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Privacy policy

Date: August 11th, 2023

Version: August 2023

I. General data.

In this privacy policy information about the protection of your personal data and privacy are mentioned. The protection of the personal privacy of the Online Education Platform Surgquest (afterwards mentioned as “the Platform”) users will be addressed in this privacy policy. 


You are typically a client of 4 Health Belgium bv (“we or “us”), a speaker during an event organized by us or a Platform-visitor.

This privacy policy will inform you of which person related data will be collected and/or stored when using the applications, the reasons why we do this and which control measurements are available to you.

It is important to 4 Health Belgium bv that the terms that are applied by the legislator are correct and explained in an understandable fashion, therefore the different terms used in this privacy policy are explained more elaborately.

a. The responsible for data processing.

What/who is the responsible for data processing?

The responsible for data processing is the person of the institution that is responsible for the collection of the personal data when accessing and using the Platform and determining the purposes of the processing.


It is of the utmost importance that we are, as data controller of the processing, always reachable for possible questions and remarks regarding the privacy policy.


Therefore, 4 Health Belgium bv has, in compliance with GDPR, assigned a Data Protection Officer. 


Please find below our contact details:

$bController of processing

4 Health Belgium bv

$bDepartment

Online Platform

Data Protection Officer

$bAddress

Proefhoevestraat 12

Kortrijksesteenweg 546

$bCity

9090 Melle

9000 Gent

$bKBO

BE0786.525.389

BE0544.823.957

$bE-mail

info@surgquest.com

gent@trustadvocaten.be

$bTelephone

+32 475 40 67 41

+32 9 277 77 20

Acknowledgement and adjustment

By using the Platform, the associated applications and filling in of the forms you acknowledge to have taken cognizance of the provisions and measures in this privacy policy.


4 Health Belgium bv reserves the right to adjust its policy at any time, provided that the users are notified via the Platform or via e-mail. The adjustments become effective on the date of their publication on our Platform.

b. Applicable law.

The processing of personal data within 4 Health Belgium bv is subject to the European regulation 2016/679 of the European Parliament and the Council of April 27th 2016 concerning the protection of the natural person in relation to the processing of personal data and concerning the free traffic of these data, as well as the law of July 30th, 2018 concerning the protection of the natural person with regard to the processing of personal data.

II. Collection of personal data.

a. Definition personal data.

Under the name of ‘personal data’ we mean all data or information (e.g. name, phone number, e-mail address, birth date, enterprise number …) that is related to an identified or identifiable natural person.


The use of our Platform and applications.

By using our Platform a number of personal data will be collected in various ways:

  1. The personal data that are shared by you.
  2. The personal data we receive when you make use of our services.

The different ways of collecting the personal data is subject to specific provisions and conditions in the applicable legislation with regard to privacy and data protection.


1. The personal data that are shared by you

a. With every login- and authentication procedure, you are asked to provide personal data (i.e. user name and password) in order to gain access to the Platform. 


b. In addition, you can be asked to provide your name, surname, an image of yourself, your professional function, employer and qualifications. This is necessary to create your user account on the Platform. The user profile is necessary if you want to make use of our services (i.e. subscription for courses, participation in tests and evaluations, publication of executed operations, etc.).


Dependent on the application, the below-mentioned categories of personal data can be requested:

$bType of personal data

$bDescription of personal data

Security

Password

Personal identification data

Name, surname, professional e-mail address

Professional experience

Academic and professional interests, expertise, fellowship

Media use

LinkedIn profile, Twitter profile, PubMed and ResearchGate

Publications

Books, articles, reports, audiovisual imagery

Current position

Employer, place of employment, function, fellowship

The personal data that are provided by you are considered correct and complete. 


When sharing incorrect personal data, we reserved the right to deny you, the access to the Platform and its services. 


2. Automated collection of personal data

By accessing our Platform, various personal and other data are collected automatically using cookies and tracking technologies:

$bType of personal data

$bDescription of personal data

Electronical identification data

GA4-User-ID,GA4-unique ID, cookies, time of connection, …

Electronical localization data

Estimated location, setting, …

Surfing behavior

What pages are being looked at, how long a page is being looked at, clicks, hits, ….

Through which channel you are accessing our Platform

Search terms, through which webpages our Platform is being accessed

Which device is being used

PC, smartphone, tablet, …

Which system software is being used

Windows, Android, Apple, …

Which browser is being used

IE, Mozilla, Chrome, …

With this automated collection your direct identification data are not being registered or kept track of.


We will ask for your explicit consent for the use of cookies and tracking technology, where needed. This is according to our cookie policy as described on our webpage: https://www.surgquest.com/cookie-policy


III. Justifications and purposes of the processing

a. Definition of processing

The processing of your personal data concerns all possible operations or a whole set of operations, whether or not automated, such as e.g. the collection, the structuring, the saving, the consulting, the archiving, the updating, the use, the combining, the erasing or the destroying of personal data. 


