Preamble
Doctizy publishes a SaaS solution called Klodios, which provides information to healthcare professionals. This information can also contain the professional contact information of individuals or entities with expertise in a subject of interest to healthcare professionals.
Two categories of people can hold user accounts on the Klodios platform and access the services provided by Doctizy:
- Any healthcare professional with a CPS card and an account on the platform.
- Any legal entity authorized to publish content intended for healthcare professionals on the platform, or its employees or assimilated, natural persons, publishing content for it.
In addition to the Klodios platform, Doctizy publishes a showcase site accessible at the address https ://klodios.com which aims to communicate information to any Internet user accessing it. Internet users can also contact Doctizy through this site or sign up for the newsletter.
Anyone who subscribes to the newsletter receives information about the Klodios platform and Doctizy by e-mail.
The Doctizy company is thus led to use personal data, i.e. data allowing the identification, directly or indirectly, of physical persons.
Doctizy places the protection of this data at the heart of the services it provides. It undertakes to respect the law of January 6, 1978, as amended, relating to the protection of personal data, as well as the Regulation (EU) 2016/679, known as the « GDPR ».
This policy sets out the principles and guidelines for the protection of your personal data and aims to inform you about:
- The personal data that Doctizy processes and the reasons for this processing,
- How this personal data is used,
- Your rights regarding your personal data.
It concerns the data processing implemented through the Klodios website and platform.
Doctizy reserves the right to modify it at any time in order to provide you with updated information on how data is collected and processed or following legislative and regulatory changes.
Users of the services provided by Doctizy via the Klodios website or platform will be notified of any material changes to this Policy.
Recipients of the document
The purpose of this document is to present the privacy policy established by Doctizy. This policy is intended to apply to the following individuals:
- Customer: Any legal entity that has signed a supply contract with Doctizy including the license to use the KLODIOS platform and associated services and their natural person representatives.
- Users: any person who has a user account on the KLODIOS platform published by Doctizy. Users are either health professionals or content creators.
- Prospects: any person who is the subject of commercial and marketing operations, whether or not they are contractually bound to Doctizy.
- Internet users: any person browsing the website https://www.klodios.com
- Newsletter subscribers: any person who has signed up to receive the Doctizy newsletter.
Glossary
For a perfect understanding, Doctizy provides Users with a Glossary. The terms used in the document have the following meaning:
“Newsletter subscribers”: means any natural person who has requested to receive the KLODIOS newsletter by providing his or her contact information and validating his or her registration.
“CPS cards”: refers to the electronic professional identity cards, dedicated to the health and medico- social sectors, issued by the Agence du numérique en santé to any person working in a health care institution or in the health field, in a private practice, in a laboratory or in a pharmacy. The CPS card allows its holder to prove his or her identity and professional qualifications. It contains the identification data of its holder.
“Account”: means the interface that allows the User to access the services provided by Doctizy via the Site or the Klodios Platform using a personal and secure space.
“Content creator”: means the natural person who uses the services provided by Doctizy via the site and/or the Platform, who has secure personal access (login and password) and who makes content available to healthcare professionals. The content creator is a user of the Platform.
“Personal Data” or “Data”: means any information relating to an identified or identifiable natural person, directly or indirectly, by reference to an identifier, such as a name, an identification number, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.
“Username”: means the email address and password chosen by the User at the time of registration and allowing access to his account.
“Internet user”: means any person who accesses and navigates on the site www.klodios.com or on the KLODIOS platform.
“Platform”: means the KLODIOS application solution accessible via the Internet at the URL address www.klodios.com published by Doctizy and which offers its products and services to Users.
“Health Professional”: refers to the natural person who uses the services provided by Doctizy via the site and/or the Platform, who has a secure personal space (login and password) and who is required to consult the published content. The health professional is a user of the Platform.
“Pro Santé Connect”: is a teleservice implemented by the Agence du Numérique en Santé (ANS) that helps simplify the electronic identification of healthcare professionals. Users can connect using their e-CPS mobile application or their CPS card, with a card reader and the necessary components
“Data Controller”: means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing; where the purposes and means of such processing are determined by Union law or by the law of a Member State, the controller may be designated or the specific criteria applicable to his designation may be laid down by Union law or by the law of a Member State.
