Privacy and Cookie Statement

This privacy and cookie statement outlines how eValetudo B.V., trading under the name SeeMe-nopause ('SMNP'), a private limited company located at Bijster 18, Breda (4817 HX), registered in the Trade Register under number 82960496, collects and processes your personal data, as well as how it uses cookies and other technologies on the website seemenopause.com ('website').

Data processing

Through SMNP, privacy-sensitive data, also referred to as personal data, is processed. SMNP places great importance on the careful handling of personal data. Personal data is therefore processed and secured with the utmost care. This entails, among other things, that:

we clearly state the purposes and legal basis for processing personal data; this is detailed in this privacy and cookie statement;
we limit the collection of personal data to what is necessary for legitimate purposes;
we always request your explicit consent to process your personal data in cases where consent is required;
we implement appropriate security measures to protect your personal data and require the same from parties processing personal data on our behalf;
we respect your rights to transfer, access, correct, or delete your personal data upon request, to object to data processing, and to restrict the processing of your data.

SMNP is responsible for data processing. In this privacy and cookie statement, we explain which personal data we collect and use, and for what purpose.

Personal data we process

We collect data when you register for our newsletter, create an account, place an order, contact customer service, or participate in an (interactive) feature on our website. These data may include personal data. We only store and use personal data that you provide directly in the context of the requested service or that is clearly provided to us for processing.

We use the following data for the purposes outlined in this privacy statement:

Name and address details
Phone number
Billing and/or delivery address
Email address
Payment details (bank account number)
Date of birth
Technical data, such as an IP address
Identity and verification data (if applicable): if we perform an identity check (depending on the country, risk assessment, and/or requirements of doctors, pharmacies, or legislation), we may process data such as:
- data from an identity document (e.g., document type, validity, document number, MRZ, and document photo);
- selfie or video images for liveness checks and/or facial comparison;
- verification results (e.g., "passed/failed"), fraud signals, and quality indicators;
- technical metadata necessary for verification and fraud prevention (e.g., timestamp, IP address, device, and session data).
National identification number (if applicable): in some cases, we process a national identification number or equivalent personal identification number (used for healthcare, prescription processing, reimbursement, identification, and/or administrative purposes) when necessary for prescription processing, legal obligations, or requirements of doctors/pharmacies.
Medical data

Purposes and legal bases for data processing

We collect and process your personal data for the following purposes:

providing access to (your personal account on) the website;
creating an account, delivering services, and communicating with you;
informing you (digitally) about menopause-related issues and topics, if desired;
organising, handling, and verifying the order you placed;
enabling independent doctors or healthcare providers to provide you with an online consultation upon request;
enabling independent pharmacies to sell and deliver requested or prescribed products to you;
conducting identity verification if necessary;
performing analyses and research to improve our services and website;
determining your (browsing, search, and/or purchasing) behaviour during visits to or use of our website to provide you with targeted information based on this ('profiling').

Identity verification (ID check) and fraud prevention

We may perform identity verification to (i) ensure you meet age requirements, (ii) prevent fraud, abuse, and identity theft, (iii) support medication safety and responsible use of our services, and (iv) comply with applicable laws and regulations and/or additional requirements of doctors and/or pharmacies.

Processing for identity verification is—depending on the situation—based on the performance of the agreement, a legal obligation, and/or our legitimate interest in fraud prevention and platform security.

Biometric verification (selfie/liveness/facial comparison)

When identity verification includes biometric verification (such as facial comparison or liveness checks), this may qualify as biometric data. We process biometric data only when necessary for identity verification and when a valid legal basis under the GDPR applies, such as your explicit consent (if required).

The aforementioned is based on free and specific consent unless consent is not required because data processing occurs in the context of the formation and/or performance of the agreement, compliance with a legal obligation, safeguarding your vital interests, and/or our legitimate business interest.

Doctors and pharmacies affiliated with SMNP operate independently of SMNP. For requested online consultations and the delivery of requested or prescribed products, SMNP collects and stores your (medical) personal data to provide the service and shares this data with the involved, independently operating doctor and/or pharmacy. SMNP employees do not have access to this medical data. The relevant personal data is only accessible to the treating doctor and pharmacy, who are independently responsible for data processing. We have agreements with the doctors to safeguard your privacy (rights). Access to medical data is technically and organisationally limited to authorised healthcare providers unless access by SMNP is necessary for support, security, compliance, or incident handling (under strict access control and logging).

Contact customer service

We offer the option to ask questions via our website (by phone or other means) through customer service, where you may be asked to provide various data to handle your enquiry. You decide which data you provide. The data you send us is stored as long as necessary for the complete response and handling of your enquiry.

Newsletter

We offer a newsletter to inform interested parties about SMNP in general and/or our services. You can indicate through an explicit opt-in that you wish to receive this newsletter. You can unsubscribe from the newsletter at any time. Each newsletter contains an unsubscribe link.

Publication and transfer outside the EU

We do not publish your personal data. We try to avoid processing personal data outside the EU/EEA as much as possible. If personal data is transferred to parties outside the EU/EEA, we only do so when:

an adequacy decision applies, or
we use appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission, and, where necessary, take additional measures.

Provision to and processing by third parties

We provide your personal data to third parties ('processors') and companies affiliated with SMNP in certain cases to organise, manage, and verify rights and obligations—including services and payments arising from the agreement with you. We have agreements with these third parties to ensure that further processing of personal data by them also complies with applicable privacy legislation.

