Privacy Policy

Last update: 17/06/2021

Dobco Medical Systems takes privacy very seriously. We strongly believe in protecting the privacy of the personal data you share with us. Dobco Medical Systems explicitly confirms that all personal data will be processed in accordance with both the Belgian law of 8 December 1992 and the Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereafter GDPR) in as far as already possible and desirable. As a controller, we also believe it is important to inform you about how we will use your personal data, and to give you choices about this. This Privacy Policy is meant to help you understand what data we collect, why we collect it, and how we use it. This is important, therefore we encourage you to take time to read it carefully.

1. SCOPE OF THIS PRIVACY NOTICE

• This Privacy Policy (Privacy Policy) applies to
• • all personal data collected of Users of the PACSonWEB platform. This implies all doctors, dentists, specialists … that register for a PACSonWEB account or use PACSonWEB through an account as well as unregistered users that logon with a reference number and date of birth for an exam.
  • all personal data collected of Users of the Dobco Medical Systems’ website that register for the newsletter or fill out a contact or demo request form
  • all personal data, processed in the context of job applications
  • the personal data, processed in the context of contractual relationships with customers and suppliers,
  • any terms and conditions and other policies of Dobco Medical Systems applicable to the Services.

This Privacy Policy does not apply to the patient data that Dobco Medical Systems processes on demand for our contracted hospitals and radiology practices. For all matters, involving these data, we refer to the privacy policy of the related radiology department.

2. THE INFORMATION WE COLLECT, THE REASON WHY AND THE APPLICABLE LEGAL GROUND

The information provided to us can, amongst others, consist of personal data. By ‘personal data’ we mean any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is someone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We will treat all personal information you provide us with, in confidence, in accordance with this Privacy Policy and the national and international legal requirements.

2.1 As a user of the PACSonWEB platform

• As part of the agreement with a registered user of the PACSonWEB portal, the following personal information is collected:
  • Name + First Name
  • Email address
  • Mobile phone number
  • Professional Telephone number (optional)
  • Gender
  • Language
  • IP address when connecting to the portal
  • Timestamp when connecting to the portal
  • List of linked radiology practices
• When using the PACSonWEB portal the required personal information is registered in our databases and will be processed in order to achieve the following goals:
  • Assure traceability on registered access to medical data;
  • Implement appropriate secure authentication and authorization methods. This implies sending e-mails and/or text messages for two-factor authentication protocols;
  • Automated sending of notification mail in case new study becomes available to the user in PACSonWEB;
  • Improve the quality of our services and information;
  • Provide a list of registered users to hospitals that use PACSonWEB for distribution. This list only includes Name, First Name and Identification Number as a doctor (RIZIV, BIG, ...).
• As part of the agreement when connecting with a reference number and date of birth, the following personal information is collected:
  • Reference number
  • Data of Birth
  • IP address when connecting to the portal
  • Timestamp when connecting to the portal

The provided personal data related to a registered user account will be stored for a period of 2 years after the last registered successful login attempt.

The data on the exams that have been accessed will be stored for 10 years, unless we have to keep the information even longer for legal purposes. This period of time is necessary to be able to realise the aforementioned purposes.

In addition, with each PACSonWEB session cookies are used e.g. to register the session ID which is used as long as the user is logged on. No personal information is stored within these cookies. For a full explanation on the use of cookies, we advise you to consult the cookie policy on the PACSonWEB portal.

2.2 As a visitor of our corporate website (www.dobcomed.com)

You can visit our company website without disclosing personal information. In specific cases, personal information is registered when e.g. filling out a contact form or subscribing to the newsletter.

The provided personal data is stored for the duration of the requested service + 2 years.

• In these specific cases, the mentioned personal data is collected:
• Request for Demo account
  • Name + first name
  • Email address
  • Company + function within the company
  • Address + country
  • Phone number
• Submitting a contact form
  • Name
  • Email address
  • Company + function within the company
  • Phone number
• Contacting the Servicedesk
  • Name
  • In case follow-up is required: email address and/or Phone number
• The purpose of the processing is to
  • Contact you to provide the requested information;
  • Improve the quality of our services and information;

  and is based on your consent, providing the details on the gathered personal information voluntarily.

If Dobco Medical Systems decides to use the gathered personal data for additional purposes and for which legitimate interest is not a valid ground, consent for the related processing will be asked before actual processing of the related data. To give consent it will be required to tick a box stating “that you consent to the processing of your personal data for the mentioned purposes”. You will have the right to withdraw your consent at any time. However, the withdrawal of consent shall not affect the lawfulness of the processing based on consent before its withdrawal. You can withdraw your consent by contacting the support desk by phone or mail.

In addition, with each web session cookies are being used. For a full explanation on the use of cookies, we advise you to consult the cookie policy on the Corporate website.

2.3 As an applicant

• When you contact us in the context of an open vacancy or spontaneous application, we collect the following data:
  • Name + first name
  • Address + country
  • E-mail address
  • Phone number
  • Curriculum Vitae

In addition, you will also be screened on relevant social media related to your professional activities such as LinkedIn.

The processing of your personal data is necessary in order to be able to take measures prior to the closure of an employment contract and it is in the legitimate interest of Dobco Medical Systems, i.e. it is the interest to assess you before making you an offer of employment, which seems to us also to be in your interest or in any case does not outweigh our interest.

By default, we keep your data for the term of the application procedure. If your application was not withheld, but we wish to keep your data for future vacancies, we will ask for your permission. Your data will then be kept for a period of 2 years.

2.4 As a customer

• When your organization has a contractual relationship with Dobco Medical Systems regarding the use of one or more services, we will collect the following information:
  • Name + first name
  • Company + position within the company
  • Address + country
  • E-mail address
  • Phone number
• We do this in the context of the execution of the agreement for all persons involved in the following phases of the service:
  • concluding the contract
  • implementing the service
  • using the service on a day-to-day basis

  and this up to two years after the termination of all contractual relationships with Dobco.

