Privacy policy

Terminology used in this privacy policy
Our personal data processing activities are governed by the General Data Protection Regulation (Regulation (EU) 2016/679) and the national data protection laws. ‘Personal data’ is any information that can be used to identify you, including your name, e-mail address, IP address, or any other data that could reveal your physical, physiological, generic, mental, economic, cultural or social identity. According to GDPR, we are in general the ‘Data Controller’ of all personal data obtained by us as set out in this Policy, because we ultimately determine how your personal data will be handled by us or our sub-contractors, who would be our ‘Data Processors’. If we handle your personal data then you are a ‘Data Subject’. This means you have certain rights under the GDPR in relation to how your personal data is processed, which are set out in this privacy policy.

Name and address of the data controller
The responsible controller of your personal data is Evenflow, SRL
​Rue de la Loi 26, Boîte 7
1040 Brussels
Belgium
Internet: www.evenflow.eu

To whom is this Privacy Policy addressed
This policy is addressed to our prospects and clients, the visitors of our website, suppliers and business providers and other parties in contact with us. Collecting and processing of your personal data on this website. We process the personal data that you have submitted to us via our website by contacting us on our email addresses and within the framework of the agreement which was concluded with EVF or which you wish to conclude with us, such as your contact details and information relating to the contract. Data we are collecting from you are your name, surname, email contact addresses, your professional situation or the name of your company. The user of this website can use the general company email address or the other email addresses presented to get in contact with the respective staff. In this case we will store the personal data transmitted by this email. The data are used exclusively for processing the conversation with you (purpose) and are not transmitted to any third party. Besides the data collected through these web forms, we store your current IP address, a few cookies, and some usage statistics in order to enhance the security and usability of this website. You can find more details on this functionality and the respective treatment of your personal data further below under the header Data collected for technical purposes. We also process data obtained via external sources, such as external databases and commercial partners, for prospection purposes.

Purposes and legal ground for processing your personal data
We process your personal data for the following purposes and based upon the following legal grounds:

1. With your consent (article 6, §1, a)) for, including but not limited to, the following purposes:
   a)   To handle your request when you send us an email;
   b)   To send you direct marketing communications that you gave consented to receive via email;
   c)   To send you direct marketing communications via email based on your implicit consent if you are an existing customer and we have received your email address from you. You have the ability to object to this use of your email address at any time and free of charge. You can unsubscribe easily via the added link at the bottom of any email;
   d)   To transfer your email address to a specified third party;
2. For the preparation or the performance of our services contract with you (article 6 §1, b)) for, including but not limited to, the following purposes:
   a)   To make a contract proposal, to conclude, execute and monitor the particular service contract;
   b)   To prevent and combat bad payment, and to determine, exercise and safeguard our rights in general, including but not limited to, debt collection, management of litigation and any legal proceedings;
3. For the realisation of our legitimate interests, when the processing of your Personal Data is necessary for us to conduct our company activities (article 6 §1, f)) for, including but not limited to, the following purposes (except where your explicit consent is required):
   a)   To establish client or prospect segments or marketing profiles;
   b)   To optimise our services and to measure our performance;
   c)   To prevent and combat fraud, crimes and possible violations;
4. For complying with legal or regulatory provisions to which we are subject (article 6 §1, c)

Deleting personal data
We delete your personal data on a regular basis in accordance with the requirements of the GDPR. If you have contacted us through email, we are deleting your personal data as soon as the relevant communication with you is concluded, unless (i) you have provided us with separate consent to store your personal data longer, (ii) we still need your personal data to fulfil a contractual obligation, or (iii) statutory retention obligations require us to retain your personal data for a longer period.
The session cookies stored while you were using our website will be deleted when your browsing session ends. The IP addresses logged on our server will be deleted after one month.

Rights of the data subject in terms of data protection
You have the following rights in relation to your personal data:
• Right to confirmation – you can ask us to confirm whether we are processing personal data concerning you.
• The right to be informed – this is information on the personal data we are processing and the purpose for which we are processing them.
• The right of access – you have the right to be provided with copies of your personal data that we are processing.
• The right to rectification – if you think the personal data that we hold on you is inaccurate or incomplete you can request us to correct this.
• The right to erasure – if you want us to delete the personal data we are holding for you then you can request us to do so.
• The right to restrict processing – if you oppose the way how we are processing your personal data then you have the right to inform us accordingly and we will restrict the processing on the basis of your right.
• The right to data portability – if you want us to forward your personal data to a different organisation or person then you have the right to inform us and we will transfer your personal data respectively (without adversely affecting the rights of others).
• The right to withdraw your consent – you can withdraw your previously given consent to the processing of your personal data at any time by contacting us using the contact form provided.
In addition to the above rights, as a data subject you have the right to lodge a complaint with your local data protection authority within the European Union. Please note that you can use whichever local data protection authority within the EEA that is most convenient for you.

Transfer of personal data
Your personal data may be transferred to our suppliers, subcontractors and business providers, who provide services that include data processed on our behalf. These parties can solely process your personal data in order to carry out their mission and within the limits of our instructions. When our suppliers and subcontractors are located in countries outside the European Economic Area, EVF will make sure that appropriate safeguards and security measures to guarantee the security and confidentiality of your personal data are put in place. If you contact our staff during their potential business trips outside the EU, the staff is receiving your email through a secure connection, so that your data is not transmitted to a third party, but remains within the sphere of influence of our company. If we are forwarding or copying a message that we have received by email to persons outside our company, we will first ask you for your consent to do so, unless you have informed us explicitly about your consent already when you were writing your email to us.

Security measures
In order to protect your personal data against loss, destruction and against unauthorised access or manipulation, EVF has taken both technical and organisational security measures. This means, on the one hand, that our IT-system is equipped with back-up, filtering and firewall systems, in accordance with the adequate industry security standards and, on the other hand, that our employees have been made aware of the risks relating to data breaches and trained to correctly deal with your personal data, and that access to your personal data is solely granted to those persons who are authorised to do so in order to perform their duties. If you contact our staff during their potential business trips outside the EU, the staff is receiving your email through a secure connection, so that your data is not transmitted to a third party, but remains within the sphere of influence of our company. If we are forwarding or copying a message that we have received by email to persons outside our company, we will first ask you for your consent to do so, unless you have informed us explicitly about your consent already when you were writing your email to us.

Automated decision making and profiling
As a responsible company, we neither use automatic decision-making nor profiling.