Additional Privacy & Cookie Policy Information


Mandatory information in the different Flen Health’s websites forms

You must fill in certain mandatory fields when completing forms. This information is essential for the functioning professional network.

 

Category      

  • Title, first name and last name
  • Job title and company name
  • Place: City and country
  • Email

 

Visibility

The following mandatory information is only visible for the concerned departments.

Those data will be automatically deleted when the service is provided.

 

By service, we mean:

  • Contest or samples request: data will be kept until prize/samples is/are delivered
  • Information request: data will be kept until we fulfil your request
  • Events inscription: data will be kept until the event is finished
  • Job application: if you are not successful, data will be deleted immediately. In other cases, data will be kept until the end of the application process before being removed. Notification of your status during the process will be provided by the concerned department.

 

Legal basis

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


E-mail address(es)

We may use the electronic mail address(es) that you have provided to us in order to send you a few newsletters and/or status e-mails electronically. In addition we may send you advertising for our own related products and services, or surveys for the purpose of our own market research, unless you have objected to this form of usage. The newsletters are a simple and effective way of finding out about Flen Health, for example, having interesting contacts suggested to you, or receiving certain personal statistics.

 

Privacy

You can unsubscribe to newsletters at any time by clicking on the link provided at the end of the e-mail newsletters.

 

Period saved for

E-mail address(es), will be kept only for the implementation of your request.

 

Legal basis

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


Events data

As a professional, it is possible to register to events and other similar services provided on Flen Health Websites. You can invite other users and/or third parties to certain events also.

 

Visibility

The event host can determine which data about an event is visible for other participants and / or third parties. This might include information detailing whether the event is open to participants only or the public and therefore third parties. Also whether the number of participants is limited and whether the guest list is publicly accessible or restricted. For example, sticker with your name and company on specific seat.

 

Period saved for

We save this data until the event has been deleted.

 

Legal basis

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


Data when providing user feedback

If you provide us with feedback of your own volition or when taking part in one of our surveys, we will process your data in order to conduct the survey, or to evaluate and, where applicable, implement your feedback.

In some cases, we may ask for separate consent from you to process your data provided as part of a survey.

 

Period saved for

We save this data until the survey is finished, unless you have provided consent to it being processed beyond this point.

 

Legal basis

The legal basis for this processing of personal data is Article 6 (1) a) (separate consent) and b) of the EU General Data Protection Regulation (GDPR).


How does tracking work?

In the so-called "back end" of our web server level, we collect the data of logged-in users and other visitors. This is used first and foremost for the provision and preservation of the security of Flen Health. In the "front end" on your end device, we, or third parties use cookies, pixels, local storage and similar tracking technologies to collect data about logged-in users and other visitors. This enables the provision of our service and the analysis of user behaviour, and for the measurement and optimisation of advertising. Tracking involves the processing of login data (e.g. date and time of the visit, referrer, IP address, cookie ID, location data, product and version information about the browser or app used, device ID or data) and interaction data (e.g. pages viewed or searches carried out). Tracking is carried out without any linking to a user ID – for example, to measure the success of advertising campaigns. To be able to identify you as a user during your visit to Flen Health, we use so-called session cookies. These session cookies are automatically deleted at the end of a session. These cookies are required to be able to use Flen Health. We also conduct a very approximate geo-localisation that informs us of the towns/cities you have been to. To do this, we use your shorted and anonymised IP address, and your geo-coordinates if you have agreed to this on your mobile end device. We do not save your precise location. We only store information about which cities you are in on a regular basis. Specific addresses or geo-coordinates are not saved.


Provision of our service

We mainly use tracking and the associated user behaviour analysis to meet our contractual obligations and to perform pre-contractual measures. The legal basis for this processing of personal data is Article 6 (1) b) of the EU General Data Protection Regulation (GDPR). If tracking is not used to meet our contractual obligations or to perform pre-contractual measures, but to provide the service you visit or use, the legal basis for this processing is Article 6 (1) f) of the EU General Data Protection Regulation (GDPR). To this end, we pursue the legitimate interest of providing you with a smooth and user-friendly service.

 

Tracking and analysing user behaviour helps us to review and optimise the effectiveness of our service, and helps us to identify and correct any errors and faults. To this end, we also use several services from third-party providers, such as Google. We always endeavour to adapt our products and services to meet the needs of our users. Personalisation is an important aspect here. The implicit feedback that you provide us through our tracking of your usage of Flen Health forms an important part of understanding what content you are more or less interested in. This also allows us to suggest to you other users as a valuable business contact or potential employee. This implicit feedback is enormously important as the information you provide to us is reflective of the past and the present for the most part and says little about what interests you have with regards to the future. After usage and/or analyse, we delete or anonymise the personal data we have obtained through tracking to provide our service.

