Privacy Policy
Version 1.0 – 30 October 2023
Article 1 - GENERAL
1.1 moveUP NV, a limited liability company under Belgian law with its registered office at Kantersteen 47, 1000 Brussels, Belgium and registered with the Crossroads Bank for Enterprises, under company number 0643.795.235 (hereinafter "we, "us", "our", "moveUP"), assumes responsibility for the processing of your Personal Data as "Controller", including the use of m yMGverse app (hereinafter “Application”).
In case our Application is used by a professional healthcare practitioner, for some processing activities we may act as “Processor”. In this case, the purposes and lawful basis of any suchprocessing activities (as well as the period your Personal Data will be retained for) will be determined by your professional healthcare professional acting as Controller.
1.2. In our Privacy Notice, "Personal Data" means any information relating to an identified ori dentifiable natural person. We may collect, use, share or otherwise process Personal Data of individuals belonging to the following categories:
Users of the Application (hereinafter “you”, “your”, “User”)
1.3 The collection and processing of Personal Data is governed by strict conditions, enforced bylaw. We act in accordance with:
i.the EU Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, regarding the freemovement of such data and repealing Directive 95/46/EC; (hereinafter“GDPR”); and/or
ii. all (future) Belgian applicable laws regarding the implementation of the GDPRor regarding the processing of Personal Data.
1.4 The access to or use of the Application implies your full and unreserved understanding of this Privacy Notice. This means that you were fully informed of how we collect, use and process your Personal Data, in accordance with the provisions of this Privacy Notice and for the purposes listed in this Privacy Notice.
1.5 Our Privacy Notice can be subject to future amendment and modification. In this event we will notify you with an invite to take a look at these changes, which we will clearly indicate in the Privacy Notice.
Article 2 – CATEGORIES OF PERSONAL DATA PROCESSED
2.1 We may process the following categories of Personal Data for the purposes set out in Article3:
Data Category
Details
Purpose
Category 1
Your identification and contact details
Your identification and contact details
1 First- and last name
2 Address
3 IP-address
4 Telephone number
5 E-mail address
6 Password hash
7 Date of birth
2 Address
3 IP-address
4 Telephone number
5 E-mail address
6 Password hash
7 Date of birth
Your identification and contact details will be processed when registeringyour account in the Application.
Category 2
Your health information
Your health information
Reports on the impact of myasthenia gravis on your daily living (on the basis medical questionnaires)
Symptoms (with regard to myasthenia gravis or other)
Medication intake
Medical profile
Name of your doctor (and corresponding registration number)
Symptoms (with regard to myasthenia gravis or other)
Medication intake
Medical profile
Name of your doctor (and corresponding registration number)
Your health information willbe processed through your use of the Application in thecontext of the care process for myasthenia gravis.
Category 3
Information about your usage of the Application
Information about your usage of the Application
Information related to your use of the Application, such as:
Features and functionalities used
Page views
Any personal preferences or settings…
Features and functionalities used
Page views
Any personal preferences or settings…
Information about your usage of the Application willbe processed when you make use of the Application, to improve the Application
Article 3 - LEGAL BASIS AND PURPOSE OF PROCESSING
We process your Personal Data only when we have a specific purpose and a lawful basis for doingso. Moreover, we only process what is relevant to pursue each specific purpose in question, and inparticular:
3.1 General purposes
Data Category
Legal basis
Purpose
Category 1
Your identification and contact details
Your identification and contact details
Necessary for the performance of the contract we have entered into or are considering entering into with you (art. 6.1 (b) GDPR)
and/or
Your consent (art. 6.1 (a) GDPR)
Our legitimate interests (art. 6.1 (f) GDPR)
and/or
Your consent (art. 6.1 (a) GDPR)
Our legitimate interests (art. 6.1 (f) GDPR)
We process your identification and contact details in order to be able to create a unique user profile through which you will be able to access the Application, in accordance with the Application’s Terms of Use.
We may process your identification and contact details where necessary to receive your feedback and/or opinion (e.g. where legally required in the context of our obligations under Regulation (EU)2017/745 on medical devices).
We may process your identification and contact details where necessary to receive your feedback and/or opinion (e.g. where legally required in the context of our obligations under Regulation (EU)2017/745 on medical devices).
