Privacy policy

We are Faceland, an international clinic chain for injectables, surgery, and skin therapy in the Netherlands, Belgium, Switzerland, and Germany. Our mission is to make our clients and patients happy with more than they expect for less than they’d expect. For this, we need personal data. To have a conversation, answer questions, for a consultation and for your treatment file. We handle your data carefully and ensure it is secure. That seems only logical to us. You can read below what data we ask for and why we need it. We will also inform you of your rights, who can access your data and how long we retain your data.

This privacy statement applies to the processing of personal data for clients and visitors of the website(s) by Faceland Netherlands as part of Aegis FF B.V. (Ltd.) registered with the Chamber of Commerce under number 59622237, designated as the data controller under the General Data Protection Regulation (GDPR). This includes Faceland HBR B.V. (Ltd.), IKV B.V. (Ltd.), Faceland CHRS B.V. (Ltd.), Faceland Surgery B.V. (Ltd.), DRS B.V. (Ltd.), and Faceland MDRS B.V. (Ltd.) These are all clinics for injectables, surgery, and skin therapy in the Netherlands. For convenience, we will refer to this as “Faceland.”

Faceland HQ
Rivium Quadrant 2
2909 LC Capelle aan den IJssel
The Netherlands

Faceland has appointed a Data Protection Officer (DPO) who oversees our processing of personal data. Our DPO can be directly contacted at fg@facelandclinic.com.

Faceland processes your personal data to provide optimal care and service. For this reason, we also record so-called special categories of personal data in a client file, which reveal information about your health, such as your treatments and medical history (anamnesis), GP, pharmacy, and other relevant data. We are also legally obliged to ask for a Dutch Citizen Service Number (BSN) for identity verification.

In addition, we also record contact information, such as name, address, place of residence, telephone number, email address, gender, date of birth, bank details and payment information. We do this even if you request information, inquire about our services or products, book a consultation, ask a question, chat with us, respond to our website or social media, or interact with us in another way.

In addition to the personal information that you provide to Faceland, we may collect and process additional information about your use of our website(s). This includes information about the device you use, such as an IP address, the operating system version, the settings of the device you use to visit the website, as well as information about the use of the website, such as the time when you visit us and the subjects you view. These data are recorded and used for analyses of website visit and click behaviour. In some cases, personal data may be validated or combined by Faceland with information from external sources. This keeps our data up to date.

We need your data for these things:

a. Intake
b. Schedule
c. Treatment and aftercare
d. Creation of a medical file
e. Quality management and audits
f. Handling questions and complaints
g. Processing payments and our financial administration
h. Processing orders from our website(s)
i. Marketing purposes
j. Security

We explain this below:

Website
If you book a treatment with us on the website, we process, among other things, the following personal data:

• Contact details (name, mobile phone number, email address)
• Date of birth
• Sex

We will send you a confirmation by text message where you must enter a code for verification. This is how you confirm the booking.

Questionnaire and additional information
Next, you will receive a questionnaire and an appointment confirmation or an invitation for a consultation from us. In the appointment confirmation, you will receive an agreement in which you give permission for the treatment. We will store the questionnaire and agreement in your file:

• Address
• Citizen Service Number (optional)
• GP (optional)
• Pharmacy (optional)
• Reference – how did you find us? (optional)
• Questionnaire with, among other things, information about the disease, medicines, other complaints and/or disorders, and the attending physician
• Patient number
• Treatment agreement
• Preliminary appointment

If you don’t answer the questionnaire online, you must do so in the clinic.

Consultation
If you wish to undergo a surgical procedure with us, you will first come for a consultation, or we will have an online consultation with you. We will also make notes of this, which will become part of a patient file, even if the procedure doesn’t ultimately take place.

• Consultation reports containing information about medical history, medications, other complaints, and conditions
• Indication
• Imaging material
• Patient number

Identification
We’re legally obliged to identify you, which is why we ask for your BSN number among other things.

• BSN (Dutch National Identification) number.

