Privacy statement Reverse Diabetes2 Now

Privacy Statement of Reverse Diabetes2 Now – October 2018

DEALING WITH CLIENT DATA
Reverse Diabetes2 Now processes your personal data carefully and in accordance with the law. We wish to provide you with the following information in this regard. The controller for the processing of personal data is the private limited company Reverse B.V., with its registered office in Amsterdam and listing in the Commercial Register under number 67392512 in Amsterdam. Reverse B.V. uses the trade names Keer Diabetes2 Om and Reverse Diabetes2 Now.

Purpose and legal basis for our processing
Reverse Diabetes2 Now processes personal data primarily for the purpose of providing services to clients to facilitate their participation in an information meeting and/or the group programme Reverse Diabetes2 Now, as well as for communication and invoicing. Reverse Diabetes2 Now also processes personal data for the purpose of its business operations, including recruiting and selecting personnel, administration, security, managing ICT systems, complying with legal obligations, archiving and handling requests, complaints, and disputes. It further processes personal data for marketing and communication purposes, including managing this website, sending e-mail newsletters, and organizing information meetings. The legal bases for the processing are entering into and performing the agreements that Reverse Diabetes2 Now concludes with you, fulfilling statutory obligations, and representing the legitimate interests of Reverse Diabetes2 Now, its clients, and third parties. To process health-related personal data (such as your medical history, blood values, and use of medication), Reverse Diabetes2 Now requests your explicit written consent. You can revoke your consent at any time. To send out the e-mail newsletter, invitations by e-mail for information meetings and/or other events, and to place cookies and web beacons, Reverse Diabetes2 Now also requests your consent. You can revoke your consent at any time.

Which personal data: origin
Among other things, Reverse Diabetes2 Now processes your name, address, postal code, town/city, telephone number, e-mail address, date of birth, citizen service number, insurance details, health-related personal data (such as your medical history, blood values, and use of medication), and other information necessary to provide its services or for any of the other purposes of processing referred to above. Reverse Diabetes2 Now obtains your medical and other personal data because you disclose them to it yourself, or because it obtains them from third parties, such as your primary practitioner or care provider, for the purpose of its services (or one of our other purposes of processing).

If you wish to, or are going to, participate in an information meeting
Before receiving the registration form, Reverse Diabetes2 Now will process only your name and contact details, so we can register you for the information meeting and send you the relevant information. After the information meeting, we use your data to contact you if you have expressed an interest in participating in the group programme. If you indicate that you are not interested, we will definitively remove your personal data from our systems within one month of your visit to the information meeting. If you have indicated when registering for the meeting that you wish to receive our newsletter, we will use and save your name and e-mail address for this purpose until you unsubscribe from the newsletter.

If you register to participate in the programme
If you use our registration form to participate in the programme, we will process these data:
• Personal data: such as your name, address, postal code, town/city, telephone number, e-mail address, date of birth, citizen service number, and insurance details.
• Special personal data: such as your medical history, certain blood values (HbA1c, fasting glucose, lipid profile, eGFR levels), and use of medication.
Sometimes, we will contact your primary practitioner (general practitioner/internal specialist) to discuss your health insofar as it relates to your possible participation in the Reverse Diabetes2 Now programme. We draw up a report of the contact and results of the consultation and also process these data.

If you participate in the group programme

0-6 MONTHS
During your participation, we process and retain your blood value measurements (HbA1c, fasting glucose, lipid profile, eGFR levels), use of medication, and discussion reports so we can monitor your progress as closely as possible and, if required, consult with your primary practitioner.

6-24 MONTHS
After you have participated in the programme (6-24 months), we use your data to inform you about the follow-up process and monitor your progress, possibly in consultation with your primary practitioner. We also offer your primary practitioner the opportunity to obtain advice from Reverse Diabetes2 Now.

ONLINE COMMUNITY
Using and sharing information on the online community within the group programme is at your own risk. The platform at mijn.keerdiabetesom.nl is a secure environment. Reverse Diabetes2 Now strives to make the platform as secure as possible and it cannot be held liable for the consequences of using this service.

After you complete the group programme
We do not retain your data for longer than is strictly necessary. After you complete the programme, we retain your data digitally for another five years so your primary practitioner can obtain advice, if required, to support you further. We have requested your express written consent to continue retaining your data. We do not retain other data for longer than necessary to comply with legal requirements. We periodically assess whether there is a valid reason for retaining data. If no such reason exists, our retention obligation ends and we destroy the data.