2.5 As a supplier

• If you have a commercial relationship with Dobco Medical Systems, we collect the following data:
  • Name + first name
  • Company + position within the company
  • Address + country
  • E-mail address
  • Phone number
• These data are only kept in the context of the execution of the commercial agreement and are deleted two years after the last collaboration.

3. YOUR RIGHTS

• Under certain circumstances, you have the right to:
  • Request an overview of the personal data we have on you
  • Correct your personal data
  • Request the erasure of your personal data
  • Object to the processing of your personal data (eg for marketing purposes)
  • Withdraw your consent at any time (eg on keeping your CV)
  • Receive your data in a structured, commonly used and machine-readable format

In case you want to exercise one of the above mentioned rights with respect to data for which Dobco Medical Systems acts as the processor and for which a hospital or private radiologist is the controller, the request must be filed with the related radiology department.

For data gathered directly by Dobco Medical Systems, the above requests can be made by contacting us by mail (data_protection_officer@dobcomed.com) or by letter addressed to our head office at
Dobco Medical Systems
Nachtegaalstraat 6 W05,
9240 Zele
Belgium
For identification purposes, we ask you to provide us with a copy of the front side of your ID card.

After verifying your identity, we will do everything reasonably possible to comply with your request unless your request would require completely unreasonable measures (e.g. would be technically or organizationally virtually impossible or extremely costly). We may refuse to process requests that are unreasonably repetitive or systematic.

Your request will, if reasonably possible, be handled within one month after receipt thereof.

4. HOW TO NOTIFY INFRINGEMENTS TO YOUR RIGHTS AND FREEDOMS?

If you believe, at any moment, that Dobco Medical Systems infringes your rights and freedoms, please send an e-mail to our data protection officer, using the following address: data_protection_officer@dobcomed.com

We will do everything reasonably possible to identify and solve the problem.

In this event, you can also contact the relevant Supervisory Authority:

For Belgium:
Gegevensbeschermingsautoriteit
Drukpersstraat 35
1000 Brussel
Tel: +32 2 274 48 00
https://www.gegevensbeschermingsautoriteit.be/

For France:
Commission Nationale de l'Informatique et des Libertés
8 rue Vivienne, CS 30223
F-75002 Paris, Cedex 02
Tel: +33 1 53 73 22 22
https://www.cnil.fr/fr

For the Netherlands:
Autoriteit Persoonsgegevens
Prins Clauslaan 60
Postbus 93374
2509 AJ Den Haag
Tel: +31 70 888 8500
https://www.autoriteitpersoonsgegevens.nl/

For Norway:
Norwegian Data Protection Authority
P.O. Box 8177 Dep
NO-0034, Oslo
Tel: + 47 22 39 69 00
www.datatilsynet.no

For Switzerland:
Office of the Federal Data Protection and Information Commissioner
Feldeggweg 1
CH - 3003 Berne
Tel: +41 58 462 43 95
https://www.edoeb.admin.ch/

For Slovenia:
Informacijski pooblaščenec Republike Slovenije
Dunajska cesta 22
SI-1000 Ljubljana
Tel: +386 1 230 97 30
https://www.ip-rs.si/

For Germany:
Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit
Husarenstraße 30
53117 Bonn
Tel: + 49 228-997799-0
https://www.bfdi.bund.de/

5. THIRD PARTIES

Personal data collected by Dobco Medical systems may be transferred or disclosed to third party contractors, subcontractors and/or subsidiaries for the purposes for which the visitor has submitted the information and for the administration of our system or site and/or other internal, administrative purposes. Personal data may also be transferred to third party service providers of identity management, website hosting and management, data analysis, data backup, security and storage services. As a result, personal data may be transferred outside the country where the visitor is located. By submitting data on Dobco Medical Systems’ website, the visitor is providing explicit consent to the transfer of such data for the fulfilment of his or her voluntary requests or otherwise as set out in the section “2. THE INFORMATION WE COLLECT, THE REASON WHY AND THE APPLICABLE LEGAL GROUND”.

• It is Dobco Medical Systems’ policy to disclose information to third parties under the following circumstances:
  • As required by applicable law, statute, rule, regulation or professional standard, or through subpoena, search warrant or other legal process
  • For regulatory compliance purposes
  • When explicitly requested by a visitor
  • When required to facilitate conferences or events hosted by a third party
  • Or otherwise as set out in this statement.

6. SECURITY

Dobco Medical Systems will, to the extent possible, take technical, physical and organizational security measures which comply with applicable laws in the field of privacy and data security in order to guarantee a secure processing of your personal data. The risks of accidental or unauthorized destruction, accidental loss, alteration of or access by unauthorized persons, and any other unauthorized processing of your personal data are therefore reduced to a minimum.

7. CHANGES TO THE PRIVACY POLICY

We may change this Privacy Policy from time to time by posting the updated version of the Privacy Policy on the Dobco Medical Systems’ company website and the PACSonWEB portal website. When we publish changes to our Policy, we will change the date of the "last update" of our Privacy Policy. We therefore encourage you to check our Privacy Policy periodically.

8. CONTACTING US

• In case you
  • Have a concern or question about our use of your data
  • Have any questions with regard to this Privacy Policy
  • Want to execute your privacy rights
• You can contact us by mail using the mail address data_protection_officer@dobcomed.com
• If you prefer, you can write us at:
  Dobco Medical Systems
  Nachtegaalstraat 6 W05
  9240 Zele
  Belgium
• 
  For identification purposes, you are requested to include a copy of the front side of your identity card.