HOSPPE

PREAMBLE

This Privacy Policy is for you, as a user of the www.hosppe.com website, and aims to inform you how your personal information may be collected and processed by French Care Partners.

Respect of your privacy and personal data is a priority for us and we are committed to processing your data in the strictest respect of the Data Protection Act of January 6th 1978 as amended and the General (EU) Regulation of April 27th 2016 for data protection.

In any event, we undertake to respect the two following essential principles:
- You remain in control of your personal data ;
- Your data is processed transparently, confidentially and securely

ARTICLE 1. DEFINITIONS

In this Privacy Policy the terms mentioned below have the following meaning :

• « Request for Quote » means all the Data and information provided by the Patient to French Care Partners that the latter transmits to the Institutions in order to issue a Quote.

• « Quote » means the commercial proposal issued by an Institution for the attention of the Patient and transmitted via HOSPPE.

• « Health Data » means the Patient’s Personal Data relating to his state of health which is therefore sensitive data and comes under Article 9 GDPR.

• « Personal Data » means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Health Data is Personal Data..

• « Establishment » refers to any structure registered with the National Register of Health and Social Institutions created by a decree of November 13th, 2013 (FINESS), to which French Care Partners address the Quote Requests, based on the Data provided by the Patient.

• « French Care Partners » designates the company French Care Partners, a simplified joint-stock company with a capital of 40,000 euros, registered with the Paris Trade and Companies Register under number 841 859 721, whose head office is located at 173, rue de Grenelle - 75008 PARIS, and which publishes and operates HOSPPE.

• « HOSPPE » designates the www.hosppe.com website, published and operated by French Care Partners and which groups together all the web pages, computer elements, services and features offered to Users.

• « IEL Law » means Law No. 78-17 of 6th January 1978 relating to information technology, files and liberties as amended by any legal or regulatory provision in force on the day of consultation of this Privacy Policy.

• « Patient » refers to any HOSPPE user who has created an Account in order to submit Quote Requests to Health Facilities.

• « Controller » means the natural or legal person, who, alone or jointly with others, determines the purposes and means of the processing of personal data.

• « GDPR » means the European Parliament (EU) 2016/679 and the Council of 27th April 2016 Regulation relating to the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing the Directive 95/46/CE.

• « Services » refers to the services provided by French Care Partners on HOSPPE, namely the provision of HOSPPE and the transmission of Quote requests to the Institutions.

• « Processor » means a natural or legal person who processes personal data under the authority and on behalf of the controller.

• « Processing » means any operation or set of operations pertaining to personal data, whatever the method (collection, recording, organisation, adaptation, alteration, retrieval, consultation, use, structuring, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction,…).

• « User » refers to anyone who accesses and browses HOSPPE, either as a simple user or as a Patient.

ARTICLE 2. IDENTITY & CONTACT DETAILS OF THE CONTROLLER

The person responsible for the processing of your Personal Data is French Care Partners.

Legal reminder : The controller is, within the meaning of the Data Protection Act, the person who determines the means and purposes of the processing. When two or more controllers jointly determine the purposes and means of treatment, they are joint (or co-responsible) controllers. The processor is a person processing personal data on behalf of the controller, acting under the authority of the controller and on the instructions of the controller.

French Care Partners is a simplified joint-stock company with a capital of 40,000 euros, registered in the Paris Trade and Companies Register under number 841 859 721, whose head office is located at 173, rue de Grenelle - 75008 PARIS.

For any question concerning the management and the use made of your Personal Data, you can contact us:
- Using the contact form available on our website and accessible here : [Specify]
- By email to [contact@hosppe.com]
- By letter to French Care Partners – 173, rue de Grenelle – 75007 Paris.
- By telephone +33 (0) 1 45 14 74 33 (24/7) (non-premium rate).

ARTICLE 3. DATA COLLECTION & ORIGIN

All your Personal Data is collected either directly from you (information provided during your registration on HOSPPE, creation of Quote Request or via the contact form available on HOSPPE), or indirectly during your navigation on HOSPPE (connection and navigation data).

In all cases, your Personal Data is collected and processed solely to manage your registration on the SITE, ensure the delivery of your products, so that you benefit from all the features and services offered, allow us to improve our services and ensure effective business monitoring.

Details of how your Personal Data is collected and processed is provided in this Privacy Policy.

When necessary we undertake, where appropriate, to obtain your consent and/or allow you to oppose the use of your Personal Data for certain purposes, such as audience measurement for HOSPPE.

ARTICLE 4. FINALITIES AND LEGAL BASIS FOR PROCESSING

Your Personal Data is collected and processed for :

Your registration and Account management

Legal basis :
- Contractual, the processing is necessary for the execution of a contract or pre-contractual measures

Submit the Quote Requests to the Institutions and their answers

Legal basis :
- Contractual, the processing is necessary for the execution of a contract or pre-contractual measures
- Your Consent regarding Health Data.

Payment of services

Legal basis :
- Contractual, the processing is necessary for the execution of a contract or pre-contractual measures

Manage and address your request for the exercise of rights « Data Processing and Civil Liberties Law »

Legal basis :

- Legal obligation : Only the persons whose Personal Data (if necessary their legal representative) is processed can claim the rights « Data Processing and Civil Liberties Law » regarding their Personal Data

The proper functioning and continuous improvement of HOSPPE and its functionalities

Legal basis :
- Our legitimate interest in guaranteeing the best level of operation and the quality of our Platform thanks to visitation metrics ;
- Your consent when required.

ARTICLE 5. DATA PROCESSED

The mandatory or optional nature of the personal data requested and the possible consequences of a failure to reply are specified during its collection.

