctor or healthcare professional if you have medical concerns.

For research and development purposes, a separate document applies: informed consent.

Depending on how you use Health.be, different roles may apply:

a. Directly via Health.be

When you create an account yourself or contact us directly via our website or the Platform (without a linked healthcare professional), Health.be acts as data controller.

b. Guidance via a healthcare professional

When a healthcare professional guides you via the Platform, that healthcare professional acts as data controller. Health.be then acts as data processor and processes data solely on behalf of the healthcare professional.

c. Research and development

For research and development purposes, Health.be acts as data controller on the basis of your separate informed consent.

Depending on your interaction with Health.be, the following categories of personal data may be processed:

• identification and contact data;
• account and user data;
• responses to questionnaires;
• journey and order data;
• lifestyle and wellbeing data;
• data from wearables or sensors;
• technical and log data.

When you complete online forms, your data may be collected via an external service provider and then, if you agree to this Privacy Policy, processed in the Platform.

Without your agreement to this Privacy Policy, we will not create a user account for you and we will not process your responses in your record.

Personal data are processed for purposes including:

• creating and managing your account and journeys;
• lifestyle guidance via the Platform;
• communication about your account and journey;
• linking with a healthcare professional, where applicable;
• security and proper functioning of the Platform;
• compliance with legal obligations and customer support.

Personal data are processed on the basis of one or more of the following legal grounds:

• the performance of a contract or pre-contractual steps;
• the explicit consent of the user, where legally required;
• compliance with legal obligations;
• legitimate interests, where applicable and legally permitted.

Personal data are not retained longer than necessary for the purposes for which they are processed, unless a longer retention period is required by law.

Personal data are not sold or rented.

Data may be shared with:

• the relevant healthcare professional, where applicable;
• sub-processors of Health.be, subject to strict contractual safeguards;
• public authorities, where legally required.

Health.be may use sub-processors for hosting, email, online forms and payments, among other things. An up-to-date list can be obtained on request via privacy@health.be.

Health.be implements appropriate technical and organisational measures to protect personal data against loss, unauthorised access or unlawful processing.

While Health.be strives to secure personal data as effectively as possible, absolute security cannot be guaranteed.

Health.be may use general feedback and user experiences solely in fully anonymised form to improve and explain our services. Use for research and development is covered by the separate document informed consent.

You have the rights provided for under the GDPR, including:

• the right of access;
• the right to rectification;
• the right to erasure;
• the right to restriction of processing;
• the right to data portability;
• the right to object;
• the right to withdraw consent, where processing is based on consent.

You may always address requests to exercise these rights to Health.be via privacy@health.be. We will handle your request and coordinate with the relevant healthcare professional when they act as data controller.

If you believe that your rights are not being respected, a complaint may be lodged with:

Belgian Data Protection Authority
Rue de la Presse 35, 1000 Brussels
www.dataprotectionauthority.be

Health.be reserves the right to amend or update this Privacy Policy.

Changes will be communicated via the Platform or by email and will enter into force as of the indicated date.

For questions about this Privacy Policy or the exercise of your rights, please contact:
privacy@health.be