“Services”: means the services provided by Doctizy via the www.klodios.com site or the KLODIOS platform, including the associated support services.
“Site”: means the web site published by Doctizy and accessible via the Internet at the URL address www.klodios.com
“Processor”: means the natural or legal person, public authority, department or other body that processes personal data on behalf of the controller.
“User”: means any person who has a secure personal account to access the KLODIOS platform and the services provided by DOCTIZY.
I. The data controller
The data controller mentioned in the present confidentiality policy is the company Doctizy whose coordinates is:
SAS Doctizy
Centre d’Innovation Technologique,
17 rue Claude Bloch,
14076 CAEN
contact@doctizy.com
II. The data protection officer
The contact details of the Data Protection Officer appointed by the company Doctizy are as follows:
Date Protection Officer
SAS DOCTIZY
Centre d’Innovation Technologique,
17 Rue Claude Bloch,
14076 CAEN
III. Processed data and their purposes
| ACTION People involved | DATA CATEGORIES | SOURCES | PURPOSE | LEGAL BASIS |
| Navigation on the platform Users | Identification data Connection data Navigation data | Direct via the navigation on the platform | Measures performance. Detect navigation problems. Optimize the technical or ergonomic performance of the platform. Estimate the power of the required servers, Analyze the content consulted. | Legitimate interests of the Doctizy company in: – improve the Klodios platform and ensure its operation – to produce anonymous statistics on the contents consulted by the users for the customers, in return for the free use of the users. |
| Sending requests and communication with Doctizy Internet users Prospects | Identification data Any data voluntarily transmitted by the Internet user | Direct when a request is entered and sent to Doctizy | Manage requests sent by email or through the contact form. Receive requests. Ensure the processing and follow-up of these requests. | Free and informed consent of the Internet user. |
| Subscribe to the newsletter Newsletter subscribers | Identification data | Direct when the email address is entered in the registration form | Manage the newsletter. Validate the subscription to the newsletter. Establish the list of subscribers. Send information to subscribers. | Free and informed consent of the subscriber. |
| Creating a user account Users | Identification data Data related to professional life Connection data | For the healthcare professional: via Pro Santé Connect service using the CPS card For the content creator: either directly or through their employer | Check the professional quality of the user. Create, manage and administer the user account. Provide Klodios services. Adapt the content accessible to healthcare professionals according to the settings of the content creators. Respond to user requests for assistance. Maintenance of the platform. | Execution of the contract |
The data collected is necessary to provide the services offered. Failure to provide this data will only result in the impossibility of accessing the services (Klodios platform, newsletter, etc.) recipients of the data.
For the purposes described above, your data may be transmitted:
- A of Doctizy’s internal services
- Doctizy’s external service providers: Doctizy’s subcontractors who are involved in the maintenance and hosting of the platform or in the management of Subscriber lists, or other external service providers acting on behalf of Doctizy (chartered accountants, etc.).
The intervention of each of the external service providers is strictly limited to the service that they perform on behalf of Doctizy.
No personal data relating to the health professional is communicated to the content creator, the data transmitted is purely statistical.
Doctizy may disclose your data, upon request, to any person or authority to whom the law, regulations or courts recognize the right to obtain disclosure of data.
No Personal data collected and processed is transmitted by Doctizy to a third party for commercial purposes. The data is neither exchanged, nor rented, nor sold.
IV. How long the data is kept
The data processed by Doctizy is kept for the time necessary to achieve the purposes pursued as specified in the table below. These periods are increased by the period of conservation necessary to satisfy legal, accounting, financial and fiscal obligations, to settle disputes and, in particular, to prevent possible illicit behavior.
| ACTION | SHELF LIFE |
| Navigation on the platform | 3 years from the date of collection of personal data |
| Sending requests and communication with Doctizy | One year after the last contact with the Internet user. Or until consent is withdrawn. |
| Subscribe to the newsletter | Until you unsubscribe. |
| User account creation | Until the user account is closed or up to 3 years after the last connection to the platform. |
V. Cookies used
1) What is a cookie
A cookie is a small computer file containing small amounts of information relating to the navigation of the Internet user (browser used, pages visited …).
