Privacy and Cookies Policy

Privacy and Cookies Policy
Health[e]Foundation, Amsterdam
Version: April 15th, 2019

a. Explanation
This Privacy Policy is based on article 13 of the Algemene Verordening Gegevensbescherming [General Data Protection Regulation (GDPR)] and contains the rights and obligations of the company with regards to external persons whose personal data they process mainly in the context of online sales and marketing of services.

b. Model
This "Privacy and Cookies Policy" regulates the processing of your personal data by the person responsible for the processing: Stichting Health[e]Foundation, situated at Meibergdreef 5, room PC0-520, 1105AZ, Amsterdam, The Netherlands (hereinafter: “COMPANY”, “us”, “we”, “organization”, ”Health[e]Foundation”, “HealtheFoundation”, “HealthEFoundation”, “foundation”) with the website and/or apps operating under the domain name and services offered using applications called Health[e]Learning, MyHealthAtHand / MyHealth@Hand / MHH (hereinafter: "WEBSITE").

Read this Privacy Policy carefully, because it contains essential information about how your personal data are processed and which cookies are used. By providing your personal data on the Website and/or apps and by providing the email addresses on this Website and/or apps with Personal Data, you declare that you have taken note of this Privacy Policy and expressly agree to it as well as to the processing itself.

I. General
1.1 COMPANY is following the Wet bescherming persoonsgegevens [law for the protection of personal information], as well as the anti-spam provisions of Telecommunicatiewet [Telecommunication law].
1.2 COMPANY is also in line with the European Regulation 2016/679 of 27 April 2016 on the protection of personal data through current Privacy Policy.
1.3 The person responsible for the processing of your personal data is COMPANY.
1.4 We may change this policy from time to time, and if we do we will post any changes on this page. If you continue to use the Services after those changes are in effect, you agree to the revised policy.

II. Personal data
2.1 Personal data that you communicate to us:
2.1.1 Category 1, without registration, including but not restricted to: your IP address, origin, referring search terms;
2.1.2 Category 2: at registration for a personal account: your profile details, password, e-mail address, login details (and possibly your profile image);
2.1.3 Category 3: at registration newsletter: when you subscribe to our newsletter: your e-mail address;
2.1.4 Category 4: via cookies: functional and non-functional, see Article 9 - Cookies;
2.1.5 Category 5: your address details as a result of placing an order.

2.2 COMPANY can collect data from you (Personal Data) in various ways:
2.2.1 through the use of cookies (see below);
2.2.2 during your registration and use of the Website and/or apps;
2.2.3 The Website and/or apps also use cookies that collect a number of personal data. For the provisions regarding the use of cookies, see article 9.

III. Purposes of the processing
3.1 General purposes
COMPANY will only use the Personal Data collected by you for the following purposes:

3.1.1 Category 1: the provision and improvement of this Website and/or apps and the inclusion of Personal Data in anonymous statistics, from which the identity of specific persons or companies cannot be ascertained, with as legal grounds the legitimate interests of the COMPANY to continuously improve its Website and/or apps and services;
3.1.2 Category 2 : the management of your account on this Website and/or apps with a view to the use of our Company and website and/or apps, with as legal basis the execution of an agreement that was requested, initiated, and/or approved by you, and, if indicated by you, also the sending of direct marketing, with your explicit prior permission as a legal basis;
3.1.3 Category 3: sending you direct marketing, newsletters, and promotions, with your explicit prior consent as a legal basis;
3.1.4 Category 4: functional cookies, with your explicit prior consent as a legal basis;
3.1.5 Category 5: the delivery and invoicing of products ordered by you, with as legal basis the provision of a service that was requested by you.

You are not obliged to release your personal data but understand that the provision of certain services becomes impossible if you refuse the processing.

3.2 Direct marketing
The personal data will also be used for direct marketing, provided you have given additional explicit permission for this ("opt-in").

If you are already included in our mailing list for receiving marketing material in paper and/or electronic form, COMPANY can use your details for sending marketing and other material with regard to COMPANY, its products and/or services. COMPANY can use the information you provide for updating documents saved by COMPANY.

This permission can be withdrawn at any time, without justification and free of charge, for example by clicking on the appropriate cancellation link at the bottom of each promotional e-mail message.

3.3 Transfer to third parties
In the event of full or partial reorganization or transfer of activities of the COMPANY, where it reorganizes, transfers, ceases or if the COMPANY goes bankrupt, this may mean that your data is transferred to new entities or third parties through which the business activities of the COMPANY are fully or partially carried out.
COMPANY will reasonably attempt to inform you in advance of the fact that COMPANY will disclose your data to said third party, but you also acknowledge that this is not technically or commercially feasible under all circumstances.

COMPANY will not sell your Personal Data, nor rent, distribute or otherwise make commercially available to third parties, except as described above or with your prior consent.

3.4 Legal requirements
In rare cases, the COMPANY may have to disclose your Personal Data pursuant to a court order or to comply with other mandatory laws or regulations. COMPANY will reasonably attempt to inform you in advance in this respect unless this is subject to legal restrictions.

IV. Duration of the processing
The personal data is stored and processed by us for a period that is necessary in function of the purposes of the processing and in the function of the contractual relationship between the COMPANY and You.