4 Health Belgium bv can make use of processors for some of these processes, such as natural or legal persons, government agencies, services or other bodies that process personal data, upon documented instructions of 4 Health Belgium bv.

b. Execution of the Agreement


1. Education, training and mentoring

Before you can subscribe to our services on the Platform, you have to create a profile (i.e. an account) on the Platform. 


When creating this profile, various personal data will be requested, as previously mentioned in point II.b.1. These personal data are necessary for the provision of our services, i.e. the organization of the trainings, education and mentoring. 



2. Customer management

During the process of contract negotiation and, further, its execution, as case may be, various personal data can be requested and/or collected that are necessary to conclude an agreement, such as:

  • Name
  • Surname
  • Professional address
  • Professional e-mail address
  • Professional phone number
  • Function
  • Employer

Without these personal data, there is no possibility to negotiate and/or execute any agreement, therefore all personal data provided by you are required to be correct and complete. 


When sharing incorrect personal data or not correcting incorrect personal data and/or updating this data, when needed), we reserve the right terminate any existing agreement with you. We also make a strict reservation for damages of any kind whatsoever.


3. Overview of the processing

The below table demonstrates the type of personal data, its description, the purposes of processing, based on the legal basis of “execution of the agreement” and, in brief, indicate what personal data is being processed of you.

Processing of personal data

Type of personal data

Description of personal data

Purpose of processing

Customer management (including speakers)

Security

Password

Authentication and identification

Personal identification data

(Account) Name, e-mail address

Set-up of a profile on the Platform with the aim of participation in trainings, education and mentoring mutual sharing of expertise, etc.

Professional experience

Academic and professional interests, disciplines, specialties, fellowship

Media use

LinkedIn profile, Twitter profile, PubMed and ResearchGate

Publications

Books, articles, reports, audiovisual imagery

Current position

Employer, place of employment, function, fellowship

Professional contact details

Name, address, professional e-mail, professional phone number

The administration of the client management and the billing

Financial identification data

VAT-number, bank account number

Other

Any other information you decide to share with us


c. Legitimate interest


1. Adjustment and regulation of online training, education and mentoring

As user of the Platform, you have the possibility to fill in the “Participant Profile”, in which you are asked to provide various professional personal data, such as personal data that demonstrate your experience, as case may be. These personal data are processed by 4 Health Belgium bv. 


Personal data that is being collected from another participant during a training and/or education program, may only be used by another participant to network, but only during this event. It is strictly prohibited to process these personal data for your own purposes, such as direct marketing. 


Based on the collected personal data, 4 Health Belgium bv can develop its courses as well as validate the best trainings, education and mentoring for you, on an individual basis. 


2. Direct Marketing

To keep you informed, 4 Health Belgium bv will keep you in the loop of new courses, trainings, education, etc. that might interest you.

In case you are no longer interested to be informed by us, you can unsubscribe, at all times.


3. Overview of the processes

Processing of personal data

Type of personal data

Description personal data

Purposes of processing

Development of training,

education and mentoring

Personal identification data

Name, e-mail address

Adjustment and regulation of the training, education and mentoring to the profile of the participants

Professional
experience

Academic and professional interests, disciplines, specialties

Direct marketing

Personal identification data

Name, e-mail address

Sending of newsletters, offering of courses

IV. Quality and balancing of interests

As a data controller, we supervise the quality and legality of the personal data that is being collected and processed. We take every necessary measure to delete or improve the personal data that is inaccurate or incomplete. 


When collecting and processing the available personal data we only collect and process the personal data that is useful for obtaining our processing purposes.

V. Retention period of personal data

The personal data will be collected for the entire period that is necessary for the accomplishment of our processing purposes. A longer retention period or further processing than necessary for reaching our purposes shall not be implemented. 


Below you will find a subdivision ofthe activities to explain these terms more elaborately.

Processing activity

Retention period*

Date of commencement term

Legal basis

Platform – Participant administration

20 years

From January 1st of the year that follows on the last subscription for a training, education and/or mentoring

Contractually

Evaluation and tests

20 years

From January 1st of the year that follows on the last subscription for a training, education and/or mentoring

Contractually

Trainings, education and mentoring

20 years

From January 1st of the year that follows on the last subscription for a training, education and/or mentoring

Contractually

Customer management

7 years

From January 1st following the invoice date

Art. 354 WIB92

Direct marketing

20 years

From January 1st of the year following the last subscription for a training, education and/or mentoring

Contractually

*the duration of the retention period is equal to the periods in the table below, or as long as legally required.


