Salvus Health | Privacy Policy

2-minute-read summary

We care about your privacy! That’s a fact!

Now, you want to know how we do not only talk the talk, but also walk the walk… But you find privacy policies long, boring and full of legalese.

That’s why we provide you with this 2 minute-read summary. This summary will provide you with the necessary information and will get you up to speed in no time on how we process your personal data.

What is there to know:

First of all, you always remain the sole owner of your data.

What information do we collect about you?

When you make an account, we collect some identification data such as your name, email address, phone number and address, as well as some health data through the measurements in the pharmacy.
Once your account is made, you can add more details about you and your lifestyle in the web-app at home.
When you have technical issues or questions about our services, we keep track of written communication with the Salvus Health Support team.
Finally, we use cookies to collect information about your use of our website.

Why do we collect this information?

To enable the booking of an appointment or consultation in the online calendar of pharmacies.
To offer you highly personalised health coaching, based on the information you share with us.
To improve our services and make sure you can make optimal use of the Salvus Health Services.
For scientific research and statistical purposes
To contact you and if wanted, keep you up to date about our services.

Who has access to your data?

Your personal data will never be sold or made available to other parties. You always remain the sole owner.
Only a specific part of the trustworthy Salvus Health team has access to the information you give us. Our entire team ensure the confidentiality of your data.
Only anonymized data - which means that you in no way can be identified - might be made available to other parties.

What do you control?

You can ask us at any moment to modify or erase your data. Just send us an email to info@salvus-health.com. Follow the procedure as set forth in our privacy policy under Article 5 of the Privacy Policy.
Also, you can always request a copy of all the information we collected about you by sending an email to the same address.

What do we do to protect your data?

We adopted all kinds of safety measures on a technical and an organizational level.
Your data is stored on a secured server within the EEA.
In order to improve our services, Salvus Health may use the data you provided us after creating an account. However, at all times, Salvus Health shall use this data in a GDPR-compliant form, using measures such as pseudonymisation or anonymisation where possible, for example when the data is used for scientific research and/or statistical purposes.
We implemented internal procedures to ensure the confidentiality of our IT-infrastructure and to make sure it is managed responsibly.

Want to know more: as a die-hard, we then invite you to read our entire Privacy Policy, where everything is explained in detail. You will love it!

Version 2.0 – 15 April 2022

Article 1 – GENERAL

Your privacy is very important to us. This privacy statement (hereinafter referred to as the “Privacy Policy”) is designed to inform you about how we handle your personal information, which is any information relating to an identified or identifiable person (hereinafter referred to as “Personal Data”), and how you can exercise control over that information. This policy applies specifically to customers and pharmacies, visitors of our website or other persons who contact us. Please read this Privacy Policy carefully as it contains your rights and obligations towards Salvus Health (hereinafter also referred to as “Salvus Health” or “We”).
Our Privacy Policy can be subject to future amendment and modification. In this event, We will notify you with an invite to take a look at these changes, whom We will clearly indicate in the Privacy Policy.
Salvus Health, with registered office in Belgium, Begijnenvest 14/22, 2000 Antwerp, registered within the Crossroads bank for Enterprises under number 0741.808.191, and available via salvus-health.com (hereinafter referred to as the “Website”); takes responsibility for the processing of your Personal Data on the application and Website as a “Data Controller”.
The collection and processing of Personal Data is governed by strict conditions, enforced by the law. Salvus Health acts in accordance with :
1. the EU Regulation of 2016 concerning the protection of individuals with regards to the processing of Personal Data, regarding the free movement of such data and repealing Directive 95/46/EC; and/or
2. all (future) Belgian laws regarding the implementation of this Regulation.
This Privacy Policy is applicable, inter alia, to how We handle your Personal Data through our ‘’Services’’ being the designated definition in this Privacy Policy for the following services, but not limited to: booking appointments and consultations in the online calendar of pharmacies, for providing highly personalised health recommendations based on weight, blood pressure, blood oxygen saturation levels, heart rate and eventually surrounding circumstances which we can analyse based on the measurements and input you provide, and the services following and linked to our Website, as well as the improvement of these services.
Salvus Health is not intended for use by young people under the age of 18. In case Salvus Health would be used by someone under the age of 18, you must have the power of an attorney or a parent/guardian before using Salvus Health.
If you want to use our Services, We will first need your express consent (opt-in) of this Privacy Policy. This means you approve of how We collect, use and process your Personal Data.
You are not obliged to provide us with your Personal Data, however you must understand that We are not able to deliver you the Services in case you refuse to provide us with certain Personal Data.
Also, you remain the owner of your Personal Data at all times. Salvus Health only uses your Personal Data to provide the Services to you. To be able to improve the Services, Salvus Health can possibly fulfil big data analysis with Your Personal Data.

