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Privacy Policy

This Privacy Policy explains how OncoDNA SA (“OncoDNA”) collects and uses information from users of OncoDNA’s website (available at www.oncodna.com – the “Website”), as well as the purpose of such collection and use. OncoDNA is committed to ensure your privacy, will safeguard the information you supply and use it only in accordance with the following provisions, and in compliance with applicable privacy and personal data protection legislation.

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Privacy policy

Data Protection Officer

We have appointed a data protection officer for our company :
Charlotte Baugnée
Rue Louis Breguet 1
6041 Gosselies
Belgium
Tel : +32 (0) 71 18 35 00
E-Mail : dpo@oncodna.com

Data Controller

The legal entity responsible for the processing of your Personal Data is OncoDNA SA, a Belgian limited liability company, having its registered offices at Rue Louis Breguet 1, 6041 Charleroi, Belgium, registered with the Crossroads bank for enterprises under company number 0501.631.837, and referred to in this Privacy Policy as “OncoDNA”.

Categories of personal data processed, legal basis and purposes of processing

By accessing or using the Website, OncoDNA may process certain personal data relating to you, such as your first and family names, email address, subject and content of messages or forms that you sent to OncoDNA through the contact and/or the complaint form(s) on the Website.

The legal basis of processing is the Article 6, §1, f) of the Regulation (EU) 2016/679 of the European Parliament and of the Council 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, better known as General Data Protection Regulation (“GDPR”), namely legitimate interests pursued by OncoDNA.

You acknowledge and, where necessary, agree that these personal data may be collected and processed for the purposes of offering you the services available on the Website, contacting you and answering to your queries.

Protection of personal data

Steps will be taken to ensure that your personal data is accurate, kept up to date and not kept for longer than is necessary. Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to the data.

Transfer of personal data

You acknowledge and, where necessary, agree that OncoDNA may disclose your personal data to its sub-contractors for the above-mentioned purposes, both inside and outside the European Economic Area. You acknowledge that this may involve transfers of your personal data to countries that do not provide an adequate level of protection. Appropriate contractual measures will be taken to ensure the security of your personal data in compliance with the with applicable privacy and personal data protection legislation.

Personal Data retention period

OncoDNA will retain your Personal Data, collected and processed by OncoDNA in accordance with this Privacy Policy, for the time required to offer you the services available on the Website, to contact you and answer to your queries.

Website Analysis

Google Analytics

On our Website, we use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”). Google will analyze your use of our Website on our behalf. To this purpose we use, among others, the cookies described in more detail in the above table. The information collected by Google in connection with your use of our Website (e.g. the referring URL, our webpages visited by you, your browser type, your language settings, your operating system, your screen resolution) will be transmitted to a server of Google in the US, where it will be stored and analyzed. The respective results will then be made available to us in anonymized form. Your usage data will not be connected to your full IP address during this process. We have activated on our Website the IP anonymizing function offered by Google, which will delete the last 8 digits (type IPv4) or the last 80 bits (type IPv6) of your IP address. Moreover, Google is certified under the EU-US Privacy Shield, which ensures that an adequate level of data protection is maintained with respect to the processing of data by Google in the US.

You may revoke your consent to the use of web analysis at any time, either by downloading and installing the provided Google Browser Plugin or by administrating your consents in the above table, in which case an opt-out cookie will be placed. Both options will prevent the application of web analysis only as long as you use the browser on which you installed the plugin and do not delete the opt-out cookie.

Further information on Google Analytics is available in the Google Analytics Terms of Use, the Privacy and Data Protection Guidelines of Google Analytics and in the Google Privacy Policy.

 

Hotjar

We use Hotjar to track and analyze user behavior across our Website.  With Hotjar, we use the following functionalities :

  • Heatmap : Understand what users want, care about and do on ourWebsiteby visually representing their clicks, taps and scrolling behavior;

  • Visit recording : Eliminate guesswork with Recordings of real visitor behavior on our Website.

  • Conversion funnel : it allows to identify on which page and at which step most users of our Websiteare leaving the Website.

  • Form analysis : it allows to discover which fields take too long tofill, which are left blank, and why your users of our Websiteabandon the form and page.

  • Feedback polls : it allows to improve the performance and experience of our Website starts with understanding what the visitors want and what’s preventing them from achieving it.