Category 2
Your health information
Your health information
Necessary for the performance of the contract we have enteredinto or are considering enteringinto with you (art. 6.1 (b) GDPR)
and
Your explicit consent (art. 9.2 (a) GDPR)
and
Your explicit consent (art. 9.2 (a) GDPR)
We process your health information in order to enable you to make use of the core functionalities of the Application, inaccordance with the Application’s Terms of Use.
Our legitimate interests(art. 6.1 (f) GDPR)
and
archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
(art. 9.2 (j) GDPR)
and
archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
(art. 9.2 (j) GDPR)
We process your health information in the context of scientific, historical and statistical research and/or to improve our (health) care related services.
When we process your information for the above mentioned purposes, we will put in place the necessary safeguards in accordance, in particular pseudonymization and (insofar possible) anonymization in accordance with art. 9.2 and 89 GDPR.
When we process your information for the above mentioned purposes, we will put in place the necessary safeguards in accordance, in particular pseudonymization and (insofar possible) anonymization in accordance with art. 9.2 and 89 GDPR.
Category 3
Information about your usage of the Application
Information about your usage of the Application
Our legitimate interests
(art. 6.1 (f) GDPR)
(art. 6.1 (f) GDPR)
We process information about your usage of the Application in order to pursue our legitimate interests of improving our services, providing technical support and ensuring the functionality and security of our Application.
3.2 Direct marketing
We will only use your Personal Data for the purposes set out under article 3.1.
In no way will your Personal Data be used for direct marketing purposes, unless you have given us your prior consent to do so.
3.3 Transfer to third parties
We treat Personal Data as confidential information and will not disclose it to third parties beyond the conditions outlined in this Privacy Notice or as required by law.
Your Personal Data may be shared with select third parties as necessary forouroperations. This may include, but is not limited to, providers of IT support, hosting, computer security, and specialized services. Such third parties are prohibited from further disclosing your Personal Data, except when:
- the communication of your Personal Data by such third parties to their suppliers orsubcontractors is necessary to be able to carry out our business activities;
- such third parties are obliged by applicable law or regulations to communicate certaininformation or documents to the competent authorities.
- Also, your personal data may be shared with your treating physician with whom you have a therapeutical relationship, and only in the context of your MG care process. Subject to your permission, your treating physician will be able to consult these results remotely through the use of an online dashboard that is part of this MyMGverse app solution. Alternatively, you can download your reports in the app and share it, using the functionalities of your smartphone e.g. via email in a pdf format.
Additionally, we may share aggregated data, including usage data, for example number of downloads of the application, countries of downloads etc, with our sponsoring and R&D partners, subject to strict safeguards and solely for legitimate (continuity of funding/research/statistical) purposes.
We will not sell, rent, distribute or otherwise make your Personal Data commercially available to third parties, except as provided in this Privacy Notice, or when you have given your explicit prior consent.
In the event of our total or partial reorganization of, the transfer of our activities or in the event of us being declared bankrupt, your Personal Data may be transferred to new entities or third parties. We will inform you in advance of the fact that we transfer your Personal Data to such third parties.
3.4 Legal requirements
In exceptional occasions, we may be legally required to share your Personal Data due to a courtorder or in compliance with laws and regulations. If permissible, we will strive to notify you in advance of such a disclosure.
We will retain your Personal Data for the duration necessary to fulfil the purposes listed in Article 3 of this Privacy Notice, including for as long as it is essential for the performance of the contract between us and you.
We may also retain your Personal Data to comply with applicable legal requirements, including requirements to retain your Personal Data further after termination of the contractual relationship between you and us. These include applicable limitation periods for billing, payment, accounting, tax and regulatory compliance purposes. The retention periods set out below may therefore be deviated from if such legal obligation applies.
Retention periods:
Data
Retention period
Category 1
Your identification and contact details
Your identification and contact details
Your Personal Data contained in Category 1 will be retained for two (2) years after the deletion of your user profile (which indicates the end of our contractual relationship). Please note that in the situation where we act as Processor as indicated under article 1.1, the retention period of your Personal Data will be determined by your professional healthcare professional or his/her healthcare organization,acting as Controller.
