Privacy policy

introduction this privacy policy describes our policies and procedures on the collection, use and disclosure of your information when you as a user, make use of our services and tells you about your privacy rights and how the law protects you this policy refers to personally identifiable information we receive from any of our services, including this website and all of its subdomains, our mobile application and our software therefore, not all provisions of this policy necessarily apply to all services at the same time section 1 – definitions account means a unique account created for you to access our service or parts of our service company (referred to as either “the company”, “we”, “us” or “our” in this policy) refers to intelliprove bv, d’haenestraat 22, 9070 heusden device means any device that can access the service such as a computer, a cellphone or a digital tablet personal data is any type of information that, when used alone or with other relevant data, can identify an individual services refers to the website, our mobile application and our software service provider means any natural or legal person who processes the data on behalf of the company it refers to third party companies or individuals employed by the company to facilitate the service, to provide the service on behalf of the company, to perform services related to the service or to assist the company in analyzing how the service is used website refers to intelliprove, accessible from www intelliprove com application (mobile application) refers to the ios and android application we provide to perform health checks software refers to the whole of our technology, provided as an api, sdk or application, which can be used to perform health checks usage data refers to data collected automatically, either generated by the use of the service or from the service infrastructure itself (for example, the duration of a page visit) cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses you means the individual accessing or using the service, or the company, or other legal entity on behalf of which such individual is accessing or using the service, as applicable section 2 – what information do we collect? when you use our service we collect information relating to you and your use of our services from a variety of sources these are listed below the sections afterward describe what we do with this information information we collect directly from you registration information you may need an intelliprove account or google account to access certain parts of our websites when you register for an account, we collect your email address other intentionally shared data we may collect your email address, phone number and name if you submit it to us in other contexts for example when you subscribe to receive communications from us or contact us in any way information recorded while you use our software or application, such as vital signs and biomarkers examples are heart rate, acute mental stress score, repiratory rate and sdnn these are the results calculated as part of the health check when you use our mobile application or software, to track your historical measurement data the results are calculated based on a video of the face, which is processed on our servers these measurement results vital signs and biomarkers are stored anonymously users can request to delete their measurement results history at any time debugging and diagnostics data we may collect certain data, including logs, error reports, and performance metrics, in order to diagnose and fix technical issues with our products or services we may retain this data for a limited period of time and restrict access to authorized personnel only job applicant information if you are voluntarily making a job application or perform an inquiry through the website, you may provide us with a copy of your cv or other relevant information that contains your personally identifiable information we use this information for the purpose of considering your application or inquiry except when you explicitly request otherwise, we may keep this information for future reference technical data (such as browser information) information we collect about you indirectly or passively when you interact with us usage data we use third party services, such as google analytics, that employ cookies to collect aggregated and anonymized data when users interact with our websites this may include webpage visits, what you click on, when you performed those actions and other user statistics for more information on cookies, refer to addendum one referral data if you arrive at an intelliprove website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us controller and processor in the cases where you contact us or interact with our services directly , we process your personally identifiable information as as the data controller , which means we legally own the personally identifiable information we collect in those cases, and for gdpr purposes, we assume the role of data controller, and one of our third party vendors is considered the data processor in case you use our product or any of our services through an organizational customer , who has integrated our service into their platform, we merely process your personally identifiable information on behalf of the organizational customer, who owns your personally identifiable information in those cases, and for gdpr purposes, the organizational customer is the data controller, and we assume the role of data processor that means that in those cases, your personally identifiable information is managed under the control and instructions of the organizational customer, who is responsible for the legal basis for the processing (the legal justification authorizing the processing), including any consent or disclosure any question or complaint regarding your personal data should therefore be addressed directly to the organizational customer without prejudice to our legal obligations as a processor, we are not responsible for the organizational user's actions or use with respect to your personal data organizational customer when you use the product at the invitation of, or subject to a license purchased by, an organizational customer, the organizational customer will have access to all or portions of the information about you (including but not limited to personal identifying information) provided or collected by you through the applicable product when you use a product pursuant to such license or invitation, we will assume that you have given organizational user permission to share your information with organizational customer while we require our organizational customer to comply with requirements that are substantially similar to these terms and applicable law, we