Privacy Policy

Privacy Policy of Spectator

Privacy Policy of Spectator eHealth Holding B.V.

(‘Spectator Healthcare Technology’)


1.                   Spectator Healthcare Technology

Spectator eHealth Holding B.V. (‘Spectator Healthcare Technology’, or ‘Spectator’) is a private company, based in The Netherlands. We commercialize our business activities not only in the European Economic Area (EEA), but also in countries in other continents, such as Africa, Middle East and Latin America. The data of our European based Business Partners is stored on servers within the EEA. Protecting the security and privacy of personal data of contact persons (each a “Business Partner Contact”) at our customers, suppliers, vendors, operators and partners (each a “Business Partner”) is important to Spectator.
This Privacy Policy contains information about when and how the personal data of a Business Partner and/or a Business Partner Contact are collected, used, protected and disclosed, when using our applications, products and website. This includes features, software and services provided via the applications, products, and website.


2.                   Spectator products and services

2.1          Processing of data

Spectator enables processing of data for healthcare providers that use the Telehealth platform, Tele-Assistance Room (TAR) and BiDiApp, that are developed by Spectator. This enables healthcare providers to monitor their patients and clients remotely. The healthcare providers, the Business Partners of Spectator, are responsible for the processing. Spectator does not have direct access to personal data.

Spectator creates the technology for the Telehealth platform and BiDiApp. Our Business Partners, the Healthcare providers, will purchase our services. Our Business Partners will determine which apps they will use, the purposes for which they will do so, the diagnoses for which an app will be implemented, and the threshold values at which action must be taken by either the healthcare provider or the patient. Spectator provides the technology and support and makes the platform and app easy to use.

Spectator Healthcare Technology reserves the right to adjust the conditions of this Privacy Policy. We advise a Business Partner and/or a Business Partner Contact to review the privacy policy on our website periodically for any changes. We will notify a
Business Partner and/or Business Partner Contacts of any changes by posting the updated Privacy Policy on this website or in the Spectator newsletter.

2.2          What data is explicitly processed in the Telehealth platform, Tele-Assistance Room (TAR) and BiDiApp?

The information from users processed by our Business Partners, the healthcare providers, contains personal contact information of patients/clients which is needed for a proper administration by those organizations. Furthermore, all kinds of information regarding the health status and medication of clients/patients will be processed by these healthcare providers. Spectator will not have access to personal information from users of the Telehealth platform, Tele-Assistance Room (TAR) and BiDiApp such as a patient or healthcare professional.

2.3          For what purposes will the data be processed?

Through our Spectator Telehealth Platform, Tele-Assistance Room (TAR) and BiDiApp we allow our Business Partners, the healthcare providers, to provide remote Primary Care, Chronic Care and Elderly Care services. To facilitate these remote services, the exchange of data, as referred to in the General Data Protection Regulation (GDPR) is necessary. Our Business Partners, the healthcare providers may only process personal data via our services if there are legal grounds to do so and if they comply with the General Data Protection Regulation (EU) 2016/679 and other national relevant guidelines and laws.

Immediate goals of services based on our technology are:

o   Provide immediate and remote access to remote care, independent of social status and geographical location

o   Monitoring complaints and symptoms, e.g. for post-surgery and chronic patients

o   Transfer knowledge and conduct tests

o   Influencing behaviour change for beneficial medical outcomes (preventive care)


3.                   Business Partners

3.1          Collection of personal data

In certain cases, Spectator processes personal data for its own purposes and, for this, Spectator takes responsibility itself. In the context of the business relationship with Spectator, Spectator may process personal data for the following other purposes:

1. Communicating with Business Partners about products, services and projects of Spectator, e.g. by
    responding to inquiries or requests;
2. Planning, performing and managing the (contractual) relationship with Business Partners, e.g. by
    performing transactions and orders of products or services, delivering our data and services,
    processing payments, facilitating updates and providing support services;
3. Administrating and performing customer surveys, marketing campaigns, market analysis,
    promotional activities;
4. Maintaining and protecting the security of our products, services and websites, preventing and
    detecting security threats, fraud or other criminal or malicious activities;
5. Ensuring compliance with legal obligations (such as record keeping obligations), Business Partner
    compliance screening obligations (to prevent white-collar or money laundering crimes), and
    Spectator policies or industry standards; and
6. Solving disputes, enforce our contractual agreements and to establish, exercise or defend legal

For the aforementioned purposes, the following data can be processed in the following categories of personal data:

o   Contact information, such as full name, address, telephone number, mobile phone number,
picture, fax number and work email and work phone number;

o   Payment data, such as data necessary for processing payments and fraud prevention,
including credit/debit card numbers, security code numbers and other related billing

o   Further information necessarily processed in a project or contractual relationship with
Spectator or voluntary provided by the Business Partners or Business Partner Contacts, such
as orders placed, payments made, requests, and project milestones;

o   Information collected from publicly available resources, integrity data bases and credit

The processing of personal data is necessary to meet the aforementioned purposes including the performance of the respective (contractual) relationship with Business Partners and/or Business Partner Contacts. Unless indicated otherwise, the legal basis for the processing of personal data is Article 6 (1) (b) or (f) of the General Data Protection Regulation or - if explicitly provided by Business Partner Contacts – the consent (Article 6 (1) (a) of the General Data Protection Regulation). If Spectator does not collect the respective personal data, the purposes described may not be met by Spectator.

