Privacy policy

1. Introduction and scope

This privacy notice aims to inform you about how Twikit NV (“Twikit”, “we”,“us”) collects and processes your personal data on our website https://www.twikit.com/ (the “Website“).

Twikit respects your privacy and is committed to protecting your personal data and your privacy in accordance with Belgian and European data protection laws, including the EU General Data Protection Regulation 2016/679 (“GDPR”) as well as any applicable national implementing and supplementing laws.

Please read this privacy policy carefully. It describes not only your rights, but also the way in which you can exercise these rights.

By visiting our Website or by disclosing your personal data to us via our Website, you acknowledge that you have read this policy and the way we collect and process your personal data.

2. Who we are and how to contact us?

Twikit is a company incorporated under Belgian law and acts as data controller in respect of the personal data collected via its Website:

We have appointed a data protection officer , whom you can contact for questions about this privacy policy and the processing of your personal data.

3. What categories of personal data do we process?

Depending on which data you choose to share with us and how you use the Website we collect and process different types of personal data.

However, in general, if we process your personal data, it will be personal data of one of the following categories:

• identification and contact details (such as your name, telephone number and email address);
• technical information (such as information about your computer, mobile and other devices (such as, your IP- address, user-ID, operating system, browser type));
• usage information (such as information regarding your usage of our Website (such as, history, logs, date, time, location, frequency, duration of the pages you have viewed, consent preferences, information regarding consent(s) given by you (such as, the date and time of your consent)).
• any other type of personal data you may decide to share with us through free field forms.

Your personal data originates from you directly or is automatically collected by us (in case of technical information).

4. For which purposes do we process personal data, on which legal basis and for how long?

Depending on your use of the Website we may process your personal data for the purposes specified hereunder. Please note that our Website may evolve and more functionalities can be added from time to time. In such case this list may also evolve and will be updated as necessary in accordance with section 16.

If we ask for your consent, the consent you give is always free and you have the right to withdraw it at any time. You can withdraw your consent by sending an email to: [email protected]. Note that your withdrawal of consent does not affect the processing of personal data prior to such withdrawal or our processing activities which are based on any other legal basis.

For more details about the retention period, you can always send an email to: [email protected].

5. Personal data of third parties

If you disclose any personal data of third parties to us, you guarantee that you have informed those third parties and you have received all necessary consents to communicate the third parties’ personal data to Twikit.

6. Cookies

The Website uses cookies and similar technologies. For more information, we refer to our cookie policy.

7. Disclosures of personal data

Twikit may share your personal data, as required for the purposes set forth in section 4, with:

• third party service providers (such as IT service providers, security providers, or hosting providers);
• professional advisers (such as lawyers or auditors); and
• third parties to whom we intend or choose to sell, transfer or merge (parts of) our shares, business or assets.

Upon request, Twikit shall, as soon as possible after the request, inform you of the third parties with whom your personal data have been shared by providing you a more detailed list.

In addition, we may disclose your personal data if this is required by law, or if we determine in good faith that such disclosure is required in order to comply with any pending judicial inquiry, judicial order or litigation and/or to safeguard our rights.

Processors and sub-processors of Twikit always act under the responsibility of Twikit. If Twikit engages processors or sub-processors, this will always be done in accordance with a data processing agreement that meets the requirements of the GDPR. We require all our processors or sub-processors to take appropriate technical and organizational (including security) measures to protect your personal data in line with our policies. We do not allow our processors or sub-processors to use your personal data for their own purposes. In the event we disclose your personal data as described above, we will implement appropriate safeguards to ensure the integrity and confidentiality of your personal data.

Your personal data will only be viewed and made available to processors, sub-processors, employees and other third parties on a “need-to-know” basis, limited to the extent necessary to perform their services.

8. Will your personal data be transferred to countries outside the EEA?

In principle, Twikit does not transfer your personal data to third countries located outside the European Economic Area (“EEA”) unless you are located outside the EEA (and are visiting our Website or otherwise provide personal data from outside the EEA).

Additionally, it is possible that in some cases Twikit – through its (sub-)processors – does transfer your personal data to countries outside the EEA. In this event, Twikit will only transfer your personal data outside the EEA in accordance with the applicable data protection legislation and subject to appropriate safeguards.

Please contact us if you want further information on the specific mechanism(s) used when transferring personal data outside the EEA.

9. Do we process your personal data for direct marketing purposes?

We may use your personal data for direct marketing purposes (including profiling).

This enables us to keep you informed about our products, updates, events, etc. We will only do this based on your explicit consent for this, but you may at any time, free of charge, withdraw your consent or object to the processing of your personal data for direct marketing purposes (including profiling), to the extent that it relates to such direct marketing, by sending an email to: [email protected]. The withdrawal of consent does not affect the processing of personal data prior to such withdrawal or our processing activities which are based on any other legal basis.

