Privacy Policy

1. Introduction

Your privacy is important to Us. We want to be transparent with You on what Personal Data We collect, why We collect it, and what We do with it. Moreover, We want you to know Your rights regarding these Personal Data. Therefore, We strongly recommend You to read this Privacy Policy and if You have any questions, please contact Us.

The legal grounds for the processing of Your Personal Data are the execution of an agreement with You, a legal obligation, our legitimate interests and, in some cases, Your consent.

The processing of Your Personal Data is subject to this Privacy Policy. In case You have questions or remarks, please contact privacy@froomle.com.

Please do not supply any other person’s Personal Data to Us, unless We ask You to do so.

2. Definitions

The following definitions will help You to understand this Privacy Policy:

“We” or “Us”, refers to Froomle NV, with registered office at Strepestraat 16, 2235 Hulshout, Belgium and company address at Mechelsesteenweg 271 bus 1.1. 2018 Antwerp, Belgium.

“You”, “Your” refers to a website visitor.

“Personal data” refers to any information which identifies You as an individual (directly or indirectly).

“Website”: refers to www.froomle.ai as well as all webpages, platforms, interactive features, applications, widgets, blogs, social networks, social network tabs, or other offerings that post a link to this Privacy Policy, are subject to this Privacy Policy.

3. What information (including personal data) do we collect about you and why?

In general

We may process data about Your use of our Website and services. This Personal Data may include Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Website navigation paths, as well as information about the timing, frequency and pattern of Your service use.

The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the Website and services.

The legal basis for this processing is our legitimate interests, namely monitoring and improving our Website and services.

We may process Your Personal Data that are provided in the course of the use of our services. The service data may be processed for the purposes of operating our Website, providing our services, ensuring the security of our Website and services, maintaining back-ups of our databases and communicating with You. The legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business or the performance of a contract between You and Us and/or taking steps, at Your request, to enter into such a contract.

We may process information contained in any enquiry You submit to Us regarding products and/or services. The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to You. The legal basis for this processing is consent or our legitimate interests.

We may process information that You provide to Us for the purpose of subscribing to our email notifications and/or newsletters. The notification data may be processed for the purposes of sending You the relevant notifications and/or newsletters. The legal basis for this processing is consent or the performance of a contract between You and Us and/or taking steps, at Your request, to enter into such a contract.

We may process any of Your Personal Data identified in the other provisions of this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, Your legal rights and the legal rights of others.

In addition to the specific purposes for which We may process Your Personal Data set out in this article 3, We may also process any of Your Personal Data where such processing is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person.

Specific: Mailing list 

We might contact You to inform You of relevant developments or innovations or potential events that might be interesting to You.

When processing for this purpose, We use the following legal base:

  • “Consent” – When You have requested access to our mailing list, or
  • “Legitimate interest” – When You are an existing customer or we have another existing (pre)contractual relationship with You.

At any time, You can easily opt-out of this communication by using the unsubscribe link included in every email.

We use Drip to manage this activity.

Specific: Job application

In order to find the best possible match between Froomle and the candidate, We will process the information provided by You for this purpose. In addition to the information mentioned above, this also includes the following:

  • Details of Your skills, qualifications, experience and work history
  • Information involving Your remuneration
  • Other specific information provided by You

We use our legitimate interest as the legal base for processing Your information in this respect.

Subsequently, with your consent, we will retain Your Personal Data for a period of 12 months for future job vacancies. At any time, You can request to be removed from our database by emailing Your recruiting contact person.

We use G-Suite and Notion to manage this activity.

4.Transfer of personal data

We will not transfer Your Personal Data to third parties outside the European Economic Area, except to subcontractors or employees who retain the Personal Data on servers in the United States, have undertaken to do so under the Privacy Shield or in accordance with the European Commission’s Standard Contractual Clauses and thereby provide an adequate level of security for the processing of Personal Data.

Furthermore, We will not transfer Your Personal Data to third parties inside the European Economic Area without Your permission, except:

  1. to affiliated companies;
  2. when these data are necessary to permit employees, agents, subcontractors, suppliers or commercial partners to provide a service or accomplish a task in our name, including but not limited to providing marketing support, accomplish market research or providing user services;
  3. if it is required or permitted by applicable laws and regulations.

Any transfer of Personal Data to one of the third parties mentioned in the list above, is in accordance with the stipulations of the General Data Protection Regulation (GDPR) 2016/679.

