1. Why this Privacy Statement?
Your privacy is very important to us. This Privacy Statement has been created to inform you (hereinafter also referred to as "You" or "Your") how we handle Your personal data, namely any information relating to an identified or identifiable natural person (hereinafter "Personal Data") and how You can exercise control over it. Please read this Privacy Statement carefully as it contains Your rights and obligations towards MediPortal (hereinafter also referred to as “We”).
2. Who processes your Personal Data?
The party responsible for processing Your Personal Data during the use of the Services (as defined below) is MediPortal, a limited liability company under Belgian law, with registered office at Molenbergstraat 94A, 2840 Rumst, registered with the Crossroads Bank for Enterprises under company number 0895.068.191.
However, when Your Personal Data is processed by healthcare providers using our Products, those healthcare providers act as data controllers for the processing of Your Personal Data. If necessary, MediPortal will act as a processor.
The collection and processing of Personal Data is subject to strict conditions. MediPortal always acts in accordance with "Privacy Legislation", namely:
- EU Regulation 2016/679 of 27 April 2016 on the protection of personal data (‘GDPR’);
- The Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data; and
- Other applicable special legal provisions on data protection.
3. What does this Privacy Statement cover?
This Privacy Statement applies specifically to how We treat Your Personal Data in the context of Our "Services'', namely:
- Services related to the use of www.mediportal.be (hereinafter "Website");
- The use of MediPortal's Mediris solutions (being Mediris Wachtpost, Mediris Specialist, Mediris Multi, Mediris eFact, Mediris eAttest, Mediris Recipe, Mediring and Mediris Agenda) (hereinafter "Products")
- Job applicants, suppliers, prospects, professional partners, and/or other persons who contact us.
4. Which Personal Data do We collect?
You may provide us with Your Personal Data in the context of the following activities, for the corresponding purposes and based on the stated reasons. Providing certain Personal Data is sometimes a condition for enjoying certain services of MediPortal.
Your application details (category 1)
You can share Your contact details, such as name, e-mail address and phone number with us, as well as Your CV, cover letter, other details and (possibly) Your photo, by applying to MediPortal.
Your professional contact details (category 2)
You may share Your professional contact details, such as your (company) name, first name, email address, telephone numbers, NIHDI number, CBE number and billing details with us by contacting MediPortal through the contact form on the Website, email or any other means of communication; by requesting a trial period on the Website; and/or by doing business with MediPortal as a professional partner or supplier.
Your communications relating to our Website (category 3)
You may share information regarding communications and the content of communications You had with MediPortal by contacting MediPortal via the contact form on the Website, e-mail or any other means of communication; by requesting a trial period on the Website; and/or by doing business with MediPortal as a professional partner or supplier.
Your use of our Website (category 4)
We may also obtain Your Personal Data by placing cookies on the Website (see our Cookie policy)
Your use of our Products (category 5)
We may process Your Personal Data as part of our services when You use our Products (including account information and usage data). Which Personal Data We process will depend on the Products You use.
We may also process the following data on behalf of Your healthcare provider when using the Products: name, date of birth, address, language, registered patient contacts, healthcare relationship, reason for treatment, medical history (risk factors, medication, etc.), medical correspondence (reports, lab results, etc.) and performance codes. Optionally, if Your healthcare provider so chooses, the following Personal Data will also be processed: national registration number, insurance details, telephone number, email address, photograph identifying the patient, identification and contact details of the GP and photographic material.
5. For what purpose will Your Personal Data be used?
We collect and process Your Personal Data primarily to provide You with our Services in the best possible way.
That said, we additionally only use your Personal Data for the following purposes:
General purposes
For category 1 data
Your application data are processed to evaluate your application and for the operation and optimisation of a recruitment policy. To do so, We rely on Your permission.
For category 2 data
We process Your contact details to contact or notify You in a simple manner, or to be contacted by You, as well as to be in a position to follow up Your communications to us - all in accordance with the performance of the agreement You requested. In addition, Your professional data are collected and processed for the purpose of executing or concluding the agreement or maintaining the professional relationship between You and MediPortal.
