FibriCheck - Privacy Policy

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Privacy Policy is supplied electronically, paper format is available on request at support@fibricheck.com

Please read our Privacy Policy carefully as it explains the following:

In order to use the Products, you must first acknowledge and agree to our Privacy Policy. You cannot use the Products without first accepting our Privacy Policy.

1. General

Qompium provides FibriCheck, a service prescribed and/or recommended by a physician that determines heart rhythm conditions, with a primarily focus on the detection of atrial fibrillation. FibriCheck consists of the FibriCheck Platform, the FibriCheck Mobile Application and the FibriCheck Dashboard (each as defined hereinafter and collectively the "Application"). The FibriCheck Platform is the engine of the Application and interacts with and transmits data between the (i) FibriCheck Mobile Application; (ii) the FibriCheck Dashboard and (iii) the Physician Dashboard. In addition, the FibriCheck Platform also analyses and stores data. The recordings via the FibriCheck Mobile Application are performed by placing the finger of the User on the camera of the mobile device thereby detecting the pulse waveform using the optical light and detector of the mobile device. The FibriCheck Dashboard is an online tool with the sole intention to display and store your data.

The Results (as defined hereinafter) are automatically transferred to your Physician's dashboard through the FibriCheck Platform. Please note that this automatic transfer is only possible after you have made the link between yourself and your Physician through correctly scanning the QR code with your mobile device. Correctly scanning the QR code with your mobile device is your sole responsibility.

Please note that you are not obliged to install the Application and your refusal to install the Application does not have any impact on the quality treatment by your Physician.

Qompium NV ("Qompium", "we", "us") recognizes and understands the importance of the privacy of its users ("Users", " you") and wants to respect their desire to store and access personal information in a private and secure manner. This Privacy Policy applies to our Application and our Website (collectively the "Products") and describes how Qompium manages, stores and utilizes your Personal Data through its Products.

In order to use our Products, we require you to consent to the collection and processing of your Personal Data before you start using the Products. If you do not agree with any of the terms of this Privacy Policy, you may not use in any manner the Products.

Qompium is committed to protecting the privacy of all of its Users Personal Data and providing a secure, user-controlled environment for the use of the Products in accordance with the Privacy Act of 8 December 1992. At the same time, you also share responsibility for maintaining privacy and security for example, by not allowing any third party to use your personal account on the FibriCheck Mobile Application and FibriCheck Dashboard. Qompium asks all Users to be responsible for safeguarding any authentication information and to immediately notify Qompium of any unauthorized use of your personal Account.

Please read this Privacy Policy carefully (which is also available on our Website: www.fibricheck.com) so that you fully understand how we obtain and process your Personal Data. By accepting this Privacy Policy, you acknowledge and agree that you were adequately informed of the functioning and objectives of the Application.

2. Definitions

"Account" means your account registered through the registration process on the FibriCheck Mobile Application or FibriCheck Dashboard;

"Application" means the (i) FibriCheck Platform; (ii) FibriCheck Mobile Application and (iii) FibriCheck Dashboard;

"FibriCheck Dashboard" means the dashboard made available to the Users, located at app.fibricheck.com;

"FibriCheck Mobile Application" means the mobile application (i) which the User has to download on its mobile device and (ii) is intended to record, display, store and transmit photoplethysmograms (PPG data);

"FibriCheck Platform" means the platform on which the FibriCheck Mobile Application, the FibriCheck Dashboard and the Physician Dashboard are connected and collectively function. Depending on the user profile (User, Physician, ...) different application functions can be made available;

"Physician" means the doctor (or other medical party) from which you obtained the prescription containing your personal QR code to make the automatic link with your Physician via the FibriCheck Mobile Application;

"Physician Dashboard" means the web-based application that is accessible by your Physician to allow your Physician to review patient information about you, including but not limited to the Results. This application is also connected with  the FibriCheck Platform;

"Products" means the Application and the Website;

"Results" means the results of the analysis by the FibriCheck Platform of the photoplethysmograms recorded by the User through the FibriCheck Mobile Application

"Third Parties" means any natural or legal person or entity other than Qompium;

"Website" means the website available at www.fibricheck.com.

3. Information we collect

We may collect several types of personal information from the Users of our Products, and store it on your mobile device and/or our server such as:

Hereinafter collectively "Personal Data".

We shall store your Personal Data on our servers located in the European Economic Area (AWS - Frankfurt - Germany).

We would like to draw your attention to the fact that Personal Data consisting of patient medical data is also protected by medical secrecy rules.

4. How do we use your Personal Data

Qompium (i) collects, (ii) uses, (iii) maintains and (iv) may share your Personal Data provided by you or collected by us with its affiliates, parent companies or other related companies for all purposes necessary to ensure the proper functioning and operation of the User accounts and/or the proper functioning of the Products. These purposes may include (collectively the "Purpose"):

Furthermore, you agree that Qompium is free to access, retain, and disclose Personal Data in the following events:

By using the Application, you acknowledge and explicitly agree that we disclose your Personal Data to your Physician by giving him access through the Physician Dashboard to your personal data and recordings performed by the Application and your personal profile on your Account. Without prejudice to the foregoing, you acknowledge and understand that the processing of your Personal Data on the Application by Qompium in accordance with this Privacy Policy occurs with the supervision of a qualified practitioner.

By using the Application, you acknowledge and explicitly agree that we may disclose certain information to vendors and service providers who help us provide the Products. Examples of these vendors and service providers include entities that process credit or debit card payments and provide analytics and web hosting services.

