AD VINCI COMPREHENSIVE PRIVACY STATEMENT FOR WEMOVE E-MAIL MARKETING CAMPAIGNS

AdVinci SPRL, headquartered in Avenue des Volontaires 19 at B-1060 Brussels, dedicates its efforts to your trust. This also applies for the way in which we handle your personal data. The present comprehensive privacy statement is intended to inform you about this in detail.

1. Who are we and what do we operate?

First, as a leading e-mail marketing agency, AdVinci SPRL collects, with your due consent (as you are an individual person concerned by such collection), some Personal Data that you own in order to provide you with some personalized content via electronic mail. The content that you will receive through AdVinci SPRL is made by AdVinci’s clients and partners, which are companies interested to communicate with their audience through the channel of the electronic marketing. AdVinci spreads this content autonomously among its registered individuals, including yourself, and does not transfer to AdVinci’s client any Personal Data previously given by the registered individuals to AdVinci. Second, as a data quality agency, AdVinci SPRL is also the contract partner of some various processors of personal data. In both cases, AdVinci SPRL is responsible for enabling the individuals involved to exercise their rights.

2. How do we collect your personal data?

We collect your personal data in various ways.

2.A. We collect data directly from you

You yourself provide most of the data that we collect directly to us. For example, data is saved when creating an account, registering a bid, contacting by e-mail or telephone, etc.

2.B. We collect data through your use of our websites

When you visit the following websites: • www.vipriva.com • www.mailgique.be • www.mailgie.be • www.mailgium.be • www.wemove.be you can surf the website anonymously and you will have access to important information without your identity being revealed. Nevertheless, AdVinci SPRL uses cookies to improve your user experience. A cookie is a small quantity of data sent by the web server to your browser and that can only be read by the server that has made the data available to you. The cookie serves as your identification card: your passwords, your purchases and preferences will be registered in the cookie. Some cookies are essential to enable the website to function correctly, while others enable anonymous measurement and analysis of the use of the site. Our websites use cookies that are useful, but not essential, ensuring that you receive the most relevant information based on your profile. Third parties, such as our partners, also have the ability to measure your surfing behaviour in order to gear their communication to you. You can manage this yourself or you will have the ability to manage this yourself soon.

3. What personal data will be processed?

The following data will be processed: • Personal contact details: name, address, telephone number, e-mail, country, language • Payment and billing data: this data will be saved to enable us to process your order • When you share content from our website on social media, such as Facebook • Information on the use of website/apps and other applications (e-mail messages). On the one hand, this information will be used for analysis purposes, and on the other hand, we combine this information with your purchase history to offer you the most relevant events (“profiling”). • Your preferences: by means of your preferences, if you have created an account, you can indicate which genres of events you would like to be kept informed of. Additionally, we combine this with products that you purchase or that you ask about and your demographic preferences. • Date of birth, in those instances in which we are legally required to obtain parental consent for people younger than 13 years of age and for the purpose of age verification for certain events.

4. Legality of the processing

All of the processing carried out by AdVinci SPRL has a legal basis. In these cases in which this is not based on regulations, AdVinci SPRL asks the customer to provide the necessary permission. The processing of personal data can be legal based on various grounds.

4.A. Consent

You give explicit consent for the processing of your personal data for one or more specific purposes, for example consent to send newsletters or to provide data to certain third parties. For minors under the age of 13, this consent must be provided by a person with parental authority. You can withdraw this consent at any time, for example by unsubscribing.

4.B. Implementation of the agreement

If you have purchased something from our web sites, a certain amount processing of personal data must be carried out in order to process this transaction.

4.C. Legal obligation

Certain processing of personal data must be carried out in order to comply with legal obligations, such as accounting obligations.

4.D. Legitimate interest

Some processes will be commenced for the protection of the legitimate interests of the controller. For example, AdVinci SPRL is permitted to conduct direct marketing in regard to its existing customers. You can nevertheless unsubscribe from this direct marketing.

5. For what purposes do we use your personal data?

5.A. We may use your date to process your transaction, if a transaction occured

If you purchased something through the web sites cited here above, or made any other transaction that involved the communication of some data to execute the subsequent agreement to that transaction, AdVinci SPRL will collect some personal data to be able to process such transaction and to ensure that the transaction runs smoothly.

5.B. We may use your data for third-parties indirect e-mail marketing

You will receive personalized content through the contact data that you gave to AdVinci SPRL. Such content is made by AdVinci’s clients and partners, which are companies interested to communicate with their audience through the channel of the electronic marketing. AdVinci spreads this content autonomously among its registered individuals, including yourself, and does not transfer to AdVinci’s client any Personal Data previously given by the registered individuals to AdVinci. This is why we speak of “indirect e-mail marketing”.

5.C. We may use your data for AdVinci’s direct marketing

The data will also be used for direct marketing for products and/or services and/or events in the AdVinci SPRL product range.

5.D. We may use your data for profiling

On the one hand, AdVinci SPRL uses the combination of the data you provided and your use of its sites to offer you an optimal surfing experience. On the other hand, we use this information to keep you up to date of a customised range of products – after approval – by e-mail.

5.E. We may use your data for transmission to third parties

We can share your data with our external services providers to the extent that this is required to enable them to provide their services. In this case, we enter into an agreement with them to ensure conformance with the General Data Protection Regulation (GDPR).