If You subscribe to the MediPortal newsletter via the Website, we will use Your email address to send this newsletter. You can unsubscribe at any time.
For category 3 data
We process this data to contact or notify You in a simple manner, or to be contacted by You, as well as to be in a position to follow up Your communications to us - all in accordance with the performance of the agreement You requested.
Content of professional communications is also collected and processed with a view to executing or concluding the agreement or maintaining the professional relationship between You and MediPortal.
For category 4 data
We process this data to maintain the security of the Website and to improve it, as well as to create statistics based on a "legitimate interest" of MediPortal to improve the Services. With regard to the use of non-essential cookies, we will only process your data based on your consent given through Your cookie settings.
For category 5 data
We process Your Personal Data to offer our Products to You and to optimise the services provided by healthcare providers. We can also use Your Personal Data (e.g. IP address) to improve our Products, such as through the use of heatmaps to capture Your use of and interaction with our Products.
Direct marketing
Your Personal Data will only be used for direct marketing purposes if You expressly and priorly agree to this.("opt-in") In case You have given Your consent and You have been added to MediPortal's direct mailing list, MediPortal may use Your Personal Data to send You marketing material as well as other material related to MediPortal and its Services.
MediPortal may also disclose some of Your Personal Data to its partners for direct marketing purposes regarding MediPortal and its Services.
This consent may be withdrawn at any time, free of charge and without justification, by clicking on the cancellation button at the bottom of each promotional e-mail.
6. With whom do we share your Personal Data?
We rely on third parties to perform and enable our Services. Examples of these suppliers and service providers include eHealthBox and entities that provide web hosting services or help improve the competences of our Services.
We will not sell, rent, distribute or otherwise make Your Personal Data commercially available to third parties, except as provided for in this Privacy Statement, or where You have given Your express and prior consent to do so.
We have taken all legal and technical precautions to prevent unauthorised access and use.
To this end, We guarantee a similar level of protection by making contractual obligations enforceable toward these appointees, which are similar to this Privacy Statement.
In the event of full or partial reorganisation or transfer of MediPortal's business whereby MediPortal reorganises, transfers, assigns its activities or in the event MediPortal would be declared bankrupt, Your Personal Data may be transferred to new entities or third parties. We will inform You in advance if MediPortal transfers Your Personal Data to a third party.
On rare occasions, we may have to disclose Your Personal Data as a result of a court order or to comply with other mandatory laws or regulations. We will make reasonable efforts to provide You with advance notice of any such use, unless it is subject to statutory restrictions.
7. For how long do we retain Your Personal Data?
Your Personal Data will be kept and processed by Us for the period We are legally obliged to do so or for as long as it is essential for the purposes of the processing or for the contractual relationship between You and MediPortal.
Should MediPortal no longer be able to keep Your data, they will be sent to You electronically and in a commonly used format. Unless You exercise Your right to erasure, Your Personal Data will be retained for the following periods:
Retention period Category 1
Application data of non-recruited candidates will not be retained for more than 1 year after the last substantive contact with the applicant.
Retention period Category 2
Your contact details will not be retained for more than 10 years after the end of the professional relationship between You and MediPortal.
Retention period Category 3
Your communications relating to our Services will not be retained for more than 10 years after the end of the professional relationship between You and MediPortal.
Retention period Category 4
The retention period for your use of our Services varies depending on the applicable Cookie. For more information, please refer to our Cookie policy.
Retention period Category 5
Your Personal Data will be retained (i) for the duration of Your use of our Products or longer if required by legal or regulatory retention periods or (ii) if Your Personal Data is processed by healthcare providers using our Products, for the duration of the healthcare relationship or longer if required by legal or regulatory retention periods.
8. What rights do You have?
8.1 Right of access and information
You have the right to access your Personal Data at any time, and to know how we use Your Personal Data.