When the user visits a website, the file is stored on his terminal (computer, smartphone, tablet, video game console…).
The file is deposited and read by the transmitter. It will allow him, during all the validity period of the cookie, to recognize the terminal which reaches the Internet site.
The objective is to allow the visited site to remember the user’s preferences (user name, language, etc.) for a certain period of time. Cookies can thus be used to improve the user’s navigation on the site, his user experience, reinforce the security of the site…
2) Use of cookies by Doctizy
Doctizy uses cookies to optimize the use of its website and its platform. Doctizy does not use any cookies or third-party tracers.
Cookies necessary for the proper functioning and security of the site may be used. For example, to allow a user to authenticate himself on the platform.
An audience measurement tool (Matomo) is also installed on the showcase site and on the platform. It is configured so as not to process any personal data and to be exempted from the collection of consent, in accordance with Article 82 of the French Data Protection Act and the recommendations of the CNIL.
Within the framework of the showcase site, you can oppose the use of the Matomo tool in order to protect your private life. Doctizy will no longer be able to collect data to improve the user experience.
Current status: AcceptedCurrent status: DeniedWithin the framework of the platform, you cannot object to the monitoring which is essential to the functioning of the platform and its continuity. It is a counterpart to the free use of the platform. Doctizy has taken measures to protect your privacy by anonymizing the data analyzed through the tool and by only communicating statistics to its clients. The results of these analyses make the platform interesting for these clients and allow them to adapt their content. The objective is to allow clients to improve their content, to allow you to discover content that corresponds to you, and to allow Doctizy to have a viable business, while respecting your privacy.
VI. Data transfers outside the European Union
All processing carried out via the Klodios website, platform and services is carried out in the European Union (EU).
In any event, if Doctizy were to transfer data outside the European Union, it undertakes to comply with the requirements of European regulations by framing any transfer by means of standard contractual clauses or other appropriate legal mechanisms.
VII. Data security
Doctizy undertakes to implement the technical and organizational means necessary to guarantee a level of security adapted to the risk in terms of confidentiality, integrity, and availability of the data according to the sensitivity of the data and the nature of the processing.
Doctizy is committed to considering the protection of your personal data and your privacy from the very beginning of the design of the new products or services that are offered to you.
VIII. Your rights on your personal data
The person concerned may at any time request to exercise his/her rights with respect to his/her personal data in accordance with the regulations. He or she has:
- a right to object to the processing of his data for legitimate reasons;
- a right of access and communication, a right of correction, update, deletion and suppression of the data concerning him, subject to legitimate reasons;
- a right to data portability: The natural persons concerned are informed that they can request the delivery of a copy of their personal data, against reimbursement of the costs of reproduction and sending of the same.
- A right to limit the processing of your data.
- Pour les traitements fondés sur le consentement (see Article 4 of this Policy), the data subject may withdraw consent at any time without affecting the lawfulness of the processing carried out prior to such withdrawal.
DOCTIZY may nevertheless object to requests that are manifestly abusive, particularly in terms of their number, repetitive or systematic nature.
These requests can be addressed to:
- Through the contact form available on the site and on the platform.
- oo by e-mail to: dpo@doctizy.com
- ou by mail to:
Data Protection Officer
SAS Doctizy
Centre d’Innovation Technologique
17 Rue Claude Bloch
14000 CAEN FRANCE
If there is reasonable doubt about your identity, you may be asked to provide proof of identity.
Concerning the newsletter, it is also possible to unsubscribe directly by clicking on “unsubscribe” in the footer of the emails sent by Doctizy.
IX. Complaint to the CNIL
If you feel that your rights have not been respected, you may file a complaint with the CNIL: https://www.cnil.fr/fr/plaintes.