Privacy Policy
Content
1. Cleo Clinics privacy statement introduction.
2. Categories of personal data
3. Basis and purposes for data processing
4. Period of storage
5. Recipients of personal data
6. Security
7. Your rights regarding your personal data
8. Right of inspection (Article 15 AVG).
9. Right to rectification (Article 16 AVG).
10. Right to transfer data (Article 20 AVG).
11. Right to erasure of data (Article 17 AVG).
12. Right to file a complaint with the Personal Data Authority.
13. Right to stop data use, objection (Article 21 AVG)
14. Duties
1. Cleo Clinics privacy statement introduction.
This is the privacy statement of Cleo Clinics. This privacy statement applies to all privacy-sensitive information or personal data that you provide to us. We clearly explain to you how we store your data, how long it is kept and what exactly is the purpose of the data processing. In addition, we give you a clear understanding of how you can make use of your rights regarding data processing.
In some situations, Cleo Clinics needs to collect and process or use your personal data. Because we process (or have processed) personal data in a variety of situations, we have chosen to provide a comprehensive privacy statement, however, this does not mean that we process a lot of personal data. Cleo Clinics processes personal data in a minimal way. It is important that you know what happens to your personal data and how you can let us know your wishes regarding the handling of
personal data.
Cleo Clinics takes your privacy very seriously and will use and process personal information in a secure manner. All articles in this privacy statement are in accordance with the applicable General Data Protection Regulation (AVG) legislation. This European privacy legislation has been applicable in the Netherlands since May 25, 2018.
Do you have any questions about our privacy statement? If so, please feel free to contact Cleo Clinics customer service.
Schiedamsedijk 81A 3011 EM Rotterdam
Chamber of Commerce number: 89896319
2. Categories of personal data
In order to best support our visitors, customers and partners, it is necessary for us to collect
process certain data, including personal data. Personal data is data that can be traced back to a natural person. The personal data we (generally) process are:
- BSN number;
- First and last name;
- Residential address;
- (Possibly) Photographs of an area to be treated;
- Medical record;
- (Personal) email address (note: under the AVG, certain company email addresses may be designated as personal email addresses. Consider the email address piet@bedrijf.nl).
We store and use only the personal data that is provided directly by you, or that is clear at the time of submission that it is being provided for processing by Cleo Clinics.
3. Basis and purposes for data processing
Under the AVG legislation, we are obliged to have a lawful basis for processing your personal data. Article 6 paragraph 1 sub a and sub b of the AVG is applicable to our situation: the processing of your personal data is done on the basis of consent or because it is necessary for the execution of an agreement between you and Cleo Clinics.
Article 13(1)(c) of the AVG then requires us to clearly indicate the “processing purposes” for which the personal data are intended. The following is therefore an overview of different processing purposes.
There are a number of purposes for which Cleo Clinics collects your data;
1. Contacting
If you have contacted Cleo Clinics in any way, the data you have provided will be stored and used for further contact. This includes name, email address and telephone number. The bases for processing in this context: our legitimate interest (we need to be able to communicate with you in order to process or follow up on questions and offer our services).
2. The Agreement
When an agreement is concluded, Cleo Clinics requires certain data. Without these data it is not possible to properly execute the agreement. These include first and last name, address, identification and contact data. The basis for processing for this purpose are: Your explicit consent (through the agreement of an Agreement with Cleo Clinics by which you indicate that you are aware of and agree to the data processing of certain personal data), performance of the agreement (being able to properly perform the services of Cleo Clinics), legal obligation (properly performing our services and the obligation to comply with the concluded agreement, fulfilling our legal obligation as healthcare providers to verify the identity of a person) and our legitimate interest (properly performing our work and being able to deliver our products).
3. Medical record
It is important for Cleo Clinics to keep a medical record. This contains data about your health and personal preferences, for example. In order to keep the file up to date, Cleo Clinics requires certain data. Without these data it is not possible to keep the file up to date correctly, and according to legal conditions. The transfer of these personal data is based on strict consent. These personal data include first and last name, gender, medical data such as GP and health insurance. This data is only collected with your express permission, as special personal data can also be processed here.
The basis for processing for this purpose are: Your express consent (your given permission to Cleo Clinics to process these personal data), performance of the contract (being able to properly tailor our services to the person’s medical conditions and properly perform our services), legal obligation (properly performing our services regarding the provision of our services as a healthcare provider, the obligation to comply with the concluded contract and our legal obligations regarding the processing of medical data) and our legitimate interest (properly performing our work and being able to tailor our assistance and the services to be offered).
