Privacy Policy

This privacy policy sets out the privacy practices of Induxx NV in relation to the Website (hereinafter referred to as the ‘Privacy Policy’). As we are committed to protecting your personal data to the fullest extent possible, we will explain in this Privacy Policy how we will treat your personal data and this in accordance with the Belgian Law of 8 December 1992 on the protection of privacy in relation to the processing of personal data, as amended and updated from time to time, and in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC once it enters into force (hereinafter the ‘Privacy Act’). This Privacy Policy allows us to be open and transparent so that you can make meaningful choices regarding the use of your personal data. 2. By using our Website and/or our Services, you acknowledge that you have carefully read this Privacy Policy and that you unreservedly agree to it. We reserve the right to modify the Privacy Policy from time to time on our sole discretion. Any such changes will be communicated through the Website. 3. Please note that we may use ‘cookies’ or similar technology as part of the Website and/or the Services. Cookies are small text files that are placed on the hard disk of a device and contain certain information, sometimes including personal data. For more information regarding our use of cookies, please read our cookie policy. 4. Your personal data shall be collected and processed by Induxx NV, a Belgian company with its registered office at B-2550 Kontich, Veldkant 33 B and registered with the Crossroads Bank for Enterprises under the number 0693.689.362. 5. This Privacy Policy was last updated on 08/10/2018. This Privacy Policy is intended to be read together with our General Terms & Conditions and our Cookie Policy. We reserve the right to make changes to our Privacy Policy. The most recent version of our Privacy Policy will always be available on our Website. By using our Website, you consent to us collecting your personal data for the purposes specified in this Privacy Policy. Our Privacy Policy clarifies: – What personal data is collected – How we use your personal data and with whom it may be shared – Your rights in relation to the information collected

WHAT PERSONAL DATA DO WE COLLECT?

• Personal data you give us: For example, your name, address, e-mail address, telephone number when you enter these data in the contact form and any additional information as a result of purchasing services.
• Personal information we receive through your use of our Website or services:
  • Log Information: We store some information in server logs such as, but not limited to:
    • Internet Protocol address;
    • Browser information;
    • The external website that directed you to ours;
    • The pages you visited on our Website;
    • The time and date of each page you visited;
    • Details on how you use our services.
  • Device information: we may collect device-specific data e.g. serial number, hardware type, version, etc.
  • Local storage: using browser web storage, application data caches and other mechanisms on your device we may collect and store data (including personal data)
  • Cookies: we use cookies to identify our visitors, to remember customised preferences (e.g. language), etc. (for more information on what cookies are and how they are used, please refer to our Cookies Policy).

WHAT DATA DO WE PROCESS AND WHY

When you use the Website and/or Services, we process personal data relating to you. Such personal data contain:

• When? When using Services, contacting us, requesting a quote, using our Website
• What? Identification data
• Why (purpose)? Processing of request
• Legal grounds? Legitimate interest

• When? Signing up for newsletters, downloading white papers, requesting brochures or information
• What? Identification data
• Why (purpose)? Sending related information and supplements
• Legal grounds? Consent

• When? Use of live chat on Website
• What? Identification data
• Why (purpose)? Sending related information and supplements
• Legal grounds? Consent

6. As a rule, we obtain the personal data mentioned above directly from you. In addition to the above-mentioned purposes, we may also process your personal data 7. a. To provide you with the information you request on products and services in a personalised and efficient manner, either through the Website, e-mail, telephone or social media channels. 8. b. To process your personal data so we can provide the Services. 9. c. For direct marketing purposes, i.e. to provide you with targeted communications, promotions, offers and other advertisements from us or our select partners. We will ask for your prior consent for this purpose. 10. d. For carrying out statistical analyses to improve our Website and/or Services, or to develop new products or services. 11. e. To provide to a financial institution or payment service provider, to enable your financial institution and the payment service provider to fulfil their legal obligations. 12. f. To transfer to the police or judicial authorities as evidence of possible crimes or if there are reasonable grounds to suspect that a wrongful act or crime has been committed by you through your registration with or use of the Website or the Services. 13. g. In the context of a possible merger with, acquisition of/by or demerger by a third party, even if that third party is located outside the EEA. 14. If and when your registration on the Website or use of the Website or Services may be considered (a) a violation of the terms and conditions or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Services, (c) a threat to the Website or Services or our subcontractors’ systems from viruses, Trojans, spyware, malware, or any other form of malicious code, or (d) in any way illegal or unlawful, discriminatory or offensive, we may process your data in the interests of ourselves, our partners or third parties.