The personal data are collected according to the term as described above, to be deleted or at least anonymized afterwards, after which identification of the data subject is no longer possible, unless this is necessary for the execution of an ongoing agreement or in the context of a legal obligation, judicial or police investigation.

VI. Transmission of personal data

4 Health Belgium bv can forward your personal data to third-party sub-processors. For this, a distinction must be made between processors and other third persons (not processors).


1. The transmission of your personal data to (sub-)processors.

The transmission is necessary for the achievement of our purposes, namely for the proper functioning of the Platform.


2. The transmission is necessary if there is a legal obligation to transmit your personal data or on request of judiciary authorities or police forces


3. The transmission of anonymized data for scientific purposes

The results of the tests, participant profile and the follow up questionnaires, which were obtained before and after participating in the courses, might be anonymized and afterwards sent to centers for scientific research with the aim of publications of scientific articles, comparative research, …


4. Transmission to third persons

Upon your request your data can be transmitted to third persons, such as hotels and taxi companies.

VII. Rights of the data subject

a. General

4 Health Belgium bv is responsible, as a data controller, to inform you with regard to the collection and processing of your personal data. This privacy policy hereby applies as a notification.

Depending on the selected legal basis for the processing, certain rights can be executed. In order to offer a clear overview, a schematic summary of your rights under GDPR has been portrayed in the table below.

Processing ground

Rights of the data subject

Necessary for the execution of an agreement

Right to access

Right to rectify

Right to object

Right to restriction of the processing

Right to be forgotten

Right of data portability

Right to file a complaint

Legitimate interest

Right to access

Right to rectify

Right to object

Right to be forgotten

Right to restriction of the processing

Right to file a complaint


b. Right to access

You have the right to obtain information from 4 Health Belgium bv on whether or not your personal data will be processed. If your personal data is processed you can have access to your data in all our files with additional information about the processing purposes, the categories of personal data, possible receivers of your personal data, the retention period, complaints procedure, …

Furthermore, you can request a copy of your personal data, without additional administrative costs. Mind you, when you request multiple copies 4 Health Belgium bv will charge you a fair compensation.

You can consult the procedure to exercise this right in point g.


c. Right to rectify

As a data subject you have the right to rectify all incomplete or incorrect personal data that relate to your person.

With the term “rectify” it is meant that you can have wrong personal data changed or even removed.

The correctness and the quality of your personal data is of great importance for the achievement of our purposes.

You can consult the procedure to exercise this right in point g.


d. Right to object

You have the right to object the processing of your personal data. The legal provisions provide a generic right to object as well as an objection with regard to direct marketing.

Therefore, you have a generic right to object.


Generic right to object:

You are entitled to object against the processing of your personal data when these data (i) are incomplete in accordance to the processing purposes or not submitted or when the data of which the registration, (ii) the communication or the storage are forbidden or (iii) when the data are saved longer than the specified storing time.


When your personal data are legitimately processed you can object against processing, conform the legal provisions ofthe privacy legislation, due to serious and justified reasons that are connected to your specific situation.


You are required to provide us with justified argumentation to preventfurther processing.


Right to object on the data subject of direct marketing:

You can object against processing of your personal data for direct marketing purposes, free of charge and without any motivation.

You can consult the procedure to exercise this right in point g.


e. Right to be forgotten

Without unreasonable delay, you may have your personal data deleted under certain conditions according to GDPR. This is under the conditions that:

  • The personal data are no longer necessary for the purposes for which they were collected or processed; 
  • You withdraw your permission for specific purposes; 
  • The personal data are unlawfully processed; 
  • The personal data must be erased to meet a legal obligation.

You can consult the procedure to exercise this right in point g.


f. Right to receive personal data

According to the AVG, you have the right to request a copy of the personal data from you, which is being processed by 4 Health Belgium bv, in a structured, common and machine-readable way.


This can be requested for personal use as well as for transmission to a third party other than 4 Health Belgium bv.


If technically feasible for us, you can request the electronical transmission of your personal data to a third party, after providing us the correct contact details, including the details of the transmission, of the latter party.


You can consult the procedure to exercise this right in point g.


g. Procedure to exercise rights

When you wish to exercise one or more of the above mentioned rights, you are required to send your request, by mail or e-mail to:


4 Health Belgium bv 
Proefhoevestraat 12
9090 Melle
Belgium
E: info@surgquest.com


After receival of your request, we will act without undue delay and in any case within one month.


Depending on the complexity of the request, this term can be extended with two months. You are notified when such an extension takes place.



h. Declaration and competent authority in case of infringement

When you believe that the before mentioned rights are not being respected by us and you wish to file a complaint, you can turn to the Data Protection Authority:


Data Protection Authority

Drukpersstraat 35, 1000 Brussel

E: contact@apd-gba.be

T: +32 (0)2 274 48 00

F: +32 (0)2 274 48 35



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