Should records show that you have not logged in to our e-learning portal after 10 years, your account along with the known personal data will be removed. This is with the exception if you are only registered with us for our periodic newsletter.

V. Your rights
5.1 Right of access and inspection:
You have the right to receive free access to your personal data at any time, as well as the use that we make of your personal data.
5.2 Right of improvement, deletion, and limitation
You are free to or not to communicate your personal data to COMPANY. You also have the right to request us to correct, supplement, or delete your personal data. You acknowledge that in case of refusal of communication or request for the removal of personal data, certain services and products are not available.

You may also request to limit the processing of your Personal Data.

5.3 Right of resistance
You have a right of opposition to the processing of your personal data for serious and legitimate reasons.
Additionally, you always have the right to oppose the use of personal data for direct marketing purposes; in such a case you do not have to give reasons.
5.4 Right of free data transfer
You have the right to obtain your personal data processed by us in a structured, standard and machine-readable form and/or to transfer it to other responsible persons.
5.5 Right of withdrawal of consent
Insofar as the processing is based on your prior consent, you have the right to withdraw that permission.
5.6 Exercising your rights
You can exercise your rights by contacting us for this purpose, either by e-mail to, by post to the COMPANY address or by using the "Contact" section on the Website and/or apps, provided you enclose a copy of your valid identity card.
5.7 Automatic decisions and profiling
The processing of your personal data does not include profiling and you will not be subject to automated decisions by us either.
5.8 Right to complain
You have the right to file a complaint with the Autoriteit Persoonsgegevens [Data Protection Authority] P.O. Box 93374, 2509AJ, The Hague, The Netherlands, telephone number: (+31) - (0)70 - 888 85 00, fax: (+31) - (0)70 - 888 85 01.

This is without prejudice to a provision for a civil court.

If you suffer damage as a result of the processing of your personal data, you can submit a claim for compensation.

VI. Security and confidentiality
6.1 We have developed security measures that are technically and organizationally adapted to avoid the destruction, loss, forgery, modification, unauthorized access or notification by mistake to third parties of personal data collected as well as any other unauthorized processing of personal data.
6.2 Under no circumstances can COMPANY be held liable for any direct or indirect damage resulting from incorrect or unlawful use by a third party of the personal data.
6.3 You must comply with the safety regulations at all times, for example, but not restricted to, preventing any unauthorized access to your login code and password. You are therefore solely responsible for the use made of the Website and/or apps or Your computer, IP address and Your identification data, as well as for the confidentiality thereof.

VII. Access by third parties
7.1 In order to be able to process your personal data, we may grant access to your personal data to our employees, country coordinators, local partners, and/or other contract-based legal people, public authority, agency, or body. The access granted to these bodies is limited to only the data concerning the activities that are directly related to the third party. The nature of the access is temporary and will be revoked upon completion of the relationship.
7.2 We guarantee a similar level of protection by making contractual obligations enforceable against these employees and appointees mentioned under 7.1, which are similar to this Privacy Policy.

VIII. Privacy commission declaration
For this processing of personal data, a declaration was made to the Autoriteit Persoonsgegevens [Data Protection Authority]. You can always contact this authority at the following addresses:
Autoriteit Persoonsgegevens
Postbus 93374
Telephone number: (+31) - (0)70 - 888 85 00
Fax: (+31) - (0)70 - 888 85 01

IX. Cookies
9.1 What are cookies?
A "cookie" is a small file sent by the COMPANY server and placed on the storage medium of your device. The information stored on these functional cookies can only be read by Us and only for the duration of the visit to the Website and/or apps.
9.2 Why do we use cookies?
Our Website and/or apps uses cookies and similar technologies to distinguish your usage preferences from those of other users of our Website and/or apps. This helps us to provide you with better user experience when you visit our Website and/or apps and also allows us to optimize our Website and/or apps.
As a result of recent legislative changes, all Website and/or apps aimed at certain parts of the European Union are required to request your consent for the use or storage of cookies and similar technologies on your computers or mobile devices. This cookie policy gives you clear and complete information about the cookies we use and their purpose.
9.3 Types of cookies:
Although there are different types of cookies, distinguished in terms of functionality, origin or storage period, the legislation mainly distinguishes between functional or technically necessary cookies on the one hand and all other cookies on the other.

The Website and/or apps only use the following cookies in order to function properly:
Name Origin Function Retention time
JSESSIONID Session tracking Various
cxexp Session tracking Various
cxid Session tracking Various

For cookies placed by third parties (for example but not restricted to: Facebook, Twitter, Google (Analytics)) we refer you to the statements that these parties give on their respective website and/or apps. Please note: we do not exert any influence on the content of these statements, nor on the content of the cookies of these third parties: Google Analytics cookies, Mixpanel cookies.

9.4 Your permission
On your first visit to our Website and/or apps, you will be asked to accept our different types of cookies. You can allow or deny these cookies. You can change the cookie settings for our Website and/or apps at any time by changing the settings of your browser and thus revoke your consent.

You can also refuse or block cookies by changing the configuration parameters of your navigation system. Refusing or disabling cookies may mean that you cannot use certain features of the Website and/or apps.

If you have further questions or comments regarding the processing of your personal data, please contact us, either by e-mail to, by post to the COMPANY, or by using the part " Contact" on the Website and/or apps.

More information about cookies can also be found at
More information on online behavioral advertising and online privacy can be found here: