Privacy policy

This Privacy Policy (« Privacy Policy ») describes which data Melimpus collects from the Melimpus solution and virtual reality software aimed at facilitating return to work as advertised on its website (www.melimpus.be) (the “Solution”) as well as the rights of data subjects regarding this data and the legal grounds for this processing. We process personal data in compliance with all applicable data protection legislation.

For the purposes of this Privacy Policy, the term “data protection legislation” refers to 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 (the “GDPR”), as well as any other legislation and/or regulation implemented or created pursuant to the GDPR and the e-privacy legislation, or which amends, replaces, re-enacts or consolidates any of them, and any other applicable national laws relating to the processing of personal data and privacy that may exist under applicable law.

For the purposes of this Privacy Policy, the terms “controller”, “processor”, “third party”, “personal data”, “processing” and “data subject” have the meaning given to them in the data protection legislation.

Article 1. The Controller

The Controller of personal data collected by Melimpus for the use of its Solution and virtual reality software is Melimpus (CBE : 0763.546.782), located at 1200 Woluwe-Saint-Lambert (Belgium), Avenue des Ombrages 25, info@melimpus.com (« We »).

Article 2. Personal data processed

2.1

The personal data we collect in the course of our relations are:

• Personal information: surname, first name, e-mail address and personal preferences;
• Professional information: career history;
• Signed participation form;
• Responses to surveys;
• Data gathered from participants during a VR session;
• Data for the configuration of a VR session;
• Browsing information on our website (see our cookie banner and Article 2.3).

2.2

We use this personal data:

• For research purposes and improvement of the Solution;
• to provide support and assistance;
• to provide some reports;
• to resolve complaints;
• to manage the rights described in Article 7;
• to comply with applicable laws and regulatory requirements;
• to perform our contractual and legal obligations;
• See further processing activities under Article 3.

2.3

About cookies: Our website www.melimpus.com uses cookies, i.e. small text files stored on your device, or similar technologies.

These are sent to your browser from the website that you visit and are stored on your computer's hard drive. Our website uses these "cookies" to collect information and to improve our website.

The cookies we use are of 2 types:

• Functional cookies: These cookies are necessary for the website to function properly;
• Analytical cookies: these cookies optimize ads based on your surfing behaviour;

You have the option to either accept or refuse these cookies and manage their use at any time via our cookie banner and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our website. Indeed, we collect information that your browser sends to us that is called Log Data. This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser version, pages of our website that you visit, the time and date of your visit, the time spent on those pages, and other statistics.

Article 3. For which purposes does Melimpus process personal data

Melimpus will process personal data because they have a legitimate interest in doing so, because it is necessary for the performance of a contractual or legal obligation or because we have obtained the explicit consent of the data subject to do so, in accordance with Article 6(1) of the GDPR.

Article 4. Transfer of your personal data

4.1

Melimpus may share certain data with its co-contractors, qualified as “subcontractors” to the extent strictly necessary for the operation applications or management systems. In all circumstances, we protect customer data by means of confidentiality agreements. The service providers with whom we share customer data are as follows:

4.2

The type of subcontractors are as follows:

• IT solution providers and suppliers
• Software developers
• Mailing solution providers
• Hosting/cloud service providers
• Accountants and financial service providers
• Bank/Insurance
• Lawyers
• Etc.

4.3

In very rare cases, our customers or practitioners who decided to use the Solution during a consultation with a data subject may send us any complaints a participant may have about the use of the Solution.

Your personal data may only be disclosed to supervisory institutions, tax authorities and investigation services if we have a relevant legal obligation to do so.

We also use external service providers who perform certain processing tasks for us so that we can bring you our products and activities, such as IT services, financial services, accounting and other similar services.

4.4

Your data will be collected in the European Economic Area ("EEA") and will only be transferred outside the EEA to a country or countries which the European Commission has ensured that they provide adequate protection.

In the event that the data we collect from you is transferred to or stored in a country outside the EEA that has not been determined to provide adequate protection, appropriate safeguards will be put in place to ensure compliance with the requirements of data protection legislation, such as the implementation of standard contractual clauses approved by the European Commission in Decision 2021/914 of 4 June 2021.

