Privacy Policy
1. Introduction and scope
This Privacy Policy (the “Policy”) applies to the products, services, software, website (the “Website”) and Platform (the “Platform”), owned, operated and/or used by:
icometrix NV
Kolonel Begaultlaan 1b/12
B – 3012 Leuven
Belgium
Company Number: 0833.377.379
hereinafter “icometrix”, “we” or “us”.
icometrix deems the protection of privacy of the utmost importance and wishes to enable you – as user of its Website and Platform – to maintain full control over what happens to your Personal Data and your privacy and to inform you accordingly.
All capitalized terms that are not defined in this Policy have the meaning as ascribed to them in 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 (hereinafter the “GDPR”).
Your Personal Data and your privacy are protected by icometrix in accordance with Belgian and European regulations on the protection of personal data and privacy. Please read this Policy carefully. The following describes not only your rights, but also the way in which you can exercise these rights.
By using our Website and Platform, disclosing some of your Personal Data, or accepting this Policy, you acknowledge the manner in which icometrix processes your Personal Data as described in this Policy.
2. Who processes your Personal Data and how can you contact us?
icometrix is responsible for the Processing of your Personal Data collected or provided through the Website and Platform and acts as a Data Controller in respect of your Personal Data Processed through the Website and Platform.
icometrix has appointed a Data Protection Officer, whom you can always contact for questions about your privacy and the Processing and protection of your Personal Data. The Data Protection Officer can be reached at:
icometrix NV
Kolonel Begaultlaan 1b/12
B – 3012 Leuven
Belgium
Company Number: 0833.377.379
Data Protection Officer
Riet De Kempeneer
+32 16 369 000
3. What Personal Data are collected and Processed?
icometrix Processes different types of Personal Data, depending on the services you use on the Website and Platform and as relevant. The following Personal Data might be Processed by icometrix when using the Website and Platform:
Contact information: Personal Data such as name, email address, login and password, etc.
History and logs: Personal Data such as browser type, OS information, etc.
Personal information: Personal Data such as email address, etc.
Technical information: Personal Data such as your IP address and browser type.
Cookies: For more information, reference is made to our Cookie Policy.
4. What are the purposes and principles of the Processing of your Personal Data?
The purpose and principles of the Processing of your Personal Data mainly depend on the category of Personal Data concerned. Below you will find an overview of the purpose and principles of the various Personal Data that we Process:
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Contact and personal information: These Personal Data are used for authentication and authorization purposes (i.e. identification of its users), for communication purposes, to give a (potentially anonymous) testimony or to answer support questions, for academic, clinical, educational, informational, medical and any other research purposes and use, for and to improve the operation of the Website and Platform and other icometrix products and services, etc.
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History and logs: These Personal Data are used to provide service support, and to improve the operation of the Website and Platform and other icometrix products and services, etc.
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Technical information: These Personal Data are used to provide service support, and to improve the operation of the Website and Platform and other icometrix products and services, etc.
Below we describe each applicable legal basis for Processing in detail:
Legitimate interest as a legal basis for the lawfulness of Processing is justified with regard to certain of the above mentioned Personal Data to improve your user experience, the Website and Platform, and icometrix other products and services. The fact that icometrix Processes this Personal Data also benefits you as a user of the Website and Platform. Moreover, such processing of Personal Data shall not create a risk to the fundamental rights and freedoms of you as a user of the Website and Platform or any other users of the Website and Platform.
The Processing of certain of the above-mentioned Personal Data by icometrix and other information you might disclose is necessary for the performance of the agreement. In the event you refuse to provide these Personal Data, icometrix will not be able to comply with certain of its obligations (e.g. (without limitation) providing access to the Website and Platform and responding to your questions).
We ask your consent to Process certain of the above-mentioned Personal Data. The consent you provide is always free, and you have the right to withdraw this consent at any time. Withdrawal of consent does not affect the processing of Personal Data (i) prior to such withdrawal, (ii) based on a legitimate ground for Processing Personal Data, and (iii) in case of a legitimate interest of the Processing.
