Privacy and Liability Policy
This Policy on privacy and liability represents the policy adopted and followed by Anticancer Fund (ACF). The ACF is a foundation of public utility with headquarters at Boechoutlaan 221, 1853 Strombeek-Bever, Belgium.
At the ACF we respect your privacy. We are committed to protecting and processing your personal data in strict compliance with data protection, and in full transparency. Take a minute to familiarise yourself with our policy. If you want to know more about the use and protection of your data or liability, please contact us at firstname.lastname@example.org.
Our commitments to protecting your privacy
We use your data to provide you with a unique support service in Europe.
We need to collect and store your data, such as your name, email address, and medical or payment details. We share your data with our trusted partners to provide you with better quality services.
We use the data you share with us and our partners to provide you with the information or services you requested.
And by listening to what you tell us, we can provide you with new and better services - online and offline.
We use your data to provide you with services that suit you better.
If you choose to receive marketing emails from ACF this means you will be the first to receive digital information regarding our fund, our research projects, our information service for patients, our activities and partnerships. Please note that in this case, your data will not be shared with these partners.
You have control of your data.
If you no longer wish to receive digital information from us, you can view and change your preferences at any time by clicking on the unsubscribe link at the bottom of each electronic communication.
Security is a priority for us.
Collecting, processing, storing and sharing your data securely is a priority. To provide you with our services, we share your data with our employees and make every effort to ensure that they are just as careful when processing your data.
If you want to obtain more information about the data we have about you or if you want to exercise your rights of rectification, portability, erasure of your data and your rights to object and limit processing, simply contact our Secretariat: email@example.com.
Our commitments to protecting your privacy
- Who is "responsible for processing"? Who is the "DPO" and preferred contact person? Who is involved?
- What data do we collect?
- For what purposes and on what legal basis is your data processed?
- How do we protect your data?
- Who is your data transferred to?
- How is your payment data managed?
- What are your rights and how can you exercise them?
- How long do we keep your data?
- Where can you make a complaint about the processing of your data by ACF?
1. Who is "responsible for processing"? Who is the "DPO" and preferred contact person? Who is concerned?
"Anticancer Fund" (hereinafter "ACF") is responsible for processing your personal data available to them. This means that we, ACF, determine the purposes and means of processing of this data and that we are your interlocutor and that of the supervisory authorities (the Belgian Data Protection Authority and the other European supervisory authorities) for any questions relating to its use.
We designated a Data Protection Officer (or "DPO") as a single point of contact within our organisation. Please contact firstname.lastname@example.org.
2. What data do we collect?
Your personal data (hereinafter "your data") is data that allows your identification either directly (data such as your name and surname allows your immediate identification), or indirectly (data such as your postal code, your phone number or your contract number allows your identification indirectly).
During our interactions with you, we may have to collect different data depending on the types of services concerned:
- Identification data (surname, first name, address, telephone number, e-mail address, etc.)
- Demographic data (such as gender, language, age)
- Professional data (such as profession, education)
- Special features of the patient (diagnosis, previous and planned treatments) and/or an dentifier of your medical records, such as an oncology report
- Recording of images and sounds
- Financial information, such as your credit/debit card number, bank account number or other billing information
- Preferred services, preferred modes of communication, etc.
- Geolocation data, including your IP address or physical location
- Information relating to navigation and behaviour on our website (including the pages viewed, the services viewed, searches performed, etc.)
In certain circumstances, we may also have to process particular categories of data, including data on patients with reduced mobility and/or decisional capacity as well as data on minors. We treat this data with special care.
a) Data of patients with reduced mobility
If you are a person with reduced mobility, we are could process some of your data as part of your request for informational services.
The processing of this data will only be done with your explicit prior consent and for the purposes to which you have consented. Access to this data is limited to those who need it for the performance of their tasks in relation to the above purpose.
- b) Patients with limited decisional capacity
If you are a patient with limited decisional capacity, we could process your data as part of your request for informational services.
The processing of this data will only be done with the explicit prior consent of you or your legal representative, where applicable, and for the purposes to which you have consented. Access to this data is limited to those who need it for the performance of their tasks in relation to the above purpose.
c) Data of minors
We could process data of a minor (age up to 18) as part of your request for informational services.
In addition to the identification data of the minor, ACF collects the identification data of the people who accompany or are responsible for the minor.
3. For what purposes and on what legal basis is your data processed?
We process your data for various purposes. For each type of processing, only the data relevant to achieving the purpose in question is processed. The processing consists of any operation (manual or automated) on any personal data.
In general, we use your data:
when we have your consent.
In this case, we process your data only for the purposes to which you have agreed, specified on the contact form on our website.
