Privacy Policy

This Privacy Policy is supplied electronically, paper format is available on request at support@minzehealth.com

Please read our Privacy Policy carefully as it explains the following:

• What personal information we collect from you and for which purpose (Section 3 and 4)
• The measures to safeguard the access to and the security of your Personal Data (Section 5);
• Your rights to access, rectify, erase your Personal Data and object to the processing of your Personal Data (Section 8).

In order to use the Products, you must first acknowledge and agree to our Privacy Policy. You cannot use the Products without first accepting our Privacy Policy.

For any further questions regarding the use and processing of your data, please contact Minze NV via support@minzehealth.com or at Minze NV, Lange Gasthuisstraat 29 bus 15, 2000 Antwerp (Belgium).

1. General

Minze provides Minze Uroflowmetry, a service intended to help a patient maintain a digital voiding diary and capture his uroflow curves without professional supervision (e.g. at their own home) or with professional supervision (e.g. in a conventional setting at a hospital). Minze Uroflowmetry consists of a measuring device (Minze Uroflowmeter), the Minze Flow Application and the Minze Clinician Portal (each as defined hereinafter and collectively the “Product”). The Minze Flow Application is used to collect data from the Minze Uroflowmeter and from manual input by the User. The Minze Flow Application sends the collected data to the Minze Clinician Portal. The Minze Clinician Portal is a web-based platform, used by the Clinician to process and visualize data coming from the Minze Uroflowmeter and the Minze Flow Application.

The Results (as defined hereinafter) are automatically transferred from the Minze Flow Application to the Minze Clinician Portal. You understand that this automatic transfer is only possible after correctly installing and using the Minze Flow Application. The Clinician will use the Results during diagnosis and treatment and for long-term monitoring for children and adults (female and male) suffering from voiding disorders. You understand that the interpretation of the Results and the follow-up of your physical condition is the sole responsibility of your Clinician.

Please note that the Results (as defined below) do not in any way constitute medical advice and Minze cannot be held liable for any consequences (including any damages) resulting from a misinterpretation of the Results by the User.

The Products shall only be used by Users in the European and other countries where CE certification applies.

Minze NV (“Minze”, “we”, “us”) recognizes and understands the importance of the privacy of its users (“Users”, “you”) and wants to respect their desire to store and access personal information in a private and secure manner. This Privacy Policy applies to our Minze Uroflowmeter, Minze Flow Application and Minze Clinician Portal (collectively the “Products”) and describes how Minze manages, stores and utilizes your Personal Data through its Products.

In order to use our Products, we require you to consent to the collection and processing of your Personal Data before you start using the Products. If you do not agree with any of the terms of this Privacy Policy, you may not use in any manner the Products.

Minze is committed to protecting the privacy of all of its Users’ Personal Data and providing a secure, user-controlled environment for the use of the Products in accordance with the General Data Protection Regulation. At the same time, you also share responsibility for maintaining privacy and security for example, by not allowing any third party to use your personal Account. Minze asks all Users to be responsible for safeguarding any authentication information and to immediately notify Minze of any unauthorized use of your personal Account.

Please read this Privacy Policy carefully (which is also available on our Website: www.minzehealth.com) so that you fully understand how we obtain and process your Personal Data. By accepting this Privacy Policy, you acknowledge and agree that you were adequately informed of the functioning and objectives of the Product.

2. Definitions

• “Account” means the personal account of the Clinician, which can be used to log in to the Minze Clinician Portal;
• “Data” means the data obtained by using the Minze Uroflowmeter, Minze Flow application and Minze Clinician Portal;
• “Minze Clinician Portal” means the portal made available to the Clinician, located at platform.minzehealth.com;
• “Minze Flow Application” means the mobile application that the User has to download on its mobile device and is intended (i) to collect voiding diary data and uroflow measurements and (ii) to transfer the collected data to the Minze Clinician Portal;
• “Patient” means the patient or person who is subject of diagnosis, treatment or long-term monitoring for voiding disorders or other by using the Product;
• “Clinician” means the doctor (or other medical expert) who is using the Product during diagnosis, treatment and long-term monitoring of children and adults (female and male) suffering from voiding disorders or other;
• “Product” or “Products” means the Minze Uroflowmeter, the Minze Flow Application and the Minze Clinician Portal;
• “Results” means the data that are collected by using the Minze Uroflowmeter and the Minze Flow Application and that are visualized in the Minze Clinician Portal;
• “Third Parties” means any natural or legal person or entity other than Minze;
• “User” means the patient or Clinician who is using the Product to collect Data of the Patient;
• “Website” means the website available at www.minzehealth.com.