 

You can opt out of tracking by Google Analytics

We use the web analysis tool Google Analytics, developed by Google Inc. ("Google"). Google Analytics uses so-called "cookies": text files that are saved on your computer and enable the analysis of your usage of a website. The information generated by the cookie about your use of this website (including your IP address) is transferred to a server of Google in the USA and saved there. We use the so-called "_anonymizeIp()" script here, which ensures that your IP address (after identifying the geolocation) is immediately anonymised by Google. We have also closed a data processing agreement with Google. Google will use this information to evaluate your use of the website, to compile reports about website activity for website operators, and to provide other services relating to website and online usage. Google may also pass this information on to third parties if this is required by law or if these third parties process the data on behalf of Google. Google will not link your IP address to any other data about you it has stored.

 

You can prevent the installation of cookies by adjusting the settings in your browser software accordingly, please note though that you may not be able to use all the features of the Flen Health Websites in full as a result. Google also offers so-called deactivation tools for some web browsers, where you can opt out of your user behaviour being recorded and analysed.

You will find more information and download options for these tools here.


Measurement & optimisation of advertising

Tracking helps us to obtain metrics for the success of advertising campaigns and to optimise the way that online ads are displayed. In this context, the servers of third-party providers (e.g. marketers) might be accessed directly when visiting Flen Health. Here, the respective third-party provider may record the fact that you have visited our website(s). In addition, such site visits may lead to information being sent to some of these third-party providers with the aim of optimising and measuring the performance of our advertising. This includes, for example information about the kind of pages you visited, or you belonging to a certain target audience we have defined. Calling third-party provider servers directly allows third-party providers to use cookies and advertising IDs for retargeting purposes. Retargeting technologies enables third-party providers to show you personalised advertising based on your previous browsing behaviour on partner websites. Third-party providers are, to some extent, able to link your various technical IDs and thus show you personalised advertising across multiple devices. Third-party providers are responsible themselves for ensuring that the operation of the IT systems they use meets the required data protection provisions. Determination of the period of time that data is stored for is incumbent upon the provider.

Tracking for the measurement and optimisation of advertising is based on your consent, see Article 6 (1) a) of the EU General Data Protection Regulation (GDPR). You can withdraw your consent at any time.

 

Third-party providers we use

In the following you will find further information about the tracking technologies used and information from providers about data processing.

Google

LinkedIn

Facebook

Twitter

 

Removal of previously saved cookies

We do not remove cookies saved on your end device if you withdraw your consent. By withdrawing your consent in the tracking settings for individual Flen Health website, you only opt out of tracking for the measurement and optimisation of advertising in the respective websites or/and applications.

If you visit third-party sites that are not covered by these tracking settings, those third parties will still be able to access cookies saved in your end device. If you would like to prevent this, please remove the third-party provider cookies from your end device. But please don't delete the "user consent" cookies we set as. Otherwise we won't be able to determine whether you opted in or out of tracking for the measurement and optimisation of advertising in the respective Flen Health website or application. If you delete this cookie, you will then be prompted to opt in or out of tracking for the measurement and optimisation of advertising when you next visit our websites and applications.

The process required to delete cookies and set what information your browser saves depends on the browser you use. Please refer to the help section of your browser for further details.


Tracking in embedded third-party content

You will also find content produced by external providers on Flen Health websites. This content is integrated into the Flen Health environment you are familiar with from external websites. When it comes to this external content, we have no control over the type of tracking used.

 

Opting out of tracking within the Flen Health environment

If you would like to prevent tracking by external providers within the Flen Health environment, you can deactivate the integration. As soon as you begin using any of the external content you will leave the Flen Health environment and be automatically forwarded directly to the page of the provider. Please note: This does not necessarily result in less tracking – it only means that the tracking does not take place on Flen Health.


Right to object

General

You have the right to object at any time to the processing of personal data concerning you, pursuant to Article 6 (1) f) of the EU GDPR. This shall also apply to any profiling carried out based on these provisions. Please use the following mail address to submit any objection: privacy@flenhealth.com

 

Direct marketing / newsletters

If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing. This includes profiling to the extent that it is related to such direct marketing. You can unsubscribe to our newsletters at any time in your e-mails by clicking on the link provided at the end of the respective newsletter. In some applications there are different ways of unsubscribing to a newsletter or notifications.


