Privacy Policy

This Privacy Policy ("Privacy Policy") governs the processing of your Personal Data by the various companies operating within the "GRIT Belgian Sports Clinic." These companies act as joint Controllers (hereinafter "We," "Us", or "Our"), as defined in the Personal Data Legislation, with regard to the processing of your Personal Data via Our Website or in the context of Our services (as defined below). A complete list of these companies can be found at the end of this Privacy Policy, together with their full addresses.

You can contact Us by email at the following email address: secretariaat@gritsportsclinic.be

We recommend that you read this Privacy Policy carefully, as it contains important information about the processing of your Personal Data. By providing your Personal Data on the Website (as defined below) and via the email addresses listed therein, you declare that you have taken note of this Privacy Policy. For information about the use of cookies, please refer to Our Cookie Policy.

Definitions

In addition to the terms defined elsewhere in this Privacy Policy, the capitalized terms in Our Privacy Policy have the meanings set forth below. Furthermore, all terms defined in Regulation 2016/679 (hereinafter: "General Data Protection Regulation" or "GDPR") have the meaning as described in the GDPR.

Patient Act	means the Act of August 22, 2002, on the rights of patients.
Personal data	means any information relating to an identified or identifiable natural person.
Privacy Policy	means this Privacy Policy.
Processor	means a natural person or legal entity, a government agency, a service, or another body that processes Personal Data on behalf of the Controller.
Controller	means a natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
Website	means the website https://gritsportsclinic.com/nl.
Personal Data Legislation	means (i) Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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, and (ii) any national law implementing, supplementing, and/or replacing this Regulation.
Cookie Policy	means Our Cookie Policy, which can be found here.

Personal Data
1. We will process the following Personal Data and categories of Personal Data:

Categories Personal Data	Description Personal data	How We collect your Personal Data:
Identification	First name Last name National registration number Date of birth Your company/club/team	· by filling out an online form for information gathering · by booking an appointment by telephone or via the Website · by logging in to the Website
Contact	Email Address Phone	· by filling in an online form for information gathering · by booking an appointment by telephone or via the Website · by logging in to the Website
Login details	Username Password Last name First name Address Email Phone National registration number Date of birth The information you spontaneously share with Us	· Through your login on the Website
Medical data	Relevant information regarding your medical situation (e.g., diagnosis, paramedical treatment, examinations already performed, medication, allergies).	· By filling out an online form for information gathering · by booking an appointment by telephone or via the Website · by logging in to the Website · during a physical consultation · through Our access to your electronic patient file in the context of Our services.
Financial administrative data	National registration number Account number Name of health insurance fund Health insurance fund number	· by logging in to the Website · during a physical consultation · via Our access to your electronic patient file in the context of Our services.
Technical data	Data collected through the use of cookies For information about the use of cookies, please refer to our Cookie Policy.	· In the event that you visit the Website.

Purposes of processing , legal basis , and retention period
1. We will process your Personal Data for the following purposes and on the following legal grounds:

