Privacy policy

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Deze policy is momenteel enkel in het Engels beschikbaar. Wenst u een Nederlandstalige versie van deze policy, gelieve dan contact op te nemen met privacy@accurat.ai.

Cette politique n'est actuellement disponible qu'en anglais. Si vous souhaitez recevoir une version française de cette politique, veuillez contacter privacy@accurat.ai.

Diese Richtlinie ist derzeit nur auf Englisch verfügbar. Wenn Sie eine deutschsprachige Version dieser Richtlinie wünschen, wenden Sie sich bitte an privacy@accurat.ai

This privacy policy (“Privacy Policy”) is applicable to all processing activities of Accurat (as defined below) as controller. In an effort to provide you with the most relevant information and to make this information more easily accessible to you, we provide a separate policy with regards to Personal Data we receive from our data partners. If you suspect that we receive or process your Personal Data (including location data) for our Service, please consult our relevant Privacy Policy here.

Please read this Privacy Policy together with Accurat’s Cookie Policy.

We are entitled to update this Privacy Policy by posting a new version on the Website whereby we will indicate the revision date at the top of this Privacy Policy. As such, it is strongly recommended to regularly consult the Website and the page displaying the Privacy Policy, to make sure that you are aware of any changes.

1 ABOUT THIS PRIVACY POLICY

Due to, for example, your commercial relationship or recent contact with Accurat, or due to a visit to or an action on our “Website” (i.e. www.accurat.ai and related subdomains), we may collect, store and otherwise process personal data relating to you or, if you are a company, your employees | representatives (“(your) Personal Data”).

This Privacy Policy describes (i) how we collect, treat and store your Personal Data; (ii) the rights you can exercise in relation to your Personal Data; and (iii) the measures we take to protect it and to secure your Personal Data.

Accurat respects your privacy and we always strive to act in accordance with the applicable privacy legislation, such as (non-exhaustive): (i) the European General Data Protection Regulation 2016/679 (“GDPR”); (ii) the Belgian Privacy Act of 30 July 2018; (iii) the European ePrivacy Directive 2002/58/EC (including future amendments and revisions thereof); and/or (iv) (future) national legislation regarding the implementation of the GDPR (together: “Privacy Legislation”).

We have appointed a Data Protection Officer (“DPO”), to support our commitment for a durable compliance with the applicable Privacy Legislation, who can be contacted at dpo@accurat.ai.

2 ACCURAT IS THE DATA CONTROLLER

We are Accurat BV, a private limited company with registered office at 9800 Deinze, Leernsesteenweg 155, Belgium, registered with the Crossroads Bank for Enterprises under number 0725.498.434 (“Accurat” or “we | us”)

Accurat is the developer and provider of a location intelligence solution providing our customers with aggregated and anonymized customer insights (“Solution”) and is the owner of the Website.

In light of Privacy Legislation, Accurat will act as the DATA CONTROLLER of your personal data for the purposes described in this Privacy Policy. This means, we are in control of (and thus, responsible for) your personal data.

3 ACCURAT’S PROCESSING ACTIVITIES

Which personal data we collect, store and otherwise process and the purpose for which we process this data may differ depending on your relation with Accurat. In particular, we identify the following different scenarios:

□ You are browsing on our Website;

□ You are a lead | prospect and/or seeking a commercial relationship with Accurat;

□ Your company is an active Accurat customer;

□ You are | your company is a partner or a supplier of Accurat; or,

□ You receive | wish to receive updates and newsletters relating to Accurat’s services.

3.1 You are browsing on our Website

Contacting Accurat via the chat

Purpose: To answer any questions you may have and/or to initiate a conversation

Personal data:

□ First name

□ (Business) email address

□ Nature of inquiry

□ Last name

□ Company

□ Voluntarily provided information

Legal ground: Consent

Retention period: Up until one (1) year after your last contact with Accurat or until you have withdrawn your consent, whichever comes first.

