At BRIGHTFOX we highly value your privacy and take all the necessary measures to protect your personal data. Therefore, we’d like to take the time to inform you what we do with the data we store about you. Moreover, we give you full control on how you like your data to be processed.
0. BRIGHTFOX Introduction
As of June 17, 2019 GEN-C NV, 7dots BV and 7dots NV have merged together and become BRIGHTFOX. However, all activities with regard to data processes are maintained as outlined below.
1. Who we are
“We”, “us” or “our” means
- BRIGHTFOX Belgium NV, with its registered office at Veldkant 33A, 2550 Kontich, Belgium and with company number BE 0821.305.136;
- BRIGHTFOX BV, with its registered office at Rithmeesterpark 50-A1, 4838 GZ Breda, The Netherlands and with company number KVK 20127055.
We act as controller for the personal data we gather through your use of our website.
- firstname.lastname@example.org or to email@example.com to the attention of our Data Protection Officer/;
- By post:
- BRIGHTFOX Belgium NV : to (Privacy, Veldkant 33A, 2550 Kontich, Belgium).
- BRIGHTFOX BV: to (Privacy, Rithmeesterpark 50-A1, 4838 GZ Breda, The Netherlands).
- Via the request form on our website which directly addresses and notifies the responsible Privacy Officer(s). Request can be submitted at https://www.brightfox.eu/privacy-policy/.
2. How we use and collect your personal data
Personal data is defined as any information relating to an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.), that can be used to directly or indirectly identify a natural person.
The personal data we collect, is collected and used for the purposes as listed hereunder:
- In the event you use the contact form on our website, we will use your personal data in order to reply to your query, via e-mail or telephone.
The following categories of personal data can be distinguished:
- Contact data: in the event you make use of the contact form, you will be asked to provide the following information: name, address, e-mail address, phone number, and any personal data that you choose to put in the designated blank field (please do not provide us with any sensitive information, such as health information, information pertaining to criminal convictions, or credit card/account numbers). This is information that is provided directly by you.
The legal basis for the processing of your personal data is
- Consent: you will, at all times, have the right to withdraw your consent. This will, however, not affect the lawfulness of any processing done prior to the withdrawal of consent. and;
Your personal data will solely be used for the purposes as set out in this article.
3. Retention of your data and deletion
Your personal information will not be kept for longer than is necessary for a specific purpose. However, considering it is not possible for us to specify a period in advance, the period of retention will be determined as follows:
- Common interests;
- Business opportunities.
In the event you withdraw your consent or you object to our use of your personal data, and such objection is successful, we will remove your personal data from our databases. Please note that we will retain the personal data necessary to ensure your preferences are respected in the future.
The foregoing will, however, not prevent us from retaining any personal data if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.
4. Your rights
This article lists your principal rights under data protection law. We have tried to summarize them for you in a clear and legible way.
The right to access
You have the right to receive from us a copy of your personal data we have in our possession, provided that this does not adversely affect the rights and freedoms of others. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies.
The right to rectification
If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed.
The right to erasure (right to be forgotten)
In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include:
- The personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed;
- You withdraw your consent, and no other lawful ground exists;
- The processing is for direct marketing purposes;
- The personal data have been unlawfully processed; or,
- Erasure is necessary for compliance with EU law or Belgian law.
There are certain exclusions to the right to erasure. Those exclusions include where processing is necessary,
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation; or,
- for the establishment, exercise or defense of legal claims.
The right to restrict processing;
You have the right to restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes), if:
- You contest the accuracy of the personal data (and only for as long as it takes to verify that accuracy);
- The processing is unlawful and you request restriction (as opposed to exercising the right to erasure);
- We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; or,
- You have objected to processing, pending the verification of that objection.
In addition to our right to store your personal data, we may still otherwise process it but only:
- with your consent;
- for the establishment, exercise or defense of legal claims;
- for the protection of the rights of another natural or legal person; or,
- for reasons of important public interest.
We will inform you before we lift the restriction of processing.
The right to data portability
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
You also have the right to have your personal data transferred directly to another company, if this is technically possible, and/or to store your personal data for further personal use on a private device.
The right to object to processing
You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
- The performance of a task carried out in the public interest or in the exercise of any official authority vested in us;
- The purposes of the legitimate interests pursued by us or by a third party.
If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
The right to complain to a supervisory authority
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In Belgium, you can submit a complaint to the Authority for the protection of personal data (Privacy Commission), Drukpersstraat 35, 1000 Brussel (firstname.lastname@example.org),https://www.privacycommission.be/nl/contact).
5. Providing your personal data to others
We may also disclose your personal data in the event such disclosure is required or necessary in order to fulfil a legal obligation. We may also disclose personal data in order to protect your vital interests or the vital interest of another natural person.
As such, we do not disclose your personal data to our social media partners. We do, however, make use of social media plugins to direct you to our social media channels and to allow you to interact with our content. These social media channels are Facebook, LinkedIn, Twitter, Youtube. In the event you click such link, such social media service provider may collect personal data about you and may link this information to your existing profile on such social media.
We are not responsible for the use of your personal data by such social media service provider. In such case, the social media service provider will act as controller. For your information only, we have included the relevant links (these may be changed from time to time by the relevant service provider):
- Facebook: http://facebook.com/about/privacy;
- LinkedIn: http://linkedin.com/legal/privacy-policy;
- Twitter: http://twitter.com/privacy;
- Youtube: https://support.google.com/youtube/answer/2801895?hl=en-GB
6. International transfers
We will ensure that any transfer of personal data to countries outside of the European Economic Area will take place pursuant to the appropriate safeguards.
Brightfox’s Trust Policy
Trust is one of our core-values and we want to ensure you that every measure is taken that your data is processed in a safe and secure way. On top of that, you can easily consult, remove and update your personal data.
With GDPR we’ve provided several new ways for you to control your personal information. You can act on how your data is processed in the following ways:
- An improved transparent overview of what we do with your data;
- An explanation on how we collect your data;
- Clear, simple unsubscribe options regarding profiling for (personalized) direct marketing purposes;
- Easily act upon your rights.
Below a more detailed overview of how these ways will help you controlling your information.
A transparent overview of what we do with your data
We do not want to bother you with information you might not like, instead we want to inform you about what you love. Therefore, we collect your information.
We’ve provided an overview of what types of data we collect from you in the data-collection -tab.
An explanation on how we collect your data
We have a series of forms on our website you can fill in to get additional information regarding our services, products or events.
We also want to ensure that by submitting any form, you’ll only receive the communication for the purpose of the form unless you chose to check the ‘I would like to receive email updates from Brightfox’-checkbox.
For example: When you submit a form to download a whitepaper, you’ll only receive one email that contains your download link for the whitepaper.
Additionally, we collect anonymous data from you. This to improve our web-experience so you can better browse our web-portal the next time you visit us. We track on which page you entered the site, how long you spent time on a page and where you left. We do not relate this data to your personal information as we gather this data anomynously via Google Analytics. More information can be found on the data collection -tab
Opting out for (personalized) direct marketing
When you no longer wish to receive our awesome content, you can choose to opt-out by submitting a request in the Requests -tab.
However, we’ve provided additional options in our email communications where you can choose which type of communication you still wish to receive and which you don’t.
Any request will be processed within 72 business hours on which you will get a personal notification upon completion.
Act on your Privacy & Rights
The General Data Protection Regulation (GDPR) comes with a few rights for you which you can act upon. You can find out what rights you have by visiting your rights -tab. Whenever you’d like to act upon your rights or have any questions regarding the processing of your data. You can submit a request in the Requests -tab.
Protection of your Personal Data
Whenever you decide to reach out to us, you give us pieces of your personal data. As we appreciate your trust in us, we also know how precious that data is to you. Therefore, we make it our top-priority to keep your data stored in a secure and locked environment. So nobody who doesn’t have your consent can view your personal data.