8.2 Right to rectification, erasure and restriction of processing
You are free to share certain Personal Data with us or not.
You always have the right to request us to amend your Personal Data. You can also change your account data at any time.
You may also request that the processing of Your Personal Data be restricted if You believe that Your data is inaccurate and You subsequently notify us of this.
In addition, You have the right to request MediPortal to delete Your data to the extent that we are not able to make it anonymous. However, if You refuse to communicate certain Personal Data, or if You ask us to delete them, we may no longer be able to provide our Services in an optimal manner.
8.3 Right to object
You also have a right to object to the processing of Your Personal Data when you have serious and legitimate reasons to do so.
You also have the right to object to the use of your Personal Data for direct marketing purposes. In this case, no specific reason will be requested.
8.4 Right to data portability
You have the right to obtain Your Personal Data processed by Us in a structured, common and machine-readable format, and/or to transfer it to other controllers.
8.5 Right to withdraw consent
You have the right to withdraw Your prior consent to the processing of Your Personal Data.
8.6 Automated decision-making and profiling
You have the right to request us not to be the subject of a decision based solely on automated processing, including profiling, that produces legal effects concerning You or significantly affects You.
8.7 Exercising your rights
You can exercise Your rights by contacting us, by e-mail to privacy@mediportal.be
or by mail to: MediPortal, Molenbergstraat 94A, 2840 Rumst
If there is reasonable doubt about your identity, MediPortal is entitled to request the front of your identity card for identification before answering your question or request. However, MediPortal expressly acknowledges that it will not systematically request the data subject's identity card in this context and that it will only use the evidence to establish whether you are actually the data subject whose personal data are being processed.
8.8 Right to complain
You have the right to lodge a complaint with the Belgian Data Protection Authority:
Data Protection Authority, Rue de la Presse 35, B-1000 Brussels,
Phone +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35, Email: contact@apd-gba.be
9. Security and confidentiality
We have developed technical, administrative and organisational security measures designed to avoid the destruction, loss, forgery, modification, unauthorised access or accidental disclosure to third parties of Your Personal Data, as well as any other unauthorised processing of this data. However, in the event that this does occur and Your Personal Data is affected, MediPortal will notify You of the breach, including a description of the potential impact and a recommendation for mitigating the potential adverse consequences of the breach.
The Website has three levels of security:
- Regular automatic updates plug any software leaks and improve the security of the Website;
- SSL secures Your connection to the Website so that Your Personal Data cannot be intercepted by hackers; and
- The firewall filters all traffic to the Website, preventing malware and hacking, similar to the virus scanner on Your PC.
Under no circumstances can MediPortal therefore be held liable for any direct or indirect losses resulting from improper or unlawful use of the Personal Data by a third party.
You are liable for maintaining privacy and security when using the Services and/or Website. You alone are liable for the use of the Website on Your devices, IP address and identification data as well as for the confidentiality thereof.
10. Privacy Statement updates
MediPortal has the right to update this Privacy Statement by posting a new version on the Website. As such, it is strongly recommended to regularly consult the Website and the page explaining the Privacy Declaration, to make sure that you are aware of any changes.
The most recent version of the Privacy Statement is always available on the Website. Any update and corresponding change will be documented in the version history of the Privacy Statement.
11. References to other websites
The Website may potentially contain hyperlinks to other websites. When You click on one of these links, You may be directed to another website or Internet source that may knowingly or through the use of cookies or other technologies collect information about You. MediPortal bears no responsibility, liability or authority of any kind for these other websites or Internet sources, nor for their collection, use and dissemination of your Personal Data. You must check the privacy policies of these other websites and internet sources yourself in order to judge whether they act in accordance with the Privacy Legislation.
12. Applicable law and competent jurisdiction
This Privacy Statement is governed by and must therefore be interpreted in accordance with Belgian law.
Any dispute arising out of or in relation to this Privacy Statement shall be subject to the exclusive jurisdiction of the competent courts of MediPortal's registered office.
