Privacy Policy Platform

1. Intro

Data protection is of a particularly high priority for WELLBEING.AI.
By means of this privacy policy, WELLBEING.AIinforms you of the nature, scope, and purpose of the personal data we collect, use and process.

2. Definitions

In this data protection declaration, we use, inter alia, the following terms:

  • Personal data: Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Data subject: A data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
  • Processing: Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means.
  • Controller: A controller is the natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of personal data;
  • Processor: A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller

3. Contact details:


WELLBEING.AI BV, Schaarbeeklei 647, 1800 Vilvoorde, Belgium


Data Protection Officer:

Apogado CVBA, Arsenaalstraat 2, 2800 Mechelen, Belgium

4. Processing of personal data

WELLBEING.AI processes data for analyzing and understanding your personal wellbeing at work. We obtain information regarding your exposure towards (i) anxiety, (ii) engagement, (iii) burn-out and (iii) enjoyment during the performance of your work.

The Wellbeing Solution aims at detecting signs of decreased well-being in the workplace (such as anxiety, stress, and burnout), preferably before they behaviorally manifest and become a serious problem for both the individual and the organization.

In order to do this, following data will be processed:

  • Name and surname;
  • E-mail address;
  • Gender;
  • Age;
  • Family status;
  • Nationality;
  • Country of residence;
  • Department of employment;
  • Current position/role and position level;
  • Answers to mental health surveys;
  • Voice;
  • Facial expression (through facial coding);
  • Eye movement (through eye tracking);

WELLBEING.AI will process your personal data based on the consent you explicitly give in the consent form.

WELLBEING.AI will not process personal data from data subjects below the age of 16.

5. Data storage

WELLBEING.AI will process your personal data until either your consent is withdrawn or the contract between WELLBEING.AI and the organization you work for comes to an end.

When you stop using the Wellbeing Solution (e.g. use of application ended, consent revoked, data removal request …) your account and accompanying personal data will be deleted within 1 month.

WELLBEING.AI will store your personal data in accordance with legal obligations to which WELLBEING.AI is subject to.

Data that is present in the training set that WELLBEING.AI uses is anonymized and will be used to continue perfecting the Wellbeing Solution.

6. Your data protection rights

As a data subject, the General Data Protection Regulation gives you some rights you can exercise regarding the processing of your personal data. Following rights are granted to you:

  • Right to information: This privacy policy informs you over the personal data WELLBEING.AI processes.
  • Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the further information regarding the processing.
  • Right to rectification: You have the right to obtain the rectification of inaccurate or the completion of incomplete personal data concerning you.
  • Right to erasure (Right to be forgotten): You have the right to obtain erasure of your personal data.
  • Right of restriction of processing: You have the right to restrict the processing of personal data. This results in a temporarily halt of certain aspects of the processing.
  • Right to data portability: You have the right to receive a copy of the personal data concerning you in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller.
  •  Right to object: At any time you may object to the processing.
  •  Prohibition to automated individual decision-making, including profiling: Your personal data will not be used to make automated decisions that significantly affect you.

In order to exercise these rights or if you have further questions regarding these rights, you can sent a written request or question to the Data Protection Officer:

To react to a request to exercise these rights, we will need to confirm your identity.  The methods we use to confirm your identity and answer to these requests are in accordance with the law.


7. Third parties

WELLBEING.AI will not transfer your personal data to your employer or other third parties.

8. Third countries

WELLBEING.AI will not transfer your personal data outside the European Economic Area. WELLBEING.AI uses a webserver hosted in Frankfurt (EU)

9. Revoke consent

You have the right to withdraw your consent at any time. As a result, your personal data will no longer be processed. You can withdraw your consent by sending a written request to WELLBEING.AI:

10. Lodge a complaint with the supervisory authority

When you think your personal data is not being processed in accordance with the law, you have the right to lodge a complaint with the supervisory authority. Within the Belgian territory the supervisory authority is the “Gegevensbeschermingsautoriteit”: