PRIVACY POLICY
Version of September 2021 (Version History)
We understand that your trust in us, is Appwise’s (hereinafter referred to as "APPWISE ", "we "or "us ") most important asset. As such, your privacy is essential to us.
This privacy policy (hereinafter referred to as "Privacy Policy ") is applicable, inter alia, to (i) our websites https://www.appwise.beand https://wisemen.digital/ (hereinafter referred to as the "Website ") and (ii) all (commercial) relations between APPWISE and its customers, prospects and business partners.
This Privacy Policy includes information about the personal data collected by Appwise, as well as the manner in which APPWISE uses and processes this personal data.
APPWISE wishes to emphasize that it always attempts to act in accordance with (i) the Belgian Privacy Law of 30 July 2018 regarding the protection of natural persons in relation to the processing of personal data, (ii) the EU Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC, and (iii) other applicable data protection legislation.
Visiting the Website, subscribing to the newsletter, making use of the services and/or any other communication with APPWISE implies your explicit approval (through disclosure of your personal information or opt-in) of the Privacy Policy and consequently how we collect, use and process your personal data.
Please read this Privacy Policy in conjunction with APPWISE’ legal disclaimer and cookie policy.
The data controller of the processing activities is Appwise BV, with its registered office at Watertorenstraat 2, 3590 Diepenbeek, and with company number 0503.920.245, VAT BE 0503.920.245. The contact details of Appwise can be found under Article X of this Privacy Policy.
General
How does Appwise process your personal data?
Appwise may use your personal data for the following purposes:
Performance of the agreement with Appwise (incl. the follow-up thereof)
Drawing up a quote and/or issuing invoices
Providing support/assistance
Responding to questions (whether or not submitted via contact form)
Optimising the quality, management and content of the Website
Sending newsletters
Creating statistics
Optimizing the customer experience on the Website
Use of cookies, pixel tags and other technologies, as set out in the Cookie Policy on the Website (Appwise/ Wisemen)
As part of any other (commercial) relationship entered into with Appwise
All personal data, collected by Appwise, are thus expressly and voluntarily provided by you.
Providing certain personal data is (sometimes) a requirement to be able to enjoy certain services (e.g. to gain access to certain parts of the Website, to subscribe to newsletters, to participate in certain activities and events, delivery of your online quote). In this respect, it shall be indicated which data must be provided mandatory and which data is optional.
What is the legal basis for processing your personal data?
Processing takes place on the following legal grounds, as the case may be:
You have given consent to the processing of your personal data for one or more specific purposes
Marketing purposes such as sending newsletters
The use of cookies, pixel tags and other technologies (except for strictly necessary cookies)
Processing is necessary for the performance of the agreement with APPWISE or in order to take steps at your request prior to entering into an agreement
Performance of the agreement with APPWISE (incl. follow-up)
Sending of quotes and/or issuing invoices
Providing support/assistance
Processing is necessary for compliance with a legal obligation to which APPWISE is subject
Invoicing
Processing is necessary in order to protect your vital interests or those of another natural person
Processing is necessary for the performance of a task carried out in the public interest
Processing is necessary for the purposes of the legitimate interests pursued by APPWISE or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data (in particular when you are a child)
Responding to questions (whether or not received through the contact form): at your request, APPWISE will answer questions or provide information through various channels (including e-mail, contact form and social media)
Marketing towards existing customers or leads: APPWISE respects the applicable regulations, whereby direct marketing e-mails may only be sent if there is an existing customer relationship regarding similar products or services of APPWISE. You will always have the possibility to unsubscribe to such marketing activity.
The use of strictly necessary and functional cookies on the Website: the use of these cookies is necessary for the functioning of the Website for the purpose for which the visitor visits the Website
In case the legal ground for processing of personal data by Appwise is legitimate interest, Appwise wil always (i) assess the necessity of the processing activity in relation to the purpose of the processing (proportionality test), and (ii) assess whether you, the data subject, could reasonably expect the specific processing activity to take place,
in order to evaluate the possible effects of the processing activity on your fundamental rights and freedoms.
