Walkly BV makes every effort to protect your personal data, in accordance with applicable laws.

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1. The person responsible

Walkly BV (hereinafter Walkly, “we”, “us” or “our”) with registered office at Persilstraat 51/G201, 3020 Herent, Belgium and with registration number 0793 705 765, is responsible for processing your personal data.

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2. The personal data that we process

Depending on your role, we collect the following information:

• Customers: general identifiers (such as name, title/position, address, mobile or telephone number, email, assigned identifiers), financial identifiers (such as identification and bank account numbers), financial transactions (such as amounts paid or payable), fees, professional activities (including the business, nature of the activity, the nature of the goods/services used, business relationships), contracts and agreements with Walkly, any other personal data that is lawfully held Walkly provided. The source of this personal data is you or your employer.
• Partners: general identifiers (such as name, title/position, address, mobile or telephone number, email, assigned identifiers), financial identifiers (such as identification and bank account numbers), financial transactions (such as amounts paid or payable), fees, professional activities (including the business, nature of the activity, the nature of the goods/services used, business relationships), contracts and agreements with Walkly, any other personal data that is lawfully held Walkly provided. The source of this personal data is you or your employer.
• Prospects: general identification data (such as name, title/position, address, mobile or telephone number, e-mail), professional activities (including the nature of the activity, the nature of the goods/services used, business relationships), all other personal data that has been lawfully provided to Walkly. The source of this personal data is you or your employer.
• Suppliers: general identifiers (such as name, title/position, address, mobile or telephone number, email, assigned identifiers), financial identifiers (such as identification and bank account numbers), financial transactions (such as amounts paid or payable), fees, professional activities (including the nature of the activity, the nature of the goods/services used), contracts and agreements with Walkly, any other personal data that has been lawfully provided to Walkly. The source of this personal data is you or your employer.
• Applicants: all personal data that has been lawfully provided to Walkly (such as a resume and/or application letter);
• Website visitors: personal data collected via cookies (see our cookie policy);
• Social media users: advertising via the personal data they provide on social media channels.

In carrying out its activities, Walkly is also a processor of personal data. The processing of personal data by Walkly, as a processor, is part of the agreements between Walkly and the controller (s) and is not part of this privacy policy.

If you provide us with personal information from a third party, such as your staff, freelancers, customers, suppliers, partners, you warrant to Walkly that you (a) lawfully obtained such personal data from the third party and lawfully provided it to Walkly, (b) provided Walkly with personal data that is accurate and up to date, (c) provided that person with relevant information about the existence and content of this policy.

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3. Purposes

We process personal data for the following purposes:

3.1 Implementation of the agreement: creating a personal account and/or profile, correctly executing and complying with the agreements (including communication), billing, customer service and support: so that we can help you with questions and/or problems.

3.2 Purchases via the website: the correct execution and compliance with the agreements regarding purchases via the website (including communication), the processing of orders and any after-sales service, billing.

3.3 Direct marketing: Sending notifications via email and/or newsletters. If you no longer wish to receive these messages, you can use the provided opt-out. After that, you will no longer receive the unwanted direct marketing messages and we will no longer process your personal data for these direct marketing purposes.

3.4. Applicant Management

3.5. Necessary for the functioning of our company: to improve and optimize our services (including through cookies and advertisements via social media), to maintain and improve the website (including through cookies), to ensure the security of our website and services, to prevent misuse or improper use of our services, to store personal data as evidence or for judicial, administrative or extrajudicial proceedings, to store personal data for the purpose of obtaining or maintaining insurance coverage, risks too control or obtain expert advice, to store personal data to ensure attendance at/participation in events.

3.6. To comply with legal obligations: (e.g. in connection with anti-money laundering and counter-terrorism legislation).

3.7. In general: you are not obliged to share your personal data with us, but if you do not share the requested personal data with us, we may not be able to provide you with the desired services and/or products.

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4. Legal basis for processing personal data

The processing of personal data under sections 3.1 and 3.2 is based on the performance of a contract to which the data subject is a party or in order to take steps at the data subject's request before entering into a contract.

The processing of prospects' personal data under section 3.3 and the processing of personal data by means of cookies (other than strictly necessary and functional cookies) under section 3.5 is based on the consent of the person concerned.

