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Privacy Policy

PROTEIN SYSTEM (“we”, “us”, “our” (”PS”)) is a company. Incorporated and registered in Luxembourg with address Eurodiet/Protein System, ZA Kaercherwee, 64 Rue de Koerich, Steinfort 8437, Luxembourg.

We provide the Eurodiet Website (“the Site”) and are committed to protecting and respecting your privacy.

We act as both a data controller and a data processor under EU Law.

We are the data controller for Site registration data and anything you enter directly into the Site (e.g.: medication reminders, self-care tracking data, etc). This means we are responsible for determining the purposes for which and the manner in which this personal data is processed. However, for other features (e.g.: appointment bookings / repeat prescriptions / etc) we provide these services on behalf of your healthcare provider. In these cases, we are simply processing your personal information on their instruction. These parties are data controllers in their own right and have their own privacy policies.


What does this policy relate to?

This policy applies to your use of the Site.

This policy sets out the basis on which any personal information we collect from you, or that you provide to us, or that is provided to us by your healthcare provider, will be processed by us. Please read this policy carefully to understand how we will treat your personal information.


What personal information does PS collect?

1 Information you give us.

This is information you give us about you when filling in forms/screens on the Site or registering for Services through the Site, any interactions you undertake or services you request or source through the Site and via any health or monitoring device you connect to the Site or by corresponding with us by phone, e-mail or otherwise.

It will be clear at the time what personal information we are requesting from you. If you do not provide the personal information necessary or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide PS services to you, we will not be able to provide these services to you. You don’t have to provide data and can simply choose to stop using the Site at any time.

2 Information we collect about you and your device.


Each time you use the Site we automatically collect the following information:

a technical information, including the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, and time zone setting;

b information either accessed through your device or stored on your device which you have explicitly consented to sharing, and the providence of that data including the device used to collect that data, time, date; and

c details of your use of the Site.

d Additionally, if you choose to enable location services on your device, location data from your device will be used to make it easier for you to search for your healthcare provider’s practice within the Site. If you choose not to share your location, you are able to enter your healthcare provider’s/address manually.


3 Information we receive from other sources.

We may receive information about you from your healthcare provider to facilitate provision of the Services. This may include your name, Health Service number and relevant contact details as well as sensitive information, for example prescription and appointment information. They provide such data to us to enable us to provide the services to you.


How does PS use your personal information?

We DO NOT use your data for marketing purposes unless we ask for your explicit consent.

Any personal information you submit through the Site or that is accessed by PS is generally required for providing the Services to you.

Where we receive information from your healthcare provider, we rely on their legal basis for processing this information.

However, we may rely on other lawful basis for using your personal information. Specifically, we use information held about you in the following ways:


1 To provide services to you or where we have a contract with you

a To register you for the Site and Services and manage your account and for our own internal administrative purposes.
b To help us to verify your identity where appropriate by crosschecking with records kept at the relevant healthcare provider’s Practice.
c To provide you with the Site and Services and to ensure that PS presents the correct version and data for your device.
d To update you on any developments or information about the Site and Services.
e To allow us to investigate and address queries, questions and complaints that affect your use of the Site and Services.

2 Where we have a legal obligation

To make disclosures as required by or in compliance with reasonable requests by regulatory bodies, or as otherwise required by law or regulation.


3 Where it is in our legitimate interest

a To review and enhance the quality of our services and products through details of your use of the Site and Services. It is in our legitimate interest to provide effective and responsive services.

b To allow us respond to general enquiries and feedback from you. It is in our legitimate interest to provide effective and responsive services to customers.

c For internal operations, including troubleshooting, detection of fraud, log data analysis, testing, security, audit and statistical purposes. This is in our legitimate interest to protect our business interests and assess our business effectiveness.

d To provide you with the option to pick alternative or additional services which are generated from the responses you give to us when you enter information into the Site; specifically, where you enter in the information requested for booking an appointment with your healthcare provider in the Site. This service is only available where your healthcare provider has requested it.

e Where we rely on legitimate interest as a ground for processing your personal information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to the information contained in these balancing tests on request and can find out more by contacting us using the details below.


4 Where we have your explicit consent

Where any of the personal information we use contains data concerning health related information and racial or ethnic information, religious or philosophical beliefs, trade union membership data, genetic/ biometric data and sex life or sexual orientation data (together ”sensitive information”), and in addition to the above, where you provide this data to us directly through your use of the Site, we rely on you having provided us explicit consent to use such data when you provide this data via the Site.