5.F. We may use your data for transmission to Black Tiger Belgium SA

Your personal data may be communicated, in the context of our legitimate interest, to independent data controllers in order to help them provide their data quality services to their clients. These third parties use these data exclusively to complete their own databases, confirm or validate their data or the data provided by their clients and/or to improve the quality of the latter via formatting, standardization, correction, completion, updating (in particular via the delivery of a new address, e.g. after moving) and/or matching of said data, for the sole purpose of:

  •    • Complying (or assisting their clients to comply) with Article 5.1(d) GDPR which requires the personal data to be accurate and, if necessary, kept up to date, and/or;
  •    • Assisting their clients in carrying out, on their behalf or that of their clients, identity verification of individuals for anti-money laundering, national/public security, crime prevention and detection, fraud prevention, debts/assets recovery, assets reunification and/or conducting pre-employment screening checks.

One of the data quality specialists we work with is Black Tiger Belgium SA, established Researchdreef 65 at 1070 Brussels, whose dedicated GDPR page https://gdpr.blacktigerbelgium.tech informs you further about the processing they do with the personal data they collect, your GDPR rights and how to exercise them.

5.G. We use your data to determine the legality of transactions

Personal data can be used for the prevention or detection of crimes, such as fraud relating to electronic payments, intellectual property violations or other crimes.

5.H. We may use your data to test data for new developments

Personal data can be used to test new software developments on behalf of AdVinci SPRL. In some cases, the data will be exported to a third party, who will take responsibility for the testing of the new developed applications and can only use your data for this purpose. In all cases, the necessary security measures will be taken.

6. Your right of access and inspection of your personal data

You have a number of rights relating to the processing of your personal data. To exercise these rights, you must send an e-mail to: privacy@advinci.be. Your request will be processed within one month. If your request cannot be honoured, AdVinci SPRL will inform you of the reason for this.

6.A. Right of inspection

You have the right to inspect the data you have provided and to manage your preferences, for example with regard to mailing.

6.B. Right of correction or deletion

You have the right to correct inaccurate or incomplete personal data or to have the data deleted. If your data was provided to third parties with your permission, these third parties will also be asked to implement the requested modifications. You will be informed of that.

6.C. Right to be forgotten

You have the right to request ‘to be forgotten’ and to be deleted from the database. In some cases, this request can be refused, for example if the data is required for the implementation of the agreement or due to other legislation (e.g. compliance with fiscal legislation). If your data is made available to third parties, your request to be forgotten will also be forwarded to these third parties. You will be informed of this.

6.D. Right of objection

You have the right at all times to object to the processing of your data that will be made based on the legitimate interests of AdVinci SPRL or its combined controllers. You can also object to the processing of your data for direct marketing, including profiling. You can also do that by using the unsubscribe link at the bottom of the e-mail message sent to you.

6.E. Automated decision-making and profiling

You have the right not to be subjected to a fully automated decision-making, unless this is necessary for the implementation of the agreement, is legally permitted or has your explicit permission. If such a decision arises, you have the right to make your views on the matter known, to challenge this decision or to demand a human intervention from AdVinci SPRL. During your initial contact with us, you are informed of the use of tracking cookies. These enable us to build profiles based on your use of the website and effective behaviour (purchase history). Based on these profiles, the communication in e-mails and on the web will be personalised. You can object to this by turning off the cookies, either in the website’s cookie settings, or on the browser. You will then only still receive standard newsletters and only see a standard website (without personal recommendations).

6.F. Right to data portability

You have the right to have personal data provided transferred to another processor in a structured, common and legible form.

6.G. Right to lodge a complaint with supervisory authorities

If you have specific complaints regarding the privacy policy of AdVinci SPRL, you can contact the supervisory authority (Belgian Data Protection Authority).

7. Retention period of the data

AdVinci SPRL has generally designated the retention period of its client data at three (3) years. This period was designated based on practical considerations, such as the user-friendliness for the customer, the relevance of the data that must often be retained for a period of 3 years. If you are no longer active for a period of 3 years or have not contact AdVinci SPRL again, you will receive an e-mail with the question of whether we can deactivate your account. We make some exceptions to this retention period in accordance with the legal obligations linked with some specific terms of retention (e.g. fiscal laws, accounting laws, etc.).

8. Data security

AdVinci SPRL will do everything possible to protect its customers against unauthorised access to or unauthorised modification, publication or destruction of the data in its possession. To do this, the follow security measures among others will be utilised:

  • Internal files will be saved at a location accessible (only) to those individuals that require these files in the context of processing, such as customer AdVinci SPRL regarding repayments or overpayment/underpayment.
  • Backups will be made frequently and saved at various locations. These backups will be retained for at least 30 days to be able to retrieve the data in the event of loss and to ensure continuity.
  • Firewalls protect our internal networks against external access.
  • All internal systems are or will be provided with the requisite EndPoint Protection (Antivirus, Antimalware, etc.).
  • The passwords of all users will be stored in encrypted form.
  • If data is exchanged for testing purposes, certain data will be pseudonymised and anonymised (such as names and e-mail addresses).
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9. Transmission of data to third-party countries

Data will only be transmitted within the EU through the partners with which AdVinci SPRL works.

10. Third-party sites

The websites may contain links to third party sites. AdVinci SPRL has no control whatsoever over these sites and is not responsible for their contents, their operation or their practices, including with regard to their privacy policy.

11. Changes to the Privacy policy

In the event of changes to the current privacy policy, we will inform you of that by e-mail. The latest version always available for you to consult on the website.

12. Contact

The general information for AdVinci SPRL is available on the website. If you have questions or comments relating to our privacy policy, we recommend that you send an e-mail to: privacy@advinci.be.

This e-mail will be received directly by the AdVinci SPRL, specially its “Data Protection Officer Team”. We will always respond to your question within one month.