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Privacy Policy

Privacy Policy – Version: June 2025

Benoliel Simon FSBD (hereinafter “we”) is aware of the importance of respecting privacy and protecting the personal data of clients, professional users and patients in the context of its activities. In this policy, we explain how we process your personal data.

This policy also applies to the use of the Odontoscope® Web-App,  which is designed for capturing, structuring and securely transmitting patients’ intraoral photos for remote dental expertise.

Scope of application

This website and the Odontoscope® Web-App are managed by Simon Benoliel (hereinafter “we”), dentist, whose registered office is at Rue Haute 322, 1000 Brussels, with BCE number 0734.431.540. We act as the data controller when processing personal data of users of our website and the Odontoscope® Web-App.

We also act as the data controller for the Odontoscope® Web-App, which is an integral part of our remote dental expertise service intended for healthcare professionals and care institutions.

It is important for us to create and maintain an environment in which users can be assured that their information will not be misused. We comply with applicable data protection regulations, including the General Data Protection Regulation 2016/679 (GDPR), as well as national legislation. This regulation is designed to protect your personal data and grants you rights regarding this data.

When you visit our website or use the Web-App, this Privacy Policy and our Terms of Use apply. The application of any other conditions is expressly excluded, except with our prior written agreement.

What personal data do we collect?

Most of our website can be accessed without having to provide personal data.

However, we may collect and process the following categories of data for the purposes described below:

  • Contact details (email address, phone number of the examiner);

  • When you complete forms on our website or when we contact you (by phone, email, at events).

We may also collect and process information obtained via our site or services:

  • Name, first name and NISS number of patients for whom an oral health monitoring procedure is initiated via our form;

  • Patients’ oral health data, including intraoral photographs uploaded via the form or captured using the Odontoscope® medical device and integrated into the Web-App to structure and standardize the clinical documentation for remote dental expertise;

  • Location data (IP addresses, GPS signals);

  • Technical information (cookies, web beacons, pages viewed, browser type, navigation time, operating system);

  • Data from third parties (e.g. login via external accounts);

  • Telephone conversations for quality assurance or training purposes.

We may also collect publicly accessible information to verify data we have previously collected or to manage our activities.

Why do we collect this information and on what legal basis?

We collect this information to better understand your needs and provide you with better service, in particular for:

Purpose Personal data Legal basis Retention period
Client management: requester Contact details (email, phone, address) Contract performance / Legitimate interest 10 years after the end of the business relationship
Form for remote dental expertise Name, contact details (email, NISS, address, phone), intraoral photos, denture photos, medical history and data structured and stored in the Odontoscope® Web-App for transmission to the dentist in charge of the remote expertise Consent and/or processing necessary for healthcare purposes (Art. 9.2.h GDPR), under the responsibility of professionals subject to medical confidentiality 5 years

How do we use and share your data?

We may share your personal data with:

  • An IT service provider who maintains and develops the application and uses your data as part of the contract performance;

  • A designated or authorized partner dentist who receives your personal data via the Odontoscope® Web-App in the context of remote dental expertise.

We may also share your data, on the basis of our legitimate interest, with third parties assisting us in providing our services: web hosting, data analysis, marketing, customer support. These third parties only have access to your data if strictly necessary and for defined purposes. They may not use your data for other purposes.

We may also disclose your data to enforce our policy, comply with legal obligations, or in the public interest (e.g. responding to judicial or regulatory authorities), in connection with legal disputes, or to protect our rights, security or interests.

In the event of a sale or merger of FSBD.org’s activities with another company, your data may be transferred to the new owners. In such cases, we will take appropriate measures to ensure the integrity and confidentiality of your personal data.

Transfer of your data outside the EEA

We do not transfer your personal data to countries outside the European Economic Area.

Rights of the data subject

In accordance with data protection legislation, you have the following rights:

  • Right of access: know if your data is being processed and obtain a copy.

  • Right of rectification: correct inaccurate or incomplete data.

  • Right to erasure (“right to be forgotten”): request data deletion within legal limits.

  • Right to restriction of processing: request limited processing in certain cases.

  • Right to data portability: receive your data in a structured, commonly used, machine-readable format.

  • Right to withdraw consent: withdraw your consent at any time when processing is based on it.

To exercise these rights, you can contact us at: simon@fsbd.org. We may ask you to provide proof of your identity before acting on your request.

You also have the right to lodge a complaint with the Data Protection Authority (APD), Rue de la Presse 35, 1000 Brussels (contact@apd-gba.be).

Security

We do everything possible to ensure the security of your data. Health data is transmitted via encrypted connections (TLS/HTTPS) and stored on servers compliant with European security standards (ISO27001/HDS). We have implemented reasonable technical and organizational measures to prevent any destruction, loss, alteration or unauthorized disclosure.

As the internet is an open system, we cannot guarantee that unauthorized third parties will never be able to circumvent these measures.

Applicable law and competent courts

Belgian law applies to this policy and all related disputes. In the event of a dispute, only the courts of the jurisdiction of FSBD’s registered office shall have jurisdiction.

Changes to this policy

FSBD.org may modify this policy at any time to reflect changes in our practices. In the event of any substantial change concerning the use of the Odontoscope® Web-App, we undertake to inform the affected professional users by appropriate means (email or in-app notification). The updated version will be published on this page and will take effect upon publication.