Requesting your personal KPI Report and/or other contact forms

Purpose: To provide you with tailored reports and to initiate a conversation

Personal data:

□ First name

□ (Business) email address

□ Last name

□ Company

Legal ground: Consent

Retention period: Up until one (1) year after your last contact with Accurat or until you have withdrawn your consent, whichever comes first.

Cookies

When browsing on our Website, we may also collect your personal data through cookies stored on your device(s) in order to optimize the functioning of the Website. Please consult our Cookie Policy for more information.

3.2 You are a lead | prospect and/or seeking a commercial relationship with Accurat

Requesting a customized proposal | demo

Purpose: To provide you with a proposal and/or schedule your personal demo of the Accurat solution

Personal data:

□ First name

□ (Business) email address

□ Last name

□ Company

Legal ground: Consent

Retention period: Up until one (1) year after your last contact with Accurat or until you have withdrawn your consent, whichever comes first.

Prospecting and lead generation

Purpose: To allow for the lead generation, cold calling /emailing and prospecting

Personal data:

□ First name

□ (Business) email address

□ Last name

□ Company

□ Phone number

□ Job function

□ Publicly available information

Legal ground: Legitimate interest

Retention period: Up until one (1) year after your last contact with Accurat or until you have objected to the processing of your personal data for this purpose (cfr. Section 8 - “Your privacy rights”), whichever comes first.

General communication with Accurat & prospecting by Accurat

Purpose: To have quality conversations (via mail, telephone or business social media channels) in which Accurat provides more information on Accurat’s Solution

Personal data:

□ First name

□ (Business) email address

□ Phone number

□ Voluntary provided information

□ Last name

□ Company name

□ Social media / business channel

Legal ground: Legitimate interest

Retention period: Up until one (1) year after your last contact with Accurat or until you have objected to the processing of your personal data for this purpose (cfr. Section 8 - “Your privacy rights”), whichever comes first.

3.3 Your company is an active Accurat customer

If you read this Policy as an employee of a company relying on Accurat, please note that your employer is to be considered your data controller (as your employer decided to rely on the Solution, assigns accounts, etc.). To set up the Solution, your employer might have provided us with some of your personal information (e.g. your name, your email-address, etc.). In this context, Accurat has adopted a Data Processing Policy. For more information regarding the Solution, you can always directly contact your employer.

General communication and (technical) support

Purpose: To enable communication with and to provide support to customers

Personal data:

□ First name

□ (Business) email address

□ Phone number

□ Last name

□ Function title

□ Company name

Legal ground: Necessary for the performance of the agreement

Retention period: For the duration of your commercial relationship with Accurat and in any event accordance with any (data processing) agreements concluded with Accurat.

Creating your account

Purpose: To set up your account(s) on our Solution

Personal data:

□ First name

□ (Work) email address

□ Last name

□ Function title

Legal ground: Necessary for the performance of the agreement

Retention period: For the duration of your commercial relationship with Accurat and in any event accordance with any (data processing) agreements concluded with Accurat.

Optimization and issue/bug resolution

Purpose: To allow us to resolve any issues and or bugs and optimize our Solution and your experience.

Personal data:

□ First name

□ (Business) email address

□ Last name

□ User ID

□ Phone number

□ Metrics on the use of our Solution

Legal ground: Legitimate interest

Retention period: Until one (1) year following the termination of the commercial relationship between your company and Accurat

Quotes | proposals

Purpose: To draw up (additional) quotes | proposals

Personal data:

□ First name

□ (Business) email address

□ Company name

□ Last name

□ Function title

Legal ground: Necessary for the performance of the agreement

Retention period: For the duration of your commercial relationship with Accurat and in any event accordance with any (data processing) agreements concluded with Accurat.

Invoicing

Purpose: To prepare and send invoices for the use of the Accurat Solution (incl. corresponding communication).

