This notice explains how, as a data controller, Isabel Group (“we”, “us”, “our”), with offices at Keizerinlaan 13-15, 1000 Brussels (phone: +32 2 545 17 11) processes personal data we collect from you through the TruliUs website and platform.
TruliUs is a platform that allows you to act digitally in name of your company by making a bridge between you and partner service providers (or “relying parties”). TruliUs allows you to:
• Identify & authenticate you and other persons in your company;
• Share and validate company data;
• Act, sign and pay in the name of your company.
2 INFORMATION WE COLLECT
When you register to the TruliUs platform, we collect the following types of personal data about you:
a. Identification data: your name, address, national register number, email address and password;
b. Information about the company you work for: its name and address, whether you are a legal representative or permanent representative of the company and the end of your mandate, your function within the company, and your signing powers for the company;
c. Information linked to your usage of the services and its security including technical information of devices used to access the website and platform, device identifiers, IP address, operating system and browser information, connections and activities performed.
3 PROCESSING PURPOSES
Your personal data is processed for the following purposes:
a. Where it is necessary for the performance of a contract between you and us or in order to take steps, at your request, to enter into a contract:
i. To allow you to register for the use of our services;
ii. To log usage events in order to send you important communication relating to your use of the platform;
iii. To log usage events in order to bill your company or relying parties.
b. Where you have given your consent:
i. To place cookies on your browser and perform advanced statistics based on the information they provide us.
c. Where necessary for our legitimate interests, as listed below, and where not overridden by your interests or fundamental rights and freedom:
i. To perform KYC (know your customer) on legal entity for new clients;
ii. To log technical events for error handling and security;
iii. To perform website and application analytics.
For these purposes, we have conducted a balancing test, as the law requires, and have determined that, taking into account the limited personal data collected, the processing performed and your reasonable expectations, our legitimate interest in conducting this processing is not overridden by your interests or fundamental rights and freedom.
4 DISCLOSURE AND TRANSFER OF PERSONAL DATA
As a controller of your personal data, we will not share this data with other parties than your company and its designated administrator(s).
As part of your use of the TruliUs platform, you and your company will be allowed to share your personal information with selected partner service providers that you and your company specifically approve; this transfer of personal data is not done at the initiative of Isabel, but only on instruction of your company who will act as a controller for the processing of your personal data.
5 DATA SECURITY AND RETENTION
Your personal data is and will be kept strictly confidential.
We take all reasonable steps to protect your personal data. This includes setting up processes and procedures to minimise the unauthorised access to, or disclosure of your personal data.
We will store your personal data for as long as it is necessary to achieve the purposes defined in section 4 (Processing Purposes), with maximum retention periods as defined below:
a. Data collected to create a personal account on TruliUs will be kept for as long as your account is not deleted (upon your or your company’s request);
b. Data used to perform KYC on legal entity for new clients will be kept for 10 years after the end of the contract, as required by Belgian law;
c. Usage event logs will be kept for 10 years after the end of the contract, as required by Belgian law;
d. Technical logs will be kept for a maximum of 6 months;
e. Data collected for statistics purpose are kept for 2 years.
6 YOUR RIGHTS
You have the right to ask us for a copy of your personal data, to ask us to correct, delete or restrict (stop any active) processing of your personal data and to obtain the personal data you provided us in a structured, machine-readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular when we do not have to process your personal data to meet a contractual or other legal requirement).
Where we have asked for your consent, you may withdraw this consent at any time; however, this will not affect processing that has already taken place before the withdrawal. You may withdraw your consent by deleting the cookies linked to our domain.
You may exercise the above-mentioned rights by contacting us as described in the “Contact us” section below.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information that we are required to keep by law or that we have a compelling legitimate interest to keep.
If you have unresolved concerns, you have the right to complain to the Data Protection Authority: https://www.dataprotectionauthority.be/.
7 CONTACT US
If you have any questions about this Privacy Notice or wish to contact us for any reasons in relation to the processing of your personal data, please contact our Data Protection Officer at Isabel NV/SA, by sending an email to firstname.lastname@example.org, or by sending a dated and signed request to Isabel NV/SA, Keizerinlaan, 13-15, 1000 Brussels, Belgium.
8 UPDATES TO THIS PRIVACY NOTICE
We reserve the right to modify this notice at any time but will in any case do so in accordance with the applicable laws and regulations. We will inform you by email, when possible, of any substantial changes to this notice.
This notice was last modified and revised on the 20/07/2020.
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