3. Which data are collected?

The use of Minze Products requires Data to be collected. Those Data identifies you either directly or indirectly. The protection of your Data is at the heart of our confidentiality policy and we undertake to preserve them by applying the optimum level of security. We may collect several types of personal information from the Users of our Products, and store it on your mobile device and/or our server such as:

• Contact information (e.g. your name, postal address, e-mail address, and mobile or other telephone number);
• The profile data provided by you on your account such as your name and profile picture;
• Image data such as any images via the camera of your mobile device captured using the Application;
• Information in helpdesk support inquiries;
• Patient demographics such as date of birth and gender;
• Information about your health conditions, and other health related information (e.g. medicine usage);
• Information about your device, such as its model, unique device identifier and operating system version;
• Information collected by the Minze Uroflowmeter or the Minze Flow Application, such as measurement of voided volume, flow rate, uroflow curves, fluid intake, voiding diary entries and the local time of the measurement;
• Notification and tags you add to your measurements, including fluid intake, voiding diary entries and more;
• Payment information, if applicable, such as transaction identifiers and summary information that does not include credit card or bank account numbers (we do not collect or store financial account information);
• Web behaviour information such as information related to how the Users use the Products (e.g. browser type, domains, page views) collected through cookies and other automated technology (cfr. Section 6 “Cookies”).

Hereinafter collectively “Personal Data”. Your Personal Data will be stored on our servers located in the European Economic Area (AWS – Frankfurt – Germany). We would like to draw your attention to the fact that Personal Data consisting of patient medical data is also protected by medical secrecy rules.

4. How do we use your personal data?

Minze (i) collects, (ii) uses, (iii) maintains and (iv) may share your Personal Data provided by you or collected by us with its affiliates, parent companies or other related companies for all purposes necessary to ensure the proper functioning and operation of the User accounts and/or the proper functioning of the Products. These purposes may include (collectively the “Purpose”):

• Creating and managing your Account to use the Product;
• Providing information and allowing the User access to the Products;
• Diagnosing technical problems and managing technical support and processing inquiries concerning the Products;
• Contacting the Users by phone, email, text message or push notifications (if they are enabled) to (i) verify your account (ii) for information and operational purposes such as account management, instructions, alerts, reminders, customer service, system maintenance and others;
• Contacting the Users to (i) communicate about, and organize your participation in market research or (ii) obtaining testimonials;
• Commercializing the Products;
• Performing data analyses (including anonymization and aggregation of Personal Data) and using and sharing the resulting data to third parties for commercialization purposes;
• The operation, evaluation and improvement of the Products (including the development of additional products and/or services, enhancing and improving the current Products, analysis of our Products, quality control activities and performing internal business functions such as accounting and auditing);
• Protecting against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
• Complying with and enforcing any applicable legal obligations with respect to our Terms of Use and Privacy Policy.

Furthermore, you agree that Minze is free to access, retain, and disclose Personal Data in the following events:

• In order to be in compliance with any applicable legislation or regulations;
• If a law enforcement authority or other government official requests so;
• To enforce the Minze Terms of Use or Privacy Policy
• The investigation of any suspected or actual fraudulent or illegal activity and
• To protect your or our safety and/or rights.

By using the Products as a Patient, you acknowledge and explicitly agree that we disclose your Personal Data to your Clinician by giving him access through the Minze Clinician Portal to your personal data and recordings performed by the Product and your personal profile on your Account. Without prejudice to the foregoing, you acknowledge and understand that the processing of your Personal Data on the Product by Minze in accordance with this Privacy Policy occurs with the supervision of a qualified practitioner.

By using the Products, you acknowledge and explicitly agree that we may disclose certain information to vendors and service providers who help us provide the Products. Examples of these vendors and service providers include entities that process credit or debit card payments and provide analytics and web hosting services. Minze does not allow these third party vendors or service providers to publish or use your Personal Data, unless this is strictly necessary for the performance of the services.

You furthermore understand and agree that the technical processing and transmission of the Products, including your Personal Data, may involve (i) transmissions over various networks; and (ii) modifications to conform and adapt to technical requirements of connecting networks, or devices.

