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Privacy Policy

1. Definitions

In addition to the terms defined elsewhere, capitalized terms used in this Privacy Policy shall have the meanings as set forth below.

Data Protection Legislation means (i) the EU Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC as from 25 May 2018; (ii) the Belgian law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data and (iii) all other current or future applicable national laws relating to or impacting the processing of Personal Data and privacy. 

Personal Data means all information relating to an identified or identifiable natural person.

Processor means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller.

Data Controller means a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

2. Identity and contact details of the Data Controller

2.1. Doggybites BV (hereinafter “Adhese”, “Our”, “We” or “Us”) is a Belgian BV with premises at Dulle-Grietlaan 1/0001, 9050 Ghent, Belgium and registered in the Crossroads Bank for Enterprises under number 0473.556.374. You can contact Us at privacy@adhese.eu.

2.2. Protecting your privacy and Personal Data is of the utmost importance to Us. This Privacy Policy describes how We will process your Personal Data.

2.3. We qualify as the Data Controller, as defined in the Personal Data Legislation, regarding the processing of your Personal Data for the purposes stated in this Privacy Policy.

3. Personal Data

3.1. We will process the following (categories of) Personal Data from you:

  • Contact information (first name, last name, (if applicable) company name, address, email address, telephone number, information provided by you in your communications to Us, etc.);
  • Job application information (information including your (i) contact details i.e. first name, last name, email address, telephone number; and (ii) information provided by you in your curriculum vitae and cover letter including for example your former and current employers, work experience, education, skills, references that are spontaneously included in your CV or for which you have explicitly given your consent, etc.)
  • Technical information (IP address, geographical location and operating system, browser type, etc.).

4. Purpose of the processing and legal basis

4.1. We will process your Personal Data for the following purposes and associated legal grounds:

Categories of Personal DataPurposes of processingLegal basis
Identification and contact details
  • Contacting you if you sign up for one of Our webinars or demos.
  • Necessary for the performance of a (potential) agreement.
    (art. 6 (1) (b) GDPR)
  • To allow you to enter into a collaboration with Us.
  • Necessary for Our legitimate interest (namely, to enter into a collaboration and to provide you with all relevant information and assistance).
    (art. 6 (1) (f) GDPR)
  • For purposes of client management (e.g. to enable Us to contact you in the context of your purchase and/or use of Our products or services).
  • Necessary for Our legitimate interest (namely, to provide Our products and services in an adequate and efficient manner and to provide you with all relevant information and assistance).
    (art. 6 (1) (f) GDPR)
  • Allowing Us to contact you for various purposes, including requesting your feedback to optimize Our services based on it or to respond to your complaint or inquiries.
  • Necessary for Our legitimate interest (namely, to be able to appropriately respond to your requests).
    (art. 6 (1) (f) GDPR)
  • Allowing Us to invite you to Our events.
  • Your consent if you are a new client; or
  • the Soft-opt-in if you are already a client who purchased Our products.
    (art. 6 (1) (a) GDPR / art. 16(2) e-Privacy Directive)
  • Sending promotional messages or information about (i) Our services and (ii) Our events and initiatives directly or indirectly related to Our core activities (“direct marketing”).
  • Your consent if you are a new client; or
  • the Soft-opt-in if you are already a client who purchased Our products.
    (art. 6 (1) (a) GDPR / art. 16(2) e-Privacy Directive)
Job application information
  • To allow you to apply for a job via Our website.
  • Necessary to take measures at your request prior to entering into an employment contract. (cf. art. 6.1, b) GDPR)
  • Allowing Us to select suitable profiles to recruit for Our company.
  • Legitimate interest to provide quality recruitment in the competitive market. (cf. art. 6.1, f) GDPR)
  • Allowing Us to defend ourselves in the event of a dispute regarding your job application.
  • The legitimate interest in defending Our rights in the best possible manner.
    (art. 6, f) GDPR)
Technical information
  • We process your contact information to perform audience measurements in order to improve Our Website (performance measurement, detection of navigation problems, optimization of technical performance or its ergonomics, estimation of the power of the necessary servers, analysis of contents consulted).
  • Necessary for Our legitimate interest (namely, to improve Our Website).
    (art. 6 (1) (f) GDPR)