10. How do we protect your personal data?

Twikit is committed to trying to make sure that your personal data is secure and makes all reasonable and appropriate efforts to protect your personal data. We take appropriate technical and organizational security measures to ensure a level of security in accordance with the GDPR and appropriate to foreseeable risks. Twikit has implemented measures to protect your personal data against destruction, loss, misuse, unauthorized alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed.

Please contact us if you would like information on the specific measures taken by sending an email to: [email protected].

Despite the above measures taken by us, 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, nor can we guarantee that unauthorized third parties will never be able to defeat those measures or use your personal data for improper purposes.

11. How long do we keep your personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes determined in section 4 of this privacy notice, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is or may be litigation pending in respect to our relationship with you.

Afterwards it is still possible that your personal data can be found in our back-ups or archives, but they will no longer be actively processed in a file. Such back-ups or archives will be deleted automatically in accordance with our back-up and archiving policies.

The applicable retention periods are set out in the table under section 4.

12. Your legal rights

Within the limits defined in Articles 15-22 of the GDPR, you have the following legal rights in relation to your personal data:

• Right of access: you have the right to obtain confirmation from us as to whether or not we are processing your personal data, to access that personal data and how and why it is being processed, as well as to receive a copy of that data.
• Right to rectification: you have the right to obtain a rectification of your personal data or to request that we complete your personal data when you become aware that we are processing incorrect or incomplete data about you.
• Right to erasure (“right to be forgotten”): you have the right to obtain erasure of your personal data in certain specific cases.
• Right to restriction: you have the right to have the processing of your personal data restricted in certain specific cases.
• Right to portability: you have the right to obtain the personal data you have provided to us in a structured, commonly used and machine-readable form, and to transfer (have transferred) that personal data to another controller.
• Right to object: you have the right to object to the processing of your personal data on the basis of our legitimate interest for reasons relating to your specific situation.

The exercise of these rights is in principle free of charge. Only in the event of unreasonable or repeated requests we may charge a reasonable administrative fee. We will always inform you of the applicable fee before charging it.

You can exercise your rights by sending an email to: [email protected].

In your request, make sure to clearly specify which right you wish to exercise so we can help you as efficient as possible. Please note that in some case we may require you to give more information about yourself to ensure that we are dealing with the correct person.

If you contact us to exercise your rights we will respond within 1 month. Exceptionally this may take longer (up to 3 months), but then we will inform you within 1 month of the reasons why.

13. Your right to lodge a complaint with a supervisory authority

If you consider that our processing of personal data infringes the GDPR, you have the right to file a complaint with a supervisory authority, in particular in the member state of your habitual residence, the place of work or the place of alleged infringement.

In Belgium the competent supervisory authority is the Data Protection Authority (“Gegevensbeschermingsauthoriteit” “Autorité de protection des données”):

www.gegevensbeschermingsautoriteit.be

Drukpersstraat 35, 1000 Brussels, Belgium +32 (0)2 274 48 00 [email protected].

However, we would appreciate the chance to deal with your concerns before you approach the authority, so please contact us in first instance.

14. Third party links

The Website may contain links to third party platforms, websites and/or applications. Twikit is not responsible for the content of these platforms, websites and applications and is not responsible for the privacy standards and practices of such third parties. We recommend you read the relevant privacy policies of these third parties and their platforms, websites and/or applications before you accept their cookies and visit them to ensure yourself that your personal data is sufficiently protected.

15. Liability

If Twikit has legitimately transmitted your personal data to a third party (not being its (sub-)processor), Twikit shall not be liable for any unlawful processing or unlawful use by that third party.

Twikit is in any case only liable for the damage caused by the processing of personal data if it did not comply with its specific obligations under the GDPR and our liability shall not exceed an amount equal to the amounts actually paid out by our insurer for the damage causing event. Twikit shall in no event be liable for any special, incidental, indirect or consequential losses or damages.

The foregoing exclusions and limitations shall only apply to the maximum extent permitted by applicable law.

16. Changes to this privacy policy

Twikit may amend this privacy notice at all times. Any changes we may make to our privacy policy will be indicated on the Website and when proportionate and in line with the significance of the changes, may be notified to you by email (or otherwise when you visit the Website). The date of the most recent version is shown below. Please review our privacy notice periodically to stay informed of changes that may affect you.

Amended versions of this privacy notice take effect ten (10) days after their publication on the Website and/or other form of announcement and, if necessary, will always be submitted for approval, unless such modifications are necessary to comply with a legal requirement. In the latter case, such changes will take effect immediately.

17. Applicable law and competence

This privacy notice shall be governed, interpreted, and implemented in accordance with Belgian laws.

The Antwerp courts (department Antwerp) are exclusively competent to decide on any dispute that may arise from the interpretation or implementation of this privacy notice, without prejudice to the consumer’s right to present a dispute before a competent court on the basis of a mandatory statutory provision.

Last updated: 08/02/2024