Processing activities for use of the Website
METHOD OF COLLECTION | PERSONAL DATA | PURPOSE | LEGAL GROUND | RETENTION PERIOD |
Fill in the contact form | Surname, first name, e-mail address, telephone/mo bile phone number, ... | Answering questions | Legitimate interest | Duration necessary to answer the question |
Cookies For more information we refer to the Cookie Policy as available on the Website of Appwiseand Wisemen. | IP address, click behaviour and input | Optimising and personalising your browsing experience. | Legitimate interest for necessary cookies. Explicit consent for non-essential cookies (consent can be withdrawn at any time). | Dependent on type of cookie. |
Subscribing to the newsletter | Name, first name, e-mail address | Informing you of news about our operations or events | Legitimate interest for existing customers, and explicit consent for others. | Immediately after the person concerned has unsubscribed or 1 year after the person no longer opens a newsletter. |
APPWISE also collects certain user and device data when using the Website. This information is anonymous when it does not reveal your identity and may not constitute processing of personal data. Examples of this type of user and device data include information collected through cookies, pixel tags and other technologies. More information about the collection of data via cookies can be found in Appwise’s Cookie Policy (Appwise/ Wisemen).
Other processing activities per category
METHOD OF COLLECTION | PERSONAL DATA | PURPOSE | LEGAL GROUND | RETENTION PERIOD |
HR-operations (job interviews) | First name, last name, address, e-mail, mobile phone number, telephone number, date of birth, place of birth, nationality, gender, language, leisure | HR (via Recruitee ) | Legitimate interest | Recruitment reserve, maximum 1 year. This period may be longer in the case of a |
activities and interests, marital status, academic curriculum, professional qualification, previous employer 's salary, work permit, current job, entire career, work organisation, training for the job | specialised profile that is more difficult to find (maximum 2 years). | |||
Finance (invoicing &payment reminders, registered mail) | Name, first name, company name, address, e-mail address, telephone number, bank account number, payment details, payment history | Invoicing | Execution of agreement | 8 years (the legal minimum retention period is 7 years) |
Operations (quotation procedure, customer acquisition, customer conversion, performance of customer contract, interaction with suppliers &partners, handling of rights of those involved, quality controls, ...) | Name, first name, company name, email address, mobile number, address, bank details and other project-specific data. | Operatio ns | Execution of agreement (customer contracts, quality controls, …) Remaining: legitimate interest | Execution of contract: The duration of the customer relationship + 6 months administrative period Justified interest: Until the processing purposes are achieved |
IT-operations (project work, internal server/backups, chatbot, platform work, IT security, customer inbox) | Name, first name, profession, position, company name, company address, email addresses, customer number, IP address, user account, click behaviour, other project-specific data | IT- operatio ns | Execution of the agreement | For the duration of the customer relationship + 6 months administrative period Server &backup data:max. 1 month Chatbot: For the duration to answer the question IT security: for the duration of the incident /investigation |
Sales &Marketing (Customer acquisition, customer management, customer inbox/customer portal, event mailings, CRM management, customer satisfaction) | Name, first name, profession, function, company name, company address, email addresses, direct marketing preferences, customer number, IP address, user account, click behaviour, other project-specific data, cookies | Sales &marketin g activities | Execution of the Agreement: customer management Legitimate interest: marketing mailings for existing customers / purely informational emails Eplicit consent: marketing mailings for non-existing customers | For the duration of the customer relationship + 6 months administrative period CRM management: as long as permission is not withdrawn/opt ed out, justified interest: 10 years (average customer relationship) |
APPWISE shall not disclose your personal data to third parties, unless it is necessary in the context of performing the agreement and optimisation thereof. In this respect, your personal data may be disclosed to software providers, cloud partners and service providers.
If it is necessary that APPWISE discloses your personal data to third parties, the third party concerned is required to use your personal data in accordance with the provisions of this Privacy Policy.
Notwithstanding the foregoing, it is however possible that APPWISE discloses your personal data:
To the competent authorities (i) if APPWISE is obliged to do so under the law or under legal or future legal proceedings and (ii) to safeguard and defend our rights
If APPWISE, or the majority of its assets, are taken over by a third party, in which case your personal data – which APPWISE has collected – shall be one of the transferred assets.
In all other cases, APPWISE will not sell, hire out or pass on your personal data to third parties, except when it (i) has obtained your permission to this end and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your personal data.
