Privacy Policy

Updated on September 19th, 2022.

1. Parties and subject matter

Co-Medic (hereinafter "Promstr BV" or the "Processor"). E-Mail: [email protected]

Promstr BV establishes this Privacy Policy, which aims to transparently inform Users about the website hosted at the following address: https://www.co-medic.com, (hereinafter the "Site"), and about the way personal data are collected and processed by Promstr BV.

The term "User" refers to any user, whether natural or legal, who visits the Site or communicates with the Site in any way. In its capacity as data controller, Promstr BV determines all technical, legal and organizational means and purposes for the processing of Users' personal data. Promstr BV undertakes to take all necessary measures to ensure that the processing of personal data takes place in accordance with the Act of July 30, 2018 on the protection of natural persons with regard to the processing of personal data (hereinafter the "Act") and 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 and repealing Directive 95/46/EC (i.e. the General Data Protection Regulation (GDPR) or "GDPR"; hereinafter the "Regulation"). Promstr BV is free to choose a natural or legal person to process users' personal data at its request and on its behalf (hereinafter the "Processor" or "Subcontractor"). Where appropriate, Promstr BV undertakes to select a Processor that provides sufficient guarantees regarding the technical and organizational measures for the processing of personal data, in accordance with the Law and the Regulation.

2. Processing of personal data.

The use of the Site by Users may result in the collection of personal data. The processing of these data by Promstr BV, in its capacity as Processing Manager or by service providers acting in the name and on behalf of Promstr BV, is done in accordance with the Law and the Regulation. Personal data is processed by Promstr BV, in accordance with the purposes listed below, through the following methods:

  • Newsletter subscription form;
  • The use of cookies;
  • Sharing of free information such as flyers and brochures.

3. Purpose of processing personal data.

In accordance with Article 13 of the Regulation, the purposes of processing personal data are communicated to the User. Those purposes are the following:

  • Maintenance of the Site;
  • Improving, personalizing and expanding the Site;
  • Gathering insights into the use of the Site;
  • Developing new products, services, features and functionality;
  • Sending emails to You;
  • Searching for and preventing fraud.

4. Personal data that may be processed.

The User agrees that, during the visit and use of the Site, Promstr BV collects and processes the following personal data:

  • Name;
  • Address;
  • IP address;
  • E-mail address;
  • Telephone number.

Promstr BV collects and processes this personal data in accordance with the terms and principles described in this Privacy Policy.

By accessing and using the Site, the User declares that he/she has read and given his/her free, specific, informed and unambiguous consent to the processing of his/her personal data. This agreement relates to the contents of this Privacy Policy. This consent is an essential condition to perform certain actions on the Site or to allow the User to enter into a contractual relationship with Promstr BV. Any agreement binding Promstr BV and a User regarding the services and goods offered on the Site is subject to the User's acceptance of the Privacy Policy. The User agrees that the Processor, in accordance with the terms and principles contained in this Privacy Policy, collects and processes his/her personal data that he/she provides on the Site or in connection with the services offered by Promstr BV, for the purposes stated above. The User has the right to withdraw this consent at any time. The withdrawal of consent shall not affect the lawfulness of the processing based on the prior consent.

6. Retention period of the Users' personal data

In accordance with Article 13, paragraph 2 of the Regulation, the Controller shall retain personal data only for as long as is reasonably necessary for the purposes for which they are processed. In all cases, this duration shall not exceed ten years.

7. Recipients of data and disclosure to third parties

Personal data may be disclosed to employees, employees, subcontractors, processors or suppliers of Promstr BV insofar as adequate guarantees are provided for data security and insofar as they cooperate with Promstr BV for marketing the products or providing services. They act under the direct authority of Promstr BV, and in particular are responsible for collecting, processing or outsourcing this data. In all cases, the recipients of the data and those to whom the data is provided comply with the contents of this Privacy Policy. Promstr BV ensures that they process this data only for the intended purposes and in a discrete and secure manner. In the event that the data would be provided to third parties for direct marketing or prospecting purposes, the User will be informed in advance so that he or she can give prior and express consent to this use of personal data.

