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PRIVACY

Content

  1. Introduction to Ageworth Clinics Privacy Policy
  2. Categories of personal data
  3. Legal basis and purposes of data processing
  4. Storage period
  5. Recipients of personal data
  6. Security
  7. Your rights regarding your personal data
  8. Right to access (Article 15 GDPR)
  9. Right to rectification (Article 16 GDPR)
  10. Right to data portability (Article 20 GDPR)
  11. Right to erasure (Article 17 GDPR)
  12. Right to lodge a complaint with the supervisory authority
  13. Right to object to data processing (Article 21 GDPR)
  14. Obligations

1.Introduction to Ageworth Clinics Privacy Policy

This is the privacy policy of Ageworth Clinics. This privacy policy applies to all privacy-sensitive information or personal data that you provide to us. We clearly explain how we store your data, how long it is retained, and the exact purpose of the data processing. Additionally, we provide clear insight into how you can exercise your rights regarding data processing.

Ageworth Clinics is a clinic where the focus is on the treatment of your cosmetic concerns rather than the procedure itself. We contribute to enhancing your appearance and character.

In certain situations, Ageworth Clinics may need to collect, process, or use your personal data. As we process personal data (or have it processed) in various situations, we have opted for a comprehensive privacy policy. However, this does not mean that we process a large amount of personal data. Ageworth Clinics processes personal data in a minimal manner. It is important for you to know what happens to your personal data and how you can communicate your preferences regarding the handling of personal data to us.

Ageworth Clinics takes your privacy seriously and will use and process personal information in a secure manner. All articles in this privacy policy comply with the applicable General Data Protection Regulation (GDPR) legislation. This European privacy legislation has been applicable in the Netherlands since May 25, 2018.

If you have any questions about our privacy policy, please feel free to contact Ageworth Clinics’ customer service.

Klantenservice@ageworth.com

Spacelab 9 l 3824 MR l Amersfoort

Chamber of Commerce Number (KvK): 73930474

2.Categories of personal data

In order to provide the best possible support to our visitors, customers, and partners, it is necessary for us to collect and process certain data, including personal data. Personal data refers to data that can be attributed to a natural person. The personal data that we (generally) process includes:

  • BSN (Citizen Service Number);
  • First and last name;
  • Date of birth;
  • Residential address;
  • (Optional) Photos of the area to be treated;
  • Medical records;
  • (Personal) email address (please note: under the GDPR, certain company email addresses may be considered personal email addresses. For example, the email address janssen@company.com).

We only store and use the personal data that you directly provide to us or that is clearly provided for processing by Ageworth Clinics.

3.Basis and Purposes of Data Processing

Under the GDPR legislation, we are required to have a lawful basis for processing your personal data. Article 6(1)(a) and (b) of the GDPR are applicable in our situation: the processing of your personal data is done based on your consent or because it is necessary for the performance of a contract between you and Ageworth Clinics.

Article 13(1)(c) of the GDPR further requires us to clearly indicate the “processing purposes” for which the personal data is intended. Below is an overview of different processing purposes.

There are several purposes for which Ageworth Clinics collects your data:

  1. Contacting you

If you have contacted Ageworth Clinics in any way, the information you provide, such as name, email address, and phone number, will be stored and used for further communication.

The legal basis for processing in this context is our legitimate interest (we need to be able to communicate with you to address and follow up on inquiries and provide our services).

  1. The agreement

When entering into an agreement, Ageworth Clinics requires certain information. Without this information, it is not possible to properly execute the agreement. This includes details such as your first and last name, address, identification, and contact information.

The legal bases for processing in the context of this purpose are:: Your explicit consent (by entering into an agreement with Ageworth Clinics, you indicate your awareness and agreement to the processing of certain personal data), performance of the agreement (to properly execute the services of Ageworth Clinics), legal obligation (to properly fulfill our services and comply with the concluded agreement, meeting our legal obligations as healthcare providers to verify a person’s identity), and our legitimate interest (to properly carry out our activities and deliver our products).

  1. Medical record

It is important for Ageworth Clinics to maintain a medical record. This record includes information about your health and personal preferences. To keep the record, Ageworth Clinics requires certain data. Without this data, it is not possible to maintain the record correctly and in accordance with legal requirements. The processing of this personal data is based on explicit consent. This personal data may include your first and last name, gender, medical information such as your general practitioner and health insurance. This data is only collected with your explicit consent, as it may involve the processing of special categories of personal data.

