Privacy Policy

Last updated March 16, 2022

Data collected about you

• (a)

  DATA PROVIDED BY YOU. We act in accordance with relevant data protection laws. You may provide us with information when you register for our services or complete online forms on our Site or engage in correspondence with us, by email, telephone or otherwise. Exact information, which is collected depends on your status on a Portal.

  • If You are Visitor, you can complete online forms on our Site and you may provide us with your real name, address, e-mail address and phone number (or other mean of communication chosen by you);
  • If You Customer or User, during registration on our Site, you may provide us with real name, surname, address, e-mail address and phone number, payment info, name of the legal entity you represent and other other information [especially, if the verification of the legal entity is required];
  • If You are Subject of Verification, during Verification, you may be required to provide us with:
    • Real Name, Surname;
    • Documents verifying your identity such as driver license, passport (forerign or national), ID-card or other;
    • Residential address;
    • Documents which can be used as proof of the address information (utility bill or bank reference, other conforming documents);
    • Tax number;
    • Document proving your tax number;
    • Selfie with the documents;
    • Credit card information;
    • Other financial information;
    • Other personal data that is transferred to us by third parties with your consent;
    • Other information especially, if the verification of the legal entity is required.

  In certain cases, (when additional verification by bank, or compliance authority or in accordance with laws applicable is needed according to governmental rules, or if such information is required for providing You with a customer support services) Company may require you to provide additional information, and namely: bank account info, place of birth, information on whether you hold a prominent public function, tax numbers, or other information.

• (b)

  AUTOMATICALLY COLLECTED DATA. We may also automatically collect information about Subject of Verification when you visit our Site including but not limited to: technical information, IP addresses, login information, web browser information, data associated with the source device’s Internet browser/content delivery software (e.g., Microsoft Explorer, Mozilla Firefox or Google Chrome). The User-Agent information We receive may also include information such as device type (e.g., computer, tablet, mobile device), preferred language, and/or date/time of visit/pattern of Website usage and other information. We do not make any attempt to associate any technical information with any individual and the information is only used for statistical and other administrative purposes.

• (c)

  PUBLIC INFORMATION. We may also obtain personal data about you from public services such as company registries.

  (collectively “your information” or “personal data” or “personal information”)

  It is important that the personal data we hold about is accurate and complete. Please keep us informed if your personal data changes during your relationship with us.

  We do not collect any Special Categories of personal data about you nor do we collect any information about your criminal convictions.

  It shall be noted that at the moment we don’t use cookies, still, we reserve the right to start using them in future.

How collected information is used

We use your data on a number of legal bases including the performance of a contract with you, necessary for our legitimate interests and as necessary to comply with a legal obligation.

• (a)

  We may share your information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries as well as our suppliers, agents, contractors, analytic and search engine providers and other companies and organisations for the purposes of fraud protection and credit risk reduction.

• (b)

  The information received from you will only be disclosed to such third parties as may be necessary in order to provide you with the services requested through our Site and in order to arrange delivery of same. By registering with us, by your use of our site, and the acceptance of our Terms you hereby authorise us to convey your information to such third parties.

• (c)

  We may also disclose your information in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

• (d)

  We may also use your information to:

  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
  • to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about and you have not opted out to the receipt of such information;
  • to notify you about changes to our service and any outages or other technical matters;
  • to ensure that content from our Site is presented in the most effective manner for you and for your computer;
  • to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • as part of our efforts to keep our Site safe and secure; and
  • to make suggestions and recommendations to you and other users of our Site about services that may interest you or them.
• (e)

  We may share your information in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to, meeting national security or law enforcement requirements. To the extent the law allows it, We will attempt to provide you with prior notice before disclosing your information in response to such a request. We may also share your personal data with regulatory, state and law enforcement agencies, courts, fraud prevention agencies, licensing authorities or other third parties, in cases where applicable laws or regulations must be observed, as well as to implement, establish or protect our legal rights (when it is possible and appropriate, we will immediately inform you about disclosure of your personal data to such third parties);

  No other information will be divulged to any other third party unless we receive your prior authorisation and/or we are required to do so by law or in order to enforce or apply our Terms.

• (f)

  We will take reasonable precautions to prevent the loss, misuse or alteration of your information. Agents or contractors who have access to information, you give us, in the course of providing services to us are required to keep that information confidential and are not permitted to use it for any purpose other than to carry out the services which they are performing for us.

