Privacy Policy

Last updated: 14 November 2026

At Functional Migraine Clinic we place great value on the protection of your personal data. This privacy policy explains what data we collect, why we need it, how we secure it, and what rights you have.

1. Who processes your data?

The controller responsible for processing personal data is:

Functional Migraine Clinic
Visualized BV
Ten Ede 114A, 9620 Zottegem, Belgium
barbara@migrainekliniek.be
BE0689734435

For questions about this privacy policy, please contact us at barbara@migrainekliniek.be.

2. What data do we collect and why?

We process personal data exclusively for the following purposes:

2.1 Building Block Analysis

When you complete the Building Block Analysis questionnaire, we collect:

  • Name and email address (to deliver the analysis and for any follow-up communication)
  • Answers to the questionnaire (to produce a personalized report)
  • IP address and technical data (to prevent misuse and improve the service)

Purpose: This data is used to produce a personalized analysis and to provide insight into factors that may contribute to migraine. It is not used for medical diagnoses or treatments.

Legal basis: Your explicit consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR), as the questionnaire involves health data.

2.2 Orders for physical products

When ordering physical products through our website, we collect:

  • Name, address and contact details (for delivery and any order-related inquiries)
  • Payment details (where a payment is required)
  • Order information (such as the products you have ordered)

Purpose: This data is processed to correctly handle, ship and - where necessary - follow up on your order.

Legal basis: Performance of a contract (Art. 6(1)(b) GDPR).

2.3 DNA Migraine Blueprint

When ordering the DNA Migraine Blueprint, we collect and process:

  • Name, email address and shipping address (to send the test kit and deliver the report)
  • Genetic data (DNA analysis based on a buccal swab)
  • Raw DNA data (the full genotyping result we receive from the laboratory)
  • Answers to the Building Block Analysis questionnaire (for the clinical context of the report)

Laboratory: The DNA analysis is carried out by Genelink S.L. (trading as tellmeGen), Arquitecto Mora 5–4, 46010 Valencia, Spain (healthcare license no. 11540). Your swab is sent to this laboratory by post. The laboratory retains the biological sample for 60–120 days after issuing results (maximum 6 months) and destroys it thereafter. All processing takes place within the EEA.

Purpose: Genetic data is used solely to produce a personalized DNA migraine report and to give you insight into genetic factors that may contribute to migraine. It is not used for medical diagnoses, treatments or commercial purposes.

Legal basis: Your explicit consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR). Genetic data is a special category of personal data that enjoys additional protection. We process it only after your explicit, informed consent at the time of ordering.

Storage at Functional Migraine Clinic: Raw DNA data and the report are retained in your personal client file (see retention periods under § 3).

2.4 Special categories: health and genetic data

The Building Block Analysis and the DNA Migraine Blueprint involve health data and/or genetic data. These are special categories under the GDPR (Art. 9). We process this data exclusively on the basis of your explicit consent. This data is protected by additional security measures and will never be shared with third parties for commercial purposes.

3. How long do we retain your data?

We retain personal data for as long as necessary for the purpose for which it was collected, within the limits set by law.

  • Building Block Analysis data: maximum 5 years after the report is sent.
  • DNA data (DNA Migraine Blueprint): raw DNA data and the report are retained for a maximum of 10 years in your client file.
    Reason: Genetic data does not change. Long-term retention allows us to reinterpret your DNA data in light of new scientific insights, without requiring a new test.
    You can at any time request early deletion of your genetic data. The biological sample is destroyed by the laboratory (tellmeGen) within 6 months of analysis.
  • Data for physical product deliveries:
    Order data (including address and contact details) is retained for a maximum of 7 years for tax and administrative purposes.
    Shipping information is retained for a maximum of 2 years for customer service and return requests.

You may at any time request early deletion of your data, unless a legal obligation requires us to retain it.

4. How do we secure your data?

We take appropriate technical and organizational measures to protect your data against loss, misuse or unauthorized access. These include:

  • Encrypted storage of data
  • Restricted access for authorized personnel
  • Regular security reviews

5. Is your data shared with third parties?

Your personal data is not shared with third parties unless this is necessary for the delivery of our services or required by law. For certain processing activities we work with:

  • Payment providers (for processing payments)
  • Shipping partners (for delivering physical products)
  • Accounting software (for invoicing and administration)
  • DNA laboratory: Genelink S.L. (tellmeGen), Valencia, Spain - for processing DNA samples and genotyping. Processing takes place within the EEA.
  • Colleague practitioners and therapists. In that case, your permission to share your data will be sought.

These parties process your data only in accordance with our instructions and applicable legal requirements.

5a. Is your data processed outside the EEA?

For hosting (Microsoft Azure) and questionnaire tools (Google Forms) we work with US-based service providers that store data in European data centres. Because these companies are subject to US law, we cannot entirely rule out that data may be accessible from the US in exceptional circumstances. In such cases, appropriate safeguards are in place through Standard Contractual Clauses (SCCs) approved by the European Commission. Functional Migraine Clinic operates online and serves clients internationally. Where data is processed outside the EEA, equivalent protections apply.

6. Your rights

Under the GDPR, you have the following rights:

  • Right of access - Request a copy of your data
  • Right to rectification - Have incorrect data corrected
  • Right to erasure - Request deletion of your data
  • Right to restriction of processing - Request reduced processing of your data
  • Right to object - Object to certain types of processing
  • Right to data portability - Receive your data in a structured, commonly used format
  • Right to withdraw consent - Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing

To exercise any of these rights, send a request to barbara@migrainekliniek.be.

You also have the right to lodge a complaint with the Belgian Data Protection Authority (GBA), Drukpersstraat 35, 1000 Brussels - contact@apd-gba.be - www.gegevensbeschermingsautoriteit.be. If you are based outside Belgium, you may also contact the supervisory authority in your own country.

7. Cookies and tracking

Our website uses the following types of cookies:

  • Essential cookies - required for the website to function (e.g. session, form security). These are always placed.
  • Analytical cookies - we use Google Analytics (GA4) to collect anonymous visitor statistics. These cookies are activated only after your consent via the cookie banner.

You can change your cookie preferences at any time via the cookie banner at the bottom of the page. More information about how Google processes data can be found at policies.google.com/privacy.

8. Changes to this privacy policy

This policy may be updated when necessary. The most recent version is always available here.

Change log:

  • 14/11/2026: Sections renumbered to match the products offered on this website (Building Block Analysis, DNA Migraine Blueprint) · contact address updated
  • 04/03/2026: Section on the DNA Migraine Blueprint added · DNA retention period added under § 3 · tellmeGen added as sub-processor under § 5