8. Rights of the Users

The User may exercise their rights at any time by sending a message by email to the following address: [email protected]

a. Right of access

In accordance with Article 15 of the Regulation, Promstr BV guarantees the User's right to access his personal data. The User has the right to access these personal data and the following information:

  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be provided;
  • in case the recipients are located in third countries or international organizations, the appropriate or suitable safeguards;
  • if possible, the proposed storage period for personal data or, if this is not possible, the criteria by which this period is determined;
  • the existence of automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the Regulation and, at least in such cases, relevant information on the underlying logic, as well as the significance and expected consequences of such processing for the data subject. The Controller may claim a reasonable fee based on the administrative costs for additional copies requested by the User. If the User makes this request electronically (e.g., via email address), the data will be provided in electronic form and for general use, unless the User requests otherwise. The copy of the data will be communicated to the User no later than one month after receipt of the request.

b. Right to rectification

Promstr BV guarantees the right to rectification and deletion of personal data to the User. In accordance with Article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User first makes the necessary changes himself from his user account, unless they cannot be made independently, in which case the request can be addressed to Promstr BV. In accordance with Article 19 of the Regulation, the controller shall notify any recipient to whom the personal data have been provided of any rectification of the personal data, unless such rectification proves impossible or requires disproportionate efforts. The controller shall provide the data subject with information about these recipients if requested by the data subject.

c. Right to erasure

The User has the right, in the cases mentioned in Article 17 of the Regulation, to obtain the erasure of his personal data as soon as possible. Where the Controller has disclosed the personal data and is obliged to erase them pursuant to the previous paragraph, the Controller, taking into account available technologies and implementation costs, shall take reasonable measures, including technical measures, to inform other controllers processing such personal data that the Data Subject has requested by such controllers to erase the connection with such personal data or a copy or reproduction thereof. The two preceding paragraphs shall not apply to the extent that such processing is necessary:

  • exercise the right to freedom of expression and information;
  • to comply with a legal obligation to process under Union law or the law of the Member State to which the controller is subject, or to carry out a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • the establishment, exercise or defense of legal claims. In accordance with Article 19 of the Regulation, the controller shall notify any recipient to whom the personal data have been disclosed of any erasure of personal data or any restriction of their processing, unless such disclosure proves impossible or involves a disproportionate effort. The controller shall provide the data subject with information about these recipients if requested by the data subject.

d. Right to restrict processing.

The User has the right to restrict the processing of his personal data in the cases specified in Article 18 of the Regulation. In accordance with Article 19 of the Regulation, the Controller shall notify any recipient to whom the personal data have been disclosed of any restriction on the processing carried out, unless such disclosure proves impossible or involves a disproportionate effort. The controller shall provide the data subject with information about these recipients if requested by the data subject.

e. Right to data portability

In accordance with Article 20 of the Regulation, Users have the right to receive from Promstr BV their personal data in a structured, commonly used and machine-readable format. Users have the right to transfer this data to another data controller without preventing Promstr BV from doing so, in the cases provided for in the Regulation. When the User exercises his right to data portability under the previous paragraph, he has the right to have personal data transferred directly from one processing controller to another, insofar as this is technically possible. The exercise of the right to data portability does not affect the right to erasure. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. The right to data portability does not affect the rights and freedoms of third parties.

f. Right to object and automated individual decision-making

The User has the right to object at any time to the processing of his/her personal data due to his/her specific situation, including the automation of data by Promstr BV. In accordance with Article 21 of the Regulation, Promstr BV will no longer process personal data unless there are legitimate and compelling reasons for the processing that override the interests and rights and freedoms of the User, or for the establishment, exercise or defense of legal rights. When processing personal data for prospecting purposes, the User has the right to object at any time to the processing of personal data concerning him/her for such prospecting purposes, including profiling insofar as it relates to such prospecting. If the Data Subject objects to the processing for prospecting purposes, the personal data will no longer be processed for that purpose.

g. Right to complain

The User has the right to lodge a complaint regarding the processing of his personal data by Promstr BV, to the Data Protection Authority competent for the Belgian territory. More information can be found on the website: https://www.gegevensbeschermingsautoriteit.be/. Complaints can be filed at the following addresses: Data Protection Authority

Drukpersstraat 35, 1000 Brussels

Tel. +32 2 274 48 00

Fax. +32 2 274 48 35

E-mail: [email protected]

The User may also file an action for cessation with the president of the court of first instance of his/her place of residence.

9. Cookies

When you visit our website, certain non-essential cookies may be installed on your end device with your consent.

10. Modification of Privacy Policy.

Promstr BV reserves the right to modify this Privacy Policy in order to comply with legal obligations in this regard. The User is therefore requested to regularly consult the Privacy Policy in order to be informed of any changes and modifications. Any such amendments will be posted on the Site or sent by email to ensure objectionability.

11. Governing Law and Jurisdiction.

This Privacy Policy is governed exclusively by Belgian law. Any dispute shall be submitted to the courts of the judicial district of the registered office of Promstr BV.

12. Contact

For any question or complaint regarding this Privacy Policy, the User may contact the Controller at the following address: [email protected].