Then, we will make a schedule for your treatment with the doctor. It may also be that we book an external treatment room.

• Date, time of treatment, and treating physician.

All details about a treatment, any medication, or other aftercare will be recorded in the client file.

• Treatment, treatment reports
• Any orders that have been made in advance, such as prostheses
• Medication
• Imaging material (photos and videos)
• Aftercare (form)
• Possible complications

We process your personal data in order to comply with the legal obligation to create a medical file. All aforementioned data will be stored in this file. The retention period for a medical file is legally set at 20 years.

Faceland strives for optimal care. Therefore, we analyse data related to our treatments. This includes the types of treatments and care, as well as the efficiency of our administrative processes. These analyses use personal data as source files, but only contain aggregated data intended to better guide the organisation. We may also be subject to external controls, such as those by the Health Care Inspectorate. Faceland may enlist an internal or external auditor for financial controls and monitoring of the quality of services. The auditor or inspector can check processes and gain access to the documentation relevant to that. This may include personal information from our clients. This will be done on the basis of a legal requirement in the case of the inspection or the legitimate interest of Faceland. In this case, the interest of the organisation in prudent management prevails over the privacy interest of employees. These checks are only meaningful if dossier reviews and tests on predetermined aspects are done in a sample-based manner. In other words, it is necessary to carry out such sample-based checks for these purposes. Faceland makes agreements with auditors in advance regarding the scope of the checks, the retention periods of the data and confidentiality.

When a client lodges a complaint about our care services, it is handled by a complaints officer. Information regarding the complaint handling is stored in a quality management system. If necessary for the handling of a claim or complaint, your data may be forwarded to our liability insurer.

We process your data to process payments. We may also use data to place orders that are necessary for the treatment. In the case of prostheses, we are legally obliged to report this to an external register: DBIR.

If you order something on our website, we process your data for this, and we can also send you an e-mail to keep you informed of the status of your order. We also keep track of what you have ordered from us in the past.

We utilise your data for marketing and advertising purposes. We endeavour to tailor the content of our newsletters, website and other communication tools to your interests and preferences. We do so by keeping track of purchasing history. We also look at how our websites and apps are used, allowing us to show you relevant content. We do indeed use cookies for this, both our own and those of other parties; you can read more about this in our cookie policy.

Newsletter
Faceland likes to keep you informed of our services, offers, and news via the newsletter. When you sign up for this, you will be asked to fill in some personal data:

• E-mail address: you will receive the newsletter at the specified e-mail address;
• First name: we like to send personalised newsletters;
• Birthday: to receive special offers;
• Gender: to receive offers and other information about relevant treatments;
• Age category: to receive offers and other information about relevant treatments;
• Country: to receive offers and other information about the correct country;
• Interests: to receive offers and other information about the correct area of interest;
• Province: to receive offers and other information about nearby locations;
• Phone number (optional): to receive text messages with interesting deals.

At the bottom of every newsletter you receive, there is also a link where you can unsubscribe or adjust your preferences.

Website and contact form
The Faceland website is secure. Data exchanged with Faceland via the website is encrypted before being sent. When you contact Faceland via the online contact form or blog, you are asked to provide certain personal data:

• Title: Form of address in our subsequent communication;
• First Name: This allows us to immediately schedule an appointment or view your appointment history; For the blog, we will address you by your first name;
• Last Name: This allows us to immediately schedule an appointment or view your appointment history;
• Email Address: This is required to contact you after your form is submitted;
• Phone Number: If the provided email address does not work, we will contact you by phone;
• Date of Birth: Faceland only serves clients over the age of 18;
• Subject: By indicating the topic of your query, we can direct it to the right person and process it as quickly as possible;
• Question: For answering by Faceland;
• Response: Your response to our blog (for publication).

Analysis of website usage
We analyse the use of our website on an aggregated level in order to improve user experience and information provision. We use a tool to generate so-called user recordings, which anonymously record user sessions. This allows us to see how a web visitor navigates the website. Pageviews, mouse movements, clicks and data input are all recorded. The recordings are anonymised, so the data does not contain any personal information and the visitor is not identifiable.

