Last Updated: 30/05/2023
WELLBEING.AI BV is a private limited liability company, with registered office at Schaarbeeklei 647, 1800 Vilvoorde and registered with the Belgian Crossroad Bank of Enterprises under number 0771.311.138 (“WELLBEING.AI” or “we”). References to “you” and “your” refer to persons external to WELLBEING.AI (users of our Website, prospects, customers, end users, resellers, suppliers and job applicants).
The protection of your personal data is really important to us. We will ensure that your personal data is processed safely and lawfully, and always in accordance with applicable data protection legislation, and in particular with the General Data Protection Regulation (“GDPR”).
- WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
WELLBEING.AI BV, with registered office at Schaarbeeklei 647, 1800 Vilvoorde and registered with the Belgian Crossroad Bank of Enterprises under number 0771.311.138 is responsible for the processing of your personal data.
- WHAT PERSONAL DATA DO WE PROCESS?
We will process directly identifying information about you when you provide us with such personal data (for example, through the completion of a contact form or your registration on our Website) or when you contact us directly by e-mail.
Such personal data can include the following information:
- Contact information. Your name, e-mail address, address and phone number.
- Log-In and Password. In order to access your account on our Website.
- Subscriptions/preferences. When you subscribe to receive briefings, updates or newsletters as well as consent preferences to help us identify which materials you are interested in receiving.
- Supplier data. Contact details and other information about you or your company where you provide services to WELLBEING.AI.
- Technical information. When you access the Website, the information being IP address, browser type and version (e.g. Internet Explorer, Firefox, Safari etc.), time zone setting, browser plug in types and versions, operating system you are using (e.g. Vista, Windows XP, MacOS, etc), device type, hardware model, MAC address, unique identifiers and mobile network information.
We will also process certain non-directly identifying data when you visit our Website, such as the type of browser you are using, the operating system you are using, your IP address, etc.
- WHY DO WE PROCESS YOUR DATA AND UNDER WHICH LEGAL BASIS?
For the technical and functional management of the Website
We process personal data for the technical and functional management of our Website and to make the Website easy to use. By using your data, we can check how our Website is used and we can improve its content and lay-out. This data also allows us to adequately secure our Website.
We process this data based on the legitimate interest of WELLBEING.AI in providing a well-functioning and secure Website.
To process your orders
If you wish to purchase our solution, we need certain information from you to be able to provide you with a formal order and to keep you informed about your order.
For this we may collect your name, e-mail address, delivery address(es), payment details and your phone number. The data is necessary to execute the agreement you have made with us or with one of our sales partners.
To manage your account and provide you with our services
In your personal account we store the following data: your name, address(es), phone number, e-mail address, payment details and communication through the Website.
To communicate with you
We process your personal data to contact you by e-mail, telephone, SMS, or other equivalent forms of electronic communication, such as through the Website or a mobile application’s push notifications regarding updates or informative communications related to the functionalities or the solution in general, including the security updates, when necessary or reasonable for their implementation. This information is necessary for WELLBEING.AI to provide you with our services.
To keep you informed of our services and activities and for direct marketing
We process your personal data to keep you informed of our activities, for example, with our newsletter and legal updates, invitations to seminars, workshops or other events.
To this end, we can process data such as your name, your behaviour on the Website, your address, your e-mail address and your preferred language.
We process this information based on our legitimate interests to keep our prospects or customers informed of our activities and services. You can object to this processing of your personal data at any time.
To answer your questions
We use your personal information to communicate with you via different channels (e.g., by phone, e-mail, through the Website).
For this, we can process data such as your name, your contact information, your correspondence with WELLBEING.AI, and any other personal data you provide that may be relevant to answering your question.
We process this information based on our legitimate interests. You are free to choose to provide us with your personal data, and you object at any time.
To make contact in the context of a selection and recruitment process
When you apply for a job through the Website or by e-mail, we process your personal data in order to contact you and to follow up your application.
For this, we can process data such as your name, your contact information, your correspondence with WELLBEING.AI, your resume, and other documents you provide us with.
The processing of your personal data for this purpose is based on your request to take steps prior to entering into a contract.
To comply with our legal and regulatory obligations
In certain cases, we collect and use your personal information to comply with laws. For instance, we have to comply with certain legal and regulatory obligations such as with respect to anti-money laundering, KYC declarations and sanction checks. We must also comply with our tax and accounting obligations.