The above reasons may not be exhaustive, and icometrix may at any time Process your Personal Data for any other legitimate reason. In such cases, icometrix will notify you as soon as possible of the reason. Updates of this Policy may constitute such a notification.
5. Receiving and sharing Personal Data
icometrix receives your Personal Data in cases as and when:
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you register your account on the Website and Platform;
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you add information on the Website and Platform;
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you visit the Website and Platform;
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you load the Website and Platform;
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you navigate to a new page of the Website and Platform;
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errors or bugs occur;
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...
Processors and Subprocessors of icometrix always act under the responsibility of icometrix. If icometrix contracts Processors or Subprocessors, this will always be done in accordance with a Data Processing Agreement that meets the requirements of the GDPR and that protects your Personal Data as well as possible.
If you are directed to another application, Website and Platform or website through the Website and Platform, other terms and conditions and other privacy and cookie policies may apply. You should take into account any such terms and conditions and privacy and cookie policies of such applications, websites, and Platforms. We encourage you to read these terms and conditions and privacy and cookie policies of the other applications, websites and Platforms you visit.
6. Profiling based on Personal Data
icometrix may use your Personal Data for profiling, this means that your Personal Data might be processed automatically by icometrix based upon the Personal Data you provide to icometrix. The underlying logic pursuant to which the profiling occurs is deliberately assessed by icometrix. Upon your reasonable written request, icometrix will provide more information on the mathematical or statistical procedures of this logic.
The profiling executed by icometrix does not produce legal effects concerning you, nor does it similarly significantly affect you.
7. Transfer of Personal Data to countries outside the European Economic Area (EEA)
icometrix may transfer your Personal Data to countries outside the EEA. In this case, icometrix only transfers your Personal Data outside the EEA in accordance with applicable law (such as chapter V of the GDPR) using appropriate safeguards (e.g. model contract clauses, binding corporate rules, codes of conduct, adequacy decisions, etc.).
8. How will your Personal Data be retained?
icometrix applies the following retention periods for your Personal Data:
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Contact and personal information: Retention of the contact information (i) as long as the consent is valid and has not been withdrawn, or longer, (ii) if and as long as icometrix has a legitimate interest or (iii) as long as reasonably needed for the performance of the agreement.
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History and logs: Retention of history and logs as long as icometrix has a legitimate interest.
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Technical information: Retention of technical information (i) for 26 (twenty-six) months or longer (ii) if and as long as icometrix has a legitimate interest,
Please note that we retain your Personal Data even if you temporarily stop using the Website and Platform until you permanently delete your account through notifying us thereof by contacting support@icompanion.ms.
9. How is your Personal Data safeguarded?
icometrix has developed appropriate technical and organizational measures, safeguards and assurances to Process your Personal Data in accordance with applicable Belgian and European regulations, in particular, to protect your Personal Data against loss, misuse, or unauthorized alteration. icometrix maintains a team of technicians, automated systems, and advanced technologies, such as:
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ISO27001 certification;
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SSAE 16-compliant SOC2;
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HIPAA compliance;
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data are kept in a database to whom only a select group of people inside icometrix and the treating health care provider have access;
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data are anonymized and encrypted to the maximum extent possible before they are transferred to third parties;
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appropriate data processing agreements are concluded with third parties and subprocessors;
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...
icometrix makes all reasonable and appropriate efforts to protect the confidentiality of your Personal Data.
Despite the above measures taken by icometrix, you should be aware that there are always risks associated with sending Personal Data over the Internet. The security and protection of your Personal Data can never be fully guaranteed.
