Appropriate Communications BV takes your rights regarding data processing seriously. In this statement, Appropriate Communications BV explains how it collects, processes and uses your personal data. It thus sets out the general data processing policy of Appropriate Communications BV.

The data controller is Ann Lambert, Director, Appropriate Communications BV, Dorpstraat 36 B1.2, 2070 Zwijndrecht, BE0472.625.273.

If you have any questions about this statement and our policy, you can always contact Ann Lambert (ann.lambert@appropr.com). For questions that go beyond a request for information, we may ask you to identify yourself, so that we can be sure we are providing the requested information and data to the right person.

When does Appropriate Communications BV collect and process data?

Appropriate Communications BV collects and processes data about you when you are treated and cared for by us as a patient, or when you contact us in any other way.

If you are a supplier, your data or that of your contact persons is processed in the context of these activities, as well as when drawing up invoices and other accounting documents. 

In some cases, we process your data with the aim of presenting our services to you (direct marketing).

Finally, we may process data about you because it is or may be relevant to our activities, for example in order to be able to call on your advice or services.

What data does Appropriate Communications BV collect and process?

This concerns the data that you provide to us and that we need for your treatment and care as a patient, such as your name and address, email address and all other related data, in particular data relating to your health. You usually provide this data to us directly, but we may also obtain it from other parties, such as your GP or other specialists.

The data may also relate to your leisure activities or consumption habits, in particular where these may be relevant to your care. Financial data must be processed for accounting purposes. 

We collect this data during conversations in person, by telephone or by email, as well as when you fill in our paper or electronic forms.

When you visit our website, cookies are used. You can find more information about these in our cookie policy below.

For what purposes does Appropriate Communications BV collect and process data?

We process this data for patient care (providing healthcare services and thus performing the contract we conclude with you),

direct marketing, supplier management, accounting and communication/public relations.

As far as our website is concerned, we tailor its content and ease of use to you as a user as much as possible. In addition, we process your data to comply with the obligations arising from making a website and its content available, and to enable you to use the interactive applications and services on this website.

What is the legal basis for the processing of data by Appropriate Communications BV?

In principle, we collect and process your data on the basis of the contractual relationship we have with you as a result of your request for care and treatment and the contract we conclude with you for that purpose. In other cases, the processing is based on the tasks of public interest that we perform as healthcare providers.

The contractual relationship is also the basis for processing data about suppliers.

Where processing is not necessary to perform the contractual relationship, such as for direct marketing and communication, it is based on our legitimate interests as a healthcare provider, in particular the freedom of association and information. In doing so, we always ensure that there is a balance between our interests and yours.

Is data shared with third parties?

Your data is mainly processed internally for the purposes of patient management and accounting.

For certain specific services or assignments, it may be passed on to processors we work with, but always under our control. In such cases, we have always concluded a data processing agreement with the processor.

Sometimes we are permitted to pass on data about you, and sometimes we are obliged to do so. This is the case in particular when we are legally required to do so or when government authorities have the right to request data from us. In all cases, the rules on professional secrecy are always respected.

Is your data transferred outside Europe?

In principle, your data is not transferred to third countries, i.e. countries that are not part of the European Economic Area (which consists of the European Union together with Iceland, Norway and Liechtenstein). If this does happen, we ensure that the third countries offer an adequate level of protection, or that we provide appropriate safeguards by concluding so-called standard contractual clauses with the recipients in those third countries. If this is not possible, we ensure that we can rely on one of the derogations provided for in the General Data Protection Regulation.

How long is your data kept?

Appropriate Communications BV retains personal data (i) for as long as necessary or relevant for the stated purposes, (ii) for the period it is legally required to, or (iii) for as long as legal disputes or investigations may arise.

Your rights

In principle, you have the following rights:

• the right to information;
• the right to withdraw consent;
• the right of access;
• the right to rectification;
• the right to object;
• the right to erasure;
• the right to restriction of processing;
• the right to data portability;
• the right not to be subject to automated decision-making;
• the right to lodge a complaint with the Data Protection Authority.

To exercise your rights, simply submit a request to Appropriate Communications BV, together with proof of your identity. We ask for this to prevent your data from being disclosed to someone who is not entitled to it.

If you disagree with the way Appropriate Communications BV processes your data, you can always lodge a complaint with the Belgian Data Protection Authority (www.gegevensbeschermingsautoriteit.be), Drukpersstraat 35, 1000 Brussels.

Changes

Appropriate Communications BV reserves the right to amend this statement and/or this policy. Users will be notified of changes via the website.