5. Security

Minze shall take appropriate administrative, technical and organizational measures against unauthorized or unlawful processing of any Personal Data or its accidental loss, destruction or damage, access, disclosure or use. Upon written request, Minze can provide you with a list of people of Minze that may have access to your Personal Data. These people have entered into confidentiality agreements prior to having been granted access to your Personal Data. In the event of and following discovery or notification of a breach of the security of the Personal Data, or access by an unauthorized person, Minze is required by law to notify the User if the breach is likely to affect your privacy.

6. Cookies

When using the Products, we may collect certain information by automated means, such as cookies (small text files stored in your browser) and similar technologies, including mobile application identifiers, to improve your experience of the Products, increase security, measure use and effectiveness of the Products, identify and resolve issues and marketing purposes. We may also use cookies and other automated means for purposes such as management our Products and other aspects of the commercialization of our business. The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system version, information on actions taken on our Products (such as usage, activity logs and click-throughs), and dates and times of visits. Log data is promptly deleted on a regular basis. You can control cookies through your browser settings and other tools. Your device may offer you control over the use of cookies or other technologies when you use the Products. For example, you may be able to set your device or browser to disable, clear, reset or block the use of cookies or similar technologies. Please note, however, that without cookies the Products may not work properly or you may not be able to use all of their features. Third parties, such as google analytics, may also use cookies to collect information about your activities on our Products to understand and continue improving the performance of our Products. Please check the relevant third party website for more information about their use of cookies. Where this site allows such cookies to be set or you access other websites from the Products using the links provided, the operators of these websites will use cookies in accordance with their own cookies policy, which may differ from ours. By continuing to use our Products, you consent to the placement of cookies and other automated means in your browser and device in accordance with this Privacy Policy.

7. Disclosure to Third Parties

In the event of full or partial merger with, or acquisition of all or part of Minze, we may transfer your Personal Data to a Third Party. In such event, Minze shall impose this Third Party to use any Personal Data strictly consistent with this Privacy Policy. Other than as set out in this Privacy Policy, we shall not sell or otherwise disclose your Personal Data to Third Parties without obtaining your prior explicit consent unless this is necessary for the purposes set out in this Privacy Policy or unless we are required to do so by law. We may also share Personal Data with Third Party service providers who help us to provide, understand, commercialize and improve our Products. We do not authorize these Third Party service providers to use or disclose your Personal Data except as strictly necessary to perform any services under our supervision or to comply with applicable legislation. We seek to provide any such Third Party service provider with only the Personal Data they need to perform their specific function. In any event, such Third Party service providers shall be obliged to treat your Personal Data in accordance with this Privacy Policy. However, Minze cannot be held liable for any damages, whether direct or indirect, that may result from the misuse of your Personal Data by such Third Party service providers.

Minze may also share Personal Data with certain Third Parties, such as your Clinician. After the transfer of the Personal Data, this Third Party shall be further responsible for taking appropriate administrative, technical and organizational measures against unauthorized or unlawful processing of any Personal Data or its accidental loss, destruction or damage, access, disclosure or use.

8. Your rights

In order to exercise your rights mentioned below or for any other question regarding this Privacy Policy, we request you to contact us at dpo@minzehealth.com or in writing to Minze NV, Lange Gasthuisstraat 29 bus 15, 2000 Antwerp (Belgium), to the attention of Gilles Tas. Please provide us with a copy of your ID card or other form of identification. Minze will take all necessary measures, within a reasonable delay and at least within 30 days after filing your request, to provide you with the requested information

• 8.1. Right of access and copy

  If you are concerned or have any questions about your Personal Data, you have the right to request access to the Personal Data we hold or process about you. We will then provide you with information about the data that are being processed, on the source of those data, the purpose of processing the data and on who has access to the data. If necessary, a copy of your data can be provided to you.

• 8.2. Right of rectification and right of erasure

  You have the right to request us free of charge to correct, erase or block any inaccuracies in your Personal Data if such Personal Data would be incomplete, inaccurate or processed unlawfully. Please note that you can change your account information in the Minze Flow Application or Minze Clinician Portal at any time on the “settings” pages.

