Last updated: October 1, 2020
Your privacy is very important to us at VIPUN Medical NV (De Regenboog 11 bus 21, 2800 Mechelen, 0698.952.009), hereinafter also “we” and/or “us” and/or “our” and/or “VIPUN”). To better protect your privacy, we provide this Privacy Notice explaining our information practices and the choices you can make about the way your information is collected and processed. To make this notice easy to find, we make it available on our homepage and at every point where personally identifiable information may be requested.
We strongly urge you read this notice and make sure you fully understand and agree with it before you access or use any of our services. If you do not read, fully understand, and agree to this Privacy Statement, you must immediately leave this website, application or service, and avoid or discontinue all use of any of our services.
- You means the individual accessing our website or purchasing our products and/or services, or VIPUN Medical, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
- Website refers to VIPUN Medical, accessible from https://www.vipunmedical.com
- Services refers to any service VIPUN Medical may provide or to the Website.
- Products refers to the VIPUN Gastric Monitoring System, its accessories or any technology VIPUN may develop and/or sell from time to time.
2. General terms
This privacy statement informs you about how VIPUN collects and manages personal data. The purpose of this Privacy Notice is to provide you with clear explanation of when, why, and how we collect and process your personal data and it explains your statutory rights. This Privacy Notice is not intended to override the terms of any contract you have with us, nor any rights you might have under applicable data privacy laws.
We strongly urge you to read this policy and make sure you fully understand our practices in relation to your personal data, before you contact us, or purchase our Products or Services. If you read and fully understand this Privacy Notice, but remain opposed to our practices, you must immediately leave this website, application, or service, and avoid or discontinue all use of any of our Services. Where you have read this policy but would like further clarification, please contact us at email@example.com.
3. What information do we collect and how do we collect it?
All personal information related to the services or professional interactions with VIPUN, i.e. your name, e-mail address and/or phone number is gathered either manually through face to face interactions or phone calls or online via e-mail or online platforms like i.e. Linkedin. VIPUN does not buy personal data from third parties.
4. Why do we collect such information?
In the following paragraphs, you can read about the purposes of collecting personal data and the applicable legal grounds.
- Providing our services or products: First, it will be necessary for us to process certain personal data such as your identification data, to process your payment and to provide the services or products, as well as customer support. This is therefore necessary for the conclusion and performance of our contract with you. For example, we may use the information collected from you to verify your identity. We may also use this information to establish and set up your profile, log your activity and contact you from time to time. The information helps us improve our services or products to you and customize your browsing experience. In addition, this information helps us track any fraudulent activities and other inappropriate activities and monitor content integrity. If you are subscribing on behalf of an organisation, we have a legitimate interest in processing your data as contact details for the conclusion and performance of the contract.
- Customer management: In order to provide optimal (future) customer experience, we process personal data such as name, address, e-mail address, phone number, profession, and organization for the purpose of customer management. We carry out this processing based on our legitimate interest in knowing our (potential) customer and maintaining our relationship with you, with a view to providing a stellar (potential) customer experience. By manually creating these profiles, VIPUN can also provide you with much more focused and useful information.
- Compliance: To maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.
- Marketing communications: All personal information related to the services or professional interactions with VIPUN, including e.g. your e-mail address and phone number, is gathered, and processed also in the interest of our own marketing purposes. However, under the legal basis of ‘legitimate interest’, we only send information that you can expect to be related to your relationship with VIPUN and relevant or of interest to you or your business. We may for example send you emails to inform you of various opportunities our site has to offer or news about our products and services, that could be relevant or of interest to your organization. You can at any time ‘opt out’ by sending an email to firstname.lastname@example.org. You can also inform us if you no longer wish to receive specific information. For marketing activities outside of the above-mentioned scope, the legal basis of consent applies and thus your consent will be asked beforehand.
