1. KEARTY.COM

Kearty.com is a Dutch company. We operate in the European Economic Area (EEA) and store our data on servers in the EEA , unless otherwise indicated. We process your personal data when you use our services, applications, websites and software. We call this the "Service". This privacy notice summarises when and how we collect, use and safeguard your personal data in relation to our Service.

2. GENERAL

We may change the terms of this privacy notice from time to time. If we do, we will notify you of the changes. However, we also encourage you to check from time to time yourself whether the privacy notice has changed.

3. WHAT PERSONAL DATA DO WE COLLECT?

3.1 There are a number of ways in which we may collect your personal data. In this section, we explain what personal data we may collect from you. The personal data is sorted according to the different processing purposes. The data retention period also varies depending on the processing purpose. This period is also mentioned below. Note that if there are legal changes to the possible retention periods, these legal changes take precedence over the periods mentioned in this privacy notice.

3.2 Processing based on a legal obligation.

Administrative obligations: we keep this personal data for a maximum of 7 years:

your name

your address

your treatment requests and approved treatment requests (if applicable)

If you want to use our Service, you must provide us with this personal data. This is because this data is needed to comply with our legal and tax obligations.

3.3 Processing required for the performance of a contract between you and us, or you and third parties on the platform (providing the Service). Non-medical data necessary for the provision of our Service to you: we keep this data for as long as you have an active account, and for 2 years after your account is no longer active.

Non-medical personal data provided to us as part of our Services:

bank account

address

e-mail address

(approved) history of your treatment requests

other personal information you provide when you contact us

If you want to use our service, you must provide this personal information to us, otherwise we cannot provide our service.

3.4 Processing necessary to justify our legitimate interests

Improving our services: we keep this personal data for as long as you have an active account, and for 2 years after your account is no longer active.

Your name

A number to identify you on our services (user or session ID)

Your IP address

A number to identify your device on our services (device ID)

A number to identify you on our services (user or session ID)

The operating system you use

The time, date and place of login

Usage of the website

Keeping the service safe: we keep this personal data for as long as you have an active account, and for 2 years after your account is no longer active.

Your IP address

A number to identify your device on our services (device ID)

A number to identify you on our services (user or session ID)

The operating system you use

The time, date and place of login

To inform you about our other services (if your handling request has been approved): we keep this personal data until you indicate that you no longer wish to receive marketing information, but no longer than 2 years from the time your account is no longer active.

Your email address

We process this personal data based on a balancing of interests. If you do not want to provide the data mentioned in 3.3.1. or 3.3.2., please let us know why you object to this. We will take your reasoning into account and balance it against our interests. If we conclude that you must provide your personal data, you will not be able to use our service if you refuse to provide the personal data. More information about your rights can be found below under the heading 'Your rights'.

You can unsubscribe ('opt-out') from our mailing list for the processing mentioned under 3.3.3. by following the unsubscribe instructions provided with each marketing e-mail. If you opt-out, this will not affect our ability to send you important emails about the Service and your account. In addition, it does not affect our ability to use your personal data as described in this privacy notice.

3.5 Processing with your consent:

Medical data: we retain this personal data for as long as you have an active account and for up to 15 years after your account is no longer active. This medical information is obtained directly from you by completing a medical questionnaire. The following information is collected:

Your name

Your age / date of birth

Your gender

Your country of origin

Any relevant medical information that you personally share with us by completing the online questionnaire, for example:

Physical and mental conditions Medication use

This information is shared with the doctor assessing your medical questionnaire.

To inform you (at your request) about the Service we have provided to you, or about other services offered by us: we keep this personal data until you indicate that you no longer wish to receive marketing information.

Your name

Your e-mail address

To inform you (at your request) and answer your questions: we keep this personal data for up to 2 months after your request or question has been processed.

Your name

Your e-mail address

Other personal data you provide when contacting Kearty.com

Please note that if you share medical information with us in any way other than by completing the medical questionnaire, this medical information will be deleted immediately. We cannot answer medical questions.

3.6 If you do not consent to the processing of the personal data mentioned in 3.5.1, it means that we cannot provide you with the Service.

3.7 You are not obliged to provide us with the personal data mentioned in 3.5.2 and 3.5.3. If you do not provide these personal data to us, this will not adversely affect your use of the Service and you can continue to use the Service. We will only process these personal data if you have given your consent and the data will only be processed if you have actually given your consent or provided the personal data yourself.

4. SHARING OF PERSONAL DATA

4.1 We only share your personal data in the manner and with the parties mentioned in this Privacy Notice.

4.2 Sharing with processors that do not require your consent. We use other parties to assist in providing the Service. These third parties may process your personal data. These third parties are referred to as "Processors" in this privacy notice. We enter into processor agreements with these processors. We use the following types of processors:

companies that provide storage of (personal) data and management and maintenance of databases:

research agencies and providers of analytical software to improve our services (e.g. privacy-friendly Google Analytics that does not share personal data with Google);

hosting provider(s);

customer management software providers;

Payment Service Provider (PSP) for processing online payments.