Article 2 – COLLECTED PERSONAL DATA

Salvus Health may collect Personal Data to that is provided by you or by third parties to the extent necessary or useful for the operation of our Services. Such information may consist of:

	Data	Details	Context
Category 1	Your user data	Information concerning your Salvus Health account, such as your first name, name, e-mail address and gender, as well as password. Information concerning your appointment in the framework of the Use of our Services with regard to the booking of appointments,	by filling in the subscription form. By booking an appointment with the relevant pharmacy
Category 2	Your health data	Information regarding your health status and other health-related information, consisting of: emotional state (illness, fatigue, anger and/or stress), weight, BMI, blood pressure, blood oxygen saturation level, heart rate, pregnancy, sports, blood group, belly circumference, height, ethnicity, whether or not you have smoked and/or drunk.	by filling in questionnaires. by using the self-tests with the blood pressure monitor, scale and saturation meter.
Category 3	Your communications through our Services	Information about the communication you had with Salvus Health or through the Services, e.g. when you had a problem with the Services and asked for support or when you communicate with us via e-mail, telephone or in any other way.	in response to questions to the helpdesk.
Category 4	Your usage of our Services	Information about your actions related to the In-Pharmacy App when You are not yet registered or logged in into your Account (such as usage, activity logs and click-throughs), domains, page views and device features (see Article 8).	by placing Google Analytics cookie (see Article 8).
Category 5	Your consent concerning our newsletters,	Information to be able to provide you with our newsletter, such as name, family name and e-mail address.	By subscribing for our newsletter.
Category 6	The Personal Data shared with us by the respective(s) pharmacy or pharmacies when the respective pharmacy completes your profile on the Salvus Health platform	Your contact details Potential medical data	By consenting and agreeing at the pharmacy to share your Personal Data which was provided by you to the relevant pharmacy when the relevant pharmacy completes your profile on the Salvus Health platform.

Article 3 – PURPOSES OF THE PROCESSING OF DATA

Salvus Health collects and processes your Personal Data primarily (but not limited) to enable booking appointments and consultations in the online calendar of pharmacies and to provide personalised recommendations based on your blood pressure, weight, blood oxygen saturation levels and heart rate. That being said, We will only use your Personal Data for the following purposes:

3.1 General purposes

	Legal Basis	Purpose
Category 1	Execution of the agreement and when necessary your explicit consent.	User data will be processed by Salvus Health to ensure that you can make optimal use of the Services in accordance with the execution of the agreement. When you book an appointment or consultation in the online calendar of a pharmacy, you will provide us your consent and authorisation on processing your phone number, e-mail address, name and postal code. You will receive an e-mail to confirm your appointment.
Category 2	Execution of the agreement and explicit consent	Health related information will be processed by Salvus Health in such a way that you are able to use the Services in accordance with the execution of the agreement, subject to your express prior consent.
Category 3	Execution of the agreement	Communications through our Services will be processed by Salvus Health to ensure that you can make optimal use of the Services in accordance with the execution of the agreement.
Category 4	Legitimate interest	Usage of our Services will be used by Salvus Health to maintain the security of the Website and/or Services and to improve it, as well as to create statistics based on a ''legitimate interest'' of Salvus Health to improve the Website and/or Services.
Category 5	Consent and legitimate interest	When you subscribe to our newsletter, you will be included in our mailing list and will receive our newsletter. At any moment you can unsubscribe from the newsletter by clicking the unsubscribe-link, included in every e-mail communication.
Category 6	Execution of the agreement and legitimate interest	When a pharmacist adds additional Personal Data to your profile (for which the pharmacist has received from you consent or even your authorisation), you will receive an e-mail from Salvus Health to confirm that this data will be added to your full profile. At any moment you can opt-out and refuse that this data will be added to your full profile.

