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Privacy Policy

Last updated: July 10, 2022

Introduction

At CareOps (the "Company") we take your privacy rights, and your expectation of privacy, very seriously. We strongly encourage you to read this Privacy Policy and to let us know if you have any questions.

This Privacy Policy describes the Company’s policies and procedures regarding the collection, use and disclosure of information which you provide when you use the Company’s web site (the “Site”).

We ask you to consent to our use of cookies in accordance with the terms of this Privacy Policy when you first use the Company Products. Your consent confirms that you have read and accepted this Privacy Policy.

The Company will not use or share your information we obtain through your use of the Company Products for any purpose or with anyone except as described in this Privacy Policy. However, please note that this Privacy Policy does not apply to information we collect by other means or from other sources.

CareOps acts in accordance with the applicable privacy regulations (i.e. the GDPR and/or future Belgian laws regarding the implementation of the GDPR).  Please read this privacy policy carefully as it contains your rights and obligations towards Awell.  If you have a specific question or request for us which relates to this privacy policy or to your Personal Data, you can send an e-mail to the following address: dpo@awellhealth.com.

Who are we?

CareOps is an initiative by AWELL HEALTH BV, a Belgian company with registered offices at 9051 Sint-Denijs-Westrem (Belgium), Kortrijksesteenweg 1126A, and business registration no. BE0696819789.  We run the website www.careops.org.

How we collect your information

Information You Provide.

When you access the Site we collect and store personally identifiable information (generally defined to mean information that can be used on its own or with other information to identify, contact or locate a single person, or identify an individual in context) about you that may include, among other things, your name, postal and e-mail addresses, information regarding your computer system. We request certain information from you if you want to subscribe to our newsletter.

Cookies

(i) For each visitor to our Site, our web server may automatically attempt to identify the user through a cookie placed within the user’s web browser (a cookie is a message given to a web browser by a web server; the browser stores the message in a text file; the message is then sent back to the server each time the browser requests a page from the server). This is done to provide users with more relevant access to the Site. From time to time we may also track information, in aggregate, on pages and features that users access or view. The activity is collected and stored in our server’s log files. We may log Internet Protocol (IP) addresses, or the location of your computer on the Internet, for systems administration and troubleshooting purposes. We use this information in an aggregate fashion to track access to the Site.  (ii) We may also place cookies on users’ computers to allow users to store login information, personalize their user experience and navigate easily through the Site. Through the use of additional cookies or technology, we will have the ability to track users by their behaviour profile and geographic location for the purpose of providing advertising that matches their interests and/or specific location.

Other disclosures of your information

(a) We may store personal information in locations outside the direct control of the Company (for instance, on servers or databases co-located with hosting providers). As we develop our business, we may buy or sell assets or business offerings. Customer, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution. In such cases we cannot control acquiring parties’ use of your information. (b) We may disclose your personal information if required to do so by law or subpoena or if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect the Company’s rights or property. Additional use of your personal information that is not described in this Privacy Policy will only take place as required by statute or when we have obtained your consent.

Links to other sites

The Company website may contain links to other sites or services that may be subject to less stringent privacy standards. The Company cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites or services. We are not responsible for how such third parties collect, use or disclose your personal information. You should review their privacy policies before providing them with personal information.

Your right to opt out

We are committed to providing users of the Company Products with the choice to receive or not receive emails, promotional materials and/or other communications from the Company. We only send commercial emails to users who have requested or consented to receive emails about our services and products. We do not send unsolicited commercial emails (“spam”), buy or sell email lists, or use purchased or harvested email lists. We offer commercial email recipients the opportunity to opt-out of further communications in every email. If you want to stop receiving commercial emails, promotional or other marketing materials, you can do so at any time by contacting the Company at rik@awellhealth.com.

Non-EU users

The Company is operated from Europe. If you are located in Canada, the United States or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to Europe. By using the Company, participating in any of our services and/or providing us with your information, you consent to this transfer.

Security

(a) The security of the Company Products and your information is of great importance to the Company. The Company has reasonable security measures in place to protect the loss, misuse and alteration of your information under the Company’s control, but we make no assurances about our ability to prevent any such loss, misuse or alteration, and we shall have no liability to you or any third party from any loss, misuse or alteration. We do not warrant that your access to the Company Products is completely secure. (b) The Company shall notify any user whose information is suspected of being accessed, disclosed, altered or deleted by an unauthorized person, so that the user can take appropriate measures to minimize the adverse effect of such a data security breach (a "Breach Notification"). The Company will make such Breach Notification soon after it learns of a breach, unless it deems, at its sole discretion, that such Notification might hinder and prevent ongoing efforts to detect the source of the breach. For the avoidance of doubt, a Breach Notification does NOT constitute an admission by the Company that the breach occurred as a result of malpractice, failure, bad faith or negligence on behalf of the Company or that the breach even occurred in the Company's systems.

