Privacy & Cookie Policy

1 BeBold Privacy Policy

1.1 In general

This Privacy Policy discloses the privacy practices for BeBold NV on our Website https://bebold.digital/, our direct marketing activities and the overall organization of BeBold NV.

Since we care about your privacy, we strive to safeguard your personal data and to always act in accordance with the provisions of the applicable data protection regulations (hereinafter the "Data Protection Legislation"). In this Privacy Policy allows us to be open and transparent so that you can make meaningful choices about the use of your personal data.

Our Privacy Policy explains:

• Which personal data are collected
• How we use your personal data and with whom it may be shared
• Your rights in relation to the gathered information

Your personal data will be collected and processed by BeBold NV, a Belgian company with registered office at Veldkant, 35 C, 2550, Kontich and known business registration number: 0762.846.206.

We reserve the right to make any changes to our Privacy Policy. The most recent version of our Privacy Policy will always be available on our Website.

By using our Website we may collect your personal data for the purposes as indicated in our Privacy Policy. If you have any questions, comments or complaints regarding this privacy statement or the processing of your personal data, or if you wish to exercise any of your rights, please contact us by e-mail info@bebold.digital.

1.2 Why and how do we process your personal data?

1.2.1 Use of our Website

When you visit our Website, we may process personal data using online techniques such as cookies, trackers, scripts, and similar technologies (hereinafter referred to as 'cookies'). To this end we refer you to our Cookie Policy for further information.

1.2.2 Contact via our website

Consent: Contact forms are available on our Website to get in touch with us. You can also reach us by e-mail or phone at any time. We process personal data to process your contact request but have no visibility or control over any other personal data you may communicate to us via the open fields. Please do not include any confidential or sensitive data.

The data are processed with your consent. Please know that you can revoke at any time. This revocation does not affect the lawfulness of the processing that took place before the revocation of your consent.

The personal data you provided us such as First Name, Last Name, Telephone Number, E-mail, etc. We acquire this data first hand when you complete our contact form or you have reached us by e-mail or phone, and we store this data up to 10 years after the contact request has been completed plus the archiving period of related communications (such as e-mails). We share the personal data with data processing partners to whom we appeal for our Website and in relation to the processing of our contacts. These activities do not include automated individual decision-making and the data is transferred outside the EEA.

1.2.3 Customer Relations Management

Legitimate Interest: BeBold NV is looking for new customers, actively establishing new contacts for this purpose and building relationships with existing customers. In this respect, your personal data will be processed (e.g. invite you to events, etc.). The data processing is based on the legitimate interest of BeBold NV. You can always object to this according to the terms described under 'right to objection' in the section 'What are your rights and how to exercise them'.

The personal data you provided us (First Name, Last Name, Telephone Number, E-mail, etc.). We acquire this data first hand via Customer Relations Management and we store this data up to 10 years after termination of a final project or contact. We share the personal data with data processing partners to whom we appeal for our Website, contact and customer relations. These activities do not include automated individual decision-making and the data is transferred outside the EEA.

1.2.4 Organisation of events

Consent: When you register for one of our events, personal data are handled to process your registration and the organization of the event. The data are processed with your consent. You can revoke the given consent at any time without prejudice to the lawfulness of the data processing up to the time the revocation took place. This means your consent applies for all previous events in which you have already participated, but you will no longer be invited to events in the future.

The personal data you provided us (First Name, Last Name, Telephone Number, E-mail, etc.). We acquire this data first hand upon registration and we store this data for up to 10 years after the event takes place. We share the personal data with data processing partners to whom we appeal to organize and shape our events. These activities do not include automated individual decision-making and the data is transferred outside the EEA.

1.2.5 Recruitment and selection

Consent to (spontaneously) applications and to build a recruitment pool: Legitimate interest for active recruitment: When you (spontaneously) apply for a position at BeBold NV, BeBold NV processes your personal data for recruitment and selection of employees for open or future vacancies. The data are processed (including building a recruitment pool) with your consent. You can revoke the given consent at any time without prejudice to the lawfulness of the data processing up to the time the revocation took place.