• (g)

  There may be occasions where your information is transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by our staff or contractors working outside the EEA. Such staff or contracts may be engaged in the fulfilment of the services we provide to you and for the processing of payment details. By submitting your personal data you agreed to this transfer, storing and processing. We will take all reasonable steps to ensure that your information is treated securely and in accordance with this policy. We will ensure that relevant safeguards are in place if transferring your personal data.

• (h)

  All information you provide to us is stored on our secure servers. Any payment transactions are encrypted using SSL Technology. Where you have a password to access our Site, you are responsible for keeping this password confidential.

• (i)

  Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted to our site and the transmission is at your own risk.

• (j)

  Where we need to collect personal data under the terms of a contract between us and you fail to provide that personal data, we may not be able to perform the contract. In that case we will have to cancel a service you have with us.

• (k)

  We will only use your personal data for the purpose for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Your rights

In certain circumstances you have rights under data protection law including:

• (a)

  Right to access your personal data;

• (b)

  Request correction of your personal data (you may delete several types of your account information, which were provided by yourself (subject to certain conditions and depending on your status [User, Visitor or other]) at any time from the relevant page. But we may retain certain personal data as required by law or for legitimate business purposes after you delete your account / end contractual relationship with us;

• (c)

  Request erasure of your personal data (Company shall fulfil your request in appropriate period of time. If there is no other lawful ground for storing and processing of your personal data, as prescribed by Applicable Law, we shall erase such information. If there is another legal ground for such processing, the Company shall notify You in an appropriate period of time);

• (d)

  Object to the processing of your personal data (In case of such objection, Company shall restrain from processing of your personal data, if there will be no other legal grounds for continuing the processing);

• (e)

  Request restriction of processing your personal data;

• (f)

  Request transfer of your personal data;

• (g)

  Right to withdraw consent for the personal data processing.

If you wish to exercise any of the rights above, you can contact us at [email protected]. We request specific information to help us with our response and we may request that you confirm your identity to us.

You can also ask us to stop sending any marketing messages by following the opt-out links on any marketing message sent to you.

Right of complaint

We have in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have in place procedures to deal with any suspected personal data breach and will notify you where we are legally required to do so.

Our protective measures include the following:

• establishing rules to access to personal data processed, as well as ensuring registration and recording of actions performed with personal data;
• detection of the facts of unauthorized access to personal data and the adoption of appropriate response measures;
• restoration of personal data that was modified or destroyed due to unauthorized access to them (within the framework of technical capability);
• we use 256-bit SSL encryption 100% of the time on every device. Database is SSAE 16, ISO 27001, and PCI DSS v3.0 compliant and supports HIPAA compliance (as it was already mentioned above);

We retain your personal data as long as it is required to fulfill our legal, operational, contractual and regulatory obligations or to fulfil other purposes we collected it for. For each type of records, the recordkeeping requirements may vary so we guarantee that in no event shall we retain your personal data longer than required. If You would like to know more about the length of retention for a specific data, please contact us via [email protected]

Where appropriate we may contact the holders of inactive accounts to determine if you wish to continue to hold an account with us. Where you do not, we will delete your personal data on expiry of one (1) year, except for any personal data we are required to retain by law. Exact period for which we retain your personal data depends from the status you have on the Website/Portal (Visitor, User, Subject of Verification or other).

We store data received from you on remote servers located in Belgium.

General

This Policy will be the subject of change and the use of information that we gather shall be subject to the Privacy Policy in effect from time to time. It shall be your responsibility to check our website frequently to see recent changes.

Children personal data. PERSONNEL OF THE COMPANY DOES NOT KNOWINGLY COLLECT OR MAINTAIN PERSONALLY IDENTIFIABLE INFORMATION OR NON-PERSONALLY-IDENTIFIABLE INFORMATION ON OUR SERVICES FROM PERSONS UNDER 18 YEARS OLD, AND NO PART OF OUR SERVICES IS DIRECTED TO PERSONS UNDER 18. IF YOU ARE UNDER 18 YEARS OLD, THEN PLEASE DO NOT USE OR ACCESS SERVICES AT ANY TIME OR IN ANY MANNER. IF WE LEARN THAT PERSONALLY IDENTIFIABLE INFORMATION OF PERSONS LESS THAN 18 YEARS OLD HAS BEEN COLLECTED ON THE OUR SERVICES WITHOUT VERIFIED PARENTAL CONSENT, THEN COMPANY WILL TAKE THE APPROPRIATE STEPS TO DELETE THIS INFORMATION. Additionally, if You are in the EEA, You must be over the age required by the laws of your country to create an account or otherwise use the services , or we need to have obtained verifiable consent from your parent or legal guardian