The legal bases for processing in the context of this purpose are:: Your explicit consent (your given consent to Ageworth Clinics to process this personal data), performance of the agreement (to properly tailor our services to the medical conditions of the individual and to correctly perform our services), legal obligation (to properly carry out our services as a healthcare provider, the obligation to comply with the concluded agreement, and our legal obligations regarding the processing of medical data), and our legitimate interest(to properly carry out our activities and tailor our assistance and services).

  1. Newsletter

Your email address will be processed for the purpose of sending the newsletter, if you choose to receive it. Other data, such as your name, may also be processed if necessary. You can unsubscribe from the newsletter at any time.

The legal basis for processing in this context is: Your explicit consent (expressing your interest in receiving our newsletter to Ageworth Clinics) our legitimate interest (for open communication and information about Ageworth Clinics, as well as the possibility to contact our customers for certain product offerings).

  1. Accounting and invoicing

Ageworth Clinics is legally obligated to maintain proper accounting records. Therefore, the data necessary for invoices or quotations is retained. This may include name and, if necessary, bank details.

The legal bases for processing in the context of this purpose are:: Performance of the agreement (in case the agreement is concluded with the customer) legal obligations (including our administration and retention obligations, tax obligations, and the obligation to prepare annual accounts and reports), and Your explicit consent (to properly and effectively carry out our regular business activities, provide and improve our services, protect our interests during disputes or legal proceedings, and prevent fraud, scams, or other unlawful behavior).

  1. Cookies, placed through the Ageworth Clinics website (Please read our cookie statement for detailed information).

All information regarding cookies is extensively explained in our cookie statement.

Note: With regard to cookies, we comply with both the GDPR and the Dutch Cookie Act (Telecommunications Act, Article 11.7a). This means that more detailed information about cookies is provided in a separate document: our cookie statement.

4.Storage period

Above, we have indicated for which processing purposes we use your personal data. According to Article 13(2)(a) of the GDPR, we are then required to specify the storage period of personal data.

  1. Contact

If the contact does not result in the provision of a service or work, the data provided by you will be stored for a period of five (5) years.

  1. The agreement

For this purpose, data will be retained for seven (7) years after the end of a customer relationship, unless longer is necessary due to a legal proceeding. The period of five (5) years is also associated with the possibility that a potential customer may become a customer again or continue being a customer at Ageworth Clinics.

  1. Medical record

Ageworth Clinics is legally obliged to retain your personal data processed for medical records for at least twenty (20) years. After the retention period, Ageworth Clinics will delete the medical data, provided that no new medical data of the individual are processed following an agreement.

  1. Newsletter

We will retain the data until you unsubscribe from the newsletter. After unsubscribing, the data will be deleted.

  1. Accounting and invoicing

For proper accounting, we need to retain personal data associated with financial purposes for a minimum period of seven (7) years.

  1. Cookies, placed through the Ageworth Clinics website (Read our cookie statement for detailed information)

All information regarding cookies is extensively explained in our cookie statement.

5.Recipients of personal data

Ageworth Clinics shares personal data with other parties to the minimum extent necessary.

Google

Certain cookies on this website may collect certain data, which may be shared with Google, depending on the website visitor’s cookie settings.

Ageworth Clinics reserves the right to share personal data with other third parties if strictly necessary or required by law. This may be the case in a legal proceeding or if a government authority requests the personal data. Ageworth Clinics always complies with confidentiality obligations.

If the data needs to be shared, Ageworth Clinics will comply with the GDPR, particularly Article 28 of the GDPR. If Ageworth Clinics is obligated to share personal data with third parties, we will inform you by amending this privacy statement or by personally contacting you.

6.Security

Ageworth Clinics takes the protection of your (personal) data seriously. To adequately secure your personal data, we store them in a cloud and do not store any personal data physically.

Personal data is only accessible to authorized employees of Ageworth Clinics who are involved in the processing of your personal data. The devices on which your data is stored are locked with a password and/or fingerprint scan and/or facial recognition. These devices include necessary equipment such as computers, laptops, and mobile phones.

Ageworth Clinics uses firewalls, protected software (including a secure program where your medical data is stored), and antivirus programs for the website and digital data.

Your visit to the Ageworth Clinics website is also secured with HTTPS encryption. This means that your connection to Ageworth Clinics is private, ensuring the safety of your personal data during your website visit.

For the sake of completeness, here is more information about online security:

  • All devices that have access to your personal data and are involved in the processing of personal data are secured with a password.
  • Security software, such as a firewall and secure software.
  • We transmit your data over a secure internet connection, which you can verify by the “HTTPS” and the padlock icon in the address bar.
  • No personal data is stored physically.