For this, we can process data such as your name, your contact information, your correspondence with WELLBEING.AI and your financial data (if any).
The processing of your personal data for this purpose is based on the need for WELLBEING.AI to respect a legal obligation we need to comply with.
Handling our own disputes
We may process your personal data to handle our own disputes and protect and enforce our rights.
For this, we can process data such as your name, your contact information, your correspondence with WELLBEING.AI and your financial data.
The processing of your personal data for this purpose is based on our legitimate interests consisting in being able to safeguard our rights in the event of disputes.
- WHO HAS ACCESS TO YOUR PERSONAL DATA?
WELLBEING.AI makes use of AWS to manage and host the Website and has therefore entered into a processing agreement with AWS.
WELLBEING.AI’s servers are located in Germany. In the context of the use of some software applications, personal data may be temporarily transferred to countries outside the Economic European Area. In such a case, an adequate level of protection is provided through the use of the European Commission’s Standard Clauses.
We may use third-party service providers to monitor and analyze the use of our Website.
Our Website allows you to follow us on social media channels, e.g., LinkedIn and Twitter. We do not use these buttons to share your personal data with social media providers. When you click on a “follow” button, the relevant social media provider will gather your personal data directly from you. Please read the privacy notice of any social media provider with which you intend to share your personal data.
Other third parties
We may share your personal data with:
- (sub)contractors for assisting us in fulfilling the purposes listed above;
- service providers to monitor and analyze the use of our Website, for payment processing, or to contact you;
- our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;
- judicial, police or administrative authorities if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, a binding decision of an administrative authority or a court order;
- investors and other relevant third parties in in the event of a potential sale or other corporate transaction related to WELLBEING.AI;
- other Website users: when you share personal data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
WELLBEING.AI will only share your personal data with these third parties provided that they comply with GDPR if they act as independent controllers, or based on a data processing agreement if they act as processors. For a detailed list of these third parties, please contact us by e-mail at firstname.lastname@example.org.
- HOW DO WE PROTECT YOUR PERSONAL DATA AND HOW LONG DO WE KEEP YOUR PERSONAL DATA?
WELLBEING.AI takes reasonable security measures to protect your personal data from destruction, loss, modification or any other unauthorized processing.
WELLBEING.AI does not store your personal data for longer than necessary for the purposes for which it is stored. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
If you would like to find out how long we keep your personal data for a particular purpose you can contact us by e-mail at email@example.com.
- WHAT RIGHTS DO YOU HAVE AND HOW CAN YOU EXERCISE YOUR RIGHTS?
- You have the right to access your personal data. This allows you to find out which personal data we process about you.
- You have the right to correct your personal data. This allows you to correct or complete incorrect or incomplete personal data that we process about you.
- You have the right of deletion of your personal data. This allows you to permanently delete the personal data we process about you. We are not always obliged to delete your personal data at your request – this right only applies in the cases and to the extent provided for by law.
- You have the right to limit the processing of personal data relating to you. This allows you to freeze our use of your personal data without deleting it. We are not always obliged to limit the processing of your personal data at your request – this right only applies in the cases and to the extent provided for by law.
- You have the right to object to the processing of your personal data. This allows you to object to the further processing of your personal data. We are not always obliged to accept your objection – this right only applies if we process your personal data on the basis of our legitimate interest.
- You have the right to withdraw your consent when the processing of your personal data takes place on the basis of your consent. Withdrawal of your consent does not affect the lawfulness of the processing based on consent before withdrawal
- You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by us or by a third party. We will be allowed to continue to process your personal data if we can demonstrate “compelling legitimate grounds for the processing which override your interests, rights and freedoms” or we need this for the establishment, exercise or defense of legal claims. You can always object to the processing of your personal data for direct marketing purposes.
- You may have the right to data portability. This allows you to easily transfer, copy or move personal data from one controller to another. This right can only be exercised if the processing is based on your consent or on an agreement concluded with you.
You can direct your request based on the above rights and your complaints to firstname.lastname@example.org.
You also have the right to file a complaint with the supervisory authority of the place where you live. For Belgium this is the Belgian Data Protection Authority, (Gegevensbeschermingsautoriteit/Autorité de protection de des données). It can be reached by mail at Drukpersstraat 35, 1000 Brussels, Belgium, via website at the following address: https://www.gegevensbeschermingsautoriteit.be/ and by phone at: +32 (0)2 274 48 00.