Savics SRL Data Privacy Policy

1. Welcome!

We are committed to ensure the protection of your privacy. This privacy policy explains how we process information that can be used to directly or indirectly identify you as an individual and collected through your use of our websites, applications, platforms, products and services.

By using our services, platforms, websites, applications and/or our online pages available on platforms and social networks, you agree to the conditions of this Privacy Policy. If we change our Privacy Policy, we will post the changes on this page to keep you informed of the information we collect, how we use this information, and whether the information is shared with other parties.

2. What terms do we use in this Privacy Policy?

We use any of the terms:

  • SAVICS, “we”, “us”, and “our” to refer to Savics SRL, a company incorporated under the laws of Belgium with registered office at Rue de l’Hospice Communal, 6, 1170 Brussels, Belgium and company number 0649.519.522, acting as controller under the Privacy Laws.
  • “User(s)” “you”, “your” and “yours to refer to the user(s) of our websites, platforms, online pages and services.
  • “Personal Data” to refer to personally identifiable information about you as defined in the Privacy Laws.
  • “Privacy Laws” to refer to EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation), together with the other related domestic and international legislation implementing, supplementing and/or resulting from such Regulation, as updated from time to time.
3. What information do we collect?

The types of Personal Data that we collect will depend on the communication, application or service you apply for or receive. We seek such Personal Data directly from you or by using log-in functionality (such as “Facebook Connect”, “Google Account” or “LinkedIn Sign In” for example). You may always choose not to provide the requested information, but we may be unable or unwilling to provide the communication, application or service you request.

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, respond to a survey, submit a description, publish or answer to a request for proposal, or make marketing research.

You and others may post content that includes information about you on our Services (as part of blog posts, feed updates and comments, documents, videos).

We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install one of our mobile apps, share articles. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

We collect information about you when you send, receive, or engage with messages in connection with our Services.

4. For what purposes do we collect Personal Data?

We will not use your Personal Data for other purposes than those stated in this Privacy Policy or for the purpose specifically indicated when we collect it.

The legal basis for the processing of your Personal Data are:

  • The contractual necessity. It means that we must process your Personal Data in order to deliver the Services that you asked for. Our online form clearly identify which fields are “required” as contractual necessity; and
  • Your consent. By ticking the box on the relevant page and submitting your Personal Data to us, you will be treated as having given your permission for the processing of your Personal Data as set out in this Privacy Notice. You have the right to withdraw consent at any time either by using the tools available on our website, platforms or apps or by sending us an email at support@savics.org.

In particular, we use your Personal Data in order to:

  • Identify you as a contracting party
  • Provide demonstrations;
  • Provide you with communication in relation to our Services;
  • Confirm or correct Personal Data;
  • Help us run our business and compliance programs;
  • Audit our business;
  • Run surveys;
  • Perform marketing researches;
  • Job Application;
  • Personalize your experience (the information will help us better respond to your individual needs);
  • Enable secure login for you in the Service;
  • Establish a primary channel of communication with you;
  • To Produce and display cookie declarations

We may use your information to produce aggregate insights that do not identify you. For example we may use your data to generate statistics about our users, their profession or industry or the demographic distribution of visitors to a site.

5. Legal Basis : EU General Data Protection Regulation (GDPR)

The processing of your data is either based on your consent or in case the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, cf. GDPR art. 6(1)(a)-(b).

If the processing is based on your consent, you may at any time withdraw your consent by contacting us using the contact information in clause 16.

In order to enter into a contract regarding the purchase of our service, you must provide us with the required personal data. If you do not to provide us with all the required information, it will not be possible to deliver the Service.

6. For how long do we store your Personal Data?

We will store your Personal Data for the duration necessary to achieve the purposes, subject to your right to erasure if applicable.

We may keep and use public and non-personal data that you provided to us and/or that we inferred from your data, for a longer period.

7. Do we transfer your Personal Data outside Europe?

We do not transfer your Personal Data outside of the European Union.

8. Do we share your Personal Data?

We will not disclose, transfer, sell, rent or exchange your Personal Data to any other organization or entity unless you are first notified and you expressly agree to it, or as otherwise required by law.

Nevertheless we are disclosing and transferring your Personal Data to services vendors and contractors, acting as processors under the Privacy Laws, which intervention is necessary in order to perform the purposes aforementioned (for example the hosting service providers)

Such trusted parties may have access to personally identifiable information on a need-to-know basis and will be contractually obliged to keep your information confidential.

We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or others’ rights, property, or safety. Furthermore, non-personally identifiable information may be provided to other parties for marketing, advertising, or other uses.

9. What are your rights in relation to your Personal Data?

Pursuant to the Privacy Laws we will make Personal Data available to you for review pursuant to a simple request from you. If you tell us that the Personal Data is incorrect or is used inappropriately, we will correct, update or delete Personal Data as appropriate. To this end you have the following rights:

9.1. Right of access

You have the right to access your Personal Data and supplementary information. The right of access allows you to be aware of and verify the lawfulness of the processing.