WITH WHOM DO WE SHARE DATA

15. With your consent: We will only share your personal data with other companies with your consent – as distinct from Induxx NV – Please note that the social media provider may collect your personal data if you press a social media button. In that case, the privacy policy of that provider shall apply. For legal reasons: We may share your personal data to comply with any applicable law or regulation or to comply with an order of a competent regulatory authority. With entities that process personal data for us: These entities may only process the personal data on our instruction and for the purposes necessary to achieve the purpose of the processing. These entities are equally bound by the Privacy Act. 16. We may use external processors to provide the Website and/or Services to you. We ensure that third party processors may only process your personal data on our behalf and upon written instruction from us. We guarantee that all third party processors are selected with due care to ensure the security and integrity of your personal data. 17. We may transfer anonymised and/or aggregated data to other organisations that may use this data to improve products and services and to organise the marketing, presentation and sale of products and services on a customised basis.

WHERE WE PROCESS DATA

18. We and our third party processors will only process your identifiable personal data in the EEA. 19. We may transfer your anonymised and/or aggregated data to organisations outside the EEA. If such a transfer takes place, we will ensure that appropriate safeguards are in place to guarantee the security and integrity of your personal data, and that all rights pertaining to personal data you may enjoy under applicable mandatory law are guaranteed. 20. If there is a transfer of your personal data and/or anonymised and/or aggregated data, the following legal protection mechanism will be implemented:

• What? HubSpot
• Country outside the EEA? USA
• Legal transfer mechanism? US – EU Privacy Shield

• What? MAILCHIMP
• Country outside the EEA? USA
• Legal transfer mechanism? US – EU Privacy Shield

• What? WHOISVISITING
• Country outside the EEA? USA
• Legal transfer mechanism? US – EU Privacy Shield

HOW WE PROCESS DATA

21. We will do our utmost to process only those personal data that are necessary to achieve the purposes stated in this Privacy Policy. We will process your personal data in a lawful, fair and transparent manner. We will do our utmost to keep the personal data accurate and up to date. 22. Your personal data will only be processed as long as necessary to fulfil the purposes set out in this Privacy Policy or until you withdraw your consent to its processing. Please note that withdrawal of consent may mean that you are no longer able to use all or part of the Website and/or Services. If you have registered on our Website, we will delete your personal data when you delete your profile, unless a legal or regulatory obligation exists or a court or administrative order would prevent us from doing so. 23. We will take appropriate technical and organisational measures to keep your personal data safe from unauthorised access or theft and from accidental loss, manipulation or destruction. Access by our staff or staff of our external processors is only possible on a need-to-know basis and is subject to strict confidentiality obligations. You understand, however, that the care for safety and security are only best effort obligations that can never be guaranteed.

YOUR RIGHTS

24. You have the right to request access to all personal data we process about you. However, requests for access which are manifestly made with the intention of causing inconvenience or damage to us will not be entertained. 25. You have the right to request that any incorrect or inaccurate personal data about you be corrected free of charge. If you have registered on our Website, you can correct many of these details yourself through your profile. If such a request is made, you must also include proof along with it that the personal data for which correction is requested is incorrect. 26. You have the right to withdraw your previously given consent to the processing of your personal data. You may withdraw your consent at any time by sending an e-mail to info@induxx.be, or by deleting your profile (if applicable). 27. You have the right to request that personal data relating to you be deleted if it is no longer necessary in light of the purposes set out in this Privacy Policy, or if you withdraw your consent to its processing. However, you should note that a deletion request will be assessed by us in light of legal and/or regulatory obligations or administrative or judicial orders which may prevent us from deleting the personal data in question. 28. Instead of deletion, you may also request that we restrict the processing of your personal data if (a) you dispute the accuracy of that data, (b) the processing is unlawful or (c) the data is no longer necessary for the stated purposes, but you need it to defend yourself in legal proceedings. 29. You have the right to oppose the processing of personal data if you can demonstrate that there are serious and legitimate reasons relating to special circumstances that justify such an opposition. However, if the intended processing is qualified as direct marketing, you have the right to object to such processing free of charge and with no justification given. 30. Where your personal data is processed on the basis of consent or on the basis of a contract and the processing is carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and, if technically feasible, you have the right to transfer this data directly to another service provider. The technical feasibility of this is exclusively assessed by us. 31. Under no circumstances will we process personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, or personal data concerning health or sex life. 32. If you want to make a request to exercise one or more of the rights mentioned above, please send an e-mail to info@induxx.be. This request must clearly state which right you wish to exercise and why. It must also be dated and signed, and be accompanied by a digitally scanned copy of your valid identity card proving your identity. We will immediately inform you of the receipt of such a request. If the request proves to be well-founded, we will comply with it as soon as reasonably possible and no later than thirty (30) days of receipt of the request. 33. If you have a complaint or question about the processing of your personal data by us, you can always contact us at the e-mail address info@induxx.be. If you are not satisfied with our response, you are free to file a complaint with the competent data protection authority, the Belgian Data Protection Authority. For more information, visit http://www.privacycommission.be.