3.2         Information we collect

We will collect personal data on this website via the contact form only if it is directly provided to us by you, the user, e.g. your name, email address and telephone number, and therefore has been provided by you with your consent.

We will process the data that you provide to us in accordance with the DPA and GDPR, but we will not transfer, share, sell, rent or lease your personal data to third parties.

We use cookies to ensure that we give you the best experience on our website. These cookies are all anonymized and functional, therefore we do not need to ask for your consent but do want to inform you. Click here for the cookie policy of Spectator Healthcare Technology. 

3.3          Links to Other Sites

Our Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.


4.                   Processing of personal data of companies, job applicants and website visitors

4.1  We may process your personal data for our own purposes. We are then responsible for the processing. We do this in the following cases:

o   You are a business customer of ours, such as a contact person of a healthcare institution, who uses or wishes to use our services.

o   You contact us by phone, email, website, social media or in another way, because you have a question, comment or complaint.

o   You are interested in our organization and wish to apply for a job with us or participate in a recruitment event.

For job applicants and participants in recruitment events, we process the personal data provided before or during the application or participation. This may include contact details (name and address), information contained in a CV or cover letter, diplomas and qualifications, information on work experience, references and public profiles on social media, such as LinkedIn, and information provided by you during the procedure. When you participate in a recruitment event, we may record details of your participation and your interests in a report. If you complete an assessment or submit results, we will process these results for your application.

We may send our (business) customers direct marketing emails about our services and relevant industry developments. We use common tracking techniques that provide insight into the reach and effectiveness of our direct marketing communications. This helps us to improve our services and to focus our information and communications on relevant target groups.


5.                   Children’s Privacy

Our Services do not address anyone under the age of 13. We do not knowingly collect personal identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.


6.                   Security

Spectator has taken appropriate technical (e.g. encryption technology) and organisational measures to protect personal data against loss or against any form of unlawful processing. Information security is in the hands of our excellent internal Security professionals and has been awarded with a number of external recognitions.

The latest version of the information security policy of Spectator is available upon request. A copy of the information security policy can be requested from the Data Protection Officer using the contact details set out under the section "How you contact us" of this Privacy policy.

Spectator and/or its Business Partners will make sure that the General Data Protection Regulation (EU) 2016/679 and relevant guidelines, e.g., concerning the logging of actions are complied with.


7.                  Storage terms

We do not store your personal data longer than is strictly necessary. If there is a contract, we will process your personal data for the duration of the contract. Thereafter, we may retain your personal data to the extent necessary for the purposes set out in this Privacy Statement or to the extent required by law. For example, we are obliged to keep certain tax data for seven years. After this period, we will delete your personal data.

We process applicants' personal data up to 4 weeks after the application process or the recruitment campaign has ended, unless you have indicated that we may keep your personal data on file. In that case we will keep your personal data for another year in order to inform you about interesting vacancies or new recruitments.

Retention periods for e-mail messages depend on the nature of the messages. For example, if you make a request or complaint, we will keep your message for two years after the request or complaint has been dealt with. Depending on the type of cookie, we will retain the data collected via cookies for up to two years thereafter. Click here for the cookie policy of Spectator Healthcare Technology. 

8.                   Your rights

Under the Privacy Act, you have a number of rights in relation to your data and its processing.

o   Right of access. This is the right to ask us whether we hold personal data about you and to see this data.

o   Right to rectification. You can ask us to amend incorrect or incomplete personal data.

o   Right to be forgotten. In some cases, you have the right to have your personal data deleted by Spectator, for example, when your personal data is
     no longer needed for the purposes for which we obtained it.

o   Right to restriction. This is the right to have less personal data processed or to temporarily stop processing. You can request this, for example, if
     you have disputed the accuracy of your personal data.

o   Right to data portability. If we process your personal data on the basis of a contract or consent, you have the right to data portability. This is the
     right to receive your personal data from us so that you can transfer it to another party.

o   Right to object profiling. You can object to the processing of your personal data. If your personal data is processed for direct marketing purposes or
     on the basis of Spectator's legitimate interests, you can always object to the processing of your personal data.

o   Withdrawal of consent. If you have given us your consent to process your personal data, you may withdraw this consent at any time. This
     withdrawal will not affect the processing of your personal data before your consent was withdrawn.

o   Right to lodge a complaint with a supervisory authority as mentioned under the subchapter ‘Updates and adjustments’ of this privacy policy.

o   We are not always obliged to comply with your request(s). However, we will always respond to your request, at least within one month. Only in
     special cases may we take longer, but if that is the case, we will always keep you informed of our progress.


9.                   Contact and complaints

If you have any questions or complaints about this Privacy Statement, or if you wish to exercise your rights, please contact us by e-mail at


10.               Updates and adjustments

If you suspect that Spectator Healthcare Technology is in breach of privacy and data protection legislation (GDPR), please feel free to contact us. We will be happy to assist you further. For the avoidance of doubt, you have the right to lodge a complaint with a regulator. In the Netherlands this is the Dutch Data Protection Authority.