Privacy
PRIVACY.
Who sees what, why, and for how long. Written for reading, not for filing.
Square brackets mark details to be filled in before launch.
WHO IS RESPONSIBLE.
[Frankly legal entity], registered at the Chamber of Commerce under [KVK number], [address], is the controller for your account and order data. The independent GP who reviews your case is the controller for your medical record, as any GP is for a patient file. The pharmacy that dispenses is the controller for the prescription and delivery. Questions go to hello@franklymen.nl.
WHAT WE PROCESS.
- AccountEmail address, age, chosen programme, the result of the identity check, your messages to support.
- MedicalYour questionnaire answers, photos you upload, your messages to and from the GP, the GP's decision. Seen by the GP, stored in the medical record.
- OrderDelivery address, order status, payment status. The payment itself is handled by the payment provider; Frankly never sees your card details.
- Waiting listYour email address and the programme you asked about, used for one message when that programme opens. Removed once that message is sent, or earlier if you ask.
- DeviceYour theme and photo-set choice, stored on your own device only. See the cookie page.
WHO SEES WHAT.
The GP sees your medical answers and your messages to the GP. The pharmacy sees the prescription and your delivery address. Frankly staff see your account, order status and support messages, not your questionnaire. Your own GP is informed only if you ask us to.
ON WHAT BASIS.
Account and order data: to carry out the agreement you make with Frankly. Medical data: the care relationship with the GP, under the Dutch Medical Treatment Agreement Act (WGBO). Informing your own GP and the waiting list: your consent, which you can withdraw. Identity check: a legal requirement for treatment at a distance.
HOW LONG.
Medical records are kept for twenty years from the last change, as Dutch law requires. Account and order data are kept while you have an account and for [period] after you close it, longer where tax law requires it for invoices.
WHERE.
In the European Union, encrypted, under Dutch medical record-keeping rules. Nothing is sold or shared for advertising.
YOUR RIGHTS.
You can see your data, correct it, have it deleted where the law allows, take a copy with you, and object. Write to hello@franklymen.nl; we answer within one month. You can also complain to the Autoriteit Persoonsgegevens.