This privacy policy outlines the approach taken by Dr. Christine Dierickx in her professional medical practice as a certified dermatologist based at 2A, rue Pletzer, L-8080 Bertrange, Luxembourg.

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Dr. C. Dierickx requests that you read this privacy policy carefully to understand how your data is processed and to be fully aware of your rights.

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This privacy policy applies to all information provided by you or collected by Dr. C. Dierickx during your doctor-patient interactions.

As a healthcare professional, Dr. Dierickx is already bound by confidentiality obligations regarding the processing of your personal data. This policy on privacy protection and the processing of personal data is intended to inform you about how your personal data ("Data") is processed and your rights under the European General Data Protection Regulation (GDPR) and Luxembourgish laws related to privacy and personal data protection.

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The GDPR (Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016) is available on the EU legislative website (eur-lex.europa.eu) and came into effect on 25 May 2018. It applies exclusively to the processing of data concerning natural persons.

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When you engage with Dr. Dierickx in any capacity, she collects only the Data necessary for the purposes for which it will be processed. This Data pertains to you and/or any related individual and allows direct or indirect identification.

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You are encouraged to read this policy carefully to understand how Dr. Dierickx uses your Data.

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DEFINITIONS

• "Personal Data": Any information relating to a natural person that allows them to be identified directly or indirectly. This may include names, birth dates, personal addresses, email addresses, photographs, phone numbers, medical information, or banking details (non-exhaustive list).

• "Sensitive Data": Data related to genetics or health within this context.

• "Data Subject": Any natural person who can be identified directly or indirectly via an identifier (e.g., a name, identification number, or location data) or one or more factors specific to their physical, physiological, genetic, psychological, economic, cultural, or social identity.

• "Processing": Any operation performed manually or through automated means on personal data. Examples include collection, recording, organization, storage, modification, retrieval, consultation, use, transmission, dissemination, alignment, restriction, deletion, or destruction.

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DR. C. DIERICKX IS THE DATA CONTROLLER

Dr. C. Dierickx determines the purposes and methods of processing your Data and ensures its protection in compliance with regulations, transparently and securely.

 

Dr. C. Dierickx, her staff, and, if applicable, third-party providers are bound by confidentiality obligations, such as data protection laws, contractual obligations, or professional secrecy. The processed Data is subject to these obligations.

 

This policy describes how Dr. Dierickx processes (i.e., collects, uses, stores, transmits, or otherwise handles) Data. As the data controller, she processes information about you and/or any related individual (such as a close relative) primarily within the doctor-patient relationship ("the Relationship").

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For any questions regarding this policy or the processing of your Data or related individuals' Data, you are invited to contact Dr. Dierickx via email at INFO@SKINPERIUM.COM.

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HOW AND WHEN IS YOUR DATA COLLECTED?

As the Data Controller, Dr. Dierickx primarily collects your Data when you interact with her through her website (via a contact form), during consultations, or through health questionnaires completed to build your medical file, for diagnosis, and treatment management throughout your Relationship with her.

 

This Data is stored on the clinic's internal network in your medical file and is accessible only by Dr. Dierickx, her staff if necessary, and her IT provider, but only at her exclusive request and for resolving technical issues. The IT provider is also bound by a confidentiality agreement.

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Additionally, electronic data may be collected when you visit the clinic's website ("server log files" and "cookies"). Refer to the cookie policy on the clinic's website for more information: https://www.drdierickx.lu.

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PURPOSES AND LEGAL BASES FOR DATA PROCESSING

Dr. Dierickx collects and processes your Data for one or more of the following purposes:

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• Recording your Data in your secure electronic medical file.

• Responding to your inquiries and providing information or advice.

• Managing and following up on your medical file.

• Transmitting your Data to another practitioner, if necessary.

• Using or transmitting anonymized Data to other medical professionals for research and statistical purposes (e.g., photos of treatments, subject to your prior consent).

• Billing for services provided.

• Sending electronic communications.

• Managing appointment scheduling.

• Complying with legal obligations.

• Managing disputes and potential conflicts.

• Ensuring the security and protection of her practice and activities.

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Data processing is based on one of the following legitimate grounds:

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• Compliance with legal and regulatory obligations, particularly as a medical professional (e.g., medical ethics, health codes, or maintaining a medical file).

• Execution of the doctor-patient relationship.

• Preservation of Dr. Dierickx's legitimate interests.

• Your explicit, freely given, specific, informed, and unambiguous consent (e.g., obtained via the website's contact form or a signed consent form for using photos of medical treatments).

 

Dr. Dierickx complies with legal and regulatory obligations, which may require the processing and communication of your Data to national, European, or foreign authorities or third parties. She ensures that such Data is shared only as necessary.