9.2. Right to rectification

You have a right to have inaccurate Personal Data rectified, or completed if it is incomplete. You can make a request for rectification verbally or in writing. In certain circumstances we can refuse a request for rectification if it is manifestly unfounded or excessive.

9.3. Right to erasure

You have a right to have your Personal Data erased. The right to erasure is also known as ‘”The right to be forgotten”. You can make a request for erasure verbally or in writing.

This right is not absolute and only applies in certain circumstances. You have the right to have your Personal Data erased only if:

  • the Personal Data is no longer necessary for the purpose which we originally collected or processed it for;
  • we are relying on your consent as your lawful basis for holding the data, and you have withdrawn your consent;
  • we are relying on legitimate interests as our basis for processing, and you have objected to the processing of your Personal Data, and there is no overriding legitimate interest to continue this processing;
  • we are processing your Personal Data for direct marketing purposes and you have objected to that processing;
  • we have processed your Personal Data unlawfully
  • we have to do it to comply with a legal obligation; or
  • we have processed your Personal Data to offer information society services to a child.

Also the right to erasure does not apply if processing is necessary for one of the following reasons:

  • to exercise the right of freedom of expression and information;
  • to comply with a legal obligation;
  • for the performance of a task carried out in the public interest or in the exercise of official authority;
  • for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing; or
  • for the establishment, exercise or defense of legal claims.
9.4. Right to restrict processing

You have the right to request the restriction or suppression of your Personal Data. You can make a request for restriction verbally or in writing. When processing is restricted, we are permitted to store the Personal Data, but not use it.

This is not an absolute right and it only applies in certain circumstances.

9.5. Right to object
  • You have the right to object to:
    processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
  • direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.
9.6. Right to transparency

We will at all times keep you informed about changes to the processes to protect data privacy and security, including practices and policies. You may at any time request information on where and how data is stored, secured and used.

9.7. Personal Data breach notification

In the event that your data is compromised, we will notify you and competent Supervisory Authority(ies) within 72 hours by e-mail with information about the extent of the breach, affected data, any impact on the Service and SAVICS action plan for measures to secure the data and limit any possible detrimental effect on the data subjects.

“Personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed in connection with the provision of the service.

9.8. Right to data portability

The right to data portability allows you to obtain and reuse your Personal Data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.

The right to data portability only applies:

  • to Personal Data that you have provided us;
  • where the processing is based on the individual’s consent or for the performance of a contract; and
  • when processing is carried out by automated means.

Upon valid request, we will provide your Personal Data in a structured, commonly used and machine readable form, free of charge.

For more information about how to get access to your Personal Data and for exercising your rights, please refer to the contact points mentioned in this Privacy Notice.

10. Is your Personal Data protected?

We maintain reasonable physical, electronic, standard security practices, including encryption, passwords and physical security measures, and managerial procedures to protect the security and confidentiality of your Personal Data. Only a limited number of persons within us are authorized to access, delete or modify your Personal Data. We will make reasonable efforts to ensure that your privacy interests are protected.

All personnel to access, delete or modify your Personal Data, are subject to full confidentiality and any subcontractors are required to sign a confidentiality agreement if not full confidentiality is part of the main agreement between the parties.

11. Are we using automated decision or profiling?

We do not use automated decision mechanisms or profiling based on your Personal Data.

12. Do we use cookie to obtain information?

As further described in our Cookie Policy, we use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to personalize your viewing experience and to recognize you and/or your device(s) on, off and across different Services and devices. We also allow some others to use cookies as described in our Cookie Policy. You can control cookies through your browser settings and other tools. You can also opt out from our use of cookies and similar technologies that track your behavior on the sites of others for third party advertising.

When you visit our online pages within a platform or social network (Facebook, Google+ …) they could also use cookies.

13. Other Privacy policies?

When you visit our online pages within a platform, a social network (Facebook, Google+, …) or a third-party website, you are also subject to the Privacy policies and terms and conditions of these platforms, social networks and third-party websites. We recommend that you also read their Privacy policies and terms and conditions.

14. Google Analytics

We use the “Google Analytics Service”.

You may use the Google Analytics Opt-out Browser Add-on which provides you the ability to prevent your data from being collected and used by Google Analytics.

The services described in this section involve the use of Cookies. For more information please visit our Cookie Notice.

15. How to lodge a complaint ?

You have the right to lodge a complaint with the Belgian Data Protection authority (https://www.dataprotectionauthority.be/).

16. How to contact us?

For further information, or inquiries about our Privacy practices, please contact us at:
SAVICS SRL
Rue de l’Hospice Communal, 6, 1170 Brussels, Belgium
support@savics.org

 

–
Last Updated: November 27th , 2019