PRIVACY POLICY

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

1. The responsible

Walkly BV ( hereinafter Walkly, ‘ we ’, ‘ us ’ or ‘ our ’ ) with registered office at Persilstraat 51G, 3020 Herent, Belgium and with registration number 0506.841.925, is responsible for the processing of your personal data.

 

2. The personal data we process

Depending on your position, we collect the following data:

  • Customers: general identification data ( such as name, title / position, address, mobile phone or telephone number, e-mail, assigned identification data ), financial identification data ( such as identification and bank account numbers ), financial transactions ( such as amounts paid or payable ), fees, professional activities ( including the company, the nature of the activity, the nature of the goods / services used, business relationships ), contracts and agreements with Walkly, any other personal data lawfully provided to Walkly. The source of this personal data is you or your employer.
  • Partners: general identification data ( such as name, title / position, address, mobile phone – or telephone number, e – mail, assigned identification data ), financial identification data ( such as identification – and bank account numbers ), financial transactions ( such as amounts paid or payable ), fees, professional activities ( including the company, the nature of the activity, the nature of the goods / services used, business relationships ), contracts and agreements with Walkly, any other personal data lawfully provided to Walkly. The source of this personal data is you or your employer.
  • Prospects: general identification data ( such as name, title / position, address, mobile phone – or telephone number, e – mail ), professional activities ( including the nature of the activity, the nature of the goods / services used, business relationships ), any other personal data lawfully provided to Walkly. The source of this personal data is you or your employer.
  • Suppliers: general identification data ( such as name, title / position, address, mobile phone – or telephone number, e – mail, assigned identification data ), financial identification data ( 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, all 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 CV and / or cover 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.

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

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

 

3. Purposes

We process the personal data for the following purposes:

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

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

3.3 Direct marketing: Sending notifications via e – mail 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. Management of applicants

3.5. Necessary for the functioning of our company: to improve and optimize our services ( o.a. by means of cookies and advertisements via social media ), to maintain and improve the website ( o.a. by means of 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 purposes, administrative or extrajudicial procedures, to store personal data for the purpose of obtaining or maintaining insurance coverage, to manage risks or to seek expert advice, to store personal data to ensure attendance / participation in events.

3.6. To comply with legal obligations: ( for example 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 provide you with the desired services and/or can supply products.

 

4. Legal basis for the processing of personal data

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

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 data subject.

The processing of prospects’ personal data under section 3.3 for customers and initial contact with prospects, as well as other processing of personal data under paragraphs 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 below section 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.

 

5. Share the 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 or under contract with Walkly. Naturally, 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 ( crucial ) interests. We may also release your personal data when such disclosure is necessary to establish, exercise or defend legal claims, in legal 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 provisions, 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 data you submit for publication through our website or services may be available worldwide over the Internet. We cannot prevent the use of ( or misuse ) of such personal information by others.

 

6. Storage and deletion of personal data

We only keep personal data for as long as is 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.

 

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, 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, to have access to the personal data, together with the additional information stated 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 incorrect and / or incomplete personal data corrected and / or supplemented.

7.3. Right to remove: you have the right to have your personal data deleted in the circumstances stated in article 17 ( 1 ) AVG, 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 undue delay, unless the exclusions stated in article 17 ( 3 ) AVG 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 restriction of processing: you have the right to restrict the processing of your personal data in the circumstances stated in Article 18 ( 1 ) AVG, as in the event that you dispute the accuracy of the personal data.

7.5. Right to data portability: you have the right to have your personal data that you have provided to us in a structured, commonly used and machine-readable format and to send such data to another controller if ( a ) the processing is based on consent or is 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: insofar as 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. Withdrawal of consent is without prejudice to the lawfulness of the processing before its withdrawal.

7.7. Right to lodge a complaint with the supervisory authority: if you believe that our processing of your personal data violates data protection law, if you disagree with Walkly’s position or if you have any comments about the use of your personal data, you have the right to lodge 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. It is of course possible that we will contact you about the execution of the agreement.

You also have the right to object to our processing of your personal data based on Article 6 ( e ) or ( f ) GDPR for reasons related to your specific situation. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate processing reasons that exceed your interests, rights and freedoms, whether 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 performed for reasons of public interest.

 

8. Contact

If you would like to contact us regarding this policy, you can do this by emailing our DPO: legal@walkly.app.

If you contact us because you want to exercise one of your rights ( see paragraph 7 ), we kindly request you to clearly indicate which right you want to exercise. Be as specific as possible in exercising your rights.

 

9. Cookies

You can read more about our use of cookies via the following link.