cannot (and do not) guarantee such compliance, and in no event are we responsible for the actions of the organizational customer section 3 – purpose of the processing intelliprove will process your personal data for following purposes as controller of the processing to provide you with any of our services, including the software and the application to monitor, maintain, and improve our services we internally perform statistical and other analysis on information we collect to analyze and measure user behavior and trends, to understand how people use our websites, including to help us evaluate or devise new features we may use your information for internal purposes designed to keep our websites secure and operational, such as for troubleshooting and testing purposes to enforce our terms of use general docid 1eimkkqy p8yiquw5rbcz to create new services, features, or content to contact you about your service or account we can occasionally send you communications of a transactional nature (e g service related announcements, billing related matters, changes to our websites or policies, a welcome email when you first register) to provide you with customer support, which requires us to access your information to assist you (such as technical troubleshooting) we are committed to handling your personal information and data with integrity and care however, regardless of the security protections and precautions we undertake, there is always a risk that your personal data may be viewed and used by unauthorized third parties as a result of collecting and transmitting your data through the internet if you have any questions about the security of your personal information, contact customer support at support\@intelliprove com section 4 – the legal basis for the processing of your information under the gdpr we will only process and use your personally identifiable information when the law allows us to, i e , when we have a lawful basis for such usage (in terms of the gdpr) such lawful and legal basis can be any of the following processing actions related to your requests or to carry out our obligations arising from any contracts entered between you and us for example, providing you with our services per your demand or purchase, or contacting you per “contact” form filled by you; our use of your information is necessary to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal obligations; our use of your information is in our legitimate interest as a commercial organization for example, to operate and improve our services and keep people informed about our products and services in these cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights, making sure our legitimate interest is not overridden by your interests or fundamental rights and freedoms as detailed above, we do not rely on consent as a legal basis for processing your personally identifiable information yet, in any case, in which you have provided your consent to our processing of your information, you can withdraw this consent at any time by contacting our customer support team at support\@intelliprove com section 5 technical and organizational measures to protect your data intelliprove has implemented and will maintain appropriate technical and organizational measures intended to protect personal data or the systems that process personal data against accidental, unauthorized or unlawful access, disclosure, alteration, loss or destruction these measures will take into account and be appropriate to the state of the art, nature, scope, context and purposes of processing and risk of harm which might result from unauthorized or unlawful processing or accidental loss, destruction or damage to personal data intelliprove will adapt these measures systematically to the development of regulations, technology and other aspects and supplemented with the applicable technical and organizational measures of sub processors, as the case may be in any event, the implemented technical and organizational measures will ensure a level of security appropriate to the risks represented by the processing and the nature of the personal data to be protected, taking also into account the state of technology and the cost of their implementation section 6 how do we anonymize your data? see below the measures taken to guarantee complete anonymization of the data data collection for each measurement, a video of the individual is recorded and uploaded to our secure server however, this video is referenced only by a unique number, ensuring that there is no direct link to any personal data that could identify the patient or authorized user unique number reference the unique number serves as the sole identifier during the processing of the video at no point is any personal information associated with this reference, ensuring complete anonymity throughout the entire data handling process absence of personal data linkage our system is designed in a way that guarantees no link exists between the unique number reference and any personal identifiers of the patient or authorized user this separation of data ensures that the collected information cannot be traced back to any individual optional patient reference while we offer the option to provide a patient reference, it is important to note that this reference is merely a customizable identifier chosen by the customer it is not connected to any personal information, and its sole purpose is to facilitate grouping of measurements under a patient entity this allows customers to request historical data for specific patients without compromising their privacy immediate video removal once the video has been processed and the necessary data has been extracted, the original video is promptly removed from our system this step ensures that no identifiable information is retained beyond the necessary processing time limited data retention following the video's removal, intelliprove no longer possesses any data that could be linked back to the patient or authorized user we adhere to strict data retention practices to protect the anonymity and privacy of all individuals involved we are committed to maintaining the highest standards of data protection and privacy the anonymized data is used exclusively for research, development, improvement, or support of the intelliprove solution section 7 – when might we disclose your data to third parties? intelliprove will not disclose or otherwise reveal any personal data to a data subject or third party, unless otherwise stated in the agreement or required by law or a court or official authority’s decision in the event that intelliprove must disclose such personal data due to law or a court of official authority’s decision, intelliprove will notify the licensee and/or the data controller, unless this is prohibited