- Marketing optimization – Cookies and other tracking technologies: VIPUN, together with its marketing, analytics and technology partners, may use certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags, and scripts). These technologies are used in order to maintain, provide, and improve our Services on an ongoing basis, and in order to provide our Customers with a better experience. Functionality tags/files do not require your consent and fall under the legal basis legitimate interest. For analytical and other tags/files, however, we request your consent before placing them on your device. You can give your consent by allowing cookies in your browser settings, by continuing to use our website, or by clicking on the appropriate button on the banner displayed to you. All details are described in section 12 below.
- Product development and improvement: We thrive to ongoingly improve our products and services in order to make them fit our customers’ needs. For this reason, and based on our legitimate interest in doing so, we process personal data such as name, e-mail address, profession and organization and draw insights in relation to possible improvements and statistical purposes.
- Job applicants: To consider Applicants’ candidacy for working at VIPUN or as a consultant.
Should you ever deactivate your account with us, we will keep your information on file, but only use it to comply with regulatory requirements and to contact you occasionally with the option to reactivate your account.We will ask for your consent before using information for a purpose not mentioned or other than those set out needing consent in this Policy.
5. Protecting your privacy
We will only use your personal data for the purposes set out in Section 3 where we are satisfied that:
- our use of your Personal data is necessary to perform a contract or take steps to get a contract with you (e.g. to provide you with our customer assistance and technical support), or
- our use of your Personal data is necessary to comply with a relevant legal or regulatory obligation that we have, or
- our use of your Personal data is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our Products and Services by identifying user needs and trends and the effectiveness of VIPUN campaigns and identifying technical issues, sending relevant marketing messages), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.
We may retain your data as long as necessary to provide our products and services, and beyond such time to the extent legally permitted and based on our legal obligations (e.g. in relation to invoice retention) or legitimate interests (e.g. in retaining data for the purposes of responding to possible disputes or complaints or for possible reactivation of subscriptions).
We maintain a data retention policy which we apply to information in our care. Where your data is no longer required or in case the data subject uses the right to object we will ensure it is either securely deleted or anonymized.
7. Where do we store your information?
The personal data collected by us may be transferred for the purposes mentioned under section 3 above (purpose of processing and legal grounds) to any third parties to whom VIPUN subcontracts all or part of this processing. This may for instance include e-marketing service providers, hosting providers and any other relevant roles. Note that we will never sell your personal data to a third party.
In the event of transfer of personal data to a country outside of the European Economic Area, VIPUN systematically ensures the application of an adequate level of protection of such personal data by means approved by applicable data protection legislation. Where VIPUN is legally required to make guarantees with non-European processors you can request a copy of these guarantees by sending an e-mail to the following e-mail address email@example.com.
8. VIPUN job applications
VIPUN welcomes all qualified Applicants to apply spontaneously or to any of the open positions published by sending us their contact details and CV (“Applicants Information”) by email to firstname.lastname@example.org.
We understand that privacy and discreetness are crucial to our Applicants and are committed to keep Applicants Information private and use it solely for VIPUN’s internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).
Please note that VIPUN may retain Applicants Information submitted to it for no longer than five year after the applied position has been filled or closed. This is done so we could re consider Applicants for other positions and opportunities at VIPUN; so we could use their Applicants Information as reference for future applications submitted by them; and in case the Applicant is hired, for additional employment and business purposes related to his/her work at VIPUN.
If you previously submitted your Applicants Information to VIPUN, and now wish to access it, update it or have it deleted from VIPUN’s systems, please contact us at email@example.com.
9. Share personal data with third parties
Personal data are only processed for internal purposes, except in exceptional cases, namely when VIPUN is obliged to do so based on a statutory provision or a decision of the court or supervisory authority, or if this is necessary in the interests of the prevention, or prosecution of criminal offenses (such as fraud or deception).
VIPUN employees who process your data internally only have access to your personal data to the extent that this is necessary to perform their duties. All employees are also informed about the limitations of the processing of your personal data.
VIPUN may share your Personal data with third parties (or otherwise allow them access to it) only in the following manners and instances: Third Party Services.
VIPUN has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co location services, data and cyber security services, domain name registrars, web analytics, session recording and remote access services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”).