4. Newsletter
Your e-mail address is processed at least for sending the newsletter, if you wish to receive our newsletter. If necessary, other data (such as your name) may also be processed. You can unsubscribe from receiving the newsletter at any time. The basis for processing in this context: your explicit consent (making it known to Cleo Clinics that you are interested in receiving our newsletter), our legitimate interest (for open communication and information about Cleo Clinics, if possible to offer certain products, we must have the possibility to contact our customers).
5. Accounting and Invoicing
Cleo Clinics is required by law to keep thorough accounting records. To this end, the data that is reasonably present on quotations or invoices will be saved. This includes name and, if necessary, bank details.
The bases for processing for this purpose are: Execution of the agreement (in case the agreement is concluded with the client); legal obligations (including our administration and retention obligations, tax obligations and obligation around the preparation of annual accounts and annual reports); our legitimate interest (to be able to carry out our regular business activities in a correct and effective manner; to be able to perform and improve our services, to be able to protect our interests during a dispute or legal proceedings, for example, and to prevent fraud, scams or other unlawful behavior).
6. Cookies, placed through the Cleo Clinics website (Read our cookie statement for detailed information).
All information regarding cookies is explained in detail in our cookie statement. Please note: With regard to cookies, we conform to both the AVG and the Dutch cookie law Telecommunications Act article 11.7A). This means that more extensive information about cookies is given in a separate document: our cookie statement.
4. Period of storage
Above, we have indicated the processing purposes for which we use your personal data. According to Article 13(2)(a) of the AVG, we must then indicate the storage period of personal data.
1. Contacting
If the contact does not result in the provision of a service or work, the data you provide will be retained for a period of five (5) years.
2. The agreement
For this purpose, data will remain stored for seven (7) years after the end of a client relationship, unless longer is necessary in connection with legal proceedings. In this context, the five (5) year period is also linked to the possibility of any relationship becoming a client again/again at Cleo Clinics.
3. Medical Records
Cleo Clinics is required by law to keep your personal data processed for medical records for at least twenty (20) years. Upon expiration of the retention period, Cleo Clinics will delete the medical data, provided no new medical data of the person is processed following an agreement.
4. Newsletter
We keep the data until you unsubscribe from the newsletter. After unsubscribing, the data will be deleted.
5. Accounting and Invoicing
In order to maintain proper accounting records, we must retain personal data associated with financial purposes for a period of at least seven (7) years.
6. Cookies, placed through the Cleo Clinics website. (Please read our cookie statement for detailed information)
All information regarding cookies is explained in detail in our cookie statement.
5. Recipients of personal data
Cleo Clinics shares personal data with other parties in a minimal way.
Google
Certain cookies on this website may collect certain data, this data may be shared with Google depending on the website visitor’s cookie setting.
Cleo Clinics reserves the right to share personal data with other third parties if strictly necessary/legally required. This may be the case in legal proceedings or in the event that a government agency requests the personal data. Cleo Clinics complies with the duty of confidentiality at all times.
If data must be shared, Cleo Clinics will comply with the AVG, specifically Article 28 AVG. If Cleo Clinics is required to share personal data with third parties, we will notify you by amending this privacy statement or contacting you personally.
6. Security
Cleo Clinics takes the protection of your (personal) data seriously. To adequately secure your personal data, we store it in a cloud and do not store personal data in a physical way.
Personal data can only be accessed by authorized Cleo Clinics employees involved in processing your personal data. The devices on which your data is stored are locked with a password and/or fingerprint scan and/or facial recognition. This obviously involves the necessary devices, such as computers, laptops and cell phones.
For the website and digital data, Cleo Clinics uses Firewalls, protected software (including a locked program where your medical data is stored) and anti-virus programs.
Also, your visit to the Cleo Clinics website is protected by ”http” security. This means that your connection to Cleo Clinics is private. This ensures that your personal data remains secure during your website visit.
For completeness, more information on online security:
All devices that have access to your personal data and are part of the processing of personal data are password protected.
- Security software, such as a firewall and locked program.
- We send your data via a secure Internet connection. You can tell this by the address bar ‘http’ and the padlock in the address bar.
- No personal data is physically stored.
7. Your rights regarding your personal data
Listed below are the rights you can exercise with respect to your personal data. Here we indicate in as much detail as possible the way in which the right in question can be exercised.
a. Right of inspection (Article 15 AVG).