5 Where we rely on your healthcare provider’s Medical diagnosis or healthcare purposes

Where any of the personal information we use contains Sensitive Information, in addition to the above, where this data is received from your healthcare provider, we rely on their lawful basis to use such data for healthcare purposes.


When will PS share your personal information?

We will not sell your personal information or share it for marketing purposes. We may disclose your personal information:

a To you and your healthcare provider in the course of providing the Services to you; or

b To additional processors who support us to provide the Services to you, where this is the case, their use of your data is governed by strict contract terms; or

c To third parties who offer additional services you may wish to benefit from, where this is the case, a formal Data Sharing Agreement is in place with the third party and you will be asked for your explicit consent; or

d If we are under a duty to disclose or share your personal information to comply with any legal or regulatory obligation; or

e To enforce or apply our Terms and other agreements or to investigate potential breaches of such Terms; or

f To protect the rights, property or safety of PS, our customers, or others.


How does the App store your personal information?

We will store your personal information at our secure data centre which is located within the EU. We do not transfer your personal information outside the European Union. All data will be encrypted when being transferred to and from your device to the Site or to our data centre. It is your responsibility to keep any passwords or pin codes used to access the Site confidential. If you choose to enable access to your medical record through the Site, please note that we do not store this content, we simply make the information held by your healthcare provider available to you on your device.

If you choose to conduct a video consultation with your healthcare provider through the Site then please be assured that at no time do we record or store the video footage in any form. We take all steps reasonably necessary to ensure that your data is treated securely through strict procedures and security features to prevent unauthorised access to your personal information. However, we cannot guarantee the secure transmission of information via the internet due to security threats outside our control and as such, any transmission of information is at your own risk.


How long does PS store your personal information?

We will retain your personal information for as long as needed to fulfil the purposes outlined in the ‘How does the App use your personal information?’ section above or for a period specifically required by applicable regulations or laws. For example, we generally keep your personal information for as long as you remain a registered user of the Site.

When determining the relevant retention periods, we will take into account factors including:

a our contractual obligations and rights in relation to the information involved;
b legal obligation(s) under applicable law to retain data for a certain period of time;
c statute of limitations under applicable law(s);
d our legitimate interests where we have carried out balancing tests (see section on ‘How do we use your information above);
e (potential) disputes; and
f guidelines issued by relevant data protection authorities.

Otherwise, when requested we securely erase or anonymise your personal information where you cease to be a user of the Site and we no longer require your information for the purposes collected.


What about third-party sites?

PS or any other Service we offer may contain links to other independent third-party websites or mobile applications (“Third-party Sites”).
These Third-party Sites are not under our control, and we are not responsible for and do not endorse their content or their privacy policies (if any). You will need to make your own independent judgement regarding your interaction with any Third-party Sites, including the purchase and use of any products or services accessible through them.

What rights do you have?

By law, you have a number of rights (subject to certain conditions) when it comes to your information. Further information and advice about your rights can be obtained from the Information Commissioners Office (ICO). You can exercise any of these rights by contacting us using our details below.

Rights What does this mean?
The right to object to processing You have the right to object to certain types of processing, including processing where we rely on our legitimate interest as a ground for processing.
The right to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy.
The right of access You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy).

This is so you’re aware and can check that we’re using your information in accordance with data protection law.
The right to rectification
You are entitled to have your information corrected if it is inaccurate or incomplete.
The right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure, there are exceptions.
The right to restrict processing You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
The right to data portability You have rights to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
The right to lodge a complaint You have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator. See details of the EU data protection regulator in the contact us section below.
The right to withdraw consent If you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your information with your consent up to that point is unlawful). Note that such withdrawal in certain circumstance may mean we can no longer continue to provide the Services to you.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

• baseless or excessive/repeated requests, or

• further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.

Changes to this Site Privacy Policy

We update our privacy policy from time to time and any changes we may make to our privacy policy in the future will be posted online and, where appropriate, notified to you through the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App.

Contact Us

If you have any questions, comments and requests regarding this Policy, please get in touch with us:

PROTEIN SYSTEM SA
Eurodiet/Protein System
ZA Kaercherwee
64 Rue de Koerich
Steinfort 8437
Luxembourg

Tel: +352 2 630 0812

Data Protection Officer contact details:

If you are not satisfied with our response to a complaint you have made, or think we aren’t complying with data protection law, you can make a complaint to the EU data protection regulator – the EUROPEAN DATA PROTECTION SUPERVISOR’s Office:

Address: Rue Wiertz 60, B-1047 Brussels

Telephone: +32 2 283 19 00

Email: [email protected]

Website: www.edps.europa.eu


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