Article 5. Safety measures

5.1

We take appropriate technical and organisational measures to comply with applicable privacy and data protection regulations. We have signed contracts with our subcontractors guaranteeing that they have taken appropriate technical and organisational security measures. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal data, the transmission of it to and from us is at your own risk. You should only transmit your personal data to and from us within a secure environment.

5.2

If you provide us with personal data in relation to other individuals, you undertake: (a) to inform them of the contents of the Privacy Policy, and (b) to obtain their consent in accordance with the terms of the Privacy Policy where needed.

Article 6. Time-limit for storage

6.1

We store your personal data for as long as your data is necessary for the performance of the processing activities set out in this Privacy Policy, for as long as you have been informed otherwise or for as long as permitted by applicable law (such as tax, accounting or other legal requirements).

6.2

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

6.3

However, your personal data will be kept and used as long as necessary to meet our legal obligations, settle disputes or guarantee the performance of our contracts.

Article 7. Your rights

7.1

You have the following rights:

7.1.1 Right of access and rectification

At any time, you might:

• access all the personal data we hold about you and find out where it comes from;
• request a copy ;
• request that this data be rectified, completed, updated, restricted or deleted. In this respect, you are expressly requested to inform us of any changes to your personal data.
• The right to the portability of the personal data processed.

7.1.2 Right to withdraw your consent

Where the processing of your data requires your consent, you have the right to withdraw your consent, without such withdrawal being such as to call into question the processing of your personal data that took place prior to the withdrawal of your consent.

7.1.3 Right to restriction of processing

You may ask us to restrict processing of your personal data in each of the following cases:

• if you dispute the accuracy of your personal data, you may request a restriction of processing for a period of time allowing us to check the accuracy of the personal data;
• if said processing is illegal, you object to the deletion of personal data and ask us instead to restrict its use;
• if we no longer require your personal data for the processing objectives mentioned in Article 2, but you still need it to file, conduct or support a legal action;
• if you have objected to a processing operation, we will restrict this operation while awaiting a decision as to whether our legitimate interests prevail over yours.
• if your right to restriction of processing is acknowledged, we will cease to perform operations on the relevant personal data, independently of storing this data.

7.1.4 Right to object to specific processing

When processing depends on your consent, you have the right to withdraw this consent at any time.

7.1.5 Right to erasure

You have the right to erase your personal data in certain circumstances. On this basis, you can request us to stop using your personal data if you no longer wish to be in contact with us. However, we may keep some personal data that is necessary to provide evidence.

Pursuant to your right to delete data, you also have the right to ask us to stop using the personal data we process on the basis of your consent or our legitimate interest, at any time. We may continue to process your personal data for legitimate reasons after weighing up your interests and ours, unless you decide to terminate the relationship with us.

7.1.6 Right to portability of your data

You may ask us to send you the personal data we process on the basis of your consent or because it is necessary for us to supply the requested products or services, in a structured, current and digital form, so that you can store it for your personal use or reuse, or ask us to send this personal data directly to another data processor, if this is technically possible for us.

7.2

All these rights may be exercised free of charge by sending an e-mail to info@melimpus.com. We undertake to respond to your request within one (1) month of receipt of the e-mail. In certain special cases, we may need more time to examine your request and may require a further two (2) months. We will inform you accordingly if this is the case.

You can also speak to the practitioner accompanying you, who will help you contact us to assert your rights.

7.3

If your concerns are not resolved, you have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, your place of work or the place of the alleged infringement, if the data subject considers that the processing of his or her personal data is in breach of data protection legislation. We encourage you to contact us in the first instance. However, insofar as this right applies to you, you have the right to complain directly to the supervisory authority : the Belgian Data Protection Authority at www.dataprotectionauthority.be - Rue de la Presse 35 - 1000 Brussels - Tel: +32 2 274 48 00.

Article 8. Privacy Policy modification

We review the rules contained in the Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. In the event of a material change, we will take the liberty of contacting you again to inform you of these changes.