Privacy policy personal data policy

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

• Seenspire NV
• Attn. Data Protection Officer
• Entrepotkaai 11
• 2000 Antwerp
• Belgium
• Email: gdpr@seenspire.com
• Tel.: +32 (0)3 336 67 47

What Personal Data are being collected and Processed?

1. SEENSPIRE collects and Processes different types of Personal Data depending on the services you use on the Applications and as relevant:

   Analytical cookies	compile statistics on certain information (e.g. popularity, number of visitors).
   Session cookies	to be retained during a browsing session; these cookies are not stored but will disappear when your browser closes.
   Tracking cookies	track your browsing behavior and follow visitors of the Applications in order to later respond to their browsing behavior (e.g. personalized promotional campaigns).

2. More specifically, SEENSPIRE uses the following cookies:

   Social Media Information	Information such as information available on your social media profiles
   Personal Information	Information provided by yourself such as (without limitation) first name, last name, address, e-mail address, company, phone number, login details, information linked to a specific transaction, etc.
   Technical information	Information such as (without limitation) data of the computers, phones and other devices from which you visit the Applications, IP address, location etc.
   History and Logs	Information such as (without limitation) IP address, browser type, referring / exit pages, URLs, number of clicks, your interaction on the Applications, domain names, landing pages, pages viewed, date, time and other user activities, etc.
   Cookies	reference is made to our Cookie Policy

3. If you opt to provide additional Personal Data, you explicitly agree that we can use this Personal Data in accordance with this Privacy Policy.

What are the purposes and principles of the Processing of your Personal Data?

1. The purposes and principles of the Processing of your Personal Data depend on the category of Personal Data concerned. Below you will find an overview of the purposes and principles of the various Personal Data we Process.

   Social Media Information	Purpose	We collect your social media information which is pulled for feeding the Applications and to cater our Applications better to your needs and the needs of our customers in general and to allow you as a user to curate and publish your user-generated and brand-owned content on public screens.
   	Lawfulness of Processing	Legitimate interest and consent
   Personal Information	Purpose	We collect your personal information in order to answer your questions submitted through the Applications, for customer support and account management, to create an account on the Applications, to grant access to the Applications, to enable your use of the Applications, to offer personalized services, to provide you with information of SEENSPIRE’s partners, to monitor and improve the Applications, to link social media to your SEENSPIRE account, to keep you informed about SEENSPIRE and its services and products, for promotional offers and news articles, to administer contests, events, surveys and other Applications features, for direct marketing purposes, etc.
   	Lawfulness of Processing	Necessary for the performance of the agreement, legitimate interest and consent
   Technical information	Purpose	We collect your technical information for the purpose of authentication, license management and caching, customer support and account management, to offer personalized services, to monitor Applications performance and issues, to improve SEENSPIRE’s Applications and SEENSPIRE’s products and SEENSPIRE’s services, for statistical and diagnostic purposes, for purposes of high availability and accessibility, to monitor the effectiveness of the Applications, etc.
   	Lawfulness of Processing	Legitimate interest and consent
   History and Logs	Purpose	We collect your history and logs to further tailor our Applications to your use, to monitor and improve the Applications, etc.
   	Lawfulness of Processing	Legitimate interest and consent
   Cookies	Purpose	We collect your cookies for the purpose of authentication, customer support and account management, fetching media content, granting access to the Applications, to improve our Applications and your user experience, etc. For more information, reference is made to our Cookie Policy.
   	Lawfulness of Processing	Legitimate interest and consent

2. The consent your provide is always free, and you have the right to withdraw this consent at any time. Withdrawal of consent does not affect the Processing of Personal Data (i) prior to such withdrawal, (ii) based on any legitimate interest for the Processing of Personal Data and (iii) in case of a legitimate interest of the Processing.
3. The above reasons may not be exhaustive and SEENSPIRE may at any time Process your Personal Data for any other legitimate interest. In such cases, SEENSPIRE will notify you as soon as possible of such reason. Updates of this Policy may constitute such notification.

Receiving and sharing Personal Data

1. The purposes and principles of the Processing of your Personal Data depend on the category of Personal Data concerned. Below you will find an overview of the purposes and principles of the various Personal Data we Process.
   • - you register on the Applications;
   • - you create an account on the Applications;
   • - you login on the Applications;
   • - you use content from the Applications;
   • - you connect to social media;
   • - certain information is forwarded through partner landing pages;
   • - certain information is forwarded via cookies or your browser;
2. SEENSPIRE will always share your Personal Data in a minimal way, e.g. SEENSPIRE shall only share your Personal Data which is adequate, relevant and limited to what is necessary in relation to the purposes for which they are being processed as set out in this Policy.
3. SEENSPIRE may share your Personal Data with third parties in accordance with this Policy for storing and Processing your Personal Data, e.g. for sending newsletters, responding to your queries, enabling your use of the Applications, for optimizing the Applications, etc. You provide your express consent to share your Personal Data as described in this Policy.
4. Processors and Sub-Processors of SEENSPIRE always act under the responsibility of SEENSPIRE. If SEENSPIRE contracts with Processors or Sub-Processors, this will always be done in accordance with a Data Processing Agreement in accordance with the requirements of the GDPR and that protects your Personal Data as best as possible.
5. SEENSPIRE does not share, sell, trade or otherwise transfer your Personal Data with or to any commercial third party.