Right of access

You have the right to demand confirmation as to whether we process your personal data. If this is the case, you are entitled to receive information about this personal data.

 

You have a right to access the following information:

  • The reasons for the data processing.
  • The categories of personal data that are processed.
  • The recipients or categories of recipients who have had or will have access to the personal data, particularly in the case of recipients in third countries and international organisations.
  • If possible, the planned period that the personal data will be saved for, or if this isn't possible then the criteria used to determination this time period.
  • The existence of a right to rectification or removal of your personal data and/or the right to restriction of processing by the controller, or a right to object to this processing.
  • The existence of a right to lodge a complaint with a supervisory authority.
  • All available information about the origin of the personal data if the data was not obtained from the person in question.
  • The existence of automated decision-making including profiling pursuant to Article 22 (1) and (4) of the EU GDPR and – at least in some cases – insightful information about the logic involved plus the scope and aims of the repercussions of this kind of processing for the person affected.

 

If personal data is passed on to a third country (outside EU) or an international organisation, you have the right as the person affected to be informed about the respective guarantees (pursuant to Article 46 of the EU GDPR) regarding this sharing of data.


Right to rectification

You have the right to demand that we correct any incorrect personal data concerning about you with an immediate effect. Taking the purposes of processing into account, you have the right to demand the completion of any incomplete personal data – including by means of a supplementary explanation.


Right to remove

You are entitled to demand that we delete your personal data without delay if one of the following applies: The personal data is no longer required for the purposes for which it was collected or processed in some other way. You withdraw your consent that the processing was based on pursuant to Article 6 (1) a) or Article 9 (2) a) of the EU GDPR, and there are now no valid legal grounds for processing. You submit an objection to the processing of your data pursuant to Article 21 (1) of the EU GDPR and there are no overriding justifiable grounds for the processing, or you submit an objection to the processing of your data pursuant to Article 21 (2) of the EU GDPR. The personal data was processed unlawfully. The deletion of the personal data is required to fulfil a legal obligation in accordance with EU law or the law of individual member states. The personal data was recorded in relation to the offer of information society services directly to a child, pursuant to Article 8 (1) of the EU GDPR. Once you have made your request, we are obliged to delete the data with immediate effect. The lawfulness of the data processing for the period between the consent and the withdrawal of this consent shall remain unaffected.


Right to restriction of processing

You are entitled to demand a restriction to the processing of your personal data in cases where you dispute the correctness of the personal data, for a period of time that allows the controller to review the correctness of that personal data. If the processing is unlawful and you reject the removal of the personal data in favour of demanding a restriction to the use of the personal data, we will fulfil this request. Processing will also be restricted if we no longer require your personal data for the purposes of processing but do require it for the establishment, exercise, or defence of legal claims. Or if you have objected to processing pursuant to Article 21 (1) of the EU GDPR, for as long as it is not yet ascertained whether the justifiable grounds of the controller outweigh your grounds. We will inform you in advance should the restriction be revoked.


Right to data portability

You have the right to receive personal data concerning about you that you have made available to us in a structured, conventional and machine-readable format. You also have the right to transfer this data to another controller without being impeded by us to whom the personal data has been made available. The condition is that a) processing is based on consent pursuant to Article 6 (1) a) of the EU GDPR or Article 9 (2) a) of the EU GDPR or on a contract pursuant to Article 6 (1) b) of the EU GDPR, and b) the processing is conducted with the help of automated processes. When exercising your right to data portability, you have the right to demand that the personal data is transferred directly from us to another controlling body, provided this is technically viable.


Right to withdraw consent

If processing is subject to your consent you have the right to withdraw this consent at any time. This shall not affect the lawfulness of any processing that took place with your consent up until its withdrawal.


Right to lodge a complaint

The supervisory authority responsible for our company is the Commission for the Protection of Privacy / Commission Nationale pour la Protection des Données

 

1, avenue du Rock’n’Roll

L-4361 Esch-sur-Alzette

Tel. +352 2610 60 1

Fax +352 2610 60 29

e-mail: info@cnpd.lu

Website: www.cnpd.lu

 

If you feel that the processing of your personal data infringes upon the EU GDPR, you have the right to lodge a complaint with the supervisory authority in your regular place of residence, your place of work, or alleged place of infringement. Further information about the complaint’s procedure is available in Article 77 of the EU GDPR.