In particular, when exchanging information with ACF, you can explicitly consent via an opt-in to receiving communications from ACF and/or ACF partners (without transferring data to these partners). The ACF will only send you digital information on our activities if you consent thereto.
If you no longer wish to receive digital information, you can withdraw your consent at any time via the link at the bottom of the received electronic informaiton. You can find more information about this under the point Withdrawing your consent below.
as part of your question or donation to the ACF, to:
- Register and track the donations you made;
- Be able to deal with your question, message or request and to respond to it;
- Provide you with a fiscal certificate, if applicable.
We need to collect some of your data to answer to your question or request. If you choose not to share this data with us, it may be not possible to do this.
to comply with all legal and regulatory obligations to which we are subject, including:
- prevention and detection of terrorist offences and other serious forms of crime;
- implementation of legislation (such as the GDPR);
- tax and accounting obligations of ACF.
for purposes that are in our legitimate interest, in which case we seek to preserve a proportionate balance between our legitimate interest and respect for your privacy. In this context, your data can be processed in order to:
Protect ACF property;
Prevent abuse and fraud;
Disclose any abuse that may or may seriously prejudice the financial status, results and/or reputation of ACF;
Control the regularity of our operations;
Maintain safety on our premises;
Exercise, defend and preserve our rights, for example during litigation, as well as to compile the proof of a possible violation of our rights;
Manage and improve our relationship with you;
Continuously improve our website and our services (in particular by conducting satisfaction surveys and analysing data collected via cookies);
Conduct market research on our services or to develop new services;
Adjust our services that are available to you and adapt them to your needs, in particular by offering tailored services that could interest you based on the consumer profile created for you;
Analyse data, establish activity reports, frequency of visits and establish marketing profiles. We reassure you that this profiling is not intended for automated decision making with negative consequences for you.
4. How do we protect your data?
ACF is committed to maintaining the confidentiality and security of your data and to implementing appropriate security measures to prevent the loss, destruction, misuse, unintentional modification or disclosure of your data:
- By updating security measures as the technology evolves, as needed;
- By ensuring that your data are not accessible to unauthorised persons;
- By requesting a proof of identity before being able to provide you with any personal information about you as part of the security procedures;
- By performing periodic back-ups and storing this data on secure servers;
- By deleting or anonymising your data at the end of the legal period or if ACF does not need it any more for the purposes for which the personal data was collected.
5. Who is your data transferred to?
ACF undertakes not to sell or rent your data to third parties.
In order to provide certain services, ACF may communicate your data to third parties and to its processors.
If we are obliged to do so by virtue of a legal obligation or if a legitimate interest justifies it, ACF may transfer some of your data to third parties, among others, for the following purposes:
- To ACF partners (e.g. email management platform MailChimp) for the management and execution of your request to use our services.
- To the competent authorities, in the context of legal proceedings.
Processors on behalf of ACF
To manage our organization and help us provide you with certain products and services (for example: running our website), we use specialised partners who act as processors and are related contractually to us. They must then follow our instructions and respect the confidentiality of the data received on behalf of ACF and may under no circumstances use them for any purpose other than the performance of services on behalf of ACF.
ACF ensures that these subcontractors:
- Only have data that are necessary for the performance of their tasks and,
- undertake, with regard to ACF, to treat this data in a secure and confidential manner and to use them only for the performance of their tasks.
Exceptionally, in the context of certain processing activities, data may be transferred to processors located outside of the European Economic Area.
In this case, in accordance with the legislation in force, we take care to increase the level of security required in the contracts to be concluded with our subcontractors, to guarantee an adequate protection of your data.
If you wish, you can obtain a copy of the adapted contractual clauses by contacting our Secretariat: email@example.com.
6. How is your payment data managed?
All the financial transactions that you make (for example donations) including your means of payment are made on a secure server ('Secure Server Technology') which allows:
- Authentication that verifies your identity and ensures secure browsing and access to your data;
- Encryption that ensures the confidentiality of your data by modifying it so that it cannot be read by others;
- Data integrity that controls whether the transferred data has been tampered with.
Payment is made via the payment system of your financial institution. In this case, your payment-related financial data is managed by our bank and securely stored in our accounting system.
7. What are your rights and how can you exercise them?
In accordance with the law, you have a right of access, a right of rectification, a right of erasure and a right to portability of your data. In certain cases, you also have the right to object to or restrict its processing.
These rights can be exercised at any time.
- Right of access: You have the right to access the data concerning you and to receive a copy.
- Right of rectification: We take all reasonable steps to ensure that the data we hold is up-to-date and to delete data that is incorrect or no longer required for processing. If you find that your data is inaccurate or incomplete, you have the right to ask us to correct it.
