PRIVACY POLICY, COOKIE POLICY AND TERMS AND CONDITIONS FOR PARTICIPATION ASPEN OSS B.V. / MOEDERS VOOR MOEDERS
Protecting the personal data and respecting the privacy of the visitors and users of our online platforms and (prospective) participants in our program is of great importance to Moeders voor Moeders (Mothers for Mothers), part of the Aspen Oss B.V. pharmaceutical company. That is why Moeders voor Moeders carefully processes and protects personal data. We do this by complying with the laws and regulations regarding the protection of personal data, such as the General Data Protection Regulation (GDPR).
We use this document to provide information about the data that we process regarding (prospective) participants, subscribers to email newsletters and visitors and users of our online platforms and other services such as online promotions, trade fairs and offers, contests and loyalty programs. In general, when you visit the online platforms and view the content, you can remain anonymous by not providing any personal data. If you disagree with this privacy policy, then we request that you not provide any information and not use the online platforms.
The terms “we”, “our” and “us” used in this privacy policy refer to Moeders voor Moeders, part of Aspen Oss B.V.
The term “personal data” is defined in the data protection legislation that is applicable in your country. It includes all information regarding an identified or identifiable natural person. This means any person who can be identified directly or indirectly by referring to an identifier such as a name, identification number, location data, online identifiers (for example, IP addresses, if they can be used to identify you) or one or more factors that are specific to the physical, physiological, genetic, intellectual, economic, cultural or social identity of that natural person.
In short, it concerns data that can be used to identify you based on the data itself or combined with other data that we have or that is available to us.
We collect and process personal data for the following purposes:
Moeders voor Moeders uses participants’ data for its own purposes and will only share this data with external parties and organizations that act on behalf of Moeders voor Moeders. This sharing of data is necessary, among other things, in order to faciliate visits to participants in their homes. To this end, Moeders voor Moeders only shares with consultants, transport companies and other service providers that information that is necessary for that visit. Each external party that works for Moeders voor Moeders signs a one-time confidentiality statement before starting its activities. The use of personal data by external parties and organizations is covered under agreements that require that personal data can only be used for the purpose for which the data has been made available and that the personal data is protected in an appropriate manner.
The website www.moedersvoormoeders.nl provides the option to subscribe to the Prénatal email newsletter after registration. This option only occurs upon the user’s own initiative by placing a check mark next to “Yes, I want to subscribe to the Prénatal newsletter”. A screen then appears with the following data already filled in: name, due date, zip code and email address. If “send” is clicked on, the data is sent directly to Prénatal. In any event, Moeders voor Moeders will not provide personal data to Prénatal without consent.
We can provide personal data to third parties without consent in special situations, such as, for example, legal requests from authorities, subpoenas or court orders, actions in order to detect or prevent damage or fraud, or actions in order to safeguard the security of our network and our services.
We can process your personal data into statistical or collected data so that you cannot be identified or identifiable on the basis of that data. We can use this collected data to conduct market research and analysis, including statistical research and statistical reports.
We use this technology particularly for collecting anonymous information about the use of our online platforms. For example:
We use this anonymous data to improve the content and functionality of our platforms and to consider areas and subjects for which there is interest so that we can focus our email updates there (for those who want to receive such emails). In this way, we can gain a better understanding, in general, of what visitors to our platforms are interested in and with that, we can improve our platforms and the products and services that we provide.
We strive to take appropriate technical and physical security measures in order to protect personal data that is sent, stored or otherwise processed by us against inadvertent or unlawful destruction, loss, modification, unauthorized disclosure or access in connection with our platforms. These measures include computer security and protected files and facilities. Moreover, our service providers are carefully selected and required to take appropriate protective measures. In certain areas, Aspen Oss B.V./Moeders voor Moeders uses the industry standard SSL encryption in order to protect data transfers. Most current browsers support the required level of security for using these areas.
In particular, we strive to take appropriate technical and organizational measures in order to guarantee a level of security that is appropriate in light of the risks, including, where applicable: (a) pseudonymization (for example, when data is separated from direct identification data so that it is impossible to link the data to an identity without additional information that is stored separately) and encryption, (b) guaranteeing the continued confidentiality, integrity, availability and resilience of systems and services that are used to process your personal data, (c) guaranteeing the possibility to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident, and (d) guaranteeing a process for the testing, assessing and evaluating of the effectiveness of technical and organizational security measures on a regular basis.
We can use cookies from time to time on our online platforms. Cookies are small text files that your web browser leaves on your hard disk in order to recognize you as a return user to our website(s), to keep track of your use on our website(s) and to offer targeted advertising. In this way, certain aspects of your visit to our website(s) can be personally tailored to you. Data collected from cookies in this manner is only used on the basis of collection. Unless a visitor himself/herself provides his/her identity to us, for example, by registering on our online platforms, providing information via an online form or sending us a message via the platforms, we will not know the identity of individual visitors. We can use cookies to store preferences, to register session information, to gather information about the preferences and interests of visitors to the website(s), to register previous activity on a website in order to better serve you when you return to our website(s), or to adjust the content on a web page based on information that you provide voluntarily.
