Privacy + Cookie Policy​

I. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy describes how DESelect BV and its affiliates (“we”, “us” or “our”) collects, uses, consults, retains or otherwise processes your personal data when you are visting our website and when you leave your personal information. We understand that privacy is important to both our online visitors and registered users. We respect your privacy and have taken adequate steps to protect your personal data. This Privacy Policy (the “Privacy Policy”) does not apply to information our customers may process when using our Services which is covered by a different privacy policy. DESelect BV and you are jointly referred to as “Parties” and individually as “Party”.

PLEASE READ THIS PRIVACY POLICY CAREFULLY!

This Privacy Policy applies globally on the basis of EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data (the “GDPR”), as well as any legislation and/or regulation implementing or enacted pursuant to the GDPR and current and future e-Privacy legislation.

Terms defined in article 4 of the GDPR shall have the meaning as defined therein.

Personal Data as defined in the GDPR includes cookies and other “Navigational Data” such as information about your computer and your visits to our website, your IP address, geographical location, browser type, referral source, length of visit and pages of our website you viewed.

Whilst you are afforded the rights based on the GDPR irrespective of your nationality and irrespective of whether or not the GDPR applies to you as matter of EU or local applicable law, to the extent that your personal data does not fall within the material, territorial or personal scope of the GDPR, DESelect is only held to best efforts obligation to comply with the GDPR and you agree that DESelect shall not be liable in any way for a breach of the GDPR (or any national legislation or regulations implementing the GDPR) to the extent that the GDPR does not apply to your personal data as a matter of law.

The rights granted to you by the GDPR are set out below.

If you live in California, USA and to the extent that the CCPA is applicable: (i) either Party agrees to comply with all of its obligations under the CCPA; and (ii) in relation to any communication of “personal information” (as defined by the CCPA) from one Party to the other Party pursuant to this Privacy Policy, the Parties agree that no monetary or other valuable consideration is being provided for such personal information and therefore neither Party is “selling” (as defined by the CCPA) personal information to the other Party.

DESelect will be operating as data controller of your personal data if you are located within the European Economic Area.

As a rule, your personal data is only retained for as long as is required to fulfil the activities set out in this Privacy Policy, for as long as otherwise communicated to you in this Privacy Policy or for as long as is permitted by applicable law. By way of example, we may have to retain some of your personal data if it is reasonably necessary to comply with any legal obligations, meet any regulatory requirements, perform contractual obligations, resolve any disputes or litigation or as otherwise needed to enforce this Privacy Policy and prevent fraud and abuse such as identity-theft or misrepresentation of your identity.

To determine the appropriate retention period of your personal data, due account is taken of the amount, nature, and sensitivity of your personal data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which your personal data is processed (if processing is at all required for the purposes) and the applicable legal requirements including those imposed by local law.

DESelect BV is a Belgian corporation with its administrative seat at with its registered office at Berchemstadionstraat 76, 2600 Antwerp, BELGIUM with company number 0737.366.383.

For any privacy related questions or to exercise your rights relating to your personal data, please contact us at: [email protected]

II. Your Rights pursuant to EU law and this Privacy Policy

EU privacy regulation (most notably the GDPR) grants specific rights, summarized below, which you can in principle exercise free of charge.

In some cases, these rights may be limited e.g. if your personal data has to be retained on the basis of local applicable law or if you request the deletion of personal data which is required to complete the contract with you.

Your personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of the controller(s) legitimate interests in compliance with applicable laws.

In addition, your personal data may be shared with a successor to all or part of our business, where this is in our legitimate interests in facilitating a business sale and in this context our business interests prevail. By way of example, if parts of our business or assets are sold, personal data may be shared as part of that transaction, subject to applicable law. To exercise any of your rights set out below, you can file a request via email at: [email protected]

Please note that if you have unresolved concerns, we would appreciate it if you would inform us of any such unresolved concerns using the same e-mail address.

You do however have the right to file a complaint with the data protection authority of your country of residence or of the country wherein you believe a breach may have occurred (to the extent that these data protection authorities are competent to handle your complaint).

II.1 Right to withdraw your consent

If your consent is the basis for processing of your personal data, you will be able to withdraw that consent at any time you want by expressing your intent to withdraw consent by e-mail to: [email protected]

Similarly, you can withdraw your consent by unsubscribing to certain services (such as our newsletter), usually by clicking on a hyperlink in an e-mail addressed to you.

Please note that the withdrawal of your consent will not affect the lawfulness of the collection and processing of your personal data based on your consent up until the moment where you withdraw your consent.

Moreover, withdrawing your consent is only effective to the extent that the processing of your personal data is happening only on the basis of your consent and is not based on another ground such as a legal requirement.

II.2 Right to access and rectify your personal data

You have the right to access, review and rectify your personal data. You therefore have the right to obtain the rectification of inaccurate personal data or to complete incomplete personal data.

You are entitled to request a copy of your personal data, to review or correct it if you wish to rectify any personal data like your name, email address, passwords and/or any other preferences. As a rule, this can be achieved by logging in to your account on our website (if you have created one) or by contacting us at: [email protected]

II.4 Right to restriction of processing and/or erasure of your personal data

You have the right to request deletion and erasure of your personal data which is processed as described in this Privacy Policy in case this personal data is no longer needed for the purposes for which it was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this Privacy Policy and no other legal ground for processing applies (such as the performance of the contract concluded with you or legal requirements imposed by applicable law). 

If you wish to exercise your right to erasure, please send an e-mail to this effect to: [email protected]

Under certain circumstances, you may ask us to restrict the processing of your personal data.

