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Privacy Policy

TechWolf Privacy Policy – website users

Last Updated: [26/01/2023]

General

TechWolf BV is a limited liability company (“besloten vennootschap”) incorporated under the laws of Belgium, with its registered office at Overzet 14B, 9000 Ghent (Belgium) and registered with the Crossroads Bank for Enterprises under number 0702.852.201 (hereinafter referred to as "TechWolf", "we" or "us"). References to “you” and “your” refer to persons external to TechWolf who are users of our website www.techwolf.com/ (“Website”), job applicants and prospects.

Your privacy is very important to us. This Privacy Policy is intended to inform you about the processing of your personal data that takes place (i) via the Website, (ii) through your use of our contact details referred to on the Website (e-mail, phone numbers and post), or (iii) when the services offered on the Website are being used (inter alia by requesting of a demo or offer, or subscribing to a newsletter).

For the purposes of this Privacy Policy:

  • processing means any operation performed on personal data such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction; and

  • personal data means any information relating to you as an identified or an identifiable natural person.

This Privacy Policy applies only to the processing of data of physical persons, not of legal persons. This Privacy Policy must be read in conjunction with the Cookie policy, which can be found here: https://techwolf.com/cookie-policy

This Privacy Policy may be modified, for example, in connection with new features on the Website or to comply with new legal, contractual or administrative obligations. We therefore recommend that you regularly consult this Privacy Policy. Important changes will be announced on our Website. This version of the Privacy Policy was last modified on the date referred to above.

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”).

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

TechWolf is the controller, in the meaning of the GDPR, for the processing of your personal data.

2. WHAT PERSONAL DATA DO WE PROCESS?

We will process your personal data when you provide us with such data (for example, through a contact form on our Website or via e-mail) or when you contact us directly by e-mail, phone or post.

Such personal data can include the following information:

  • your name, address, e-mail address, phone number, your job title, your company, your company size and all personal data freely provided to TechWolf (e.g. in light of correspondence with TechWolf)

  • if you visit our Website: usage data such as your IP address, browser type, browser version, the pages of our Website you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data (depending on the consent that you give us)

  • if you are a job applicant: your current role and name of your employer, the industry sector where you work, your CV and covering letter

3. 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.

To this end, we can process data such as your IP address, the pages you visit, the browser you are using, the websites you visited earlier, and the time and duration of your visit. We do this, for example, by using cookies. More information about the use of cookies can be found in our Cookie Policy https://techwolf.ai/cookie-policy .

We process this data based on the legitimate interest of TechWolf in providing a well-functioning and secure Website.

To provide you with our services

We process your personal data to provide you with the services offered on our Website which you requested us to perform. Such services can inter alia include the provision of a demo.

To this end, we can process data such as your name, your job, your company name, your address, your e-mail address and your invoicing information.

We process this information either for the performance of the contract with you or based on your consent. Without your personal data, we cannot perform provide you with our services.

To contact you and answer your questions

If you ask us a question via a contact form on the Website, by telephone, e-mail or post, we will process your personal data in order to answer that question.

To this end, we can process data such as your name, your contact information, your correspondence with TechWolf, and any other personal data you provide that may be relevant for answering your question.

We process this information based on our legitimate interest or based on your consent. You are free to provide us with your personal data, and you can object the processing thereof at any time (see point 6).

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 invitations to events.

To this end, we can process data such as your name, your job, your company name, your address, your e-mail address and your preferred language.

We process this information based on our legitimate interest to keep our website users and prospects informed of our activities and services or based on your consent. You can object to this processing of your personal data at any time (see point 6).

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.

To this end, we can process data such as your name, your contact information, your correspondence with TechWolf, 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 or based on your consent.

To comply with our legal and regulatory obligations

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.

To this end, we can process data such as your name, your contact information, your correspondence with TechWolf and your financial data.

The processing of your personal data for this purpose is based on the need for TechWolf to respect its legal obligations.

Handling our own disputes

We may process your personal data to handle our own disputes and protect and enforce our rights.

To this end, we can process data such as your name, your contact information, your correspondence with TechWolf and your financial data.

The processing of your personal data for this purpose is based on the legitimate interest of TechWolf in safeguarding our rights in the event of disputes.

4. WHO HAS ACCESS TO YOUR PERSONAL DATA?

Website Hosting

We make use of Combell to manage and host the Website and have therefore entered into a processing agreement with such Combell.

Our servers are located in Belgium and we will not transfer your personal data to countries outside the European Economic Area (EEA) except (i) at your request, or (ii) to the extent necessary for the institution, exercise or substantiation of a legal claim. In the context of the use of some software applications, personal data may however be temporarily transferred to countries outside the EEA. In such a case, an adequate level of protection is provided through any relevant protection mechanism such as an adequacy decision of the European Commission, the use of the European Commission's standard contractual clauses or binding corporate rules.

Analytics

We may use third-party service providers to monitor and analyze the use of our Website.

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.

Social media

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 policy of any social media provider with which you intend to share your personal data.

Recruitment

Our Website allows you to apply for a position at TechWolf. In order to manage all applications, we make use of a hiring tool which assists us in following up on your application more efficiently and effectively.

Prospects

Our Website allows us to gather information about potential customers. We make us of tools that enable us to reach out to prospects more efficiently and effectively.

Other third parties

We may share your personal data with the following persons, who we will require to honor this Privacy Policy:

  • our (sub)contractors for assisting us in fulfilling the purposes listed above

  • our service providers to monitor and analyze the use of our Website, for payment processing, or to contact you

  • our affiliates, such as subsidiaries and parent companies, joint venture partners or other companies that we control or that are under common control with us

  • our accountants, auditors, lawyers or similar advisors when we ask them to provide us with professional advice

  • the competent authorities, 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 TechWolf

We will only share your personal data with these third parties provided that they comply with the 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 privacy@techwolf.ai.

Other websites

The Website may potentially contain hyperlinks to other websites. When you click on one of these links, you may be redirected to another website or internet source that could collect information about you through cookies or other technologies. We do not exercise any control over these other websites or internet resources and does not bear any responsibility or liability in relation to the collection, use or disclosure of your personal data by these websites or internet sources. You must check the privacy policies of these other websites and internet sources in order to ensure that they act in accordance with the relevant privacy legislation.

5. HOW DO WE PROTECT YOUR PERSONAL DATA AND HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We take reasonable security measures to protect your personal data from destruction, loss, modification or any other unauthorized processing.

We do 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 privacy@techwolf.ai.

Any transfer of personal data to a third country, which means outside the European Economic Area (EEA), or international organization shall be subject to one of the following safeguards:

  • an adequacy decision by the European Commission (if any); or

  • a data transfer agreement, which shall contain the standard contractual clauses, as referred to in the 'European Commission decision of 5 February 2010 (Decision 2010/87/EC); or

  • binding corporate rules, as implemented by TechWolf (if any).

6. 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 to delete 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 or the legitimate interest of 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 if we need this processing for the establishment, exercise or defense of legal claims.

  • 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 your withdrawal.

  • 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 a contract concluded with you, or if the processing is carried out by automated means.

At any time, you can direct your request based on the above rights and your complaints to privacy@techwolf.ai.

You also have the right to file a complaint:

  • internally with our DPO office to privacy@techwolf.ai; or

  • externally 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.