The cookies that our websites can place can be divided into four categories:
We use Google Analytics, a web analysis service from Google Inc. (Google) on our website(s) and app. Google Analytics uses cookies, that is, small text files that are stored on your computer in order to enable the analysis of your use of websites. Information generated by the cookie about your use of our website(s) is usually sent to a Google server in the United States and stored there. If IP anonymization has been activated on this website, your IP address will first be truncated by Google and made anonymous within the Member States of the European Union or in other countries that are parties to the Agreement regarding the European Economic Area. Only in exceptional cases is a complete IP address sent to a Google server in the United States and truncated there.
Google will use this information on behalf of the owner of this website in order to evaluate your use of the website, prepare reports about the activity on the website and to provide extra services to the website administrator in connection with website and internet use. The IP address that is sent by your browser as part of Google Analytics will not be combined with other data by Google. You can block the storage of cookies through the settings in your browser software. However, keep in mind that you may not be able to fully use all of the functions on the website(s). In addition, you can prevent Google from collecting and processing data generated by the cookie about your use of the website(s) (including your IP address) by downloading and installing a browser plug-in via the following link: http://tools.google.com/dlpage/gaoptout?hl=en
We use Google Analytics on our websites with the extension “anonymizeIP ()”. IP addresses are truncated for further processing in order to prevent data from being directly related to individuals.
You can disable cookies through your internet browser settings. Consult your browser’s help function for information about disabling cookies. When you disable cookies, specific functions on our websites may not work properly.
Our social media channels and websites www.moedersvoormoeders.nl, www.berichtjeuitjebuik.nl and www.vriendinnenonderelkaar.nl contain hyperlinks to websites that we do not manage.
Although these websites have been carefully selected, we cannot bear any responsibility regarding the use of your data by these organizations. Please read the privacy policies, if present, of the websites that you visit.
We look forward to starting a dialogue with our participants and followers via the web and social media channels. The goal is to provide useful and relevant information and/or answer questions that have been posted on social media. For this purpose, we monitor the Internet, such as forums and social media channels like Facebook and blogs. We also make an effort to follow the feeds on these channels, participate and/or proactively follow up and answer individual, relevant questions and comments. We expressly reserve the right to not respond to every question or comment.
Therefore, no right can be derived from whether or not we give a substantive response. It is possible that Moeders voor Moeders will record (personal) data when participating in online initiatives and answering questions or responding to comments. Of course, this data will be processed in accordance with that which is stipulated in this document. We are not responsible for the handling of personal data by other participants via social media channels.
You can register for participation in Moeders voor Moeders up to and including week 11 of your pregnancy. In order to register, you can use the registration form on the website, call us by using the free information number or contact one of our consultants directly.
When you register, the following personal data will be requested and recorded: first name, last name, address, zip code, city, email address, first day of your last period, phone number and time when you are available. This data is stored in a database and sent to the consultant in the relevant region. She will then contact the prospective participant in order to make an appointment for a home visit.
During the home visit with the consultant, the prospective participant’s personal data will be entered on a paper registration form. The consultant will also present a question with reasons why a candidate may unexpectedly be unable to participate in the Moeders voor Moeders program. This question must be answered truthfully and confirmed with a signature. The answer to this question determines whether someone may participate. If this is the case, then the extra information obtained by the consultant can be added to the online database and this is then shared with the Moeders voor Moeders organization. The paper registration form is sent to the Moeders voor Moeders office in Oss (the same applies when a prospective participant is not allowed to participate).
Each participant will receive her personal login data via email. The participant can use this data to login to a protected environment on the Moeders voor Moeders website and arrange a number of matters relating to participation.
Personal data is recorded within the context of our service. This personal data refers explicitly to not only the data that a prospective participant shares with us on the online registration form, but also to the data that is added during the consultant’s home visit. By agreeing with the privacy policy, you explicitly provide consent with regard to the recording, processing and use by Moeders voor Moeders of the information you provided. The basic assumption is that providing personal information is not mandatory. You always have the choice to decide whether you share your personal data. However, in order to be able to participate in Moeders voor Moeders, you will have to provide personal data.
At the start of participation, active participants in Moeders voor Moeders receive a weekly email newsletter with information about the organization, current news, tips and facts, etc. You can always unsubscribe from this newsletter. When you unsubscribe from the email newsletter, we reserve the right to inform you via email of any changes regarding the participation process or other information that is important for you. We also reserve the right to ask you, as (former) participant, to cooperate in market research.
GEOGRAPHIC AREA
Participation in Moeders voor Moeders is only possible if you live in the Netherlands.