- Right to erasure ("right to be forgotten"): in certain circumstances (for example when you withdraw your consent or when the processed data is no longer necessary for the purpose of the processing), you have the right to ask us to delete your data.
- Right to restrict the processing: you may request the limitation of the processing of your data, in which case your data will no longer be processed (but will be retained).
- Right to data portability: you have the right to the data you have provided being transmitted to you in a structured format, or being transmitted directly by ACF to another controller.
- Right of opposition:
- When the processing of your data is based on a legitimate interest, you have the right to object to it at any time. However, be aware that in this case, ACF has the right to present you with its legitimate reasons justifying the continuation of processing.
- You always have the right to object, at any time and without charge, to the processing of your data in the context of direct marketing and no exception can be opposed by ACF. It also includes the right to object to profiling as it relates to direct marketing.
Withdrawing your consent
When the processing by ACF is based on your consent, you can withdraw it at any time. This withdrawal will not affect the legality of the processing of your data during the period preceding your withdrawal of consent.
In the context of direct mailings, this means that you can unsubscribe at any time from the digital information you receive and other ACF communications. You will be put in "opt-out". You can unsubscribe by contacting us at firstname.lastname@example.org or by clicking on the unsubscribe link at the bottom of each email.
However, please note that when you exercise your right to object to the sending of direct mailings, this only applies to the given e-mail address. If you receive mailings on several e-mail addresses, the unsubscription procedure must be repeated as many times as necessary, either via email@example.com or via the "unsubscribe" link in each e-mail. If you unsubscribe by post, you will need to specify the e-mail addresses you want to disable.
Who can you contact?
To exercise your rights, simply contact our Secretariat (firstname.lastname@example.org).
When you send us an application relating to your rights, please provide us with your full contact details (name, surname, e-mailaddress(es), full postal address) and please attach copy of the front and back of your identity card to prevent abuse and to ensure the security of your data.
8. How long do we keep your data?
When your data is collected based on your consent, we use it only until you withdraw your consent. From the withdrawal of your consent, your data will be kept for the minimum amount of time necessary to accomplish the necessary technical measures to delete or anonymise your data.
When your data is used to provide you with our services (e.g. insight into your medical file, responding to your questions and requests, make a donation, etc.), this data is kept for a reasonable period limited to the accomplishment of the objective pursued during its collection, including for the minimum amount of time necessary to perform the technical measures necessary to delete or anonymise your data.
In any case, your data is kept for the statutory limitation period or any other period of retention that would be required by law.
When you use our website, we place "cookies" on your computer. A "cookie" is a small file sent by our server to the hard disk of your computer, tablet or smartphone that identifies your navigation device and collects certain personal data.
We use different types of cookies:
"Strictly necessary cookies and functional cookies": for instance, they allow us to identify your country and the language you prefer to use, to make the use of our site as simple and pleasant as possible;
"Performance cookies": they allow us to collect traffic statistics from our site to make it more user-friendly and to offer content better suited to your needs;
"Commercial cookies": they allow us to propose services to you that are tailored to your interests. However, this type of "cookie" will only be installed on your computer if you have consented.
You may refuse to install "cookies" on your computer, but such a refusal may result in decreased functionality or slow-down, or may even prevent access to certain services on the site.
10. Where can you make a complaint about the processing of your data by ACF?
If you believe that there is a violation of the privacy legislation, you have the right to lodge a complaint about the processing of your data with the Data Protection Authority, whose contact details are as follows:
Data Protection Authority
Tel: +32 2 274 48 00
Patients and their loved ones regularly ask the ACF questions on their treatment (read more). If we respond by providing information, that information is not intended as a second opinion or as medical advice. The Anticancer Fund, any of its employees and/or any of its partners will always proceed from the information you have provided, with the intention being to make the scientific information concerning your diagnosis and treatment understandable, allowing you to engage in the conversation with the team treating you in a reasonably informed manner.
In view of the fact that the ACF does not deal with your complete medical file, nor is it available to it, and that our doctors are not acting as your treating physician, the information provided to you will always be non-binding and for the purpose of complementing the information already provided to you, and the actual assessment thereof must always be performed by the team treating you. Consequently, the Anticancer Fund, any of its employees and/or any of its partners cannot be held liable in any manner whatsoever for, for example but not limited to, the information it provides, including any options for treatment or clinical examinations, the results (or lack) thereof, and in a general sense all that it does for you, in an entirely complementary and non-binding manner, on the basis of the information available to it.
It is your responsibility to, should you wish to do so, discuss with your treating physician the relevant information provided by the Anticancer Fund. Any support provided - at your request - by the Anticancer Fund team (communicating with your doctor, documents containing information) does not imply liability on the part of the Anticancer Fund, any of its employees and/or any of its partners.
Version: 23 September 2019