Such Third Party Services may receive or otherwise have access to Customers’ Personal data, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes.
Note that while our Services may contain links to other websites or services, we are not responsible for such websites’ or services’ privacy practices and encourage you to be aware when you leave our Services and read the privacy statements of each and every website and service you visit before providing your Personal data.
This Privacy Notice does not apply to such linked third party websites and services.
10. Law Enforcement, Legal Requests and Duties
Where permitted by local data protection laws, VIPUN may disclose or otherwise allow others access to your Personal data pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.
If warranted, we may also allow access to this information in special emergencies where physical safety is at risk. We reserve the right to disclose any personal data or other information obtained from or about you, to third parties in connection with a merger, acquisition, bankruptcy or sale of all or substantially all of our assets, to the extent that this is necessary for the process.
11. Your rights in relation to your Personal data
11.1 Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, where you reside within the European Union (EU), you have the following rights in this paragraph:
- to request that we provide you with a copy of your Personal data that we hold and you have the right to be informed of; (a) the source of your Personal data; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entity to whom your Personal data may be transferred;
- to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawa;
- to request that we cease processing your Personal data, in whole or in part, as you direct us, for any purpose, save to the extent it is lawful to do so without consent;
- to request that we restrict the processing of your Personal data where: (a) the accuracy of the Personal data is contested; (b) the processing is unlawful but you object to the erasure of the Personal data; (c) we no longer require the Personal data for the purposes for which it was collected, but it is required for the establishment, exercise or defence of a legal claim;
- to request that we erase your Personal data in limited circumstances where it is no longer necessary in relation to the purpose(s) for which it was collected or processed;
- to challenge processing which we have justified based on legitimate interest;
- to request that we not transfer your Personal data to unaffiliated third parties for the purposes of direct marketing or any other purposes;
- to request that we change the way we contact you for marketing purposes;
- to request that we correct any errors in your Personal data;
- to request that we update your Personal data as required;
- to obtain a copy of the safeguards under which your Personal data is transferred outside the EEA;
- to lodge a complaint with your local supervisory authority for data protection.
11.2 We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
12. Commitment to data security
In order to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
VIPUN, together with its marketing, analytics and technology partners, may use certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags, and scripts). These technologies are used in order to maintain, provide, and improve our Services on an ongoing basis, and in order to provide our Customers with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Customers’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.
Please note that Third Party Services placing cookies or utilizing other tracking technologies through our Services may have their own policies regarding how they collect and store information. These are not covered by our Privacy Statement and we do not have any control over them.
In many cases, these tags/files lead to the use of your device’s processing or storage capabilities. Some of these tags/files may be set by VIPUN itself, others by third parties; some only last as long as your browser session, while others can stay active on your device for a longer period of time.
These tags/files can fall into several categories: (i) those that are necessary for functionality or services that you request or for the transmission of communications (functionality tags/files); (ii) those that we use to carry out website performance and audience metrics (analytics tags/files) and (iii) the rest (tracking across a network of other websites, advertising, etc.) (other tags/files).
Internet browsers allow you to change your cookie settings, for instance to block certain kinds of cookies or files. You can therefore block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of the website, due to the fact that some may be functionality cookies. For further information about deleting or blocking cookies, please visit: http://www.allaboutcookies.org/manage-cookies/
Functionality tags/files do not require your consent. For analytical and other tags/files, however, we request your consent before placing them on your device. You can give your consent by allowing cookies in your browser settings, by continuing to use our website, or by clicking on the appropriate button on the banner displayed to you.
14. Contact information
For EU Member State residents, you also have a right to lodge a complaint with your national data protection supervisory authority at any time. However, we encourage you to first contact us.
15. Changes to this Privacy Statement
We may update and change this privacy statement from time to time, as we may find necessary and as our site evolves and grows. While we will do our best to bring updates to your attention, it is your responsibility to keep track of such updates. Your continuing use of this site constitutes an acknowledgement of any changes in this privacy statement.