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Privacy Policy

Docemo

Last updated: 24/07/2026

Docemo places great importance on the protection of your personal data and your privacy. In this privacy policy, we transparently explain which personal data we process when you use our platform (https://docemo.tech), for what purposes, on what legal grounds, how long we retain them, and what rights you have. The processing is carried out in accordance with the General Data Protection Regulation (GDPR), the Belgian Act of July 30, 2018, on the protection of natural persons with regard to the processing of personal data, and the applicable ePrivacy regulations.

1. Data Controller

[Fill in the full company name and legal form], acting under the name Docemo, with registered office at Marsveldplein 5/14, 1050 Brussels, and office at Berchemstadionstraat 78, 2600 Berchem, registered in the Crossroads Bank for Enterprises under number 0643.617.170 (VAT BE 0643.617.170).

Email: support@docemo.tech

Phone: +32 2 550 34 49

2. What Personal Data Do We Process

Depending on your use of the platform, we process the following categories of data:

●       Registration and account data: first and last name, email address, password (stored encrypted), RIZIV number, profession, qualification and qualification date, and your language preference.

●       Access method data: whether you have free access as a general practitioner, or whether you have chosen a partner who finances your e-learning, and which partner that is.

●       Usage and learning data: the e-learnings you are enrolled in, your progress and results, and the certificates and accreditations obtained.

●       Communication data: the data you provide us via the contact form or via support, and your subscription to the newsletter.

●       Billing data: name, billing address, if applicable company/VAT number, and the data necessary to process the payment via our payment provider. We do not store complete card details.

●       Technical data: IP address, device and browser data, and log data generated during your use of the platform. More information about cookies can be found in our cookie policy.

3. Purposes and Legal Grounds

We process your personal data only for specific purposes and each time on a valid legal ground:

●       Creating and managing your account: necessary for the performance of the contract.

●       Providing access to and delivering the e-learnings: necessary for the performance of the contract.

●       Determining whether you are entitled to free access as a general practitioner: necessary for the performance of the contract.

●       Communicating your completed e-learnings for the purpose of awarding accreditation points by the RIZIV: necessary for the performance of the contract and in the context of the accreditation of physicians.

●       Sharing your contact details with the partner you have chosen to finance your e-learning: based on your consent, which you can withdraw at any time. See point 5.

●       Billing and accounting: necessary to comply with a legal obligation.

●       Customer support and communication regarding your account or the e-learnings: necessary for the performance of the contract and based on our legitimate interest in being able to assist you smoothly.

●       Sending our newsletter: based on your consent, which you can withdraw at any time.

●       Analyzing and improving the platform via Google Analytics: based on your consent, which you provide via the cookie banner.

●       Securing the platform and preventing abuse and fraud: based on our legitimate interest.

4. Your RIZIV Number

Your RIZIV number is a professional identification number. We process it solely for the following purposes:

●       identifying you as a healthcare provider and determining whether you are entitled to free access;

●       communicating your completed e-learnings to the RIZIV;

●       awarding accreditation points by the RIZIV.

Your RIZIV number will not be used for other purposes. It will not be shared with a partner under any circumstances.

5. Free Access and Our Partners

Are you a general practitioner? Then all e-learnings are free for you. You do not need to choose a partner, and no data will be shared with a partner in that context.

Are you a specialist physician or practicing another medical specialty? Then you can choose a partner who finances the cost of your e-learning upon registration, making the e-learning free for you. If you do not choose a partner, you will pay yourself, and no data will be shared with a partner.

What the partner receives. If you choose financing by a partner, we will share with that partner: [to be filled in: for example, your first and last name and your email address], along with the indication that you have chosen that partner. The partner may use this data to present their offer to you. This occurs solely based on your explicit consent, which you provide on the selection screen before your registration.

What the partner does not receive. Your RIZIV number, your progress, your results, and your obtained accreditations will never be shared with a partner.

Withdrawing your consent. You can withdraw your consent at any time via support@docemo.tech or via the unsubscribe link in the partner's communication. The withdrawal applies to the future and does not affect the lawfulness of the processing prior to the withdrawal. You retain access to the e-learnings for which you were already registered.

No influence on content. Partners do not determine which subjects are covered, do not write lesson content, and do not have access to your learning results. The editorial responsibility for the e-learnings rests solely with Docemo.

Partner's own responsibility. Once a partner has received your data, they act as an independent data controller for the use they make of it. For exercising your rights regarding that processing, you can directly contact that partner; we will assist you if requested.

6. Recipients and Processors

For certain processing, we rely on external service providers who act as processors and only act on our behalf and according to our instructions. We have entered into a processing agreement with each of them. These include:

●       the hosting provider responsible for hosting the platform;

●       the email provider that sends our confirmation and system emails;

●       the newsletter provider responsible for sending our newsletter;

●       Google Analytics, for measuring and analyzing the use of the platform, provided by Google Ireland Limited (with Google LLC in the United States);

●       the payment provider that processes the payment for paid e-learnings.

In addition, data is shared with the following recipients, who act not as processors but as independent data controllers:

●       the RIZIV, as the competent authority for awarding accreditation points, for the data regarding your completed e-learnings;

●       the partner you may have chosen, for the data and on the basis described in point 5.

Outside the cases described in point 5, we do not share your personal data with third parties for their own commercial purposes. We do not sell your personal data under any circumstances.

7. Transfer Outside the European Economic Area

In the context of using Google Analytics, data may be transferred to the United States. This transfer occurs with appropriate safeguards, namely based on the EU-US Data Privacy Framework and/or the standard contractual clauses (SCCs) approved by the European Commission. We do not transfer personal data outside the EEA without an appropriate safeguard in place.

8. Retention Periods

We do not retain your personal data longer than necessary for the purposes for which they were collected:

●       account and learning data: 2 years after the last activity on your account or until the deletion of your account;

●       data related to obtained accreditations: 10 years, in accordance with the general statute of limitations, so that you can demonstrate your accreditation and the awarding of points upon request;

●       billing and accounting data: 7 years, in accordance with the Belgian legal retention obligation;

●       proof of your consent for sharing with a partner: 5 years after the withdrawal of consent or after the end of the agreement, to demonstrate the lawfulness of the processing;

●       newsletter data: until you unsubscribe;

●       support and contact data: 2 years after your inquiry has been handled.

9. Your Rights

You have the following rights regarding your personal data: the right to access, to rectification, to erasure, to restriction of processing, to object to processing, and to data portability. When processing is based on your consent, you can withdraw that consent at any time, without affecting the lawfulness of the processing prior to the withdrawal.

You can exercise these rights by contacting us at support@docemo.tech. We may ask you to confirm your identity before we respond to your request.

If you believe that we are not processing your personal data correctly, you can always contact us. You also have the right to lodge a complaint with the supervisory authority:

Data Protection Authority (GBA), Drukpersstraat 35, 1000 Brussels — +32 2 274 48 00 — contact@apd-gba.be

10. Security

We take appropriate technical and organizational measures to protect your personal data against loss, misuse, and unauthorized access, and to ensure the secure operation of the platform.

11. Cookies

Our platform uses cookies and similar techniques. More information about this can be found in our cookie policy.

12. Changes to this Privacy Policy

We may amend this privacy policy from time to time, for example, in response to changed processing or new legislation. The most recent version is always available on our platform. The date at the top indicates when the policy was last updated.

13. Contact

For questions or comments regarding this privacy policy or the processing of your personal data, you can contact us at support@docemo.tech or at the address mentioned above.