When BeBold NV actively recruits, BeBold NV processes your personal data. This only includes the data that are publicly available (e.g. LinkedIn and Google Platforms) or data transferred through third parties. This processing is based on the legitimate interest of BeBold NV. You can always object to this according to the conditions described under 'Right to object' in the section 'What are your rights and how to exercise them'.

Finally, we refer to our legitimate interest in sharing your personal data with our affiliated and associated companies as part of our recruitment process. We always proceed with a view to finding a suitable assignment for you. You can always object to this according to the conditions described under 'right to object' in the section 'What are your rights and how to exercise them'.

The personal data you provided us and the personal data that is mentioned on your CV (First Name, Last Name, Telephone Number, E-mail, etc.). We acquire this data first hand during the application process or via third parties such as public platforms or intermediaries. Of non-retained applications, we store the personal application data up to maximum 5 years after your candidacy. Of recruitment pool applications, as long as the consent is not revoked, up to 10 years after the candidacy. We share the personal data with data processing partners to whom we appeal for recruitment and selection. These activities do not include automated individual decision-making and the data is transferred outside the EEA.

1.2.6 Supplier Relations Management

Legitimate Interest: BeBold NV actively establishes contacts with potential suppliers and solidifies existing partnerships. To this end, our suppliers process data of co-workers (cfr. account managers). The data processing is based on the legitimate interest of BeBold NV. You can always object to this according to the terms described under 'right to object' in the section 'what are your rights and how to exercise them'.

The personal data you provided us and other data possibly shared during subsequent contacts (First Name, Last Name, Telephone Number, E-mail, etc.). We acquire this data first hand via relation management and we store this data up to 10 years after termination of a final contract or contact. We share the personal data with data processing partners to whom we appeal for relation management. These activities do not include automated individual decision-making and the data is transferred outside the EEA.

1.3 Sharing personal data with third parties

When you visit our Website or use our products and services as a customer, we may use third parties, such as partners, affiliated and associated companies and suppliers to whom we transfer your personal data as part of this process. The third parties help us provide support, develop and understand the use of our products and services and provide services such as hosting, customer and technical support, marketing, analytics, content delivery and or execution of online payment(s), among others.

In addition, we may also share data (including personal data) with third parties as part of a reorganization, restructuring, merger, sale or other transfer of business assets. We share information provided by you, automatically collected information and information from others with the third parties to extent necessary to enable them to provide their services or support. In the activities described above, we indicate for each activity the categories of third parties, other than affiliated and associated companies, with which we share your personal data.

Furthermore, we may have to provide access to your data or transfer your data because of a legal obligation. This can imply authorities, government agencies or third parties. Finally we may share your data if this proves necessary to your vital interest.

1.4 Transfer of personal data outside the EEA

BeBold NV always tries to limit the transfer of personal data to third parties outside the European Economic Area ("EEA"). Should this nevertheless occur, we will ensure as soon as possible that this transfer is brought into line with the GDPR.

We refer to our section "Why and how do we process your personal data" under article 1.2 for the specific transfers.

1.5 How long do we store your personal data?

We will not retain your personal data for longer than strictly necessary to fulfill the purposes for which the personal data were collected or according to the legal obligations imposed on us. We refer to the section "Why and how do we process your personal data" under article 1.2 for the specific retention period.

1.6 Automated individual decision-making

European data protection legislation (GDPR), imposes certain conditions about individuals solely on the basis of processing operations that are fully automated, including profiling, and when these decisions have legal effects or other significant consequences, BeBold NV does not engage in this type of decision-making.

1.7 What are your rights and how to exercise them?

BeBold NV considers it important that you always retain control over the processing of your personal data. Below you will find more information on the various rights you have and can invoke in relation to the processing of your personal data. Depending on the processing and its legal ground, certain conditions or restrictions may be attached to the exercise of the rights below.

To exercise the aforementioned rights, or information about them, please contact info@bebold.digital. We will provide more information if there are certain modalities associated with your request. Furthermore, we may request additional information to verify your identity so that your personal data are not erroneously deleted or shared with someone who is not entitled to them. We will endeavor to respond to your request without unreasonably delay, but in any event within a period of one month from receipt of your request. If we cannot respond within one month and wish to extend the deadline, or if we will not act on the request, we will notify you.