Personal data:

□ First name

□ Last name

□ (Business) email address

□ Company name

□ Function title

Legal ground: Necessary for the performance of the agreement

Retention period: For the duration of your commercial relationship with Accurat and in any event accordance with any (data processing) agreements concluded with Accurat.

3.4 You are | your company is a partner or a supplier of Accurat

General communication and provision of services

Purpose: To communicate with you in the scope of our commercial relationship

Personal data:

□ First name

□ (Business) email address

□ Phone number

□ Last name

□ Function title

□ Company name

Legal ground: Necessary for the performance of the agreement

Retention period: For the duration of your commercial relationship with Accurat and in any event accordance with any (data processing) agreements concluded with Accurat.

Concluding and managing of partnership / commercial relationship

Purpose: Negotiating and concluding the commercial agreement and managing the relationship between your company and Accurat.

Personal data:

□ First name

□ (Business) email address

□ Phone number

□ Last name

□ Function title

□ Company name

Legal ground: Necessary for the performance of the agreement

Retention period: For the duration of your commercial relationship with Accurat and in any event accordance with any (data processing) agreements concluded with Accurat.

Invoicing

Purpose: To settle invoices for the services provided (incl. corresponding communication).

Personal data:

□ First name

□ (Business) email address

□ Company name

□ Last name

□ Function title

Legal ground: Necessary for the performance of the agreement

Retention period: For the duration of your commercial relationship with Accurat and in any event accordance with any (data processing) agreements concluded with Accurat.

3.5 You receive | wish to receive updates and newsletters relating to Accurat’s services

The Accurat newsletter

Purpose: Providing general information on Accurat

Personal data:

□ First name

□ (Business) email address

□ Last name

Legal ground: Consent or, if you happen to be a customer or partner of Accurat, legitimate interest

Retention period: Up until one (1) year after your last contact with Accurat or until you have objected to the processing of your personal data for this purpose (cfr. Section 8 - “Your privacy rights”), whichever comes first.

Direct marketing

Purpose: Providing more information on (new features of) the Accurat Solution or related products/services

Personal data:

□ First name

□ (Business) email address

□ Last name

Legal ground: Consent

Retention period: Up until one (1) year after your last contact with Accurat or until you have objected to the processing of your personal data for this purpose (cfr. Section 8 - “Your privacy rights”), whichever comes first.

3.6 You apply for a job position at Accurat

Job application process

Purpose: Assessing your application and managing the recruitment process

Personal data:

□ First name

□ Last name

□ (Business) email address

□ Motivational letter

□ CV (including voluntarily provided information)

Legal ground: Consent

Retention period: Up until one (1) year after your application, unless a legal obligation requires otherwise.

In case you are offered and accept a job position at Accurat, your personal data will be further processed in the context of your employment relationship.

4 LEGAL GROUNDS

You can find more information on the applicable ground for each of the identified processing activities in Section 3 above.

In case the legal ground for processing happens to be legitimate interest, Accurat shall always (i) assess whether this is in proportion with the purpose for which your personal data was collected and used; and, (ii) take your reasonable expectations into account and ensure a balance with your fundamental rights and freedoms. If we cannot guarantee this, we will stop storing | using your personal data or we will determine a new legal ground.

5 RETENTION PERIODS

You can find more information on the retention period of your personal data for each of the identified processing activities in Section 3 above.

6 DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

Accurat shall not disclose your personal data to third parties, unless it is necessary to achieve the purposes described in this Privacy Policy. In this respect, (some of) your personal data may be disclosed to:

□ Payment providers;

□ Software and cloud providers; and,

□ Freelancers or other service providers.

Of course we have made sure that the necessary contracts or similar legal binding acts are in place to ensure that these third parties treat your personal data in accordance with the Privacy Legislation (e.g. Article 28 GDPR).

In addition, we might transfer your personal data:

□ to competent authorities: for instance, because (i) we are obliged to provide your personal data under law or in the scope of (future) legal proceedings, or (ii) this is necessary to safeguard our rights; or,

□ in M&A context: meaning, if Accurat or the majority of its assets, is taken over by a third party, in which case your personal data – which Accurat has collected – may be one of the transferred assets.