Where’s your data stored?
We keep your personal data in our secure database called Salesforce. And that’s where your data stays. Your personal data will not be processed or transfer to third-parties for commercial purposes.
How is your personal data collected?
We collect your data via request submittals. Whenever you submit a request for a registration, download a whitepaper, application or simply to contact us; we ask for personal data. If you no longer wish to receive this communication, please follow the instructions by clicking this link.
What Personal Data we collect from you
|Salutation||Because we do not want to assume genders.|
|First – and Last Name||To address you correctly because we think “Hi” is something you say to your friends.|
|Phone & Mobile number||You’ll only be contacted by phone if you have submitted a request. We could communicate by phone for verbal communication, a text to remind you for an event you’ve registered or to check if everything is working as expected in your Salesforce instance.|
|Language||To communicate with you in a language you can understand. At GEN-C we communicate by default in English, sometimes as well in dutch or french.|
|You’re receiving emails for the following communications. Being:
Why we collect your Personal Data
Initially, the data we collect from you may seem overwhelming but is crucial to provide you the level of service you deserve. In the following column you’ll see how we put your Personal Data to use, to give you the ultimate GEN-C Experience.
|Customer Service / Tailored Advice
||We communicate via phone, mail and/or social messages. To make sure you do not hear the same story twice, we keep track of it. We store each touchpoint in our secure database, Salesforce. We also learn from each touchpoint, so we can help you even better the next time we interact with each other.|
||When you choose to subscribe to our professional communications you will receive
If you no longer like to receive these mails, you can always change the way you receive communication via this link.
|Web Improvement||We collect behavioral data in an anonymous way. We do this by registering anonymous, but unique, visits to see what activities each visitor has performed. Like viewing a page, time spent on a page, clicks, etc. This data is stored safely and anomynously in Google Analytics.|
Act upon your rights
This page serves the purpose of changing the way we process your data. Below you’ll find a form on which you can make requests regarding the personal data we store from you.
What do I select to act upon a right?
|Request Form Option||Right(s) to act upon
|Request my personal data||
|Update my personal data||
|Remove my personal data||
Frequently Asked Questions
What is GDPR?
In its shortest version, GDPR or the General Data Protection Regulation is an EU legislation which comes into effect at the end of May 2018.
GDPR serves the purpose to protect an individual’s personal data that’s being processed by a business. Which means, giving you, the individual, the right to do whatever you wants with your personal data and act upon it whenever you like. And that’s definitely a good thing.
Which rights do I have?
We’d like to inform you that GDPR also brings along a few additional rights for you which you are free to call upon at any given time. These rights include:
- The stopping the collection of your data;
- Consultating your data;
- Correcting of your data;
- Removing of your data;
- Forgetting of your data for future direct marketing;
For a more detailed overview of your rights, please click here.
How do I act upon my rights?
We’ve set up a simple way for you to control the way we process your data and act upon your rights.
Simply fill out the form on the requests -tab to submit your request and we’ll handle it within the respected timeframe.
What happens when I submitted a request regarding my data?
First and foremost, you’ll receive an on-screen confirmation that you’re request has been sent. In addition to the on-screen confirmation, we’ll send you an email confirming that we’ve received your request and have begun the proces.
How long does it take until my request is completed?
After you’ve received your confirmation email it takes up to 72 hours (business days) to complete your request. Afterwards, you’ll receive an email that your request has been succesfully handled.
Why am I still receiving e-mails while I’ve opted out?
Whenever you decide to opt-out, you will only be opted-out from our direct marketing communication. However, crucial information will still be sent to you in the following cases:
- You have registered for an event which hasn’t yet took place: you will still receive a practical info and recap of the event;
- Currently, you are in discussion with us regarding potential business opportunities;
- You are an existing customer of ours and it’s necessary to communicate administrative matters to you.