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Privacy Policy

Last updated: February 13, 2021

 

Privacy statement of the esperity.com website

 

1        GENERAL

 

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

We attach great value and care to the protection of your privacy and personal data.

 

This statement aims to explain:

  • Who we are and to what Site this policy applies
  • To whom we address to
  • Which data we handle
  • Why we process your personal data
  • How we process your personal data
  • How long we process your data
  • To whom your personal data can be transmitted
  • What your rights are
  • How you can exercise your rights

 

We also share all information that is made mandatory by the privacy act in Belgium, and its regulation 2016/679 from the European Parliament and Council dated 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46 / EC, hereinafter GDPR.

We implement appropriate technical and organizational measures to ensure an appropriate level of security and to mitigate the risks of violation of your data, with regards to any new technological developments, implementation costs, the nature of the risks and the impact on your rights and fundamental freedoms. We use your data to provide and improve our services.

By using our services, you agree with the terms of this Privacy Policy and the collection and use of your personal information.

 

2        WHO WE ARE ?

 

Esperity bv is a privately owned company under Belgian law, with registered office at BLSI, 30, Clos Chapelle-aux-Champs, B1.30.30, B-1200 Brussels, Belgium.

 

The purpose of this Privacy Statement (hereafter referred to as “Statement”) is to define the processing of your personal data as a user (hereafter referred to as “User”)  of one of the esperity.com websites, including esperity.com, community.esperity.com (also known as patientuniverse.com), education.esperity.com (also know as empowermeapp.com) and health.esperity.com (also know as Esperity Health); hereafter referred to as the “Site”) user according to the definition in the Terms of Use (hereafter referred to as “Terms”). Please refer to the Terms concerning the use of the Site.

The Esperity Private Company with Limited Liability (hereafter referred to as “esperity”) undertakes to comply with the Belgian law of 8 December 1992 concerning the protection of privacy with regard to personal data processing. This law can be consulted on the Privacy Commission website (www.privacycommission.be).

 

The Site is released by the Belgian Esperity Private Company with Limited Liability (hereafter referred to as “esperity”), with its office registered at BLSI, 30, Clos Chapelle-aux-Champs, B1.30.30, B-1200 Brussels, Belgium. esperity is recorded in the Business & Company Register under number 0848.466.027, company number BE 0848.466.027 and VAT number 0848.466.027.

 

 

3        WHO IS IN CHARGE OF PROCESSING THE DATA ON THE SITE?

 

esperity is responsible for all processing of personal data on the Site.

 

esperity – with its office registered at BLSI, 30, Clos Chapelle-aux-Champs, B1.30.30, B-1200 Brussels, Belgium, recorded in the Business and Company Register under number 0848.466.027, company number BE 0848.466.027 and VAT number 0848.466.027 – has declared these processing operations to the Privacy Commission, which delivered a receipt. This declaration can be consulted on the Privacy Commission website (www.privacycommission.be).

 

 

4        TO WHOM DOES THIS STATEMENT APPLY?

 

This statement is for people who:

  • Surf on our website;
  • Request information about our services;
  • Use our apps, platforms and other services;
  • Work with us, or work for the natural or legal persons who work for us;
  • Work for one of our suppliers;
  • Spontaneously share their personal data with us, for instance by sending unrequested application forms or when they submit their business card;
  • These persons to which we turn to, are referred here by User

 

We inform you that your data will be used in accordance with this declaration and the provisions on the data protection act and private rights in Belgium.

 

 

5        INTERPRETATION AND DEFINITIONS

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Data processing is a transaction applied to data. For example, collection, recording, organization, storage, adaptation, alteration, retrieval, consultation, use, alignment, combination, blocking, erasure, destruction, disclosure by transmission, dissemination or otherwise making available, etc.

DPO: the data privacy officer (DPO) is the person who monitors whether esperity handles the data with a personal character correctly, according to the General Data Protection Regulation (GDPR).

Entity in charge of data processing is a natural or legal person, unincorporated association, or government with the sole authority to determine the purpose and means of data processing. The entity can make such determinations alone or jointly with others.

Medical twin is a person similar to the User him/herself. The extent and kind of similarity is for the User to decide. For example, medical twins might have the same age or sex; they may even be living in the same city. As soon as Users enter sufficient information about themselves and their condition, esperity will start providing them with twin suggestions based on the information on its database.

Personal data is information pertaining to an identified or identifiable person. A person is considered identifiable if s/he can directly or indirectly be identified, in particular by reference to an identification number, or to one or more specific cultural or socioeconomic factors pertaining to his or her physical, physiological and/or mental attributes.

Personal health data is any personal information on the basis of which one can deduce information about the past, present or future physical or mental health. These data do not have any administrative or accounting components pertaining to treatments or healthcare.