7 CROSS-BORDER PROCESSING OF PERSONAL DATA

In case any of the above mentioned third parties or other recipients are located in a country outside the European Economic Area, Accurat will ensure that one or more of the listed EU-approved safeguards are in place:

□ European Commission adequacy decision;

□ Data transfer agreement (cfr. the Standard Contractual Clauses as provided in the European Commission Implementing Decision (EU) 2021/914 of 4 June 2021);

□ Binding corporate rules; or,

□ Certification mechanisms.

8 YOUR PRIVACY RIGHTS

The Privacy Legislation (e.g. GDPR) gives you certain rights over your personal data vis-à-vis Accurat. You can exercise these rights by contacting us, as specified in Section 11, and by using the Data Subject’s Rights Form (see at the end of this Section 8).

Access: you can ask for confirmation of whether or not personal data that relates to you is being processed. If so, you can ask us to give you copies of your personal data. We may charge you a small fee for this service;

Rectification: you can ask us to correct | complete any information you believe is inaccurate | incomplete;

Erasure: you can ask us to erase your personal data, under certain conditions. Please be aware that in this context certain services will no longer be accessible and/or can no longer be provided;

Objection: you can object to us processing your personal data, under certain conditions;

Restriction of processing: you can ask us to restrict the processing of your personal data, unless we have legitimate interests for the processing of your personal data that prevail over your interests;

Data portability: you can ask us to transfer your personal data to another organization, or directly to you in a commonly used structured format readable by automatic device, under certain conditions.

Updates | Newsletters. You can always change your communication preferences in the Accurat Subscription Preferences Centre (you can find a unique link in the footer of every Accurat communication).

If you no longer wish to receive any of our Accurat communications, you can object to these direct marketing communications by either (i) using the Data Subject’s Rights Form (you can download it here.); or (ii) by unsubscribing in our Subscription Preferences Centre (as indicated above). Upon receipt of your objection, we will stop processing your personal data for Accurat communications. This is done free of charge.

9 SECURITY

Accurat undertakes to take reasonable, physical, technological and organisational precautions in order to avoid (i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data.

Please consult Accurat’s Security page here, for more information on the security measures taken.

Notwithstanding the security measures we have taken, the checks we carry out and the actions we propose in this context, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the internet, or any method of electronic storage is 100% secure, we are not in a position to guarantee absolute security.

Finally, the security of your account will also partly depend on the confidentiality and complexity of your password. Accurat will never ask for your password, meaning that you will never be required to communicate it personally. Accurat therefore strongly advises you, if you observe that someone has accessed your account, to immediately change your password and contact us.

10 UPDATES

We are entitled to update this Privacy Policy by posting a new version on the Website whereby we will indicate the revision date at the top of this Privacy Policy. As such, it is strongly recommended to regularly consult the Website and the page displaying the Privacy Policy, to make sure that you are aware of any changes.

11 NOTIFICATIONS AND QUESTIONS

Notifications under this Privacy Policy (such as, exercising your rights as a data subject) and/or any questions or concerns with regard to the provisions of this Privacy Policy must be directed at privacy@accurat.ai. You can reach our DPO at dpo@accurat.ai.

12 COMPLAINTS?

You are not satisfied with the manner in which we collect, store or otherwise treat or secure your personal data? We are sorry to hear that, and are prepared to take all measures to remedy this situation. Please do contact us as specified above in Section 11.

You also have the right to lodge a complaint with the authorized supervisory authority (i.e. the Belgian Data Protection Authority or the data protection authority of (i) your residence or (ii) your workplace) should you consider that the processing of your personal data infringes the Privacy Legislation. You can send an email to the Belgian Data Protection Authority at contact@apd-gba.be or any other email address provided by the Belgian Data Protection Authority (https://www.dataprotectionauthority.be/contact-us).