Privacy policy

Privacy Policy (version 21 march 2021)

This Privacy Policy applies to the website https://www.conneqtr.com/ (the "Website"), and by extension to the Conneqtr Smooth Android application (the "Smooth App"), owned and operated by:

Conneqtr BV, Grootveldlaan 148, 1150  Sint-Pieters-Woluwe, Belgium

Enterprise  Number: 0765.529.146

hereinafter "Conneqtr", "we" or "us".

Conneqtr deems the protection of privacy of the utmost importance. Conneqtr wishes to inform you about the Processing of Personal Data that takes place via the Website, in accordance with the applicable data protection legislation and more specifically with the General Data Protection Regulation (“GDPR”) and its relevant national implementing legislation. All capitalized terms that are not defined in this Privacy Policy shall have the meanings as ascribed to them in the GDPR.

This Privacy Policy describes your rights for you to make informed decisions when using the Website and to exercise your rights when necessary. Please read this Privacy Policy very carefully.

This Privacy Policy must be read together with our cookie policy, which can be found on our website, https://www.conneqtr.com/cookies.

Conneqtr may amend this Privacy Policy from time to time. The date of the most recent version is shown in the top right-hand corner. Any significant changes to this Privacy Policy will be clearly indicated on the Website. Please review this Privacy Policy periodically to stay informed of changes that may affect you.

Who Processes your Personal Data and how can you contact us?

Conneqtr is responsible for the Processing of your Personal Data that you provide through the Website and shall act as a Controller.

Conneqtr has appointed a Data Protection Officer whom you can always contact for questions about your privacy and the Processing of your Personal Data. The Data Protection Officer can be contacted via dpo@conneqtr.com.

What Personal Data are collected and Processed, for which Purposes and for how long?

Conneqtr Processes different types of Personal Data for different purposes via its Website, depending on the services you use and on the type of relationship (visitor, prospective client, client) you have with Conneqtr.

Where Personal Data of a third party are disclosed via t Website or with a view to visit the Website, the person communicating the Personal Data guarantees that he or she has informed that third party and that he or she has received all necessary consents to communicate the third party's Personal Data via the Website to Conneqtr.

Who do we share your Personal Data with?

To be able to follow through on your request or action on the Website, Conneqtr may sometimes need to share Personal Data with third parties.

Your Personal Data may be shared or transferred to the following entities:

• (currently no external entities)

This listing may evolve and shall be updated from time to time.

Processors and Subprocessors of Conneqtr always act under the responsibility of Conneqtr. If Conneqtr contracts Processors or Subprocessors, this will always be done in accordance with a Data Processing Agreement that meets the requirements of the GDPR and that protects your Personal Data as well as possible.

If you are directed to another application, platform or website through the Website, other terms and conditions and other privacy and cookie policies may apply. You should take into account any such terms and conditions and privacy and cookie policies of such applications, platforms and websites. We encourage you to read these terms and conditions and privacy and cookie policies of the other applications, platforms and websites you visit.

Transfer of Personal Data outside the European Economic Area (EEA)

In principle, Conneqtr does not transfer your Personal Data to countries outside the EEA.

It is, however, possible that Conneqtr - through its Processors or Subprocessors - does transfer your Personal Data to countries outside the EEA. In this case, Conneqtr shall only transfer your Personal Data outside the EEA in accordance with applicable law (such as chapter V of the GDPR) (e.g. model contract clauses, binding corporate rules, codes of conduct, adequacy decisions, etc.).

How are my Personal Data safeguarded?

Conneqtr has developed appropriate technical and organizational measures, safeguards and assurances to Process your Personal Data in accordance with applicable Belgian and European regulations, in particular to protect your Personal Data against loss, misuse, or unauthorized alteration or destruction.

Conneqtr maintains advanced technologies, such as third-party CRM and/or mailing list management solutions with proven track record of data protection and security for storage of the Personal Data. These platforms have sufficient security measures in place to prevent unauthorized access.

Conneqtr makes all reasonable and appropriate efforts to protect the confidentiality of your Personal Data. Within Conneqtr access to you Personal Data will only be granted a need-to-know basis.

Despite the above measures taken by Conneqtr, you should be aware that there are always risks associated with sending Personal Data over the Internet. The security and protection of your Personal Data can never be fully guaranteed.

What rights do I have?

If and in as far as provided for in the applicable Belgian and European legislation, you have the right:

1. to receive confirmation as to whether Conneqtr Processes your Personal Data and, where this is the case, to access the Personal Data that Conneqtr Processes;
2. to corrections by Conneqtr, without undue delay, of any inaccurate or incomplete Personal Data;
3. to have your Personal Data deleted by Conneqtr;
4. to obtain your Personal Data and to transfer them to another controller or processor;
5. to obtain a limitation of the Processing of your Personal Data from Conneqtr, to the extent possible subject to applicable Belgian and European regulations;
6. to receive your Personal Data in a structured, common and machine-readable format;
7. to prevent the Processing of your Personal Data and the use of your Personal Data for direct marketing purposes.

You may exercise these rights by contacting the Data Protection Officer and providing him or her with a copy of your identity card (e.g. no identification number may be visible).

If and to the extent provided for in the applicable Belgian and European legislation, you have the right to file a complaint with the competent supervisory authority should the Processing of your Personal Data violate the applicable regulations. In Belgium, this is the Data Protection Authority ("Gegevensbeschermingsautoriteit"):

Drukpersstraat 35, 1000 Brussel, Belgium, +32 (0)2 274 48 00 / +32 (0)2 274 48 35

contact@apd-gba.be, https://www.dataprotectionauthority.be

Despite the above measures taken by Conneqtr, you should be aware that there are always risks associated with sending Personal Data over the Internet. The security and protection of your Personal Data can never be fully guaranteed.

Consent for disclosure

You acknowledge that we may disclose your Personal Data if this is required by law, or if Conneqtr determines in good faith that such disclosure is required in order:

1. to comply with any pending judicial inquiry, judicial order or litigation pertaining to the Website;
2. to respond to claims against Conneqtr regarding Personal Data that violate any rights of third parties;
3. to safeguard the rights, property and safety of Conneqtr, its employees, users, and the general public.

Conneqtr may disclose your Personal Data to competent police or judicial authorities or other official government authorities if Conneqtr deems this useful or necessary, in its sole discretion, for the investigation of fraud, intellectual property infringement or any other harmful activity, or if Conneqtr reasonably suspects that such activity may expose Conneqtr or you to any liability.

Liability

If Conneqtr has legitimately transmitted your Personal Data to a third party (not being a Processor or subprocessor), Conneqtr shall not be liable for any unlawful Processing or unlawful use by that third party.

Under no circumstances does Conneqtr accept responsibility for any direct or indirect damage resulting from faulty or unlawful use of the Personal Data by a third party (not being a Processor or subprocessor).

Conneqtr is also not liable when third parties process or use your Personal Data illegitimately and Conneqtr has taken the appropriate technical and organizational measures to go against such illegitimate Processing or use.

Conneqtr is in any case only liable for the damage caused by Processing of Personal Data if it did not comply with its specific obligations of GDPR. Conneqtr shall in no event be liable for any special, incidental, indirect or consequential losses or damages.

Applicable law and competence clause

This Privacy Policy shall be governed, interpreted, and implemented in accordance with Belgian law, which applies exclusively in the event of any dispute.

The Belgian courts and more specifically, the Dutch-speaking courts of Brussels are exclusively competent to decide on any dispute that may arise from the interpretation or implementation of this Privacy Policy, without prejudice to the consumer’s right to present a dispute before the competent court on the basis of a mandatory statutory provision.