Scientific research or statistical purposes. Your Personal Data can be processed for scientific research purposes or statistical purposes in an GDPR-compliant way.

As stated above, all above-mentioned categories of Personal Data can be processed by performing big data analyses with a view to improving and complementing our Services.

3.2 Transfer to third parties

Salvus Health will not sell, rent, distribute or otherwise make your Personal Data commercially available to third parties, except as provided in this Privacy Policy, or when you have given your express prior consent.

Salvus Health has taken all legal and technical precautions to prevent unauthorized access and use.

Disclosure of Personal Data by Salvus Health

Salvus Health shall not disclose any of the Personal Data to third parties unless it is necessary in the context of providing proper functionality of the Services and optimizing them. If it is necessary that Salvus Health discloses the Personal Data to third parties in this context, the third party is required to use the Personal Data according to the provisions of this Privacy Policy.

Salvus Health use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Exceptions from nondisclosure rule

Notwithstanding the foregoing, it is however possible that Salvus Health discloses the Personal Data:

to the competent authorities (i) if Salvus Health is obliged to do so under the law or under legal or future legal proceedings and (ii) to safeguard and defend Salvus Health’s rights;
if Salvus Health, or the majority of its assets, are taken over by a third party, in which case the Personal Data shall be one of the transferred assets;
in all other cases, Salvus Health will not sell, hire out or pass on the Personal Data to third parties, except when it (i) has obtained permission of a data subject and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of the Personal Data.

Article 4 - DURATION OF THE PROCESSING

We will store and process your Personal Data for the period we’re legally permitted to do so, or for as long as this is essential for the purposes of the processing, as well as the contractual relationship between you and Salvus Health.

You have at any time the possibility to stop using the Services. However, if you no longer use Salvus Health, Salvus Health will contact you from time to time (= at least once every 2 years) to ask if you want us to keep storing your Personal Data.

If Salvus Health is no longer able to keep track of your Personal Data, it will be sent to you electronically and in the format normally used.

If you do not exercise your right of deletion, your Personal Data will be kept for the following periods:

Category	Personal Data	Retention period
Category 1	Your user data	We will keep your user details for as long as your account is active and for the next 2 years;
Category 2	Your health data	We will keep your health data for as long as your account is active and for the next 2 years, as it contains medical information that may be important to you in the future;
Category 3	Your communications through our Services	We keep your communications through our Services for as long as your account is active and for the next 2 years.
Category 4	Your usage of our Services	We keep track of your use of our Services for as long as your account is active and for the next 3 years for which it is essential to ensure the security of our Services.
Category 5	Your consent concerning our newsletters,	Your e-mail address will be kept for as long as you wish to receive the newsletter.
Category 6	The Personal Data shared with us by the respective(s) pharmacy or pharmacies when the respective pharmacy completes your profile on the Salvus Health platform

However, we may be under a legal obligation to hold on to some data for longer or we may need your Personal Data to continue to perform our contractual obligations towards you, in which case we may have to hold on to your Personal Data to for as long as we legally or contractually need to.

Article 5 – YOUR RIGHTS

5.1 Right of access and right to obtain a copy

You have the right to freely obtain at any moment access to your Personal Data, as well as to be informed about the purpose of the processing by Salvus Health.

5.2 Right to rectification, erasure or restriction

You have the choice to share your Personal Data with Salvus Health.

You always have the right to ask us to rectify your Personal Data.

You can also request the processing of your Personal Data to be restricted if you think that your Personal Data is inaccurate and you subsequently notified us about this.