You always have the right to inspect the data processed and stored by Cleo Clinics. To make use of this right, please send an e-mail with your request to Cleo Clinics customer service.
b. Right to rectification (Article 16 AVG).
If the data kept by Cleo Clinics proves to be incorrect, you have the right to have this data rectified. Cleo Clinics will then replace the current incorrect data with the correct data.
c. Right to transfer data (Article 20 AVG).
You have the right to have personal data transferred from Cleo Clinics to a similar party. This means a party that offers and performs roughly the same services as Cleo Clinics.
d. Right to erasure of data (Article 17 AVG).
In certain cases, you can request Cleo Clinics to have data deleted. To this end, you have the right to oblivion. Below you will find a list of situations in which Cleo Clinics must remove your data:
If the data processed by Cleo Clinics are no longer needed for the purpose of processing.
If consent to the use of personal data is withdrawn by you, for example by means of the ‘unsubscribe button’ on the Cleo Clinics newsletter.
If you object to the processing of your data. In the case of direct marketing, you always have an absolute right to object. At the moment when your interests regarding the processing of personal data outweigh those of Cleo
Clinics, you have a relative right. Erasure of the data will then only take place if it has been demonstrated that your interests outweigh those of Cleo Clinics.
If Cleo Clinics processes data unlawfully, you have an immediate option to have the data deleted by Cleo Clinics. This is the case, for example, if there is no legal basis for the processing of personal data.
If a legal retention period has been exceeded, Cleo Clinics is obliged to delete the processed personal data.
If you as a data subject are under 16 years of age and no consent of a parent or guardian has been granted for the processing of personal data. In this case, Cleo Clinics will immediately delete your personal data. There may be exceptions to the right to oblivion. For more information, please consult the following page.
e. Right to file a complaint with the Personal Data Authority.
If you are of the opinion that Cleo Clinics does not handle your personal data properly, you always have the right to file a complaint with the Dutch Data Protection Authority. You can do this via this link. The Personal Data Authority will handle your complaint.
f. Right to stop data use, objection (Article 21 AVG)
You have the right to object to data processing at any time. Especially in the case of ‘direct marketing’. Furthermore, we would like to point out the following rights:
Right to restriction of (part of) processing: under conditions, you have the right to obtain from Cleo Clinics the restriction of the processing of your personal data. In brief, this means that Cleo Clinics temporarily “freezes” the processing of the data. You can invoke this right in four situations: (1) pending the assessment of a correction request, (2) if data should actually be deleted but you do not wish it to be deleted, (3) if Cleo Clinics no longer needs the data while it is still necessary for (the preparation of) a court case and (4) pending the assessment of an objection.
Withdrawal of consent: you have this right insofar as we process of your data on the basis of your consent. You have the right to withdraw a consent once given at any time. This has no consequences for the past, but does mean that we may then no longer Process that data. Cleo Clinics may no longer be able to provide you with certain services as a result.
Make use of the above rights?
In most cases, an e-mail to Cleo Clinics, info@cleoclinics.nl. is enough to exercise the aforementioned rights. If we have doubts about the validity of your identity, we may take other measures to ascertain it. For example, by asking you to provide us with a copy of your proof of identity. This is always done in the manner prescribed by the Central Government. In most cases, a less intrusive method of proof of identity will suffice.
Use of the aforementioned rights is free of charge; subject to abuse. We would like to point out that the rights described above are not absolute rights. There may be circumstances that make it impossible for Cleo Clinics to comply with a particular request. We will always assess each request on its own merits. If we are unable to comply with a particular request, we will of course inform you of this with reasons.
8. Duties
Cleo Clinics processes your personal data, as indicated, on the basis of a legitimate interest. Your personal data will never be sold to a third party. The data that are mandatory to supply are the minimum required personal data necessary for the provision of services. If you do not supply these mandatory data to us, Cleo Clinics cannot provide the services (properly).
If it is necessary to share your data with other parties, your permission will of course first be requested by amending our privacy statement. We always announce changes via the Cleo Clinics website.
Cleo Clinics reserves the right to disclose data when required by law, or when Cleo Clinics deems it justified to comply with a legal request or process. Also when it concerns property or protecting Cleo Clinics. In doing so, we try to respect your right to privacy as much as possible.
Do you have any questions about our privacy statement? Please feel free to contact us via Cleo Clinics customer service or the information below.
Schiedamsedijk 81A 3011 EM Rotterdam
Chamber of Commerce number: 89896319
Version October 2023