Consent for disclosure

1. You acknowledge, confirm and expressly consent that we may disclose your Personal Data if this is required by law, or if SEENSPIRE determines in good faith that such disclosure is required in order:
   • to comply with any pending judicial inquiry, judicial order or litigation pertaining the Applications;
   • to enforce and to compel observance of SEENSPIRE’s terms and conditions and / or to protect the security, quality or integrity of SEENSPIRE’s Applications;
   • to respond to claims against SEENSPIRE regarding Personal Data that violates any rights of third parties;
   • to safeguard the rights, property and safety of SEENSPIRE, its employees, users and the general public.
2. SEENSPIRE may disclose your Personal Data to competent police or judicial authorities or other official governmental authorities if SEENSPIRE deems this useful or necessary, in its sole discretion, for the investigation of fraud, intellectual property infringement and any other harmful activity, or if SEENSPIRE reasonably suspects that such activity may expose SEENSPIRE or you to any liability.

Direct marketing

How will my Personal Data be retained?

1. SEENSPIRE manages the following retention periods for your Personal Data:

   Social Media information	Retention of the Personal Data (i) as long as SEENSPIRE has a legitimate interest, or (ii) as long as the consent is valid and has not been withdrawn.
   Personal information	Retention of the Personal Data (i) for the duration of the contract, (ii) as long as SEENSPIRE has a legitimate interest or (iii) as long as the consent is valid and has not been withdrawn.
   Technical information	Retention of the Personal Data (i) as long as SEENSPIRE has a legitimate interest, or (ii) as long as the consent is valid and has not been withdrawn.
   History and Logs	Retention of the Personal Data (i) as long as SEENSPIRE has a legitimate interest, or (ii) as long as the consent is valid and has not been withdrawn.
   Cookies	For more information, reference is made to our Cookie Policy.

2. SEENSPIRE retains your Personal Data in its own databases and/or in the databases of its Processors or Sub-Processors. You may ask SEENSPIRE to provide a copy of the list of these Processors and Sub-Processors.

How are my Personal Data safeguarded?

1. SEENSPIRE makes all reasonable and appropriate efforts to protect the confidentiality of your Personal Data and has developed appropriate technical and organizational measures, safeguards and assurances to Process your Personal Data in accordance with the applicable Belgian and European regulations, in particular to protect your Personal Data against loss, incorrect use and unauthorized modification. Only authorized Processors, Sub-Processors and employees, agents and contractors have access to this Personal Data. SEENSPIRE maintains a team of technicians, automated systems and advanced technologies, such as SSL connection encryption and data encryption, and other measures following the industry best practices.
2. Despite the above measures taken by SEENSPIRE, 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.
3. SEENSPIRE cannot be held responsible for any direct or indirect damage resulting from faulty or unlawful use of your Personal Data by third parties. SEENSPIRE is not responsible for the functionality or security measures of any such third party.

Transfer of Personal Data outside the EEA

What rights do I enjoy?

1. If and in as far as provided for in the applicable Belgian and European regulations, you have the right:
   • to receive a confirmation as to whether SEENSPIRE processes your Personal Data and, where this is the case, to access the Personal Data that SEENSPIRE processes;
   • to have any inaccurate or incomplete Personal Data corrected by SEENSPIRE, without undue delay;
   • to have your Personal Data deleted by SEENSPIRE;
   • to obtain your Personal Data and to transfer them to another Controller or Processor;
   • to obtain a limitation of the processing of your Personal Data from SEENSPIRE, in as far as this is possible;
   • to receive your Personal Data in a structured, common and machine-readable format;
   • to prevent the Processing of your Personal Data and the use of your Personal Data for direct marketing purposes.
2. You may exercise these rights (i) by contacting the Data Protection Officer by sending an email to gdpr@seenspire.com and providing him or her with a copy of the front side of your identity card (e.g. no national identification number may be visible) or (ii) by updating and changing your account and profile settings.
3. If and to the extent provided for in the applicable Belgian and European regulations, 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”) (https://www.dataprotectionauthority.be/).

Changes to this Policy

1. This Privacy Policy can be changed by SEENSPIRE at any time.
2. Changes of the Policy will be published on the Applications so that you can be informed about how we collect information, how we use this information and how we share this information.
3. Amended versions of this Policy take effect ten (10) days after their publication on the Applications. If required, the Policy will be submitted for approval. The date of the most recent version is shown above.

Links to other applications, platforms and websites

Liability

1. If SEENSPIRE has legitimately transmitted your Personal Data to a third party (not being a Processor or Sub-Processor), SEENSPIRE shall not be liable for any unlawful processing or unlawful use by that third party.
2. Under no circumstances does SEENSPIRE accept responsibility for any direct or indirect damage resulting from faulty or unlawful use of the Personal Data by a third party.
3. SEENSPIRE 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. SEENSPIRE shall in no event be liable for any special, incidental, indirect or consequential losses or damages.

Applicable law and competence court

1. This Policy shall be governed, interpreted and enforced exclusively in accordance with Belgian law.
2. The courts of the jurisdiction of Antwerp, department Antwerp, will be exclusively authorized to rule on any dispute that might arise with respect to this Policy, without prejudice to the consumer’s right to present a dispute before the competent court on the basis of a mandatory statutory provision.