You can review below the details of your personal data that we are likely to have :

For registration and Account management
- Name, first name ;
- Email ;
- Date of birth
- Country ;
- Address ;
- Telephone.

To send the Quote Request to the Institutions and their answers
- Name, first name ;
- Date of birth ;
- Nationality ;
- Country ;
- Address ;
- Telephone ;
- Email ;
- Choice of care ;
- Medical history ;
- Allergies
- Care requested in France
- Known allergy ;
- Doctor’s description of the illness ;
- Any document allowing optimal follow-up, including reports from health professionals, blood tests and medical imaging documents (option left to Patient).

For payment of the services
- Name and first name of the person paying ;
- Bank data relating to the means of payment.

To manage and respond to your request for the exercise of « Data Processing and Civil Liberties Law » rights
- Name, first name ;
- Email or postal address depending on request type ;
- Proof of identity.

To ensure the proper functioning and permanent improvement of HOSPPE and its functionalities
- IP address (if consent is given)
[To be completed according to the cookies and tracers that will be installed on HOSPPE]

ARTICLE 6. RECIPIENTS OF YOUR DATA

Within the limits of their respective powers and for the purposes referred to in Article 3, the key individuals who will be able to access your Personal Data are :
- The authorized personnel of the various departments of French Care Partners (administrative services, accounting, marketing, sales, logistics and IT) ;
- Companies in charge of the management of HOSPPE;
- The authorized staff of our subcontractors (if applicable) ;
- If applicable, the relevant jurisdictions, mediators, accountants, auditors, lawyers, bailiffs, collecting agencies, police or gendarmerie authorities in the event of theft or judicial requisition, assistance;
- Third parties likely to place cookies on your devices (computers, tablets, mobile phones ...) when you give your consent.

Your Personal Data is not communicated, exchanged, sold or rented to anyone other than those mentioned above.

List of our service providers :
- AZNetwork (hosting),

ARTICLE 7. DURATION OF DATA CONSERVATION

We keep your data only for the time required for end purposes, as described in article 3, and summarized in the table below :

For registration and Account management : If the contract is not concluded, your Personal Data will be kept for 3 years from the date they were collected or the date of your last contact with us.

To send Quote Requests to the Institutions and their replies : Until the quote has been sent by French Care Partners or the notification that there is no quote.
If the Patient wishes to send a new Quote Request concerning the same service, the data will be kept until the quote has been sent or the notification that there is no quote for this new Request.

For payment of the services : Only during the payment procedure to HOSPPE.
The data is then archived for 13 months for purposes of proof, in accordance with the provisions in force.

To manage and respond to your requests for the exercise of « Data Processing and Civil Liberties Law » rights : 1 year in the case of exercise of the right of access or rectification , 3 years in the case of exercise of the right of opposition.

To ensure the proper functioning and permanent improvement of HOSPPE and its functionalities : 13 months. After this period, the raw attendance data associated with an identifier is either deleted or anonymized.

ARTICLE 8. YOUR RIGHTS

In accordance with the IEL Law and the GRPD, you have the following rights :
- Right of access (article 15 GRPD), rectification (article 16 GRPD), updating, completeness of your personal data (read more) ;
- Right to block or erase your personal data (Article 17 GRPD), if they are inaccurate, incomplete, ambiguous, out of date, or if their collection, use, communication or storage is prohibited (read more) ;
- Right to withdraw your consent at any time (article 13-2c GRPD) ;
- Right to limit the processing of your personal data (article 18 GRPD) ;
- Right to object to the processing of your personal data (article 21 GRPD) (read more) ;
- Right to the portability of the data you provided us when your data is processed automatically on the basis of your consent or a contract (article 20 GRPD) ;
- Right to determine the fate of your data after your death and to choose whether or not we disclose your data to a third party you have previously designated (read more) ;

In the event of death and in the absence of instructions from you, we undertake to destroy your data, except where their storage is necessary for evidential purposes or to meet a legal obligation.

These rights can be exercised by simple request, by e-mail to : contact@hosppe.com or by writing to : French Care Partners – 173 rue de Grenelle – 75008 Paris.

Finally, you can also file a complaint with the supervisory authorities, the CNIL (https://www.cnil.fr/fr/plaintes).

ARTICLE 9. CONNECTION DATA AND COOKIES

We use connection data (date, time, internet address, IP address of your device, pages viewed) on HOSPPE and cookies (small files stored on your device), to identify you, store your consultations, relating to pages viewed, to measure the HOSPPE site audience.

You can consent, refuse or choose the type of cookies you accept to store on your computer terminals by going to our Cookie Management Policy.

Using a Facebook pixel: Our site is equipped with a Facebook pixel. The Facebook pixel is an analysis tool to offer you our services via our Facebook advertisements.

ARTICLE 10. TRANSFER OF DATA OUTSIDE THE EU

French Care Partners undertakes not to transfer Users’ Personal Data outside the European Union.

In the event that French Care Partners should have to do so, it will inform Users by indicating the measures taken to control this transfer and ensure the respect of the confidentiality of their Personal Data.

ARTICLE 11. SECURITY

French Care Partners and its potential subcontractors undertake to implement all technical and organizational measures to ensure the security and confidentiality of your Personal Data, pursuant to the IEL Law and the GRPD.

In this respect, French Care Partners takes the necessary precautions, in view of the nature of your data and the risks presented by our processing, to preserve the security of the data and, in particular, to prevent it from being distorted, damaged or accessed by unauthorised third parties (physical protection of the premises, authentication process of patients with personal and secure access via confidential identifiers and passwords, connection logging, encryption of certain data, etc.).

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