*Categories of Personal Data*	*Purposes of processing*	*Legal basis*	*Retention period*
*Identification data*	Patient management, to contact you for an appointment so that you can use our services Treatment of the patient, patient care Administration of our clientele, management, and invoicing The processing is necessary for the performance of the contract (cf. Article 6.1.b) GDPR)	The processing is necessary to comply with a legal obligation (cf. Article 6.1.c) GDPR), in particular to comply with Article 9 of the Patient Act. The processing is necessary for the performance of the contract (cf. Article 6.1.b) GDPR)	· Up to 30 years after last contact with the data subject.
*Contact*	Customer management, to contact you for an appointment so that you can use our services Responding to questions and complaints Administration of our clientele, management, and invoicing To contact you for promotional purposes or events or to send you information about Our future projects or initiatives that are directly or indirectly related to Our services ("direct marketing") The processing is necessary for the performance of the contract (cf. Article 6.1.b) GDPR)	The processing is necessary for the purposes of legitimate interest pursued by the Controller (Article 6.1.f) GDPR) (i.e. complaint handling) The processing is necessary for the performance of the contract (cf. Article 6.1.b) GDPR) The processing is based on the soft opt-in (see Article3.4 ) or on your consent (cf. Article 6.1.a GDPR)	· Up to 2 years after last contact with the data subject.
*Login details*	Authentication and identification via the Website Creation of a personalized online profile for the purpose of making (recurring) appointments The processing is necessary for the performance of the contract (cf. Article 6.1.b) GDPR)	The processing is necessary for the performance of the contract (cf. Article 6.1.b) GDPR)	· Up to 2 years after the last login or registration by the data subject
*Medical data*	Treatment of the patient, patient care The processing is necessary to comply with a legal obligation (cf. Article 6.1.c) GDPR), in particular to comply with Article 9 of the Patient Act. In addition, since medical data qualifies as sensitive data under Article 9 GDPR, the processing is necessary for the provision of healthcare or social services and treatments (cf. Article 9.2.h) GDPR).		· Up to 30 years after the last contact with the patient (cf. Article 24 of the Code of Medical Ethics).
*Financial administrative data*	Administration of our clientele, management, and invoicing Administration and coordination with regard to health insurance and social security institutions	The processing is necessary for the performance of the contract (cf. Article 6.1.b) GDPR) The processing is necessary to comply with a legal obligation (cf. Article 6.1.c) GDPR)	· Up to 10 years after the last contact with the patient.
*Technical data*	Optimizing the quality, management, and content of the Website	For strictly necessary cookies: Processing is necessary for the purposes of the legitimate interests pursued by the Controller (Article 6.1.f) GDPR) (i.e. optimizing the Website) For all other types of cookies: Consent (Article 6.1.a GDPR) See Our Cookie Policy Your Personal Data will (only) be processed for the purposes stated in the overview above. In the event that We wish to process your Personal Data for purposes other than those stated above in this Privacy Policy, We will inform you immediately and you will receive all relevant information. You may also object to such use, except where this use is necessary to comply with Our legal obligations. If We wish to process your Personal Data on the basis of your consent, We will clearly inform you of the specific purposes for which your data will be used and We will ask for your explicit consent before processing this data. You have the right to withdraw your consent at any time. If you withdraw your consent, We will stop processing your Personal Data for the relevant purposes, unless there is another legal basis that justifies the processing. The withdrawal of your consent is free of charge and will not affect the lawfulness of the processing based on your consent before you withdrew it. You can withdraw your consent by contacting us using the contact details in this Privacy Policy or by clicking on the button in Our email to unsubscribe ("Unsubscribe"). In some cases, the sending of direct marketing via email, text message, or other electronic means is permitted without your consent, for example because we have obtained your electronic contact details in the context of providing our services and because our commercial messages relate to our similar products or services ("soft opt-in"). Here too, you can object to the further receipt of Our direct marketing messages at any time by clicking on "Unsubscribe." Every direct marketing email contains the option to unsubscribe. You can also unsubscribe by sending an email to secretariaat@gritsportsclinic.be . If We process your Personal Data based on Our legitimate interest, this means that, after weighing the relevant interests, We could decide that Our legitimate interest takes precedence over the interests of the respective data subject. If you would like more information about the balancing of interests, please contact Us at the following email address: secretariaat@gritsportsclinic.be . Recipients of Personal Data Your Personal Data is processed by Us. We may also pass on your Personal Data to third parties who provide services to Us, such as IT service providers. These external Processors may only process your Personal Data on Our express written instructions and on Our behalf. We guarantee that all external Processors are selected with due care and oblige them to respect the security and integrity of your Personal Data. We also take the necessary steps to ensure an equivalent level of protection as described in this Privacy Policy. We will not sell, rent, distribute, or otherwise make your Personal Data commercially available to third parties, except as described above or with your prior consent. In any case, all rights and obligations contained in this Privacy Policy will also apply to the third party that processes or manages your Personal Data as described in this Privacy Policy. In exceptional cases, We may be required to disclose your Personal Data to third parties when required to do so by law or court order, or in the context of legal proceedings. To the extent possible, We will notify you of this and/or limit such processing to a minimum. In the event of a complete or partial reorganization or transfer of Our organization, We may also transfer your Personal Data to (un)affiliated third parties. Transfer of Personal Data