Any transfer of personal data outside the European Economic Area (EEA) to a recipient whose domicile or registered office is in a country which does not fall under the adequacy decision enacted by the European Commission, shall be governed by the provisions of a data transfer
/ processing agreement, which shall contain (i) the standard contractual clauses, as referred to in the 'European Commission decision of 4 June 2021 (Decision 2021/915)', or (ii) any other mechanism pursuant to privacy legislation, or any other regulations pertaining to the processing of personal data.
Unless a longer storage period is required or justified (i) by law or (ii) through compliance with another legal obligation, APPWISE shall only store your personal data for the period necessary to achieve and fulfil the purpose in question, as specified in the Privacy Policy under 'Use of personal data '.
In light of the processing of your personal data, you enjoy the following privacy rights:
Right of access to your personal data
The data subject shall at all times have the right to access and inspect the personal data processed by the company. The company will provide a copy of this personal data, if the data subject so requests.
Right to rectification, completion or update of your personal data
The data subject shall always have the right to have inaccurate, incomplete, inappropriate or outdated personal data deleted or corrected.
Right to delete your personal data ('right to be forgotten ')
APPWISE wishes to point out that in this context certain services will no longer be accessible and/or can no longer be provided if you delete resp. request deletion of certain required personal data.
Right to limit the processing of your personal data
The data subject has the right to limit data processing if:
He disputes the accuracy of the data for a period of time that allows the company to verify the accuracy
The processing is unlawful and he opposes the erasure of the personal data and instead requests restriction of their use
The company no longer needs the personal data of the individual for the processing purposes, but the data subject still needs them for the establishment, exercise or substantiation of a legal claim
He has objected to a processing operation, pending the answer to the question of whether his objection is well-founded
Right to transferability of your personal data
The data subject has the right to receive the personal data processed by the company in a structured, accessible and digital format in order to save it for personal use or reuse, or to transfer this personal data directly to another data controller. This right applies as far as this is technically possible for the data controller.
Right to object/oppose to the processing of your personal data
The data subject always has the right to object to the processing for reasons relating to his specific situation.
The data controller will immediately cease processing the personal data, unless he demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subjects or which are connected with the establishment, exercise of substantionl of a legal claim.
If you wish to invoke your privacy rights, please contact legal@appwise.be .
In principle, you can exercise these rights free of charge via the above-mentioned form.
If you no longer wish to receive newsletters or information about the products of APPWISE, you
can unsubscribe at any time by clicking the "unsubscribe "button underneath each of
APPWISE’s emails.
APPWISE undertakes to take reasonable, physical, technological and organisational precautions in order to avoid (i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data.
APPWISE shall store all personal data, which it has collected onsite or in the cloud with data centres in the EU.
Notwithstanding APPWISE’s security policy, the checks it carries out and the actions it proposes in this context, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the internet, or any method of electronic storage is 100% secure, APPWISE is, in this context, not in a position to guarantee absolute security.
Appwise is entitled to update this Privacy Policy by posting a new version on the Website. As such, it is strongly recommended to regularly consult the Website and the page displaying the Privacy Policy, to make sure that you are aware of any changes.
Each update can be consulted in detail in the version historyof the Privacy Policy.
The Website may potentially contain hyperlinks to other websites. When you click on one of these links, you may be redirected to another website or internet source that could collect information about you through cookies or other technologies. APPWISE does not bear any responsibility, liability or control authority over these other websites or internet resources, nor about their collection, use and disclosure of your personal data. You must check the privacy statements of these other websites and internet sources in order to be able to judge whether they act in accordance with the Privacy Legislation.
If you have questions and/or remarks about this Privacy Policy or the manner in which APPWISE collects, uses and/or processes your personal data, please contact us:
Via post: Watertorenstraat 2, 3590 Diepenbeek
In case you are not satisfied with the way APPWISE handled your questions and/or remarks or have any complaints about the way APPWISE collects, uses and and/or processes your personal data, note that you have the right to lodge a complaint with the Data Protection Authority:
Data Protection Authority (Gegevensbeschermingsautoriteit) Drukpersstraat 35, 1000 Brussel
Tel: +32 (0)2 274 48 00