We take the protection of your personal data seriously and comply with the applicable legislation, including the General Data Protection Regulation (“GDPR”).
2. The party that processes your personal data
Belgian Medicines Verification Organisation vzw, with its registered office at Guido Gezellestraat 126, 1654 Beersel, Belgium, registered with the Crossroads Bank for Enterprises (KBO) under number 0675.740.701 (hereinafter “BeMVO” and “We”) is responsible as a Data Controller for the processing of your personal data on the NMVS and the Website.
3. Which personal data we process
- Category 1: We process the surname, first name, and contact details of the End Users of the NMVS (email, telephone number, address, etc.), as well as your capacity (pharmacist, etc.). We also process the name and contact details of the persons responsible at End Users (for example, the name and contact details of the pharmacist who is responsible within the pharmacy or the hospital). These data are processed by us because they are communicated to us for processing, for example at the moment you register on the NMVS or sign up for our Newsletter, at the moment an agreement is entered into between us and the producers or distributors of medicinal products or “Marketing Authorization Holders”, at the moment you register on the Arvato Development Portal, or because the End User or the organisation you are affiliated with has communicated these data to us for processing. These data may also be processed by us based on lists of the National Institute for Health and Disability Insurance (“RIZIV”), via the Federal Agency for Medicines and Health Products (“FAGG”), or the Federal Public Service (FOD) for Health.
4. Legal basis for the processing of your personal data
In addition to your consent, the necessity of complying with a statutory obligation (i.e. Directive 2011/62/EU relating to falsified medicinal products and the Delegated Regulation 2016/161/EU; hereinafter referred to as “Legislation relating to Falsified Medicinal Products”) is considered to be an additional legal basis for the processing of your personal data. This also applies, for example, for data we process based on information received through the RIZIV, the FAGG, or the FOD for Health.
Finally, the necessity of offering you the contractually agreed services (i.e. access to the NMVS) is considered to be an additional legal basis for the processing of your personal data (in other words: the performance of the agreement between us and you is also considered to be a legal basis).
5. To what end we process your personal data
We process your personal data to enable the End Users to gain access to the NMVS and to allow the NMVS to function in the best possible way (e.g. identification of End Users in every stage of the verification of medicinal products) and to inform you of updates and other information regarding the NMVS.
Amongst other things, we process your personal data
- For data of categories 1 and 3: To enable the NMVS to function in the best possible way, i.e. to ensure that every End User has been registered in a correct manner, including recording the personal data of points of contact or persons responsible at each End User. The NMVS ensures that the authenticity of a medicinal product is checked at several times. Every time a medicinal product is scanned by an End User (e.g. a pharmacist at the moment of delivery to the patient), the name and the IP address of the End User are processed as well. As a result, personal data of the person responsible within the End User may also be processed at that moment;
- For data of categories 1 and 2: To provide you with targeted information, such as sending emails and newsletters that may be of interest to you (e.g. information regarding new functionalities or particulars of our services; if, for example, you state that you are a pharmacist, we can send you newsletters or other information that is specifically tailored to pharmacists);
- For data of categories 3 and 4: To carry out analytical research in order to optimise our Website (in terms of both technology and content); as well as, based on anonymous data, mapping the preferences, interests, surfing behaviour, and backgrounds of the visitors to our Website (for more information with regard to anonymous data, please refer to “cookies” below)
- For data of categories 1 up to and including 4: To answer questions from End Users, partners, and competent authorities, and to manage the technical administration of the NMVS and our Website. This only applies in the context of the applicable Legislation relating to Falsified Medicinal Products.
Your personal data may be disclosed to and further processed by partners of BeMVO in the framework of the NMVS, e.g. partners authorised for operating verification systems for medicinal products in other EU member states (i.e. National Verification Organisations authorised in other EU member states), the umbrella organisation for verification of medicinal products in Europe (European Medicines Verification Organisation vzw/asbl), and our IT partner Arvato Systems GmbH. This only applies in the context of the applicable Legislation relating to Falsified Medicinal Products.
BeMVO will only disclose your personal data to employees who are themselves contractually bound by obligations of confidentiality.
In the event of (a suspicion of) serious violations of the law or the End User Terms & Conditions (Conditions of Use), we have the right to disclose your personal data to the competent judicial authorities or police services. We can also do this to protect our rights or those of a third party or to safeguard the security of the users of the NMVS.
6. For how long we retain your personal data
All personal data are retained for the period of time that is necessary for us to provide the service.
7. Right of access, correction, and objection
You have the right to obtain free access to your personal data at any time. You can do so by sending an email to firstname.lastname@example.org.
You also have the right to correct or alter your personal data if they are inaccurate, incomplete, or irrelevant, also by sending an email to email@example.com. In case of requests for access to or correction of your data we always request you to include a copy of your identity card to enable us to verify your identity before disclosing this information. You also have the right to transfer your personal data to another controller.
You have the right to object to the processing of your personal data. You can do so by sending an email to firstname.lastname@example.org (with a copy of your ID card attached). However, you cannot object to the processing of your personal data if this is necessary for the performance of the contractual obligations or in the context of the applicable Legislation relating to Falsified Medicinal Products.
You are at all times personally responsible for the accuracy of the data you communicate to us.
8. Contact: information, questions or complaints
9. Data leaks
We take the security of your personal data seriously. We have taken adequate technical and organisational measures to protect your personal data.
We are, however, not liable for any direct or indirect damages arising from your incorrect or unlawful use of personal data. You yourself are responsible for correctly storing your password, access code and other login details, and for keeping these confidential. Any negligent or unlawful use of these data by the user or a third party (unless this was caused by a fault on our part) falls outside our responsibility and liability. In case of loss, theft, or unlawful use of your login details you must inform us as soon as possible.