You can do so when you wish to rectify your personal data pending the verification of the accuracy of your personal data by the data controller.

You can also do so when you want to prevent erasure of your personal data because you need this personal data for the establishment, exercise or defense of a legal claim.

You can also do so when you object to the processing of your personal data pending the verification of whether or not the legitimate interests of the data controller override your right to object.

If you wish to exercise your right to restrict processing, please send an e-mail to this effect to: [email protected]

II.5 Right to object to processing of your personal data

Under certain circumstances, you may object to the processing of your personal data, most notably when your personal data is processed solely for direct marketing purposes.

If you wish to exercise your right to object, please send an e-mail to this effect to: [email protected]

II.6 Right to personal data portability

Where you have provided personal data and where the processing is carried out by automated means and based on your consent or the performance of the contract concluded, you have the right to receive the personal data processed about you in a structured, commonly used and machine-readable format and to transmit this personal data to another “service provider”.

If you wish to exercise your right to data portability, please send an e-mail to this effect to: [email protected]

III. INFORMATION RELATED TO SPECIFIC PROCESSING ACTIVITIES

III.1 Subscription to Newsletters and Marketing

If you have consented to receive our newsletters or marketing communications, you may, from time to time, be contacted by e-mail with information about our services and latest offers and your personal data may be processed for this purpose.

If you no longer want to receive our newsletters or marketing communications, please let us know by sending us an e-mail at: [email protected]

You can unsubscribe from marketing emails by clicking on the unsubscribe link in the emails sent to you.

Processed personal data categories

Email address, first name, last name, your company name, your job title.

Source of personal data

  • Directly from you when subscribing to the newsletter or later when completing your account online.
  • Third party data aggregators

Grounds for processing

Ad hoc consent obtained during the subscription to our newsletter.

Recipients of personal data

  • DESelect
  • Salesforce
  • Hubspot
  • Mailchimp
  • Zapier

III.2 Website Forms

Should you have a particular query, feedback or comments, including the wish to set up a meeting with us, you can contact us through the contact forms available on our website.

This may require processing of your personal data for the purpose of handling and providing an answer to your query or request or to follow up on your feedback.

Processed data categories

Email address, first name, last name, company name, job title, phone number, first party custom cookie for storing UTM parameters and any other personal data you entered into website forms.

Source of personal data

Directly from you through input in the website form or through our custom UTM first party cookie

Ground for processing

Ad hoc consent obtained through the website form and/or cookie policy

Recipients of personal data

  • DESelect
  • Salesforce
  • Hubspot
  • Mailchimp
  • Zapier

III.3 Processing of Personal Data for Analytical Purposes

Some of your personal data may be processed for analytical and statistical purposes in order for us to measure, improve and better tailor the quality of our services.

Processed personal data categories

Third Party Cookies and Third Party Technology

Google Analytics

Source of personal data

  • Using our website and accepting our cookie policy

Grounds for processing

Processing is justified to allow improvement of our services.

Recipients of personal data

  • DESelect
  • Google
  • Facebook
  • LinkedIn
  • Hubspot
  • Mailchimp

III.4 Processing of “Navigational Data”

Some of your Personal Data (in the form of Navigational Data as defined above) may be processed in order for us to measure, improve and better tailor the quality of our services and your experience on our website. We may also use Navigational Data alone or in combination with other Personal Data to provide you with personalized information about our services. Navigational Data, such as IP address, may be used (by us or third parties) to approximate your location.

You may disable the collection and use of your Navigational Data through browser-, operating system- or device-level settings or by using a browser which blocks the collection of such Navigational Data.

Processed personal data categories

Information about your computer or device, your visits to our website, your IP address, geographical location, referral source, length of visit and pages of our website you viewed.

Source of personal data

  • Using our website
  • Third Party Cookies or Third Party Functionality such as the Facebook Pixel

Grounds for processing

Processing is justified to allow improvement of our services and tailor personalized information to your needs.

Recipients of personal data

  • DESelect
  • Facebook
  • LinkedIn
  • Hubspot
  • Mailchimp

IV. Security Measures: How we Protect your Personal Data

Appropriate technical and organizational measures are implemented in order to ensure an appropriate level of cybersecurity of your personal data, taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing.

These technical and organizational measure include pervasive encryption techniques, secure off-site backups, state of the art biometric identity verification, regular penetration testing, physical and IT system access controls on a “need to know” basis, activity logging and confidentiality obligations imposed contractually on both staff and third parties.

Appropriate technical and organisational measures are taken to ensure that, by default, only personal data which are necessary for each specific purpose of the processing are processed.

In the event personal data is compromised as a result of a personal data breach, the required notifications will be made pursuant to applicable law.

V. International Transfers of Personal Data

If you are in the European Economic Area (EEA), the data collected from you as described in this Privacy Policy may be transferred to and stored at a destination outside the EEA, including for the purpose of processing personal data by selected processors, in order to facilitate business. These transfers are however strictly limited to the extent technically possible unless the personal data is transferred to a country which has been deemed to ensure an adequate level of personal data protection by the European Commission or in compliance with binding corporate rules or standard contractual clauses approved by the European Commission.

Countries outside the EEA may however not have laws which provide the same level of protection to your personal data as laws within the EEA. Where this is the case, appropriate safeguards will be put in place to ensure that such transfers comply with the GDPR, as a rule by putting in place Standard Contractual Clauses approved by the European Commission or binding corporate rules ensuring adequate protection.

Changes to this Privacy Policy

DESelect reserves the right to modify and update this Privacy Policy from time to time. Any relevant changes will be brought to your attention (either by e-mail or via our website).

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