  • Surveys : to build responsive surveys using an easy editor.

Chat system

On our Website, we use Intercom communication and messaging services as a chat system. Intercom services are used for the purposes to answer to your queries and to put you in contact with the relevant expert personnel or Official Distributor.

The legal basis is the Article 6, §1, f) of the Regulation (EU) 2016/679 of the European Parliament and of the Council 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, better known as General Data Protection Regulation (“GDPR”), namely legitimate interests pursued by OncoDNA.

Any information you submit to such chatbox is collected and processed under this Privacy Policy. By accessing and using this chatbox:
- you acknowledge and accept this Privacy Policy;
- you understand and agree that sensitive data (like health and genetic data) cannot be disclosed without the prior consent of the subject concerned. Please, wait until you are redirected by our Customer Care team to one of our experts prior to disclose sensitive data.

In addition, the recommendations provided by OncoDNA via the chat system do not constitute and are not intended to replace an independent healthcare professional’s judgment.

In the framework of OncoDNA commercial relationships with Official Distributors, OncoDNA may communicate certain information submitted by you, to the extent permitted under and in compliance with Applicable Laws, including Data Protection Laws, to an Official Distributor with respect to your location within the distribution zone(s) allocated to such Official Distributor, pursuant to the distribution agreements entered into between OncoDNA and the Official Distributor, in order to enable such Official Distributor to contact you with respect to OncoDNA Service likely to be of interest to you.

Cookies

What are cookies?

This Website uses so-called “cookies”. Cookies are small text files that are stored in the memory of your terminal via your browser. They store certain information (e.g. site settings) which your browser may (depending on the lifespan of the cookie) retransmit to us upon your next visit to our Website.

 

What cookies do we use?

We differentiate between two categories of cookies:

  • functional cookies, without which the functionality of our Website would be reduced,

  • and optional cookies used for website analysis and marketing purposes. The following tables contain a detailed description of the optional cookies we use:

 

Optional Cookies

Name

Purpose and content

Lifespan

Google Analytics

These cookies assign a randomly generated ID to your device, enabling us to recognize your device upon your next access. For details on website analysis please see the respective chapter below

2 years

Hotjar

These cookies are set once the user interacts with Hotjar polls or feedback surveys, in order to retain the user preferences. For details on Hotjar functionalities used by OncoDNA see the respective chapter below

1 year

Intercom

This cookie is used by the Intercom chat system as a session so that users can continue a chat as they move through the site.

1 week

 

Subject to your consent

We only use optional cookies if we have obtained your prior consent (Art. 6(1)(a) General Data Protection Regulation). Upon your first access to our Website, a banner will appear, asking you to give us your consent to the setting of optional cookies. If your consent is given, we will place a cookie on your computer and the banner will not appear again as long as the cookie is active. After expiration of the cookie’s lifespan, or if you actively delete the cookie, the banner will reappear upon your next visit to our Website and again ask for your consent.

 

How to prevent the setting of cookies

You can refuse, delete or block cookies at any time, via your browser, although some functionalities of the Website requiring the use of the cookie might no longer be available to you.

 

 

Your rights

In accordance with the GDPR, you have the right to:

  • Access your personal data, as collected and processed by OncoDNA

  • Request the rectification or erasure of personal data relating to you

  • Request the restriction of the processing related to your data or object to this processing;

  • Data portability, namely the right to receive the personal data related to you, which you have provided to a controller, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller;

  • Request that OncoDNA provides you a copy of the personal data undergoing processing. For any further copies requested, OncoDNA may charge a reasonable fee based on administrative costs.

To exercise these rights, please send an email to the Data Protection Officer dpo@oncodna.com together with a copy of your identity card or other identification document.

Moreover, you have the right to lodge a complaint before the Supervisory Authority, i.e. the Belgian Data Protection Authority, either by postal means at Rue de la Presse 35, 1000 Brussels, or by email at contact(at)apd-gba.be.

Amendment of Privacy Policy

We may update our Privacy Policy from time to time. Updates of our Privacy Policy will be published on our Website. Any amendments become effective upon publication on our Website. We therefore recommend that you regularly visit the site to keep yourself informed on possible updates.

Last update:

October 1st 2019