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CATEGORIES OF DATA COLLECTED

As a patient:

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• Identification Data: name, surname, birth date, nationality, gender, national identification or social security number.

• Contact Data: phone numbers, email address, residential address, preferred language.

• Payment Data: banking details.

• Medical and Care Data: reason for consultation, personal/family medical history, ongoing treatments, individual risk factors (e.g., allergies), data from previous consultations, diagnostic and treatment-related information, medical reports, and prescriptions.

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DATA TRANSFERS

Dr. Dierickx may anonymize your identification data and share certain medical data, including photos from treatments, with partners for research and statistical purposes. She may also use such information for her own research and to publish articles in scientific journals reserved for healthcare professionals.

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Data may also be transferred to authorities, legal counsel, or third parties if required by law or deemed necessary in good faith to protect her rights, property, or safety (e.g., in legal disputes).

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Data is not transferred outside the European Economic Area (EEA). If such a transfer is necessary, she will ensure the destination country provides adequate protection or appropriate contractual safeguards.

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SECURITY MEASURES

Dr. Dierickx takes organizational and technical measures to ensure the confidentiality, integrity, availability, and resilience of Data and processing systems. Access to Data is restricted to relevant staff for specific tasks, all of whom are bound by strict professional discretion and confidentiality obligations.

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The clinic’s IT systems, including firewalls, encrypted communication channels, and a dedicated internal server, ensure secure Data storage and processing. No medical data is stored on external cloud services.

 

IN CASE OF DATA BREACH

In accordance with Regulation (EU) No. 611/2013, Dr. C. Dierickx must notify the National Commission for Data Protection of the Grand Duchy of Luxembourg (the "CNPD") of any data breach within 24 hours of identifying a breach of security and confidentiality involving personal data. Additionally, you will be informed if the incident could adversely affect the level of protection of your privacy and data.

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HOW LONG ARE YOUR DATA RETAINED?
Dr. C. Dierickx retains your data for as long as necessary to fulfill the specific purposes for which they were collected, as well as to comply with legal obligations or for evidentiary purposes.
Throughout the retention period, Dr. C. Dierickx is committed to implementing all necessary measures to ensure the confidentiality and security of your data, preventing damage, erasure, or unauthorized access by third parties.

 

As a medical professional, Dr. C. Dierickx is legally obligated to keep your medical records for a minimum period of thirty (30) years.
After this period, the data will be deleted or anonymized.

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WHAT ARE YOUR RIGHTS REGARDING YOUR DATA AND ITS PROCESSING?
You have several rights under the conditions outlined in the GDPR (see the section dedicated to rights), including the right to:

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• Request access to the data in your patient file held by Dr. C. Dierickx and receive a copy free of charge within reasonable limits;

• Request rectification or erasure of data that are found to be inaccurate, if applicable;

• Request the deletion of data when their processing is no longer necessary for the intended purposes, is unlawful for other reasons, or when you withdraw your consent, subject to applicable retention periods and the conditions under Article 17 of the GDPR;

• Request restriction of data processing if the accuracy of the data is contested, if the processing is unlawful, or if you have objected to the processing;

• Object to the processing of your data under Article 21 of the GDPR (note that this does not apply to medical records).

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It is important to note that in certain cases, even if you object to the processing of all or part of your data, Dr. C. Dierickx may be authorized to continue processing, for example:
(i) If it is legally required (e.g., maintaining a medical file is a legal obligation), or
(ii) If it is necessary for the legitimate interests of the medical practice, including the establishment, exercise, or defense of legal claims.

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You also have the right to refuse to provide certain data to Dr. C. Dierickx. However, you understand that such a refusal may prevent the establishment of a medical relationship with you, the performance of certain services in your interest, or the continuation of the relationship.

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CHANGES TO THE PRIVACY POLICY
Dr. C. Dierickx ensures that the privacy policy is updated as necessary to remain compliant with the applicable regulations.

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CONTACT INFORMATION – QUESTIONS AND COMPLAINTS
Dr. C. Dierickx can be contacted via:

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• Email: Info@skinperium.com

• Mail:
  Dr. C. Dierickx
  2A, rue Pletzer
  L-8080 Bertrange

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Additionally, you may file a complaint directly with the National Commission for Data Protection ("CNPD") if you believe that the processing of your personal data constitutes a violation of the GDPR:

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National Commission for Data Protection
15, Boulevard du Jazz
L-4370 Belvaux
Tel.: (+352) 26106026
Fax: (+352) 2610602

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You may also contact a supervisory authority of your choice directly.

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The privacy policy is available for consultation and printing at any time on the medical practice's website: https://www.drdierickx.lu/