Processing: all operations or parts of operations, whether or not carried out with the help of automated processes and applied to personal data, such as collection, registration, organization, storage, modification or modification, extraction, consultation the use, communication by transmission, dissemination or any other form of provision, connection or link, as well as the locking, erasure or destruction of personal data; in the present declaration the terms «processing», «process», «processed», etc. refer to this definition;

Unstructured data is information that the User generates outside the structure provided by the Site. It typically consists of free text-input the User sends to his contacts or the comments he writes on his or her profile.

 

Account means a unique account created for You to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Application means the software program provided by the Company downloaded by You on any electronic device, named Esperity Health

Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Esperity bv, Veldkapelgaarde 30 b 1.30.30.

For the purpose of the GDPR, the Company is the Data Controller.

Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

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.

Country refers to: Belgium

Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Facebook Fan Page is a public profile named Esperity specifically created by the Company on the Facebook social network, accessible from Facebook.com/esperity

Personal Data is any information that relates to an identified or identifiable individual.

For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.

Service refers to the Application or the Website or both.

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. For the purpose of the GDPR, Service Providers are considered Data Processors.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

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).

Website refers to Esperity, accessible from http://esperity.com

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.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

6        WHAT IS THE LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

 

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

7        WHAT ARE YOUR RIGHTS UNDER THE GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

 

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

 

 

Exercising of Your GDPR Data Protection Rights

 

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

 

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data at the following address: 35 rue de la Presse – 1000 Brussels – Phone 02/274.48.00 – or via their website: https://www.autoriteprotectiondonnees.be.

 

8        What data do we collect and how do we use Your Personal Data?

 

What type of data is collected?

There are different types of data being collected: personal data; user data and tracking technology and cookies.

 

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information or other medical profile data that can be used to contact or identify You, or to allow you to optimally use our Services.

 

The main data fields comprise all the information provided in your User account during sign-up and Site use. In particular, they may include the following:

  • Identification data:
    • First name and last name
    • Date of birth
    • Pseudonym: giving a pseudonym that cannot be linked to your real identity is strongly recommended. (*),
    • E-mail address. (*),
    • Your password or pincode that was crated through the account creation at one of the Esperity sites (Site) (*),
    • Usage Data
    • Picture: uploading a ‘fantasy’ picture that cannot be linked to your real identity is strongly recommended.
    • Physical and ethnic data: height, weight, ethnic type

 

The use of all data provided in these fields should not break any laws or infringe on any rights of third parties. For more information, please refer to the General Conditions.

 

  • Medical profile data:
    • Personal characteristics: in particular, age, sex and date of birth.
    • Physical and ethnic characteristics: in particular, height, weight and ethnicity.
    • Lifestyle habits: in particular, tobacco & alcohol consumption, and physical activity.
    • Health: in particular, type of disease, first diagnosis, past & current treatments, secondary effects, depression, mood, and other characteristics associated with your quality of life or day-to-day surroundings, temperature, etc.
    • Biological data: in particular, tumor markers, blood test results, etc.
    • Subjective data about healthcare variables, such as a rating of how you feel on a scale from 0 to 10
    • Quality of Life data: data related to surveys that measure quality of life
    • Medication data: type of medication and dosage
    • Location: in particular, your geographic zone of residence.
    • All types of other data provided during sign-up or Site use: in particular, what is provided while updating the User profile, using the Site tools or communicating with other Users.

 

Some of these data fields, which are marked with an asterisk (*), are necessary and mandatory to open your User account and to access the Site. The rest of the fields are optional, but you benefit from a better service if/when you complete them.

 

The Site also offers Users data fields similar to those above for them to be used by third parties as caregivers. Completing these fields, caregivers can also sign up as Users on behalf of the respective patients.

 

Whatever their nature or gravity may be, esperity cannot be held liable for any consequences of your making data, e.g., names or photographs, public, and thereby allowing others to identify you or a third party.

esperity protects your data, which are not accessible via search engines.

 

You undertake to enter only data concerning yourself. esperity cannot be held responsible for the registration of third party data.

 

An exception is made in the case of entering the data of a third party under your legal responsibility, e.g., minors or incapacitated adults. You, therefore, take full responsibility for obtaining any consent necessary to enter data concerning a third party, and you undertake to scrupulously respect their rights, including those described herein.

 

You undertake to enter accurate, complete and up-to-date data. You also undertake to update your personal data without delay in the event of a change.

 

You understand that your registration on the Site is equivalent to a written consent to process your personal data, including sensitive data pertaining to factors such as health, ethnicity and lifestyle.

 

 

 

 

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. This empowerme app also considers answers to quizzes, ratings to articles and feedback on polls as usage data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

 

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

 

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies here: All About Cookies by TermsFeed.

9        WHY DO WE USE YOUR PERSONAL DATA

 

Data are processed in order to operate the Site for its intended purpose, which is to enable you to do the following:

  • Registering to the Site, and then using it.
  • Having access to educational content
  • Search for clinical trials
  • Track your health over time
  • Describing your condition and following its evolution; following your treatments and identifying their implications on your life and pathology; identifying other users with whom you want to communicate by allowing them to follow your profile along with their own.
  • Providing the Site and the authorized third parties with information – except for the identification data – about yourself for them to conduct studies, improve treatments, analyze statistics and develop new protocols, therapies, etc. These endeavors can involve the third parties’ wanting to contact you; in such cases, the third party sends the Site a request, which is then relayed to you.
  • Interacting with other Users to exchange and share information and messages with them, and to generate reports based on your health.
  • Sharing personal messages with your medical twins through the activation of the “share” function. Your messages can then be translated into other languages to facilitate communication with other Users all around the world. The translations are automatically made with software in order to ensure confidentiality.
  • Contacting partners of esperity and health professionals.
  • Contacting esperity to receive answers to your questions.
  • Identifying your interests better.
  • Displaying personalized content, possibly with ads, and receiving product or service offers. These ads and offers are customized based on your profile, such that they are the ones most likely to serve your best interests.
  • Receiving updates about new developments on the Site and its activities.
  • Making your data – except for the ones used to identify you – available for scientific research and statistics analyses.

 

In general terms, esperity may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.

To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To manage Your requests: To attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

 

 

10    WITH WHOM DO WE SHARE YOUR DATA

 

We do not share identifiable data with third parties, unless you consent to do so, or in the case that one of the situations described below may occur:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

 

 

All employees are required to respect the confidentiality of all personal data.

 

According to what is described above, your data – except for the ones used for your identification and the ones that are unstructured – may be shared in an aggregated way (meaning your data will be pooled with data from other users)  with third parties without your prior consent. These third parties may be other Users, and if applicable, partners of the Site, medical professionals or pharmaceutical companies.

 

 

Processing your data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

 

 

 

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

 

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

 

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

 

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

 

 

11    WHAT ARE YOUR RIGHTS OF ACCESS, RECTIFICATION, DELETION AND OPT-OUT

You can exercise your rights of access and rectification for data concerning yourself by simply connecting to your User account.

 

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

You can always check the status of the processed data about yourself by sending us a request. We will be sending you the respective information as soon as possible, after verifying your identity.

You can request the rectification of incorrect, incomplete or out-of-date data.

You can also request the deletion of your account. As stated in the Terms, which you have validated, deleted accounts are no longer visible for other Users, but they are not erased either. esperity is in fact expressly authorized to indefinitely retain all the information accumulated in the account prior to its deletion, with the exception of the identification data, which must either be erased or coded at the discretion of esperity. All unstructured data will, however, be erased during the deletion process.

 

In addition, all the regular communications esperity sends you include information about how you can opt out of receiving them.

 

As a security measure, esperity reserves the right to ask you to verify your identity for all access, rectification, deletion or opt-out requests.

 

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

 

If you believe that the Site does not comply with privacy protection laws and regulations, please alert us by sending an e-mail to info@esperity.com

12    HOW DO WE ENSURE THE SAFETY OF YOUR DATA?

We strive to optimally secure personal data against unauthorized use or leakage. For this, we use physical, organizational, technological, administrative and adequate measures such as, but not limited to:

  • We use well known security and encryption methods to ensure the security of your data transmission.
  • We limit access to the computer system, according to the strict needs of each members of our team in terms of his function.
  • As soon as we can, we proceed to the anonymizing or pseudomizing of your data (depending on the purpose).
  • We host your data on our servers that are protected by ad hoc security and certificates.
  • We have implemented an internal policy of protection of privacy, and conventions that ensure the awareness of the confidentiality of your data.

13      DETAILED INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

Mailchimp

Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement of our Service.

Invisible reCAPTCHA

We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.

The reCAPTCHA service may collect information from You and from Your Device for security purposes.

The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

 

 

14    FACEBOOK FAN PAGE

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page Facebook.com/esperity, the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy

15    CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

 

16    LINKS TO OTHER WEBSITES

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

 

17    CHANGES TO THIS PRIVACY POLICY

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

18    QUESTIONS, COMMENTS, COMPLAINTS AND DATA LEAK

We remain at your disposal for any questions, comments or complaints formulate against our protection of your personal data. If you are aware of the existence of a data breach or if you suspect one, you are asked to immediately report it to us at info@esperity.com. In addition, and in accordance with Article 37 of GDPR we proceeded to the appointment of a Data Protection Officer (DPO), to be reached on dpo@esperity.com

 

Finally, you also have the right to file a complaint to the Data Protection Authority (DPA) at the following address: 35 rue de la Presse – 1000 Brussels – Phone 02/274.48.00 – or via their website: https://www.autoriteprotectiondonnees.be.

19    CONTACT US

If you have any questions about this Privacy Policy, You can contact us:

 

By email: info@esperity.com

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