by applicable law or a court of official authority’s decision intelliprove represents and warrants that persons acting on behalf of intelliprove and who are authorized to process personal data or to support and manage the systems that process personal data (i) have committed themselves to maintain the security and confidentiality of personal data in accordance with the provisions of this data processing agreement, (ii) are subject to user authentication and log on processes when accessing the personal data and (iii) have undertaken appropriate training in relation to data protection legislation intelliprove will inform the persons acting on its behalf about the applicable requirements and ensure their compliance with such requirements through contractual or statutory confidentiality obligations section 8 – consent when you provide us with personal information to register and use one of our services, we assume that you consent to our collecting it and using it for that specific reason only if we ask for your personal information for a secondary reason, like marketing, we will ask you directly for your consent if after you opt in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at support\@intelliprove com section 9 – security to protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed intelliprove bv, located at d’haenestraat 22, 9070 heusden, belgium is the data controller for all data we collect from users in the eu section 10 – cookies what are cookies? cookies, also known as ‘http cookies’, ‘web cookies’ or ‘browser cookies’, are small text files that are sent to and stored on your computer or mobile device through your browser when you visit a website, or use a mobile application when you surf the same website later on, the data stored in that cookie can be retrieved by the website in order to notify the website of the last activity this allows the services or a third party to recognize you and make your next visit easier and the services more useful to you, for example by remembering your language preferences each cookie expires after a certain amount of time, depending on what we use it for how do we use cookies? when you use and access the website www intelliprove com , we may place a number of cookies files in your web browser we use cookies for the following purposes to provide analytics to store your preferences which cookies do we use? we may use analytics cookies to track information on how the website is used so that we can make improvements we may also use analytics cookies to test new advertisements, pages, features or new functionality of the website to see how our users react to them name retention time description ga 1 minute set by google to distinguish users gat gtag ua 206124958 1 2 years the ga cookie, installed by google analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report the cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors gid 1 day installed by google analytics, gid cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously please be aware you can still choose to remove or disable cookies via your browser, or here manage consent section 11 – your rights you can update your account details access and correct your personal information as an account holder, you may access and correct certain personal information that intelliprove holds about you in all cases, requests to exercise these rights may be directed to our customer support team at support\@intelliprove com delete your data deleting data will not permanently delete data immediately as long as you maintain an account with us, we may retain your deleted data for a limited time in case you delete something by accident and need to restore it (which you can request by contacting customer support at support\@intelliprove com ) to the extent permitted by law, we will permanently delete your data if you request to cancel your account (“right to be forgotten”) cancel your account to cancel and delete your account, please contact customer support at support\@intelliprove com we will respond to any such request, and any appropriate request to access, correct, update, or delete your personal information within the time period specified by law (if applicable) or without excessive delay we will promptly fulfill requests to delete personal data unless the request is not technically feasible or such data is required to be retained by law (in which case we will block access to such data, if required by law) portability taking into account that intelliprove product offers data in a structured, commonly used and machine readable format, you as a client, already have the right to transmit those data to another company if desired (“right to data portability”) submit a complaint if at any time you believe we are invading your privacy, you have the right to file a complaint with the belgian data protection authority gegevensbeschermingsautoriteit, drukpersstraat 35, 1000 brussel, tel +32 (0) 2 274 48 00, e mail contact\@apd gba be section 12 – your responsibilities by using our services, you agree to comply with applicable data protection requirements when collecting and using your data, such as requirements to inform respondents about the specific uses and disclosures of their data section 13 – how long do we retain your data? the personal data are processed by intelliprove during the term of the agreement, in line with the eu general data protection regulation intelliprove stores the personal data for a period of 3 months after termination of the agreement, after which the data is made anonymous or deleted upon the termination of the agreement between intelliprove and you, intelliprove will, at your request which will be made no later than sixty (60) calendar days after the termination of the agreement, delete or promptly return all personal data to you the personal data available electronically will also, if requested, be submitted in electronic form in accordance with your instructions, provided this is reasonable section 14 – changes to this privacy policy we may modify this privacy policy at any time, but if we do so, we will make these available to you by publishing the changes on this website if we determine the changes are material, we will provide you with additional, prominent notice as is appropriate under the circumstances, such as via email or in another conspicuous manner reasonably designed to notify you if, after being informed of these changes, you do not cancel your subscription and continue to use our websites beyond the advance notice period, you will be considered as having expressly consented to the changes in our privacy policy if you disagree with the terms of this privacy policy or any updated privacy policy, you may close your account at any time last updated on march 17, 2023