Children's privacy

Protecting the privacy of children is especially important. the Company does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to access the Site or use the Company Products. If we become aware that we have collected personal information from a child under age 13 without verification of parental consent, we take steps to remove that information.

Changes to our privacy policy

If we change our privacy policies and procedures, we will post those changes on this page to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page. Please check this page on a consistent basis.

Your Rights

Regardless of in which capacity you make use of our services or Platform, you always have the rights listed below.  If you are a Patient or Healthcare Provider whose Personal Data we process at the request of a Data Controller, please note that if you contact us regarding any of these rights, we will notify the Data Controller of your request and we will deal with your request in accordance with the Data Controller’s instructions.

Right of access

You are always entitled to receive confirmation as to whether or not your Personal Data is being processed and, where that is the case, access and receive a copy of such Personal Data in an intelligible form.  Furthermore, you are also entitled to receive information concerning: the purposes of the processing; the categories of Personal Data concerned; the recipients (or categories thereof) to whom the Personal Data have been or will be disclosed; where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from us rectification or erasure of personal data or restriction of processing of your Personal Data or to object to such processing; the right to lodge a complaint with a supervisory authority; the source of the Personal Data; the existence of automated decision-making; where Personal Data are transferred to a third country or to an international organization, the appropriate safeguards relating to the transfer.

Right to withdraw consent

You are always entitled to withdraw, at any time, your consent to the processing of your Personal Data, both on legitimate grounds (even though they are relevant to the purpose of the collection) and if the processing is carried out for direct marketing purpose.  The preceding will not affect the lawfulness of processing based on consent before the withdrawal.

Right to rectification, erasure and restriction

You are always entitled to obtain from us, without undue delay: the rectification or integration of your Personal Data that are inaccurate or incomplete; the erasure of your Personal Data that have been processed unlawfully or whose retention is unnecessary for the Purposes; the restriction of processing, in case you challenge either the accuracy of your Personal data or the lawfulness of the processing, or in case we no longer need the Personal Data for the purposes mentioned in this privacy policy, but they are required by you for the establishment, exercise or defense of a legal claim.

Right to data portability

You have the right to receive your Personal Data in a structured, commonly used and machine-readable format, as well as the right to transmit those data to another controller without hindrance from us, where technically feasible.

Right to lodge a complaint

In any case, you have the right to lodge a complaint with the relevant supervisory authority, if you believe that there is an issue with the way we deal with your Personal Data.  For Belgium, the relevant supervisory authority is the Belgian Data Protection Commission (Gegevensbescherminsautoriteit / Autorité de protection des données) based at, Rue de la Presse 35, 1000 Brussels (Belgium).  The Belgian Data Protection Commission can be reached on the following telephone number: +32 (0)2 274 48 00 and on the following e-mail address: commission@privacycommission.be.

Exercising your rights

Contact us

You can contact us through any available means to exercise your rights, but we prefer that you send us an e-mail to the following address: dpo@awellhealth.com.  As has already been highlighted before, if you are a Patient or Healthcare Provider whose Personal Data we process at the request of a Data Controller, please note that if you contact us regarding any of these rights, we will notify the Data Controller of your request and we will deal with your request in accordance with the Data Controller’s instructions.  You can also contact the Data Controller directly in relation to your request.

What we do when we receive a privacy related request from you

Any privacy related request is passed to our Data Protection Officer as soon as received and a record of the request is noted.  The following steps will be put in place:

  1. Identification:  we will use all reasonable measures to verify the identity of the individual making the request, especially where the request is made using online services.  In particular, where we are unable to utilize the request information to ensure that we can verify the data subject identity, we may contact the individual making the request to provide evidence of his/her identity prior to actioning any request.  If a third party, relative or representative is requesting information or is asking us to take certain steps on behalf of a Patient, we will verify their authority to act on behalf of the Patient and may contact the Patient to confirm their identity and authorization prior to acting to the request.
  2. Responding to your request:  We will respond to your request within one month; however, where the retrieval or provision of information is particularly complex or is subject to a valid delay, this period may be extended by two further months.  If this is the case, we will write to you within one month and keep you informed of the delay in responding to your request and the reasons for such delay.  If we need more information from you to be able to respond to your request, we will let you know.  The information requested will be sent to you in writing or, where the request is made by electronic means, we will provide the information in a commonly used electronic format, unless an alternative format is requested.

Changes to this privacy policy

This Privacy Policy came into force on the date specified above.  We reserve the right to amend or to update its content, whether in whole or in part, also following changes in the legal and regulatory obligations regarding data protection.  We will inform you on such amendments and updates through their publication on the Platform as soon as they are adopted, and they will be binding from the moment of their publication. Therefore, we invite you to visit this section of the Platform regularly, in order to be aware of the most recent and updated version thereof, so that you are always updated on the processing activities that we carry out.

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