Privacy Notice

SATMED – Privacy Notice

Last updated June 2019

General

This website (the “Platform” or the “Website”) is implemented and operated by SES TechCom S.A., located at Château de Betzdorf, L-6815 Betzdorf, Grand Duchy of Luxembourg (who acts as data processor), on behalf of the Government of the Grand-Duchy of Luxembourg, represented by the Ministry of Foreign and European Affairs (who acts as data controller) for the processing of personal data (the “Government” or “We”).

The Platform is a global satellite enhanced cloud based telemedicine platform which mainly allows to connect health-related and/or EU-based Non-Governmental Organisations (“NGOs“) and/or Governmental Organizations (“GOs“) to various doctors, nurses and other health care providers working in various developing countries.

The Government has provisioned SATMED to enable NGOs/GOs to collect patient personal data necessary for the purposes of medical care. The Government is instructing SES TechCom S.A. to run the underlying systems to this end, with SES TechCom S.A. acting as subcontractor to the Government and processing personal information within Luxembourg.

As a consequence, the use of your personal data is subject to applicable laws which may include Luxembourg data protection laws and regulations, as amended from time to time, and is subject to the regulatory supervision of the Commission Nationale pour la Protection des Données (“CNPD”), located at 1, avenue du Rock’n’ Roll, L-4361 Esch-sur-Alzette. Please find hereunder a link to the CNPD website https://cnpd.public.lu/en/support/contact.html, where complaints about the misuse of personal data can be made.

Please note that the Government solely provides a communication platform to NGOs/GOs and users and does not contract nor provide services through the Website. Nothing on the Website shall be construed as an offer and/or the solicitation of an offer to buy or sell products or conclude any other transactions.

In order to provide you access to the Platform and to meet our legal and regulatory obligations, we need to collect certain information about you.

This Privacy Notice (“Privacy Notice”) governs your use of the platform and sets forth the manner in which the Government uses and processes your personal data that you provided to us through the Platform.

Please read the terms below carefully before using this Website. By using our Website or submitting your personal data to it, you consent to, and agree with the terms of this Privacy Notice and you expressly consent and agree to us using your personal data in the manner set out herein. If you disagree with the terms of this Privacy Notice, please do not sign up or use the Website.

Personal Data Collected and Used

We collect the information you give us about you when opening a user account on this Website as well as the information we received from other users you are working with. Such information may consist of, but is not limited to, your name, email address, language.

This information is collected for the primary purpose of enabling you to communicate via the Platform. This information is necessary for us to manage the use of the platform as well as the user account and to comply with our legal and regulatory obligations.

We will store and keep your personal data on the system only as long as you are a user of the platform and/or to the extent that we are obliged to do so under applicable legal data retention requirements. As soon as you remove your account your personal data is automatically deleted and removed from the system to the extent compatible with applicable legal data retention requirements.

Further, we collect some technical information (via the use of cookies) when you browse the Website such as your IP-address and other log data.

Your personal data will be hosted in a central hub and data centre in Luxembourg or within the European Economic Area. Your personal data may be disclosed to our authorised service providers or other third parties in the course of processing your personal data, provided it is disclosed in accordance with this Privacy Notice.

Depending on your account settings, your data may only be available for members of your group in the event that you are member of such a group created within the framework of the Platform.
In order to comply with legal or regulatory obligations or requests, your personal information may be disclosed to law enforcement, regulatory, government agencies, or to other third parties, as may be required by applicable laws and regulations.

Your rights attached to your personal data

Under applicable data protection laws, notably the EU General Data Protection Regulation, you have the following rights regarding your personal data:

• you can object to the processing of your data;
• you have the right to know which personal data we store and process and can request this information;
• you can request rectification of incorrect data; and
• you can request deletion of such data.

To exercise these rights, please contact satmed.dataprotection@mae.etat.lu with a copy to dataprotection-officer@ses.com.

For any further data protection related questions or complaints, please contact our data protection officer at satmed.dataprotection@mae.etat.lu with a copy to:

SES Group Data Protection Officer
Château de Betzdorf
L-6815 Betzdorf
Grand Duchy of Luxembourg

dataprotection-officer@ses.com

For the avoidance of doubt and subject to limitations specified in the terms of use, any user is able to rectify certain personal data (email, name, password, title) on their own through the Website.

In all cases we will treat requests to access information or change information in accordance with applicable legal requirements.

Data Retention

The data controller and data processor shall ensure that only data strictly necessary for the pursuit of the purpose is retained and the data processor will delete all personal data on the instructions of the controller, or where applicable the joint controller, and at the latest 1 year after the end of the collaboration relationship between the parties. Without prejudice to the obligation to destroy provided for in the preceding sentence, the processor shall return all personal data in its possession or otherwise processed by it under this contract as the controller may choose, prior to destruction to the controller or a third party designated by the controller.

Information security

We have implemented technology and policies with the objective of protecting your personal data from unauthorised access and improper use and will update these measures as new technology becomes available.

The Platform users shall be responsible for any security vulnerabilities, and the consequences of such vulnerabilities, not intrinsic to the software or negligence of the Government and/or SES TechCom S.A., and arising from local conditions not within direct reach or oversight of the Government and/or SES TechCom S.A., including but not limited to any viruses, trojan horses, worms or other programming routines contained that could limit or harm the functionality of a computer or local server and that could damage, intercept and/or expropriate data.

Linked sites

As a convenience to you this Website may host links to other websites. Such sites are outside of our control and governed by their own privacy statements and we are not responsible for their operation. If you use any such linked sites, you should consult the privacy policies posted on those websites before disclosing your personal data.

Changes to our Privacy Notice

We may modify or amend this Privacy Notice from time to time at our discretion. When we make changes to this Privacy Notice, we will amend the revision date at the top of this page, and such modified or amended Privacy Notice shall be effective as to you and your information as of that revision date. We encourage you to periodically review this Privacy Notice to be informed about its most current version.

Contact

For more information regarding this Privacy Notice you can contact our Data Protection Officer at satmed.dataprotection@mae.etat.lu with a copy to dataprotection-officer@ses.com.