In principle, We will only process your Personal Data within the European Economic Area ("EEA"). In the event that We transfer your Personal Data to countries outside the EEA, We will ensure that the same level of protection is achieved as within the EEA (for example, by concluding standard contractual clauses with the Processor located outside the EEA or by only working with entities from countries for which the European Commission has issued an adequacy decision). If you would like more information about the balancing of interests, please contact Us at the following email address: secretariaat@gritsportsclinic.be .

Your Rights

In accordance with the provisions of the Personal Data Legislation, you have the right to request Us:

access and obtain a copy of your Personal Data that We hold (right of access);
to request the correction of your Personal Data if it is incorrect, inaccurate, or incomplete (right to rectification);
to have your Personal Data deleted if it is no longer necessary or if its processing is unlawful (right to erasure or to be forgotten);
to object to the processing of your Personal Data for reasons relating to your personal situation (right to object);
in specific cases, request a restriction on the processing of your Personal Data (right to restrict processing); and
to obtain the Personal Data concerning him/her in a structured, commonly used and machine-readable format and to transfer it to another controller, without being hindered by Us, insofar as the processing would comply with Article 20 of the GDPR.
1. If you wish to exercise the above rights or if you have a question about the way in which We process your Personal Data, please contact Us by sending an email to secretariaat@gritsportsclinic.be .
2. We will do our best to process your request within one (1) month. In exceptional cases, if your request is complex, this period may be extended by one (1) month. We will always try to inform you of such an extension.

Please ensure that it is always clear which of the above rights you wish to exercise and how you would like to receive a response (e.g., by email, by post, etc.). Please note that in certain cases, we may request additional documentation to ensure that we are assisting the correct person.

If you believe that We have not processed your Personal Data in accordance with the applicable regulations, you can contact Us or submit a complaint to the Data Protection Authority via this link or by letter or email using the details below:

Data Protection Authority

Drukpersstraat 35
1000 Brussels

Email contact@apd-gba.be

Security and confidentiality
1. We have developed and implemented security measures that are technically and organizationally appropriate to prevent the destruction, loss, falsification, alteration, or unauthorized access to Personal Data.
2. We take the necessary measures to ensure that our employees are bound by the level of protection described in this Privacy Policy.
3. We cannot be held liable in any way for any direct or indirect damage resulting from the incorrect or unlawful use of your Personal Data by a third party.
External links
1. We may provide links to third-party websites via Our Website. These links clearly indicate that you, as a user, are leaving the Website. Activating these links is your responsibility as a user. However, we recommend that you consult the relevant Privacy Policy and cookie policy of the third-party website in question.
Changes to this Privacy Policy

We reserve the right to change this Privacy Policy at any time. We will announce any amended version of this Privacy Policy in a timely manner.

Contact details of joint controllers

GRIT Health&Sports Management BV	0681.789.046 Testeltsesteenweg 24 3201 Aarschot Belgium Tel: 016/417528 Email: secretariaat@sportsclinic.be
Dr Johan Bellemans Orthopedie BV	0548.699.997 Testeltsesteenweg 24 3201 Aarschot Belgium Tel: 016/417528 Email secretariaat@sportsclinic.be
GRIT Sports Performance BV	0673.618.181 Asstraat 2 3000 Leuven Belgium Tel: 016/417528 Email secretariaat@sportsclinic.be
Vluymans-Bellemans VOF	1029.630.947 Engels Plein 35/103 3000 Leuven Belgium Tel: 016/417528 Email secretariaat@sportsclinic.be

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