 

Cooperation with third parties
Reverse Diabetes2 Now Om currently works with care groups and the Louis Bolk Institute.

Your rights
You may request Reverse Diabetes2 Now to access your data. If these data are incorrect, incomplete, or irrelevant, you may request changes or additions. You may also object to the processing of these data and request Reverse Diabetes2 Now to delete your data. Reverse Diabetes2 Now’s processing of your personal data is based on your consent. You may withdraw this consent at any time. Withdrawing consent cannot have retroactive effect and therefore does not affect the lawfulness of any processing of your data before the withdrawal. You can lay claim to the above rights by e-mail or letter, using the contact details included under the ‘Contact’ paragraph below. Reverse Diabetes2 Now will make a decision within four weeks of receiving your request. In the unlikely event you are dissatisfied with how we handle your data, refer to the ‘Complaints procedure’ paragraph below.

Amendments
Reverse Diabetes2 Now reserves the right to amend this privacy statement at any time in accordance with applicable laws and regulations. Check the web page occasionally to stay informed of any changes.

Systems, or third party services used Reverse Diabetes2 Now uses MailChimp as a processor for its mailings. MailChimp is based in the United States and participates in Privacy Shield. For more information about MailChimp’s processing of personal data, refer to the MailChimp privacy policy. Reverse Diabetes2 Now uses the CRM system Sales Force as a processor for processing special personal data. Sales Force is based in the United States and participates in Privacy Shield. For more information about Sales Force’s processing of personal data, refer to the Sales Force privacy policy.

Complaintsprocedure
It is important to Reverse Diabetes2 Now’s organization and support teams that you are satisfied with the quality of our services. Although Reverse Diabetes2 Now tries to perform its best work and guarantee quality at both head office and the programme locations, you may be less than satisfied or even have a complaint. We take your complaint very seriously and are committed to finding a solution together.

What can you do?
• Compliments and suggestions can be passed on by e-mail or telephone.
• If you have a complaint about communication, participation, or support during participation in the programme, first contact the programme coordinator of your group. The programme coordinator will consider your complaint or problem with you and look for a solution. If you cannot solve the problem together, the complaint or problem will be referred to Reverse Diabetes2 Now’s Quality Manager, Lotte Schaffer. Lotte will contact you to discuss your complaint and find a solution together. Reverse Diabetes2 Now strives to ensure and improve quality where necessary.
• If you have complaints unrelated to the programme, you can contact us by e-mail or telephone (see contact details on the home page). Your message will then reach head office and be dealt with there. You will be contacted by telephone or e-mail.

Contact

For questions or comments about the processing of your personal data, and to exercise your aforementioned rights, send an e-mail to info@reversediabetes2now.com or call Reverse Diabetes2 Now’s head office on +31 (0)20-2217906.

Cookies, Google Analytics, and other data we process when you use the Reverse Diabetes2 Now website:

 

Cookies

  • A cookie is a text file that your browser stores on your computer’s hard drive. Most

web browsers automatically accept cookies, but you can usually change your browser settings to prevent that. If you do not wish to receive cookies, look under the Help function of your web browser to see how you can block all cookies. You can also be alerted before a cookie is stored.

  • These cookies may be placed when you visit our website:

 

Google Analytics

This website also uses cookies from Google Analytics. These cookies (‘_ga’, ‘_gat_ua’, and ‘_gid’) are used to keep track of general visitor data, such as the most frequently visited pages. The purpose of this is to optimize the layout of the website and the information presented on it. To ensure that information from cookies cannot be traced back to an individual, and cannot be viewed or used by Google, Reverse Diabetes2 Now has adopted measures in line with the Dutch Data Protection Authority’s manual on privacy-friendly settings for Google Analytics. A processing agreement has been concluded with Google. It has also been decided to mask the last octet of the IP address and disable data sharing. Reverse Diabetes2 Now uses no other Google services combined with the Google Analytics cookies. More information about these cookies can be found on the Google website.

 

MailChimp

Reverse Diabetes2 Now uses MailChimp to send e-mail newsletters and invitations to group meetings and other events. MailChimp places a cookie (‘AVESTA_ENVIRONMENT’) on the registration pages for newsletters and invitations. More information about these cookies can be found on the MailChimp website. E-mails sent with MailChimp also contain web beacons. A web beacon, also known as an internet tag, pixel tag, or clear GIF, is used to collect information about the use of the e-mails. Based on this information, Reverse Diabetes2 Now can analyse the use of the newsletter and invitations and optimize their design and content.