We ensure that measures are taken to make sure that third parties cannot use Your Personal Data for other purposes than the purposes mentioned above, and that these third parties have taken the necessary technical and organizational measures to protect these data.

We will have data processing agreements in place with the aforementioned third parties in order to ensure the security of the Personal Data.

Finally, We shall take all necessary precautionary measures to assure that our employees and associates who have access to Personal Data will process these Personal Data exclusively in accordance with this Privacy Policy and the obligations under the applicable privacy regulations. 

5. How long do we keep your personal data?

Personal Data will be kept and processed by Us for the duration that is required in relation to the purposes of the processing depending on whether We have a contractual relationship with You or not.

Client data and supplier or subcontractor data will be removed from our systems after 7 years after the termination of the agreement involved, except for the Personal Data that We have to store for a longer duration based on specific legal obligations or in case of pending litigation(s).Data collected through the Website or through any other channel will not be kept longer than 2 years after the last useful contact between Us and You.

Notwithstanding the other provisions of this article 5, We may retain Your Personal Data where such retention is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person.

6. Your rights regarding your personal data

By virtue of both Belgian and European legislation concerning data protection, You have the rights as mentioned below. If You want to exercise these rights, you have to send Us a written request and provide a recto copy of Your ID card to privacy@froomle.com.

Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

We will provide You with information within one (1) month of receipt of the request on the action that will be taken. We can extend this one-month period to a maximum of three (3) months, in which case You will be informed about the reasons for such delay within one (1) month of the original request.

The right of access to Personal Data

You have the right to instruct Us to provide You with any Personal Data We hold about You, providing the rights of other data subjects are not affected.

The right to rectification of Personal Data

We kindly ask You to help to make sure that the Personal Data in our records are as accurate and up-to-date as possible. If You believe that the Personal Data submitted to Us are incorrect or incomplete, please notify Us as described above. We will correct or adapt Your Personal Data as soon as possible.

The right to erasure of Personal Data 

In some circumstances You have the right to the erasure of Your Personal Data without undue delay.

Those circumstances include:

  1. the unnecessity to hold the Personal Data any longer in relation to the purposes for which they were collected or otherwise processed;
  2. the withdrawing of the consent to consent-based processing;
  3. the processing that is for direct marketing purposes; and
  4. in case the Personal Data have been unlawfully processed.

However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary:

  1. for exercising the right of freedom of expression and information;
  2. for compliance with a legal obligation; or
  3. for the establishment, exercise or defense of legal claims.

The right to restrict the processing of Personal Data

In the following circumstances You have the right to restrict the processing of Your Personal Data:

  1. for contesting the accuracy of the Personal Data;
  2. when the processing is unlawful but You don’t want the Personal Data to be erased; or
  3. when You objected to processing, pending the verification of that objection.

Where processing has been restricted on this basis, We may continue to store Your Personal Data. However, We will only process it with Your explicit consent, for the establishment, exercise or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.

The right to object

You have the right to object to our processing of Your Personal Data.

The right to data portability

If You wish to exercise Your right to data portability, We will send the Personal Data in a structured, commonly used and machine-readable format to a controller of Your choice.

The right to withdraw consent

To the extent that the legal basis for our processing of Your Personal Data is consent, You have the right to withdraw that consent at any time. However, withdrawal will not affect the lawfulness of processing before the withdrawal.

The right to complain to a supervisory authority

You can file a complaint with the Data Protection Authority (“Gegevensbeschermingsautoriteit”) by sending an e-mail to contact@apd-gba.be or by sending a written request to the Data Protection Authority with registered address located at 1000 Brussels, Drukpersstraat 35.

7. We commit to protecting your personal data

We are committed to protecting the security and confidentiality of Your Personal Data. We use appropriate technical and organizational measures in such a manner that processing will meet the requirements of the national and European Union laws and ensure the protection of Your rights.

8. What happens if the Privacy Policy changes?

We may change this Privacy Policy at any time and from time to time. All updates and amendments are effective immediately upon notice, which We may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Website. We encourage You to review this Privacy Policy to stay informed of changes that may affect You, as Your continued use of the Website signifies Your continuing consent to be bound by this Privacy Policy.

 

Last modified on 1 April 2020.

FROOMLE NV
Strepestraat 16
2235 Hulshout
Belgium
Company number: 0654.854.720
Privacy@froomle.com