• Anonymous user recordings

Landing pages and conversion measurements
For certain treatments or campaigns, we create so-called landing pages. On these webpages, you immediately get all the information about the topic. You can also reach these pages via social media or an ad on a third site. When you click on something in the landing page, you are linked to www.facelandclinic.com. We measure how many people come to these landing pages and where they come from. Your IP address is registered for this.

• Visitor’s origin
• Click behaviour
• UID using cookie/pixel
• IP address

Chat
You can also contact us through the chat on the website. The conversations you have with us are securely stored in our webcare monitoring tool. The contact history is securely stored so that we can see what the conversation was about, but also to read back questions and complaints. When you contact Faceland via the chat on the website, you are asked to fill in some personal information.

• Name: form of address in our follow-up communication.
• Email address: this is a requirement to contact you if you accidentally close the chat.
• Phone number: if the e-mail address entered does not work, we will contact you by phone.

Loyalty and Giftcards
Faceland has the Facecard Loyalty programme, and it’s also possible to give a gift card. Many benefits are automatically provided when you purchase the Facecard, including personalised offers. Your data is stored to send you the Facecard or gift card and to keep track of when you are entitled to a voucher of a certain value. A registration of your data is made.

• Name: form of address in our follow-up communication;
• E-mail address: this is a requirement so that we can send you the Facecard or Giftcard;
• Purchase date: this way we know exactly when the Facecard or Giftcard was purchased and when it expires;
• Purchase amount: if you wish to return the Facecard or Giftcard, we can see how much you’ve paid for it

Social Media
Faceland posts social media content from our own social media channels, those of the doctors and those of customers (with permission) on our website. In this way, website visitors can see results of treatments carried out with us. We only see the photos of customers who have tagged us with @facelandnederland, @facelandgermany_, @facelandbreatsurgery, @facelandswitzerland, @facelandbelgium or hashtags with #faceland. We make a selection of these customer photos to place on our website. Photos of clients are only posted on Faceland channels when the client has given permission. The social media post is visible on our website with permission.

You can also contact us through the social media channels Facebook, WhatsApp, Instagram, YouTube and LinkedIn. Your messages will come in through the mentioned platforms and our online webcare monitoring tool. Your contact history is securely stored there to be able to read back information about appointments, but also to read back questions and complaints. Photos of clients are only posted on Faceland channels when the client has given permission.

Furthermore, you may see an advertisement from Faceland on Facebook, Snapchat, YouTube, LinkedIn or Instagram. If you, as a Facebook and Instagram user, agree to their terms and conditions, you are consenting to these advertisements. Consult the Privacy Policies of the social media channels/third parties on their website for more detailed information.

At our locations, we use camera surveillance. The camera surveillance is for the safety of our clients and employees, for the protection of our property and for the protection of the infrastructure and business processes against theft, fraud or other forms of unauthorised access. Due regard is given to the privacy of those involved. We store security images for a maximum of four weeks, and these may only be viewed if an incident has occurred, and only by authorised personnel.

In order to process personal data, the processing must be based on one of the legal bases from the privacy legislation (AVG). In the case of Faceland, we process your personal data:

• To give effect to a treatment agreement – we process certain data to make your treatment possible.
• In order to comply with a legal obligation that lies with us – for example, we are obliged to set up a client file and keep it for 20 years, and we must keep our financial administration for at least 7 years based on fiscal legislation.
• With your consent – We ask for your permission to contact you with our marketing messages. We also do this if we post your social media content on our channels or if we want to use photos and videos of treatments.
• Because this is necessary for a legitimate interest of Faceland: this is for example the case for quality management. Faceland has an interest in improving the quality and efficiency of care. Or when we use cameras in our establishments to protect our safety and property.

Organisations within the Faceland group
All employees of Faceland, including all subsidiaries, are bound by a medical confidentiality or contractual non-disclosure obligation that applies to all data of which they have knowledge. This obligation of confidentiality also applies to medical specialists, temporary employees, self-employed persons hired by us and temporary workers. Employees are only granted access to data to the extent that this is necessary for the performance of their duties.