In addition, you have the right to ask Salvus Health to erase your Personal Data in as far we were not able to anonymize it, meaning you can exercise your right to be forgotten.

Furthermore, you acknowledge that a refusal to share Personal Data or a request to erase Personal Data will make the delivery of several Services impossible.

5.3. Right to object:

You have the right to object to the processing of your Personal Data when you have serious and legitimate reasons to do so.

You also have the right to object to the use of your Personal Data for purposes of direct marketing. In such case specific reasoning will not be requested.

5.4. Right to data portability:

You have the right to obtain your Personal Data which is processed by Salvus Health in a structured, commonly used format and/or to transfer this Personal Data to another data controller.

5.5. Right to withdraw consent:

When the processing is based on prior consent you have the right to withdraw this consent.

5.6. Automated decisions and profiling:

You have the right to request us not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. The processing of your Personal Data does not include profiling, nor shall you be subjected to automated decisions.

5.7 Exercising your rights:

You can exercise your rights by submitting a written request, together with a copy of your identification and/or documentation via the contact form on the Website: https://www.salvus-health.com/en/contact-us or via e-mail addressed to info@salvus-health.com.

Or by mail to,

Salvus Health

Lange Gasthuisstraat 29/001

2000 Antwerp

Belgium

5.8. Right to file a complaint:

If you are or were residing in the EU at the time of processing your Personal Data, and you feel unhappy about how We handled your privacy requests (which we truly hope won’t be the case), you may of course always lodge a complaint with the Belgian Data Protection Authority, which is Salvus Healths supervisory authority. However, We request that you first report them to us using the contact details mentioned above. In this way We can reach an amicable solution in mutual consultation.

If, after this notification, you are still not satisfied with the processing of your Personal Data by Salvus Health, you can still file a complaint with the Belgian Data Protection Authority:

Gegevensbeschermingsautoriteit / Data Protection Authority

Drukpersstraat 35,

1000 Brussels,

Tel +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35,

e-mail: contact(at)apd-gba.be

However, you are always free to contact your own European or EU-vested authority thereto.

This does not affect a procedure before the civil court.

If you have suffered damages caused by the processing of your Personal Data, you can file a claim for damages.

Article 6 – SAFETY AND CONFIDENTIALITY

We have adopted safety measures which are suited on both a technical and an organizational level to avoid the destruction, the loss, the forgery, the adjustment, the non-authorised access or the notification of the Personal Data by accident to a third party, as well as the non-authorised processing of these Personal Data. Nevertheless, if these events would occur and would affect your Personal Data, Salvus Health will inform you of the breach without undue delay, including a summary description of the potential impact and a recommendation on measures to mitigate the possible adverse effects of the breach.

Salvus Health shall not be liable in any way for direct or indirect damages caused by a wrongfully or improper use of the Personal Data by a third party.

At the same time, you also share responsibility for maintaining the privacy and security of the Services, for example: by not allowing any third party to have insight in the PDF provided by Salvus Health where your Personal Data and results are gathered.

You are solely responsible for the use of the Services on your devices, IP-address and identification data, as well as for its confidentiality.

In any case, you need to immediately notify Salvus Health of any unauthorized use of your personal account by sending an e-mail to info@salvus-health.com.

Article 7 – APPLICABLE LAW AND JURISDICTION

This Privacy Policy is managed, interpreted and executed in accordance with Belgian law which exclusively applies to every potential dispute.

The courts and tribunals of Antwerp have exclusive jurisdiction to settle any dispute arising out of or in connection to the interpretation or execution of the present Privacy Policy.

Article 8 – COOKIES

Salvus Health uses cookies during your use of their Services. For more information about the cookie, We refer to the Cookie Policy which entails more detailed information: www.salvus-health.com .

Regarding the Third Party Cookie of Google Analytics used in the In-Pharmacy Application on the tablet in the Pharmacy, no health data will be captured by Google Analytics, but only the clicks will be processed. In doing so, Google Analytics will only collect anonymized or at least strongly pseudonymised data.