• 8.3. Right to transferability

  You may also request Minze at all times to directly transfer the Personal Data about you which are processed by way of automated processes pursuant to your consent or in performance of the Agreement, in machine-readable form to a different data processing controller (e.g. a physician). However, this only applies to Personal Data supplied by you or which we obtained through observation (e.g. via the sensor of your mobile device), not to data we have developed in-house.

• 8.4. Right not to be subject to individual decision-making

  You have the right to request not to be subjected to decision-making that is based on automated processing of your Personal Data, including profiling, without human intervention, if such decision-making could have legal implications for you or which could have a significant effect on you in a similar manner. In theory, Minze could perform profiling by establishing a health profile. However, no fully automated individual decisions are arrived at on the basis thereof. If you have any questions relating to specific automated processing operations by Minze, please feel free to contact us for more details at any time.

• 8.5. Right to withdraw your consent

  You are free to withdraw your consent for the processing of your Personal Data by Minze for one or several purposes at any time by definitively removing your Minze Flow Application and/or by notifying us thereof in writing by e-mail sent to support@minzehealth.com. In response, Minze shall immediately cease all processing of your Personal Data for purposes for which you have withdrawn your consent. However, the withdrawal shall have no impact on the validity of the processing operations, which Minze previously performed with your Personal Data.

• 8.6. Right to object against specific processing operations without your consent

  For some processing operations, Minze does not require your express consent. This relates to processing operations on the grounds of Minze’s vested interests (e.g. contacting you to invite you to take part in a marketing study). Nonetheless, you may request us in specific cases, and at all times in the event of direct marketing, to cease using your Personal Data for these purposes.

• 8.7. Right to erasure

  Furthermore, you are within your rights to request for your Personal Data held by Minze to be erased if:

  • you withdraw your consent and no further legal grounds exist for Minze to be permitted to process your Personal Data; or
  • you are of the opinion that your Personal Data do not fully serve or they are irrelevant with a view to the purpose of the processing of the Personal Data; or
  • the said Personal Data are kept on record for longer than permitted; or
  • your Personal Data are processed in a general unlawful sense.

• 8.8. Right to restricted processing

  If you are of the opinion that:

  • the Personal Data about you as processed by Minze are inaccurate; or
  • are being processed unlawful; or
  • are no longer relevant with a view to the purpose of the processing;

  However, if the Patient does not wish for these Personal Data to be erased by Minze, you can also ask us to process these Personal Data on a restricted basis for the time being. This means we still keep your Personal Data on record, but other than that, we shall only process your Personal Data subject to your consent or as part of a claim pursued before the courts or if the processing is necessary to protect the rights or other parties or for imperative reasons of public interest;

• 8.9. Right to complain

  You have the right to submit a complaint with a supervisory authority (for Belgium: the Data Protection Authority) if you believe that your Personal Data are not being processed by Minze in compliance with the applicable privacy laws and regulations. In that case, we would kindly ask you to contact us first to enable us to try and rectify the problem.

9. Data retention and deletion

We may retain information regarding you and your use of the Products, including Personal Data, for as long as reasonably needed to provide you with the Products and the uses described in this Privacy Policy. Please note that we retain your Personal Data even if you temporarily stop using the Application until you permanently delete the Application on your mobile device and notify us thereof. Upon notification, we may retain and continue to use and disclosure your Personal Data to Third Parties exclusively on a fully anonymized basis.

10. Updates or changes to our Privacy Policy

Occasionally, we may change or update this Privacy Policy to allow us to use or share your previously collected Personal Data for other purposes. If Minze would use your Personal Data in a manner materially different from that stated at the time of the collection, we will provide you with a notice on our Website, Clinician Portal and in our Minze Flow Application indicating that the Privacy Policy has been changed or updated and request you to agree with the updated or amended Privacy Policy.

11. Suspension

If Minze becomes aware or suspects, in its sole discretion, any violation by you of this Agreement or any other instructions, guidelines or policies (including but not limited to the Privacy Policy) issued by Minze, then Minze may suspend or limit your access to the Product. The duration of any suspension by Minze will be until you have cured the breach that caused such suspension or limitation.

12. Support

In case technical support is needed, Minze can be contacted via the following channels:

• Website helpdesk: https://support.minzehealth.com
• Email support: support@minzehealth.com

Minze assures to make all reasonable efforts to respond as quickly as possible to any inquiries of Users.

Data controller
Minze NV
Lange Gasthuisstraat 29 bus 15
2000 Antwerp
Belgium
https://www.minzehealth.com