The processing of prospects' personal data under section 3.3 for customers and the first contact with prospects, as well as the other processing of personal data under sections 3.4 and 3.5, is based on our legitimate interests (only when the legitimate interest of our company prevails over the interests of those involved). The interests are set out in sections 3.3 — 3.5.

The processing of prospects' personal data under section 3.6 is necessary to comply with a legal obligation to which we are subject.

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5. Sharing personal data with others/international exchanges

We only provide relevant aspects of personal data to third parties if those parties are contractually bound to Walkly or act on behalf of or under contract with Walkly. Of course, we have made agreements with these parties about the protection of your personal data.

However, we may disclose your personal information when such disclosure is necessary to comply with a legal obligation to which we are subject, or to protect your (critical) interests. We may also disclose your personal information when such disclosure is necessary to establish, exercise or defend legal claims, in court proceedings, or in administrative or extrajudicial proceedings.

We do not provide personal data to companies outside the European Economic Area unless there is an adequacy decision or standard clauses, appropriate safeguards, binding business rules or exchanges as referred to in Article 49 (1) GDPR.

In the event of a total or partial reorganization, merger, division, acquisition or sale of assets, we are entitled to transfer personal data to the relevant third party.

You accept that personal information that you submit for publication via our website or services may be available worldwide via the Internet. We cannot prevent the use (or misuse) of such personal information by others.

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6. Storage and deletion of personal data

We only keep personal data for as long as necessary to achieve the purpose set out above. Because the retention period depends on the purpose, but also on the type of personal data, these retention periods vary.

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7. Your rights

We have summarized your rights in this section. Because some of these rights are complex, not all details are included in our summaries. Therefore, please read the relevant laws and regulatory guidelines for a full explanation of these rights.

7.1. Right of access: you have the right to confirm whether or not we are allowed to process your personal data and, when we do so, to have access to the personal data, along with the additional information set out in Article 15 GDPR. Ensuring the rights and freedoms of others is not affected, we will provide you with a copy of your personal data.

7.2. Right to rectification: you have the right to have inaccurate and/or incomplete personal data corrected and/or completed.

7.3. Right to delete: you have the right to have your personal data deleted in the circumstances set out in Article 17 (1) GDPR, such as when you withdraw your consent to consent-based processing or object to processing for direct marketing purposes.

Walkly will then delete your personal data without unnecessary delay, unless the exclusions set out in article 17 (3) GDPR apply. For example, Walkly does not have to delete your data if the processing is necessary to comply with a legal obligation.

7.4. Right to restrict processing: you have the right to restrict the processing of your personal data in the circumstances set out in Article 18 (1) GDPR, such as in the event that you dispute the accuracy of the personal data.

7.5. Right to data portability: you have the right to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format and to transmit such data to another controller if (a) the processing is based on consent or necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract, and (b) such processing is automated. However, this right does not apply if it would harm the rights and freedoms of others.

7.6. Right to withdraw consent: to the extent that the legal basis for our processing of your personal data is based on consent, you have the right to withdraw this consent at any time. Withdrawing consent does not affect the lawfulness of the processing prior to its withdrawal.

7.7. Right to file a complaint with the supervisory authority: if you believe that our processing of your personal data violates data protection laws, if you disagree with Walkly's position, or if you have any concerns about the use of your personal data, you have the right to file a complaint with the competent supervisory authority.

7.8. Right to object to processing: you have the right to object to our processing of your personal data for direct marketing purposes at any time. Practically, you can do this via the 'opt-out' option. After that, you will no longer receive the unwanted direct marketing messages and we will no longer process your personal data for these direct marketing purposes. Of course, it is possible that we will still contact you in connection with the execution of the agreement.

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You also have the right to object to our processing of your personal data under Article 6 (e) or (f) GDPR for reasons related to your particular situation. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate reasons for processing that override your interests, rights and freedoms, or the processing is necessary to establish, exercise or defend legal claims.

In addition, you have the right to object to our processing of your personal data for scientific, historical or statistical (research) purposes for reasons related to your specific situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

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8. Contact

If you want to contact us regarding this policy, you can do so by sending an email to our DPO:

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l e g a l @ w a l k l y. a p p

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If you contact us because you want to exercise one of your rights (see section 7), please clearly state which right you want to exercise. Be as specific as possible when exercising your rights.

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9. Cookies

You can learn more about our use of cookies at the following link.