Category 2
Your health information
Your health information
Your Personal Data contained in Category 2 will be retained for two (2) years after the deletion of your user profile (which indicates the end of our contractual relationship). Please note that in the situation where we act as Processor as indicated under article 1.1, the retention period of your Personal Data will be determined by your professional healthcare professional acting as Controller.
Category 3
Information about your usage of the Application
Information about your usage of the Application
Your Personal Data contained in Category 3 will be retained for two (2) years after the deletion of your user profile (which indicates the end of our contractual relationship).
Article 5 - YOUR RIGHTS
5.1 Right of access and right to obtain a copy
You have the right to request access to your Personal Data at any time and to be informed about thepurpose of our processing.
5.2 Right to rectification, erasure or restriction
You always have the right to ask us to rectify your Personal Data if you believe it to be incorrect or no longer up to date. You can also request the processing of your Personal Data to be restricted if you think that your Personal Data is inaccurate and you subsequently notified us about this.
In addition, you have the right to ask us to erase your Personal Data in as far we were not able to anonymize it, meaning you can exercise your right to be forgotten.
Furthermore, you acknowledge that a refusal to share data or a request to erase your data may make the delivery of several of our services impossible.
5.3 Right of objection
You have the right to object to the processing of your Personal Data if you have legitimate reasonsand communicate them to us. You also have the right to object to the use of your Personal Data fordirect marketing. In this case, you do not need to provide a specific reason for your objection.
5.4 Right to data portability
You have the right to request to obtain your Personal Data processed by us in a structured,commonly used format and/or to transfer such data to another controller.
5.5 Right to withdraw consent
Where the processing of your Personal Data by us is based on your prior consent, you have the right to withdraw this consent at any time. Your withdrawal of consent shall not affect the lawfulness of processing based on consent before such withdrawal.
5.6 Automated decisions and profiling
You will not be subjected to decisions based solely on automated processing which produces legaleffects concerning you or similarly significantly affects you. Nevertheless, youhave theright to request us not to be subject to such automated decisionmaking.
5.7 Exercising your rights
You can exercise your rights by contacting us with a copy of the essential parts of your proof of identity, such as name and date of birth, attached:
Either through email to p r i v a c y @ m y m g v e r s e a p p . c o m
Or via ordinary mail to, moveUP NV, Kantersteen 47, 1000 Brussels, Belgium
5.8 Right to file a complaint
If you feel unhappy about how we treated your Personal Data or handled your privacy requests (which we truly hope won’t be the case), you have the right to lodge a complaint with the Belgian data protection supervisory authority:
Data protection authority,
Drukpersstraat 35, 1000 Brussel,
Tel: +32 (0)2 274 48 00, Fax: +32 (0)2 274 48 35,
This is without prejudice to proceedings before the civil courts. If you are from an EU member state other than Belgium, you can also complain to your national data protection authority (a list of thedata protection authority for each EU member state can be found here: https://ec.europa.eu/justice/article-29/structure/data-protection- authorities/index_en.htm).
If you have suffered damages as a result of the processing of your Personal Data, you may file a claim for compensation.
Article 6 - SAFETY AND CONFIDENTIALITY
We have taken security measures that are appropriate on a technical, organizational and physical level to prevent the destruction, loss, falsification, modification, unauthorized access or notification of Personal Data accidentally to a third party, as well as the unauthorized processing of such data.
If these events should nevertheless occur and affect your Personal Data, we will, where appropriate and permitted by law, notify you of the breach without undue delay, including a brief description of the potential consequences and a recommendation for measures to mitigate the potential negative impact of the breach.
We are in no way liable for any direct or indirect damage caused by an unlawful or improper use ofthe Personal Data by a thirdparty.
At the same time, you also share responsibility for maintaining your privacy, for example by notallowing third parties to see your confidential communication(s).
Article 7 - APPLICABLE LAW AND JURISDICTION
This Privacy Notice is administered, interpreted and implemented in accordance with Belgian lawwhich is exclusively applicable to any potential dispute.
The courts and tribunals of Brussels shall have exclusive jurisdiction to settle any dispute arising out of or in connection with the interpretation or implementation of this Privacy Notice.
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