Privacy Statement LNGVTY

LNGVTY B.V. believes that the protection of personal data is essential. We therefore process your data with the utmost care. With this Privacy Statement, we inform you about how we handle personal data.

1. Who is responsible for processing your data?

In this Privacy Statement, LNGVTY B.V. (hereinafter “LNGVTY” or “we”) describes how it handles your personal data as controller.

2. What is personal data?

Personal data is information about an identified or identifiable natural person. Whether certain information should be qualified as personal data also depends on whether LNGVTY has (legal) means that can reasonably be expected to use to identify a data subject.

3. Personal data that we process

We process your personal data because you provide us with data yourself when entering into an agreement with us, or when you use our services through your employer. In doing so, we may provide information to service providers and other third parties that is necessary for our services (see section 7, sharing with third parties).

A) Information that is necessary to allow you to participate in the LNGVTY Health Monitoring program or to provide one of our separate products or other services LNGVTY offers various products and services. For example, you can participate in our Health Monitoring program [hyperlink to the information document or page of the website where this is being written about] or you can purchase various separate products or services such as a Dexa Scan [hyperlink to webpage and information letter] through our external partners. If you or your employer enters into an agreement with LNGVTY, we process the following personal data about you in order to provide our services: Your name, address, place of residence, date of birth, employer personnel attribute (if applicable), email address and telephone number, gender.

B) Data generated by your use of our services or purchasing our products

If you use LNGVTY services, purchase one of our products or otherwise have contact with us, we process the following (personal) data as part of our services - depending on the exact use you make of them:

  • Information that you use to access the LNGVTY Portal, such as your username, PIN, and password;
  • Your communication preferences and settings;
  • If applicable, data that we process in order to provide you with personal Health Monitoring advice, such as your preferences in which parts of the program you want to participate and whether, and if so to what extent, you want us to discuss the results of external tests and checks with you;
  • If applicable, data that we process to schedule an appointment for you with an external party in our network, such as your name, email address and telephone number;
  • If you have given explicit permission to do so, data that we obtain from third parties where you have had a check or test carried out as part of the Health Monitoring program or after purchasing our separate products or services, such as the results of the check or test or other information that you want us to share with you;
  • Browsing behavior, determined by our own observations or cookies (see also article 9 of this Privacy Statement);
  • Information related to your peripherals, such as a MAC address, IP address, or other number; Customer Satisfaction Data; Information about your use of our customer service.

4. Processing: principles and legitimate interests

The processing of personal data takes place on the following legal bases:

  • Consent;
  • Execution of an agreement with you;
  • Legal obligation;
  • Performance of a task in the public interest;
  • Legitimate interest of LNGVTY or a third party.

5. Purposes for processing personal data

When processing your personal data, we work carefully. We only use the information that is necessary for the service. LNGVTY processes your personal data for the purposes listed below. The number behind each goal corresponds to the basis set out in article 4 of this Privacy Statement.

A) Purposes for participating in the Health Monitoring program and providing one of the separate LNGVTY services or products

  • The request, processing and possible follow-up of the Health Monitoring program or the separate LNGVTY services or products, including making an appointment for you with one of the external parties that perform a test or check [basis 2];
  • Taking care of LNGVTY's administration for financial and tax obligations [basis 2 or 3]; Charging you and/or your employer for the costs of using the LNGVTY service or purchasing separate products [basis 2];
  • Communicating with and informing you and/or your employer and providing service (e.g. via the service desk) [basis 2 or 5];
  • Processing and reporting on services purchased from LNGVTY by you and/or your employer through management information. The information provided to your employer and the processing of personal data into management information is not directly traceable to you [basis 2 or 5];
  • Providing service to you and/or your employer, for example in the event of loss and theft of a product purchased separately [basis 2].

B) General purposes

  • Building and maintaining the customer relationship including maintaining a direct relationship between LNGVTY and its partners [basis: 2];
  • Fulfilling orders (including billing), processing them in financial administrations and logistical processing [basis: 2];
  • Providing customer service including service around purchasing services and products, dealing with complaints and requests [basis: 2];
  • In certain cases, maintaining communication with external parties belonging to our network in order to proactively contact us in the context of problems or complaints [basis: 2 or 5];
  • Carrying out market research, including measuring customer satisfaction, to improve our business operations, services and products [basis: 5];
  • (further) developing and improving new and existing products and services [basis: 5];
  • Complying with legal obligations, resolving disputes, and enforcing our rights and agreements [basis: 2, 3 or 5];

6. No processing of data from persons under the age of 16

We do not intend to collect information from persons under 16 years of age. We recommend that parents be involved in their children's (online) activities to prevent LNGVTY from processing their personal data. Our Health Monitoring Program and separate products and services are not available to people under 18 years of age.