7.Your rights regarding your personal data

Below are the rights you can exercise regarding your personal data. We provide detailed information on how to exercise each right.

a. Right of access (Article 15 GDPR)

You always have the right to access the data processed and stored by Ageworth Clinics. To exercise this right, you can send an email with your request to Ageworth Clinics customer service.

b. Right to rectification (Article 16 GDPR)

If the data stored by Ageworth Clinics is found to be incorrect, you have the right to have this data rectified. Ageworth Clinics will replace the current incorrect data with the correct data.

c. Right to data portability (Article 20 GDPR)

You have the right to have your personal data transferred by Ageworth Clinics to a similar party, meaning a party that offers and performs services similar to Ageworth Clinics.

d. Right to erasure (Article 17 GDPR)

In certain cases, you can request Ageworth Clinics to erase your data. This includes the right to be forgotten. The following list includes situations where Ageworth Clinics is required to delete your data:

  • When the data processed by Ageworth Clinics is no longer necessary for the purpose of processing.
  • When you withdraw your consent for the use of personal data, such as unsubscribing from the Ageworth Clinics newsletter.
  • When you object to the processing of your data. In the case of direct marketing, you have an absolute right to object. If your interests regarding the processing of personal data outweigh those of Ageworth Clinics, you have a relative right. The deletion of the data will only occur if it is demonstrated that your interests outweigh those of Ageworth Clinics.
  • When Ageworth Clinics processes data unlawfully, you have the immediate right to have the data deleted. This is the case when there is no legal basis for the processing of personal data.
  • When a statutory retention period has expired, Ageworth Clinics is obliged to delete the processed personal data.
  • If you are a data subject under the age of 16 and no consent has been given by a parent or guardian for the processing of personal data. In this case, Ageworth Clinics will immediately delete your personal data.

There may be exceptions to the right to erasure. For more information, please refer to the following page.

e. Right to lodge a complaint with the Dutch Data Protection Authority

If you believe that Ageworth Clinics is not handling your personal data in a proper manner, you always have the right to lodge a complaint with the Dutch Data Protection Authority. You can do this via this link. The Dutch Data Protection Authority will handle your complaint further.

f. Right to object, objection (Article 21 GDPR)

You have the right to object to data processing at any time, especially in the case of “direct marketing”.

Furthermore, we would like to inform you about the following rights:

  • Right to restriction of (part of) the processing: under certain conditions, you have the right to obtain from Ageworth Clinics the restriction of the processing of your personal data. This means that Ageworth Clinics temporarily “freezes” the processing of the data. You can invoke this right in four situations: (1) while waiting for the assessment of a correction request, (2) when data should actually be deleted but you do not want deletion, (3) when Ageworth Clinics no longer needs the data while they are still needed for (preparing for) a legal case, and (4) while waiting for the assessment of an objection.
  • Withdrawal of consent: you have this right to the extent that we process your data based on your consent. You have the right to withdraw your consent at any time. This does not affect the past, but it means that we are no longer allowed to process those data. It may be that Ageworth Clinics can no longer provide you with certain services as a result.

How to exercise the above rights?

In most cases, an email to Ageworth Clinics, Klantenservice@ageworth.com, is sufficient to exercise the aforementioned rights. If we doubt the validity of your identity, we may take other measures to verify it. For example, you may be asked to provide us with a copy of your identity document. This always happens in the manner prescribed by the Dutch government. In most cases, a less invasive form of identity verification will suffice. The use of the aforementioned rights is free of charge, except in cases of misuse.

We would like to point out that the aforementioned rights are not absolute rights. There may be circumstances that prevent Ageworth Clinics from complying with a specific request. We will assess each request on its own merits. If we cannot or are unable to comply with a specific request, we will of course inform you of this with reasons.

8.Obligations

Ageworth Clinics processes your personal data, as indicated, on the basis of a legitimate interest. Your personal data will never be sold to a third party.

The data that are mandatory to provide are the minimum required personal data necessary for the provision of services. If you do not provide us with these mandatory data, Ageworth Clinics cannot offer the services (properly).

If it is necessary to share your data with other parties, your consent will always be requested through an amendment to our privacy statement. We always communicate changes via the website of Ageworth Clinics.

Ageworth Clinics reserves the right to disclose data when required by law or when Ageworth Clinics deems it justified to comply with a legal request or process. We also aim to respect your right to privacy as much as possible in these cases.

If you have any further questions about our privacy statement, please feel free to contact the customer service of Ageworth Clinics using the contact details below.

Klantenservice@ageworth.com

Spacelab 9 l 3824 MR l Amersfoort

Chamber of Commerce Number (KvK): 73930474

Version December 2022

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