4.2.  If you decide to apply for a job at Adhese, note that we use an external recruitment platform (Applicant Tracking System) i.e. “Recruitee by Tellent”. We receive your Personal Data and any required written consent (regarding, for example, a reference) through that external recruitment platform. The recruitment platform will notify you of this Privacy Policy, if necessary, but we recommend that you also consult the Privacy Policy of the provider of that recruitment platform to find out what Personal Data it processes, what the conditions for that processing are, and how you can exercise your rights against the provider of that external recruitment platform.

4.3. If We process your Personal Data on the basis of Our legitimate interest, this means that, after balancing all relevant interests, We have determined that Our identified interest outweigh yours. If you would like more information about the balancing of interests, please contact Us at privacy@adhese.eu.

4.4. If the processing of your Personal Data as per the above table is necessary to perform the agreement, We cannot execute the agreement if you do not provide your Personal Data to Us.

4.5. We will inform you in advance if We intend to process your Personal Data for purposes other than those indicted in this Privacy Policy.

4.6. Sending direct marketing via email is, in some cases, allowed without your explicit consent, for example, because We have obtained your electronic contact details in the context of the sale of products or services and because our commercial messages relate to Our own similar products or services (“Soft opt-in“). You can object to receiving further direct marketing messages from Us at any time by clicking on the UNSUBSCRIBE” button included in every direct marketing email we send. The option to unsubscribe is provided in every direct marketing email. You can also send your intention to unsubscribe to privacy@adhese.eu.

4.7. To receive other direct marketing than that described in the above article, you can give your consent when the relevant Personal Data is requested by Us. You have the right to withdraw your consent at any time. This withdrawal will not affect the lawfulness of the processing of Personal Data based on your consent before the withdrawal of consent.

4.8. Finally, please note We use “Piwik PRO Analytics Suite” to perform audience measurements in order to improve Our Website (performance measurement, detection of navigation problems, optimization of technical performance or its ergonomics, estimation of the power of the necessary servers, analysis of contents consulted). We host Our solution in Germany and the data is stored for a period of 25 months.

5. Recipients of Personal Data

5.1. Your Personal Data is processed by Us for the purposes described above. We may also disclose your Personal Data to third parties who provide services to Us, such as but not limited to marketing offices, recruitment offices, payment service providers, logistical service providers and IT-service providers. These external Processors may only process your Personal Data on explicit and written instruction from Us for Our benefit. We guarantee that all external Processors are selected with due care and oblige them to observe the security and integrity of your Personal Data.

5.2. In any other case, We do not send your Personal Data to third parties.

5.3. We may disclose your Personal Data to third parties when required by law or a court order.

5.4. In case of a total or partial sale, reorganization or transfer of Our organization (including a merger or acquisition), We may also disclose your Personal Data to (non-)affiliated third parties including advisors involved in the process of the partial sale, reorganization or transfer.

6. Transfer of Personal Data

6.1. We will primarily process your Personal Data within the European Economic Area. In the event that We transfer your Personal Data to countries outside the EEA (for example, through the use of cookies related to Piwik PRO,We will ensure that the same level of protection is achieved as within the EEA (for example, by concluding standard contractual clauses with the Processor located outside the EEA or by only cooperating with countries for which the European Commission has issued an adequacy decision).