REGISTRATION AND PARTICIPATION
Registration for Moeders voor Moeders is possible starting from the moment your period is late up to and including week 11 of your pregnancy. This does not necessarily have to be determined by a midwife or gynecologist, your own estimate is sufficient. Participation in Moeders voor Moeders is possible starting from week 6 up to and including week 16 of your pregnancy (calculated starting from day 1 of your last menstruation) provided that the terms and conditions for participation are satisfied.
The website www.moedersvoormoeders.nl offers the option to submit a personal story. Moeders voor Moeders receives this story via email. When Moeders voor Moeders decides to publish the submitted story on the website www.moedersvoormoeders.nl or the blog www.vriendinnenonderelkaar.nl, then the person who submitted the story is always contacted first for approval.
The website www.moedersvoormoeders.nl offers the option to submit personal photos that Moeders voor Moeders may use for promotional purposes, such as, for example, in printed matter, advertisements and on the website. When submitting the photos, the sender must agree to a few terms and conditions by placing a check mark next to “Yes, I agree with the terms and conditions”.
Terms and Conditions:
All residents of the Netherlands can register for the newsletter “Berichtje uit je Buik” (Message from your Belly) at www.berichtjeuitjebuik.nl. When registering, the following personal data is requested and recorded: week of pregnancy (if you are expecting), email address, first and last name. This data is stored in a database within a secured management system. You can modify your data by registering again using the registration form on the website. The data in the database will then be overwritten automatically. Every email from Moeders voor Moeders contains the option to unsubscribe.
The Moeders voor Moeders app called “Sara” can be downloaded from the Appstore and Google Playstore. When using the app, one or more of the following data is stored on a central server, in the online database and/or on your own mobile device:
By using and installing the app, you give Moeders voor Moeders explicit consent to process your personal data (Article 6 paragraph 1 under a GDPR).
When the app is used, we collect and process personal data for the following purposes:
We store personal data as long as necessary for the purposes for which they were collected, as described above. The criteria that we apply in order to determine the storage periods for personal data include:
Personal data of participants in the Moeders voor Moeders program is stored electronically for five years. The paper registration form is carefully stored in a closed archive at Aspen Oss/Moeders voor Moeders and remains there for 20 years. In this way, we satisfy the legal (storage) obligations.
After a successful job application, when you begin to perform services for Moeders voor Moeders, your personal data will be transferred to your personal file and will be processed for the contract. If your job application was unsuccessful, we will store your personal data for a period that is in accordance with the applicable legislation, after we have notified you that your job application was not successful.
You have various rights in the context of the privacy legislation in your country. These can include (where applicable), among other things: the right to request access to the personal data we have about you, the right to rectification, including the correction by us of incorrect personal data, the right to request the limitation of processing personal data concerning you or to object to the processing of your personal data, the right to request the deletion of your personal data when it is no longer necessary for us to store it, the right to transfer data, including the right to obtain personal data in a standard machine-readable format under specific circumstances, for example, when our processing is based on consent; the right to object to automated decision-making, including profiling (if applicable), which may have legal consequences for you as a person or which may affect you considerably; and the right to withdraw your consent for any processing for which you previously provided. You can also file a complaint with a supervisory authority in the country where you live.
We believe it is important to be transparent about the way we handle your personal data. We want to contribute to that transparency through this document. Nevertheless, if you have questions about how we handle your personal data, please send an email to info@moedersvoormoeders.nl or a letter addressed to Aspen Oss B.V., Moeders voor Moeders, Postbus 98, 5340 AB in Oss.
If you want to know which personal data has been recorded about you, or you want to change data or have it deleted in accordance with the applicable regulations, please send an email to info@moedersvoormoeders.nl or a letter addressed to Aspen Oss B.V., Moeders voor Moeders, Postbus 98, 5340 AB in Oss, stating “access/change/delete personal data”.
In any event, remember to include your full name, address and city in your message. If we are unable to fully determine to which personal data your request for access, modification or deletion pertains, we may ask you to (further) specify your request. We will suspend the execution of your request until you have provided us with (additional) specifications. After executing your request, we will always send you a confirmation message. As soon as possible after receiving your request for that purpose, we will terminate the use of your data for the purposes to which you object and in the event of a legal request for deletion or modification of data, we will delete or modify the relevant personal data, unless and insofar as we are required by law to store the relevant personal data or if there are (other) urgent reasons that oppose deletion.
We reserve the right to make changes to this document. We therefore recommend that you check this document on a regular basis for an update to our privacy policy, cookie policy and terms and conditions for participation.
Questions
If you have questions about our privacy policy, our cookie policy and/or terms and conditions for participation, please contact: Aspen Oss B.V., Moeders voor Moeders
Postbus 98
5340 AB Oss
Email: info@moedersvoormoeders.nl
Last updated: December 2018