1.7.1 Right to information / access

When we process your personal data, you have the right to access your personal data as well as certain additional information as described in the Privacy Policy. You have the right to receive from us a copy of the personal data we hold, provided this does not adversely affect the rights and freedoms of others. The first copy will be provided to you free of charge, but upon repeated request we reserve the right to charge a reasonable fee.

1.7.2 Right to rectification

If the personal data we hold about you are inaccurate or incomplete, you have the right to have this information corrected or, given the purposes of processing, completed.

1.7.3 Right to restriction of processing

You have the right to have the processing of your personal data restricted. This means that the personal data may only be stored by us and used only for limited purposes. This right applies if any of the following situations occur:

• You dispute the accuracy of the personal data, for a period that allows us to verify the accuracy of the personal data
• The processing is unlawful, but you oppose the deletion of the personal data and request instead that its use be restricted
• We no longer need your personal data for the processing purposes described above but you need it for the establishment, exercise, or defence of legal claims
• You have objected to a processing operation and request to restrict the processing pending the answer to whether our interests outweigh yours

In addition to our right to store your personal data, we can still process them, but only:

• With your consent
• For instituting, exercising, or defending legal action
• To protect the rights of another natural or legal person
• For reasons of public interest

Before we lift the restriction on processing your personal data, you will be informed about it.

1.7.4 Right to data portability

If the processing of your personal data is based on your consent, and the processing is carried out through automated processes, you have the right to receive a copy of your personal data in a structured, common and machine-readable form. You also have the right, where technically possible, to have your personal data transmitted directly by us to a third party. This right does not apply where this would infringe the rights and freedoms of others.

1.7.5 Right to object

You have the right to object to the processing of your personal data in the activities described above. In the latter case, this is only possible if the activity is related to (1) the performance of a task in the public interest or in the exercise of a task in the exercise of a public authority conferred on us or (2) the protection of our legitimate interests or those of a third party. If you object to the processing of your personal data, we will no longer process the personal data unless we can demonstrate legitimate interests for processing that outweigh your interests, fundamental rights and freedoms.

If your personal data are processed for direct marketing purposes, regardless of whether this is initial or further processing, you have the right to object to this processing at any time and free of charge, including in the case of profiling insofar as it relates to direct marketing. If you raise such an objection, we will cease to process your personal data for this purpose.

1.7.6 Right to data erasure

You have the right to request us to delete your personal data. This means that the personal data must be deleted by us without unreasonable delay. This right applies if any of the following situations occur:

• The personal data are no longer necessary for the purposes for which they were collected or otherwise processed
• You withdraw your consent on which the processing is based, and there is no other legal basis for processing your personal data
• Your personal data have been processed unlawfully
• Erasure of your personal data is necessary to comply with European or Belgian law

If you request to delete your personal data, we will delete the personal data unless any of the following situations (exceptions) occur:

• The processing is part of exercising the right to freedom of expression and information
• Deletion is not applicable for the reason of general interest in the domain of public health
• Deletion is not applicable given the need for archiving in the public interest or statistical purposes
• A legal obligation to retain the data applies or deletion is not applicable given the institution, exercise, or substantiation of a legal claim

1.7.7 Right to revoke your consent

If you have consented to certain processing of your personal data, you can withdraw your consent at any time. We try to make withdrawal of consent as simple as giving your consent possible, wherever possible.

1.7.8 Right to object to automated individual decision-making

When your personal data are used in the context of automated individual decision-making and when these decisions have legal effects or other significant consequences, you can ask us to stop using your data. If you oppose such processing, we will stop or restrict processing unless there are compelling reasons to do so.

1.8 Contact information

If after reading this Privacy Policy you have further questions or comments regarding the collection and processing of your personal data, you can always contact us at: info@bebold.digital.

