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Flen Health Privacy & Cookie Policy

Flen Health SA values the personal information you provide to us and we wouldn’t want to use it in a way that you won’t expect. This Privacy Notice explains how we protect your privacy and how you can control how we use your personal information. If you want to change the way in which we use your data or if you have a question about how your personal information is used please contact us using the methods below:

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Phone: +352 2634 06 27 1
Postal address: 29, rue Henri Koch
L-4354 Esch sur Alzette / Luxembourg

Information automatically collected through your use of Flen Health websites & applications

1. General statement about the purposes of data processing

Flen Health do intend to inform you of all the key information about our data processing. We process data first and foremost to fulfil our contractual obligations towards our customers (sell of products, training requests, …). In addition, we process your data to preserve our justifiable interests while taking your interests into account (e.g. when we send you promotional newsletters). And, of course, in some cases we are legally obliged to process data (e.g. to pass the data on to any investigative authorities). In all other cases we will ask for your separate consent to process your data (e. g. when using tracking technologies for the measurement and optimisation of advertising or when you enter a prize draw). When it comes to fulfilling our contractual obligations towards our customers, we always try to tailor our products and services to their needs. We also use information that you provide to us, in addition to implicit feedback, i.e. information that we automatically obtain through your usage of our websites (by means of so-called "tracking"), as well as information that we may possibly receive indirectly. To meet our contractual obligations, we also serve you third-party advertising. To this end, we provide advertisers with certain targeting criteria which will correspond to the different Flen Health values (for e. g. information about partner seminar regarding specific sickness or/and injuries).

2. Information you provide to us

This includes data that we have obtained from you directly and information that you publish or send on Flen Health Websites. There are both mandatory entry fields (which as marked as such) and optional information you can provide.

Mandatory information in the different Flen Health’s websites forms

e.g. job title, company name, company

E-mail address(es)

e.g. to send you newsletters or status e-mails

Events data

e.g. for events and seminars created on Flen Health Websites

Data when providing user feedback

e.g. when taking part in surveys

3. Information automatically collected through Flen Health websites & applications

Data about you is automatically collated by means of tracking whenever you visit or make use of the Flen Health websites. This takes place with the help of various tracking technologies.

How does tracking work?

Data about users and other visitors are collated on our server along with cookies, pixels, and similar tracking technologies on end devices.

The purposes of tracking & opt-out options

  • Ensuring security

One reason for tracking is to ensure and preserve the legitimate interest of the protection of users, the security of user data, Flen Health websites, and the Flen Health application (CRM). To this end, we save the data we record for up to 180 days in its full form. Only a limited number of our employees with the respective authorisation rights have access to this data. The legal basis for this processing of personal data are Article 6 (1) f) and Article 32 of the EU General Data Protection Regulation (GDPR).

The main purpose of tracking and the analysis of user behaviour is to provide our service. The legal basis for this processing of personal data are Articles 6 (1) b) and 6 (1) f) of the EU General Data Protection Regulation (GDPR). You can opt out of tracking by certain third-party providers if you wish.

Tracking is also carried out to measure the success of advertising campaigns and optimise the display of advertising. This involves the use of providers such as Google. The legal basis for this processing of personal data is your consent, see Article 6 (1) a) of the EU General Data Protection Regulation (GDPR). You can withdraw your consent at any time.

Tracking of content & opt-out options

In some of our applications or websites, we make the content of external providers available to you. When it comes to this external content, we have no control over the type of tracking used, as responsibility for this lies with the respective external provider. Nevertheless, it is possible if you wish to opt out of this type of tracking at least within the Flen Health environment.

 4. Information we obtain about you from other sources

We also process data that we have not obtained directly from you. This occurs whenever a user provides us with information, or we collect information from other sources. In such cases we process the respective data within the scope of fulfilment of our contractual obligations towards the respective user and/or to safeguard our legitimate interests, while giving due consideration to your interests.

Visibility

No third parties have access to the uploaded data.

Period saved for and objection

Data will be deleted by Flen Health when the scope of the usage is reached. At any time of the process, users can request the deletion and/or modification of their data.

Legal basis

The legal basis for this processing of personal data is Article 6 (1) f) of the EU General Data Protection Regulation (GDPR).

Events data

This includes the following data; which users provide us with to register attendees for an event at the organiser's request:

  • Salutation, title, first name and last name
  • E-mail address
  • Company name
  •  …

Intended purpose

Users who register for an event may also register other persons as event attendees. Therefore, the personal data may be processed on this user's behalf and responsibility.

Source of the data

Users who have data for other persons can register them as event attendees by entering data on Flen Health websites and/or applications.

Visibility

The organiser can access the attendee's registration details.

Period saved for and objection

We save this data until two weeks after event occurred. You have the right to file an objection at any time to the processing of your personal data pursuant to Article 6 (1) f) of the EU General Data Protection Regulation (GDPR). Please use our contact form to file your objection.

Legal basis

The legal basis for this processing of personal data is Article 6 (1) f) of the EU General Data Protection Regulation (GDPR).

 5. Who may receive information about you?

 We only pass your personal data on to third parties when this is required to fulfil our business purposes (i.e. in particular to perform the services we are obliged to provide you with, e.g. making your profile available to another user), when you have given your consent to this (e.g. when using an external application), or when we are obliged to on legal grounds, by court order, or at the request of another official authority.

In cases where we work together with external service providers for our data processing (e. g. in software development), this is usually carried out on an order processing basis, whereby we remain responsible for data processing. We review each of these service providers beforehand with regard to the measures they have undertaken to ensure data protection and data security, thereby safeguarding the contractual provisions as stipulated by law for the protection of the personal data.

  • Public authorities and courts
  • Technical service providers
  • Hosting providers
  • Ad server providers
  • E-mail sending providers
  • E-mail marketing providers
  • Marketing automation software providers
  • CRM providers
  • Software developers
  • Agencies
  • Postal providers (letter shops)
  • Market research and survey tool providers
  • Remarketing/Retargeting providers
  • Sales service providers
  • Service providers for advertising campaigns and the display of ads
  • Providers of tools for website use analysis
  • Cooperation partners
  • Event partners

 What rights can you exercise?

You have legal rights available to you with regards to data access, rectification, removal and restriction of processing and objection to processing, as well as the right to data portability, amongst others. In addition, you can withdraw any consent you may have given to data processing at any time and have the right to lodge a complaint with a supervisory authority.

Right to object

You have the right to file an objection at any time to any processing of your personal data pursuant to Article 6 (1) f) of the EU General Data Protection Regulation (GDPR).

Right of access

You can request to receive clear and transparent access to information regarding the processing of your personal data.

Right to rectification

You have the right to demand that we correct any of your personal data that is incorrect and complete any personal data that is incomplete.

Right to remove

In certain cases, we are obliged to delete your personal data once you have requested this.

Right to restriction of processing

In certain cases, you can demand that restrictions be placed on the processing of your personal data.

Right to data portability

Any data disclosure report you have requested can also be sent to third parties.

Right to withdraw consent

You can withdraw any consent you have given to data processing at any time.

Right to lodge a complaint

You have the option of submitting an official complaint to the supervisory authority.