In some cases, the Processor may collect your personal data on our behalf. We contractually agree with Processors that they may only use the personal data they obtain from us to provide the Service. Processors may not use this data for advertising purposes. If you provide additional information to these Processors yourself, we are not responsible for it. It is wise to inform yourself well about the Processor and its business before you provide your personal data.

4.3 Sharing of data with your consent. In order to provide our Service, your personal data will be shared with doctors and pharmacies. This is necessary because only an authorised doctor decides which medicine to prescribe to you. The following information is shared with the aforementioned parties:

Pharmacies: the name, address details and the electronic prescription;

Doctors: the name, address details and completed medical questionnaires.

We are not responsible for how these doctors and pharmacies handle your personal data; they have their own (legal) responsibility. We recommend that you check for yourself how they handle your personal data before you decide to use the doctor or pharmacy.

Our legal responsibility. We may also share personal data with third parties if this is:

reasonably necessary or appropriate to comply with our legal obligations;

necessary to comply with legal requests from authorities;

necessary to respond to legal claims;

necessary to protect the rights, property or safety of us, our users, our employees or the public;

necessary to protect ourselves or our users from fraudulent, abusive, inappropriate or unlawful use of the Service.

We will notify you immediately if a government agency makes a request relating to your personal data, unless we are prohibited from doing so by law.

4.5 Merger or sale (of part) of business. We may disclose, share or transfer your personal data when we transfer part of our business. Examples include (negotiating) a merger, selling parts of the company or obtaining loans. Naturally, we try to minimise the impact on you by transferring personal data only when necessary. The data shared will never include your medical data.

5. PROTECTION OF PERSONAL DATA

The protection of your personal data is of utmost importance to us. Therefore, we have taken appropriate technical and organisational security measures to protect your personal data. These measures include, but are not limited to:

Physical and electronic measures designed to prevent unauthorised access, loss or misuse of personal data as far as possible.

We use TLS (Transport Layer Security) technology to encrypt sensitive information or personal data, such as account passwords and other identifiable payment information.

SSL connection.

Backups of personal data are made whenever reasonably possible.

Sensitive information is stored encrypted only when possible.

Software vulnerabilities are fixed as soon as reasonably possible.

5.2 We would like to point out that absolute security for sending personal data over the Internet or storing personal data cannot always be guaranteed. We recommend that you take this into account when deciding whether or not to consent to the processing of your personal data.

6. LINKS TO THIRD-PARTY WEBSITES

Our platform may contain links to other websites and services. In addition, our platform may also contain third-party advertisements. Third-party websites and services may collect and store information about you. If you provide your personal information to third parties, we are not involved. We have no control over these sites or the activities of the third parties. In that case, the third party's privacy policy will apply. We are not responsible for the content of these parties' privacy policies or their handling of personal data. We encourage you to review their privacy and security practices and policies before providing personal data to them.

7. COOKIES

7.1 We use cookies when you visit our website. Cookies are small pieces of software that are installed on your device. Cookies can have different functions, below we describe which cookies we use and for what purpose.

7.2 Functional cookies: these are cookies that are necessary for the use of the website. We do not need permission for these cookies and these cookies do not use your personal data.

7.3 Analytical cookies: these cookies are used for analytical purposes, such as tracking the number of visitors to our website, which links they click on and so on. These cookies do not use your personal data and therefore we do not require your consent to use these cookies.

7.4 Tracking cookies: these cookies are used to track your 'behaviour' on our website. By using these cookies, we can create a digital profile of you and how you use our website. We can also link this to the Services we provide to you. Because these cookies use your personal data, we require your explicit consent to use the cookies and you can, of course, refuse for us to install cookies on your device.

8. YOUR RIGHTS

8.1 You can review, update, amend, correct or delete the personal data we collect and you can request us to restrict the processing of your personal data.

8.2 You may ask us to transfer the personal data we process about you to another entity. If you wish to do so, please indicate which information you would like to see transferred. We will comply with such a request if it concerns information processed on the basis of article 3.2 or 3.4 of this privacy statement, unless this information also contains personal data of other persons, or another reason prevents this.

8.3 If you wish to exercise the above rights, please contact us. Our contact details can be found in article 9 of this privacy notice.

8.4 We will review your request to see whether legal requirements are met and to check that your request does not conflict with our legitimate interests. For example, we have a legitimate interest if we need the personal data to provide our Service to others, to resolve disputes, to enforce applicable terms of use, for technical and/or legal requirements and/or if required by the Service or the law.

8.5 To access your own Personal Data, you must provide sufficient evidence of your identity in the manner we require of you. If we are unsure whether you are the person whose Personal Data is at issue, we may deny you access to the Personal Data.

8.6 We will respond to all your requests as described in this article within 4 weeks. For complex requests, we may extend the deadline by a further four weeks. If we extend the deadline, we will notify you within 4 weeks of submitting the request.

8.7 You have the right to file a complaint with the competent privacy authority about how we handle your personal data. For the Netherlands, this is the Dutch Data Protection Authority (College Bescherming Persoonsgegevens), which can be reached at https://autoriteitpersoonsgegevens.nl/.

9. CONTACT

If you have any questions, concerns or comments about this Privacy Statement or our data processing, please contact us by email at hello@kearty.com.

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