7. Sharing with third parties

LNGVTY shares your personal data with third parties in, among others, the following cases and for associated reasons. The number behind each goal corresponds to the basis set out in article 4 of this Privacy Statement:

  • Your information such as name and employee number will be shared by LNGVTY with your employer if necessary, so that your employer can use this information to pay the bill for the service or product provided to you [basis: 2].
  • If necessary for the service, we share information such as your name, email address and telephone number with external parties in the LNGVTY network. We have concluded an agreement with these parties for this purpose [basis: 1];
  • If we are legally obliged or authorized to provide personal data to third parties [basis: 3];
  • If we suspect a violation of third party rights, criminal offences or abuse, we may provide personal data to third parties that have a legitimate interest in doing so or to bodies that serve the public interest. These can also be enforcement authorities, such as the Public Prosecutor's Office or supervisors [basis: 3, 4 or 5];
  • LNGVTY may also share your data with others for the execution of an agreement with you, or for legitimate business interests, such as keeping a central administration or customer service, and analyzing our services to you [basis: 5];
  • With parties that assist LNGVTY in its services and are not processors (such as accountants and (legal) advisors) [basis: 5];
  • For business purposes (such as the sale of business activities or shares or a reorganization) [basis: 5].

LNGVTY also uses services from third parties that act as “processors”, for example hosting service providers and research agencies, with the aim of conducting market research or customer satisfaction research. If these third parties are regarded as processors in accordance with applicable data protection laws, LNGVTY will make written agreements with these third parties. These service providers will only process personal data in accordance with the instructions and under the control of LNGVTY. If personal data is sent to a recipient abroad, this usually only happens to a recipient in a country that, according to the European Commission, offers an appropriate level of protection for personal data. If personal data is sent to a recipient in a country that does not offer an adequate level of protection, LNGVTY will ensure that the legally required safeguards are taken. If you would like further information about the transfer of your personal data to countries outside the European Economic Area, please contact the LNGVTY Program Coordinator (see article 11).

8. Storing your data

We will keep personal data for as long as necessary or permitted for the purposes described in this Privacy Statement and in accordance with applicable law. The criteria used to determine our storage period include:

  • The length of time we have an ongoing relationship with you and provide the services to you (for example, as long as you or your employer have an account with us or you or your employer continues to use our services);
  • Whether there is a legal obligation that we must comply with (for example, certain laws require us to keep our transactions for a certain period of time before we can delete them);
  • Whether storage is desirable in view of our legal position (such as with regard to limitation periods, disputes or investigations by regulatory authorities). If we think it may be good to keep your data longer than strictly necessary, even if this is in the context of our services, we will always ask for your permission in advance.

9. Mapping website visits

When you visit or use our website (s), services, applications, communication services (such as email) and tools, we may use cookies, web beacons, and other similar technologies to store information to personalize advertising and provide you with a better, faster, and safer customer experience. If you do not want cookies, you can indicate this. For more details about the use of cookies, please refer to our Cookie Statement [hyperlink]. On our website (s), you may find links to other websites. We are not responsible for the handling of your personal data by these websites. To do this, consult the privacy statement/Privacy Statement of the website you are visiting. To measure the business use of our website, we use the Transip service. This service shows us company names and addresses based on our visitors' IP addresses. The IP address is not included here.

10. Your rights, including the right to object

You have the right to know what personal data we process about you and to whom we have provided your personal data. If you have given your consent to the processing of your personal data, you also have the right to withdraw it. If you want to view, correct, update, limit or delete the personal data we process, object to the processing of personal data or direct marketing, or if you want to receive an electronic copy of your personal data to transfer it to another company (to the extent that this right to transfer data is provided to you by applicable law), please contact our customer service using the contact details set out in article 12. We request that you be as clear as possible in your request. possible to describe what personal data your request relates to. We will respond to your request as soon as reasonably practicable, but in any event within the time limits required by law. Finally, you have the right to file a complaint with the Data Protection Authority. You can only exercise your rights to the extent that the law grants you these rights. To ensure that a request has been made by you, we may ask you to include a copy of your ID with this request. We only ask for this if we consider it necessary to identify you and, in such a case, we request that you make the passport photo, MRZ (Machine Readable Zone; the strip with numbers at the bottom of the passport), the passport number and the Social Security Number (BSN) unrecognisable on this copy. We will destroy the copy of your ID immediately after we identify you.

11. Data security and protection

LNGVTY applies appropriate security measures to prevent misuse, loss, unauthorized access, unwanted disclosure and unauthorized modification as much as possible. LNGVTY has taken both technical and organizational measures to protect your personal data, such as applying encryption techniques. These security measures are reviewed periodically based on threats.

12. Contact

LNGVTY has its registered office in Hilversum and also has its office here. For questions and/or comments regarding this Privacy Statement, please contact: LNGVTY B.V. Attn: Personal data processing Herenstraat 12 By phone: +31 636000001 By e-mail: thomas@lngvty.health

13. Changes

The way in which we process personal data, and the composition or amount of data that we process, may change. That is why we reserve the right to amend this Privacy Statement. You will be notified of a change if necessary. This Privacy Statement always states the last date of change. This Privacy Statement was last revised on August 1, 2023.