In addition, you have the right to submit any comments and observations or complaints to the supervisory authority responsible for data protection. You can do this in the EU Member State where you reside, the place where you work or the place where the alleged breach took place. In Belgium, you can file a complaint with the Data Protection Authority:

As we are committed to our mutual relationship, we ask you to always contact us first so that we can work out a solution to what lies at the root of your complaint.

1.9 Amendments to the Privacy Policy

Our organization and our Website are a dynamic and innovative environment. This privacy statement may be modified if our services or applicable legislation so require. This means that we are constantly looking to provide a better service tailored to your needs. It is possible that there will be new applications where we will collect or process your personal data in a different way. As a matter of course, we will inform you when there are important changes to this privacy statement, and we will ask your permission if necessary.

2 Our Cookie Policy

2.1 In general

This Cookie Policy discloses the cookie practices for BeBold NV on our Website https://bebold.digital/. Since we care about your privacy and the processing of your personal data, we therefore make every effort to explain plainly and clearly with this Cookie Policy which cookies we use on our Website and how we collect personal data.

When visiting our Website, we may process personal data using online techniques such as cookies, trackers, scripts and similar technologies. In principle, however, these technologies always serve the same purpose: the retrieval and tracking of information on your device, so throughout this Cookie Policy we will continue to use the well-known term: 'cookie(s)'.

With "we" we imply BeBold NV, a Belgian company with registered office at Veldkant, 35 C, 2550, Kontich and known business registration number: 0762.846.206.

The most recent version of our Cookie Policy will always be available on our Website. The use of cookies by BeBold NV is a part of BeBold NV's general policy with regard to the protection of your privacy and processing of your personal data. Further information can be found in our Privacy Policy. If you have any questions, comments or complaints regarding this Cookie Policy or the processing of your personal data or wish to exercise any of your rights, please contact us by e-mail info@bebold.digital.

2.2 What are cookies?

Cookies are 'small information files' that a website asks your browser to temporarily or permanently store on your computer, tablet or mobile device when you visit that specific website or those specific webpages. The cookies contain a unique code that allows your browser to be recognized during your visit on our Website or also during subsequent visits or subsequent use. Cookies make it possible to simplify, complete and personalize the use of our Website.

Cookies usually have an expiration date. For example, some cookies are automatically deleted when you close your browser (so-called session cookies) while others remain on your computer, laptop or mobile device for a longer period in time or sometimes even until you delete them manually (so-called permanent cookies). In your browser you can accept, decline or delete them whenever you like.

Our Website uses cookies for a variety of purposes. We use cookies to improve your user-experience on our Website, since cookies make our Website easier to use for you and will allow us to better customize our Website to your interest and needs. Cookies are also used to help speed up your activities and experience on our Website. Such cookies allow us to analyze the traffic on our Website so we understand the usage of our Website better and thus improve our services.

We also share information about your use of our Website with our analytics partners. These partners may combine this information with other information that you have provided them or that they have collected based on your use of their services.

2.3 Which cookies do we use?

Our website uses a variation of different cookies:

• First-party cookies: these are cookies we initiated on the Website. Only we have access to the information contained in the cookie.
• Third-party cookies: these are cookies created by parties and placed on the Website. With these cookies the third party has access to the data collected in the cookie.

In these two cookie variations, we also use different cookies based on the specific purpose. For each of these categories we will always request your prior consent, unless these cookies are essential.

• Essential cookies: are necessary to improve and ensure the proper functioning of a website such as the security and accessibility. These cookies are set as soon as you have visited the Website and cannot be rejected.
• Functional cookies: ensure your optimal use of our Website by personalizing certain functionalities and remembering choices. These are only set after a choice has been made regarding the placement of cookies.
• Analytical cookies: track your use of our Website and allow us to further improve your experience. These cookies show us which pages are most and least popular and how visitors move around the website. You may refuse these cookies.
• Marketing cookies: enable (personalized) marketing activities including 'retargeting' on own and other platforms. You may refuse these cookies.

More on third-party cookies: Our website uses third-party integrations which may cause cookies to be placed. These cookies are not placed by us, but by the third party connected to our Website. We recommend you read the privacy policy of these third-party services.