Quality monitoring authorities
Faceland is subject to external inspections by the Health Care and Youth Inspectorate. In addition, Faceland is ISO certified. File investigations may be part of these inspections. Reporting takes place only at an aggregated level.

Suppliers
Faceland may engage other parties in the performance of its services. To the extent that these third parties process personal data in the performance of their services, they do so as a processor for Faceland. We enter into agreements with all processors to ensure privacy and IT security.

Right of access

You have the right to access your personal data free of charge and to obtain information about how it is processed. The right to access includes: information that Faceland processes your personal data and which data is involved, for what purpose, to whom the data has been provided and its source (if known). You can also get a copy of your client file from us. After a death, medical confidentiality remains in force. This means that relatives do not have the right to view (parts of) your file, unless you have explicitly given them permission to do so.

Right to correct the collected personal data

You have the right to request correction of your personal data if it is incorrect. The right to correction means that you may ask Faceland to correct, supplement, delete or shield your personal data if the personal data is factually incorrect, incomplete or irrelevant for the purpose for which it was collected, or otherwise used in violation of a law.

Right to be forgotten

If it is no longer necessary for Faceland to store or process your data, you can ask us to stop processing your personal data (or limit it) or to completely or partially erase the personal data. We may not always be able to comply with this request. For example, we are legally obliged to keep a client file for 20 years. The tax office also requires us to keep financial data for 7 years. If we cannot comply with your request, we will of course inform you of the reason.

Right to data portability

You can receive the data you have provided to us in a machine-readable format, for example if you want to pass it on to another agency. This only applies to data that you have provided to us yourself.

Right to object

If the processing of personal data is based on Faceland’s legitimate interests (and not on other processing grounds), you can object to the processing of personal data.

If you want to use one of the above options, please send an email to fg@facelandclinic.com. You will receive a response within four weeks.

Employees of Faceland handle patient data with care. Care providers who are directly involved in the treatment have access to the data that is necessary for them to fulfil their duty of providing care. These care providers have a legal duty of confidentiality (professional secrecy) or are bound by a confidentiality agreement.

Faceland takes appropriate technical and organisational measures to protect your data against unauthorised access, (accidental) destruction or dissemination or any other form of abuse. Only authorised personnel can view your data, and actions are logged. We use multi-factor authentication on our critical infrastructure. Periodic privacy and security audits take place. On our websites, we use secure connections (Secure Sockets Layer or SSL). Data is always sent encrypted, both to internal and authorised external parties.

We preserve data no longer than necessary for the purposes as previously outlined in this privacy statement or to comply with legal (storage) requirements. Data may be kept – anonymised – for statistical purposes for a longer period of time.

Despite our measures, it is possible that a vulnerability exists in our information security. If you believe you have found a weak spot, we would like to hear from you and work together to investigate this as soon as possible.

If you provide us with a reasonable timeframe to respond to your report before disclosing any information, and if you make an effort to prevent violations of privacy, destruction of data and disruption or degradation of our service during your investigation, we will not initiate a lawsuit or request law enforcement to investigate, unless we have grounds to believe that your conduct is not in good faith. We will follow the Coordinated Vulnerability Disclosure guideline of the NCSC in dealing with a report.

All content on Faceland websites is owned by us. This includes texts, logos, illustrations, and photos. We have created these, or the images have been used with the permission of the maker or the person depicted on our websites. Therefore, as a visitor, you cannot simply copy or reuse the material on our sites, or make them public. If you would like to do this anyway, please ask us if it is permitted.

If you have any questions about your privacy, we’re happy to help! Please send an email to fg@facelandclinic.com. Under the privacy law, you can also always file a complaint with the legal supervisor: the Dutch Data Protection Authority about our processing of personal data. You can contact the Dutch Data Protection Authority through this form.

Faceland reserves the right to make changes to this privacy statement.

February 2023