Identity verification providers (processors)

When we perform identity verification, we may use a specialised external service provider. This provider processes personal data solely on our behalf and according to our instructions, based on a processing agreement.

We typically only receive the verification result and, where necessary, limited audit or reference data.

Security

We take security measures to limit misuse of and unauthorised access to personal data. Specifically, we take the following measures:

access to personal data is protected with a username and password;
we take physical measures to protect access to systems where personal data is stored;
our (technical) equipment and infrastructure suppliers comply with applicable ISO standards;
we use secure connections (Secure Sockets Layer or SSL) to protect all information exchanged between you and our website when you enter personal data.

Retention period

The personal data described above is retained as long as your account has an active status. Your account—including the associated personal data—will be deleted by SMNP if it has not been accessed for three years, three years after your last order via SMNP, or after you request us to delete your personal data/account. Certain personal data may be retained longer if a legal obligation exists (such as the fiscal retention obligation of at least seven years for payment data and at least 15 years for medical data).

Retention periods for identity verification data

When we use an external service provider for identity verification, identity document images and selfie or video material are generally processed directly by this provider. SMNP typically only receives the verification result and does not store copies of identity documents or selfie/video images unless explicitly stated otherwise.

Verification results and associated log data are not retained longer than necessary for the purpose of verification, fraud prevention, complaint handling, and compliance with legal obligations. The external verification party applies its own retention periods in accordance with applicable privacy legislation and the processing agreement with them.

Your rights

Under the General Data Protection Regulation (GDPR), you have the following rights:

The right to access the personal data we process about you.
The right to correct or supplement the personal data we process about you if it is incorrect or incomplete.
The right to withdraw previously given consent.
The right to object to the processing of your personal data.
The right to have your personal data deleted.
The right to transfer the personal data we process about you to a third party.
The right to restrict the processing of your personal data, meaning we process less of your data.

You can exercise the above rights, as well as any other rights you hold under applicable privacy laws, by submitting a request to our Data Protection Officer; his contact details can be found in the final section of this privacy and cookie statement.

Reporting (security) incidents, data breaches

If it turns out, despite the precautions taken, that something has gone wrong with the protection of your personal data, or if we suspect this, we will report this to the Data Protection Authority. If the breach of your personal data could have adverse consequences for you, we will inform you as soon as possible. SMNP has an internal procedure for handling such incidents.

Cookies

SMNP uses cookies. Cookies are small, simple files stored on your computer or mobile device when you visit our website. These files hold a small amount of data containing information about your browser. This allows us to distinguish you from other visitors. We and third parties use cookies to:

enable website functionalities (technical and functional cookies);
analyse website usage and improve user-friendliness based on this analysis (analytical cookies).

These cookies collect the following data from you:

IP address
Cookie ID
Application and click behaviour

When you visit our website for the first time, we display a notification explaining cookies. We will ask for your consent to use cookies where required.

Our website uses the following cookies:

Functional cookies

These cookies enable you to view the SMNP website and use its features.

Since our functional cookies have no or only limited impact on your privacy, no consent is required for their placement. The information collected through these cookies is not used for marketing purposes.

Analytical cookies

These cookies collect statistics about website users. They help us improve our website. The cookies collect information about how visitors use the website, including the most visited pages or the number of error messages displayed. This allows us to make the structure, navigation, and content of the website pages as user-friendly as possible for you. We do not trace statistics and other reports back to individuals.

We use Google Analytics to track how visitors use our website. We have an agreement with Google to make arrangements about the handling of our data. Furthermore, we have not allowed Google to use the obtained Analytics information for other Google services. Finally, we anonymise IP addresses.

For placing analytical cookies, we ask for your consent via the cookie banner unless it concerns strictly necessary measurements with no or minimal impact on your privacy.

Third-party cookies

Cookies from third parties, such as Meta (Facebook), Google (e.g., Ads/DoubleClick), and Visual Website Optimiser (VWO), may be placed via our website. These cookies are only placed if you give consent via the cookie banner (except where they are strictly necessary for the website's operation). You can always adjust your preferences via the cookie settings.

Marketing and tracking cookies (only with consent)

Marketing cookies are used to track visitors across websites to make advertisements more relevant. These cookies are only placed if you give consent via the cookie banner. You can always adjust your preferences via the cookie settings.

Google Analytics

Overview of cookies

Below is an overview of cookies that are placed:

Consent and adjusting settings

You determine whether and which cookies you want to accept. You do this by explicitly giving SMNP consent or by changing your cookie settings afterwards.

Deleting cookies

Most cookies have an expiration date. If an expiration date is set, the cookie is automatically deleted when the expiration date is reached. You can also choose to delete cookies manually before the expiration date. Refer to your browser's manual for instructions.

Changes to the privacy and cookie statement

We reserve the right to make changes to this privacy and cookie statement. It is recommended to regularly consult this privacy and cookie statement to stay informed of any changes.

Data Protection Officer

SMNP has appointed a Data Protection Officer ('DPO'). The DPO is independent and acts as an internal supervisor. The DPO ensures that SMNP applies and complies with applicable privacy rules. If you have questions about the processing of your personal data, you can contact our DPO (Mr B. Teeken) via [email protected] or 088-235 3035. You can also contact our DPO if you have questions, comments, or complaints about this privacy and cookie statement.