By using the Application, you acknowledge and explicitly agree that, with your permission, we will share some health-related information, such as your heart rate, with third party devices and services, such as Apple health and Google Fit. If you connect your FibriCheck account to a third-party device or service, you may be asked to share your information with that application. We will not share your information without your permission.

You furthermore understand and agree that the technical processing and transmission of the Products, including your Personal Data, may involve (i) transmissions over various networks; and (ii) modifications to conform and adapt to technical requirements of connecting networks, or devices .

5. Security

Qompium shall take appropriate administrative, technical and organizational measures against unauthorized or unlawful processing of any Personal Data or its accidental loss, destruction or damage, access, disclosure or use. Upon written request, Qompium can provide you with a list of people of Qompium that may have access to your Personal Data. These people have entered into confidentiality agreements prior to having been granted access to your Personal Data.

In the event of and following discovery or notification of a breach of the security of the Personal Data, or access by an unauthorized person, Qompium is required by law to notify the User if the breach is likely to affect your privacy.

6. Cookies

When using the Products, we may collect certain information by automated means, such as cookies (small text files stored in your browser) and similar technologies, including mobile application identifiers, to improve your experience of the Products, increase security, measure use and effectiveness of the Products, identify and resolve issues and marketing purposes. We may also use cookies and other automated means for purposes such as management our Products and other aspects of the commercialization of our business.

The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system version, information on actions taken on our Products (such as usage, activity logs an click-throughs), and dates and times of visits. Log data is promptly deleted on a regular basis.

You can control cookies through your browser settings and other tools. Your device may offer you control over the use of cookies or other technologies when you use the Products. For example, you may be able to set your device or browser to disable, clear, reset or block the use of cookies or similar technologies. Please note, however, that without cookies the Products may not work properly or you may not be able to use all of their features.

Third parties, such as google analytics, may also use cookies to collect information about your activities on our Products to understand and continue improving the performance of our Products. Please check the relevant third party website for more information about their use of cookies. Where this site allows such cookies to be set or you access other websites from the Products using the links provided, the operators of these websites will use cookies in accordance with their own cookies policy, which may differ from ours.

By continuing to use our Products, you consent to the placement of cookies and other automated means in your browser and device in accordance with this Privacy Policy.

7. Disclosure to Third Parties

In the event of full or partial merger with, or acquisition of all or part of Qompium, we may transfer your Personal Data to a Third Party. In such event, Qompium shall impose this Third Party to use any Personal Data strictly consistent with this Privacy Policy.

Other than as set out in this Privacy Policy, we shall not sell or otherwise disclose your Personal Data to Third Parties without obtaining your prior explicit consent unless this is necessary for the purposes set out in this Privacy Policy or unless we are required to do so by law.

We may also share Personal Data with Third Party service providers who help us to provide, understand, commercialize and improve our Products. We do not authorize these Third Party service providers to use or disclose your Personal Data except as strictly necessary to perform any services under our supervision or to comply with applicable legislation. We seek to provide any such Third Party service provider with only the Personal Data they need to perform their specific function.

In any event, such Third Party service providers shall be obliged to treat your Personal Data in accordance with this Privacy Policy. However, Qompium cannot be held liable for any damages, whether direct or indirect, that may result from the misuse of your Personal Data by such Third Party service providers.

8. Your rights

Right of access If you are concerned or have any questions about your Personal Data, you have the right to request access to the Personal Data which we hold or process about you. We will then provide you with information about the data that are being processed and on the source of those data.

Right of rectification and right of erasure You have the right to request us free of charge to correct, erase or block any inaccuracies in your Personal Data if such Personal Data would be incomplete, inaccurate or processed unlawfully.

Please note that you can change your account information in the Application at any time on the "settings" pages.

Right to object to data processing Without prejudice to the termination provisions of the Terms of Use, you may withdraw at any time your consent to the processing of your Personal Data by Qompium by permanently removing the Application and notifying us in writing thereof. Upon receipt of this notification, Qompium shall promptly stop any processing of your Personal Data. You may also ask us to stop using your Personal Data for direct marketing purposes.

To exercise your abovementioned rights or any other questions concerning this Privacy Policy, please contact us by e-mail at support@fibricheck.com or by writing to Qompium NV, Kempische Steenweg 311, B-3500 Hasselt.

9. Data retention and deletion

We may retain information regarding you and your use of the Products, including Personal Data, for as long as reasonably needed to provide you with the Products and the uses described in this Privacy Policy.

Please note that we retain your Personal Data even if you temporarily stop using the Application until you permanently delete the Application on your mobile device and notify us thereof. Upon notification, we may retain and continue to use and disclosure your Personal Data to Third Parties exclusively on a fully anonymized basis.

10. Third Party websites or applications

You acknowledge and agree that certain content or services provided by Third Parties may be made available to you through the Products. You agree that such linked content or services may have their own privacy policies for which Qompium cannot be held responsible. Qompium does not in any way review or endorse the privacy practices of such Third Parties.

11. Updates or changes to our Privacy Policy

Occasionally, we may change or update this Privacy Policy to allow us to use or share your previously collected Personal Data for other purposes. If Qompium would use your Personal Data in a manner materially different from that stated at the time of the collection, we will provide you with a notice on our Website and in our FibriCheck Mobile Application indicating that the Privacy Policy has been changed or updated and request you to agree with the updated or changed Privacy Policy.

Controller

Qompium NV
Kempische Steenweg 311
3500 Hasselt
Belgium
www.fibricheck.com