10. What rights do you have?
If and in as far as provided for in the applicable Belgian and European legislation, you have the right:
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to receive confirmation as to whether icometrix Processes your Personal Data and, where this is the case, to access the Personal Data that icometrix Processes;
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to corrections by icometrix, without undue delay, of any inaccurate or incomplete Personal Data;
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to have your Personal Data deleted by icometrix;
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to obtain your Personal Data and to transfer them to another Controller or Processor;
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to obtain a limitation of the Processing of your Personal Data from icometrix, to the extent possible subject to applicable Belgian and European regulations;
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to receive your Personal Data in a structured, common and machine-readable format; and
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to prevent the Processing of your Personal Data and the use of your Personal Data for direct marketing purposes.
You can exercise your rights yourself on your account on the Website and Platform (to the maximum extent possible) or you may exercise these rights by contacting the Data Protection Officer and providing him or her with a copy of your identity card (no identification number may be visible).
If and to the extent provided for in the applicable Belgian and European legislation, you have the right to file a complaint with the competent supervisory authority should the Processing of your Personal Data violate the applicable regulations. In Belgium, this is the Data Protection Authority (“Gegevensbeschermingsautoriteit”) https://www.dataprotectionauthority.be.
11. Amendments to this Policy
icometrix may amend this Policy at any time. The date of the most recent version is shown at the top of the Policy. Amendments are posted on the Website and Platform to keep you informed at all times of the information that icometrix collects and of how it uses and shares this information.
Amended versions of this Policy take effect ten (10) days after their publication on the Website and Platform. Where required they will always be submitted for approval. Your continued use of the Website and Platform following the effective date of a change shall constitute Your acceptance of such change.
12. Consent for disclosure
You acknowledge that we may disclose your Personal Data if this is required by law, or if icometrix determines in good faith that such disclosure is required in order:
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to comply with any pending judicial inquiry, judicial order or litigation pertaining to the Website and Platform(s);
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to respond to claims against icometrix regarding Personal Data that violate any rights of third parties;
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to safeguard the rights, property and safety of icometrix, its employees, users, and the general public.
icometrix may disclose your Personal Data to competent police or judicial authorities or other official government authorities if icometrix deems this useful or necessary, in its sole discretion, for the investigation of fraud, intellectual property infringement or any other harmful activity, or if icometrix reasonably suspects that such activity may expose icometrix or you to any liability.
13. Third-Party disclosure
We will not sell, exchange or share your Personal Data with third parties unless we provide an advance notice to users and requested consent. This does not include website hosting partners and other parties who assist us in the management of our website. Your Personal Data may be shared with sales representatives in countries other than Belgium.
14. Cookie Policy
A. What are cookies?
Cookies are small pieces of information in the form of text files, created by a program on the server of the Website and Platform, which are then placed on the hard drive of your computer when you use the Website or Platform (or on any other device through which you use the Website or Platform).
The Website and Platform uses cookies to identify you as a user of the Platform, to remember your preferred language, and to facilitate navigation on the Website and Platform for you. By using cookies you do not need to identify yourself repeatedly, e.g. for personalized services (such as filling in your user name or password, selecting a language).
B. Types of cookies icometrix uses
The following types of cookies are placed:
Analytical cookies compile statistics on certain information (e.g. popularity, number of visitors, …).
Tracking cookies monitor browsing behaviour and follow users in order to later respond to their browsing behaviour (e.g. personalised promotional campaigns).
C. Cookie management
You can manage the use of cookies yourself. For example, you may choose to block all cookies or only accept cookies. Please note, however, that certain features of the Website and Platform are only available, accessible or workable if you have accepted cookies. Accepting cookies makes browsing the internet much easier and ensures that the websites you visit perform better. The use of cookies is generally accepted by internet users.
Managing and deleting cookies is also possible via the settings of your browser.
15. Applicable law and competence clause
This Policy shall be governed, interpreted, and implemented in accordance with Belgian law, which applies exclusively in the event of any dispute. The Court of Leuven (department Leuven) are exclusively competent to decide on any dispute that may arise from the interpretation or implementation of this Policy, without prejudice to the consumer’s right to present a dispute before the competent court on the basis of a mandatory statutory provision.