7. Period during which We will retain Personal Data

7.1. We will retain your Personal Data for as long as necessary for the processing of your Personal Data for the aforementioned purposes, or as long as We are legally obligated to retain them in accordance with the table below:

Personal Data Retention period
Identification and contact details 2 years after subscription
Professional information 2 years after the end of any contractual relation
Job applicant information 2 years after the end of your application process.
Technical information 25 months

8. Your rights

8.1. In accordance with the provisions of Personal Data Legislation, you have the right to request from Us:

  • access to and a copy of your Personal Data We hold (right of access);
  • correction of your Personal Data if it is incorrect, inaccurate, or incomplete (right to rectification);
  • erasure of your Personal Data if they are no longer necessary for the specified purpose or if you demonstrate that the processing of such Personal Data is unlawful (right to erasure or right to be forgotten);
  • object to the processing of your Personal Data for reasons relating to your particular situation (right to object);
  • request a restriction of the processing of your Personal Data in specific cases (right to restriction of processing); and
  • obtain and transfer the Personal Data concerning you in a structured, commonly used, and machine-readable format to another controller, without hindrance from Us, where the processing would comply with Article 20 of the GDPR.

8.2. If you wish to exercise the above-mentioned rights or if you have a question about how We process your Personal Data, you can contact Us at privacy@adhese.eu. We will handle your request within a reasonable period of time.

8.3. When contacting Us, please ensure that it is always clear which of the above rights you wish to exercise and how you wish to receive a response (e.g., by email, by post, etc.). Please note that in certain cases, We may request additional documentation or information, including a copy of your identity card, to ensure We are assisting the correct person. Under certain exceptional circumstances, We have the right not to fulfil your request (e.g. if We have the legal obligation to retain your Personal Data).

8.4. If you believe that We have not processed your Personal Data in accordance with the applicable Data Protection Legislation, you can lodge a complaint with the Data Protection Authority:

Data Protection Authority

Gegevensbeschermingsautoriteit (GBA)

Drukpersstraat 35

1000 Brussels

E-mail: contact@apd-gba.be

9. Changes to this Privacy Policy

9.1. We reserve the right to modify this Privacy Policy at any time. We will announce each modified version of this Privacy Policy and, if necessary, request your consent in accordance with the provisions of Article 4 of this Privacy Policy.

10. Our Commitment to Compliance

10.1. Adhese is committed to maintaining the highest standards of transparency and compliance in handling user data. This attestation of compliance outlines our adherence to the requirements of the IAB Europe Transparency and Consent Framework (“TCF”). As a registered participant in the TCF, Adhese ensures that its data processing activities and technology implementations align with the TCF specifications and policies, which serve to help standardize the consent signals and transparency information in the digital advertising space, as per the requirements of the General Data Protection Regulation (“GDPR”). Please refer to: https://iabeurope.eu/iab-europe-transparency-consent-framework-policies/.

 
10.2. Adhese actively implements measures to adhere to the principles of transparency, fairness, and accountability in our interactions with users, partners, and third parties. As such, Adhese is committed to: 
  • Ensure Transparency: We provide clear and comprehensive information about data processing activities to our users, allowing them to make informed consent decisions;
  • Respect User Consent: Personal data is processed only via consent expressed by the users through TCF compliant Consent Management Platform (“CMP”);
  • Accountability: We keep detailed records of consent and data processing activities as proof of our compliance and to facilitate any audits or reviews by regulatory authorities or IAB Europe;
  • Continuous Improvement: We regularly review and update our processes, systems, and documentation to align with any updates in the TCF Policies and the evolving data protection landscape.

10.3. Transparency and Consent Framework (TCF) Registration: Adhese is a registered participant in the TCF, adhering to all relevant guidelines and requirements set by IAB Europe. Our TCF Vendor ID: 553

10.4. Contact Information: If you have any questions or concerns regarding our compliance with the TCF policies, please contact us at: info@adhese.eu

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Adhese is committed to protecting and respecting your privacy, and we’ll only use your personal data to administer your account and to provide the products and services you requested from us. From time to time, we would like to contact you about our products and services, as well as other content that may be of interest to you. If you consent to us contacting you, please tick the checkboxes below to indicate for which purpose(s) you would like us to contact you.

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You may unsubscribe from all the marketing communications sent by Adhese at any time by clicking on the unsubscribe link or change your marketing communications preferences by clicking on the privacy settings link in any communication sent by Adhese. For more information on Adhese privacy practices, and how we are committed to protecting and respecting your privacy, please review our Privacy Policy.