Privacy Policy

This Privacy Policy was last updated on June 10, 2022.
If you have not reviewed it since that date, please do so now

In this document (the “Privacy Policy”), we inform you about the data we collect, the purpose of its collection, how we use it and the rights you have regarding the processing of your personal data.

Access to the sites managed by Inoopa (hereinafter, the “Sites“) or the use of their services implies the full and unreserved acceptance by the Person concerned of this privacy policy (hereinafter, the “Policy”), as well as the Terms of Use, the General Terms and Conditions, the Cookies Policy, the Subcontracting Agreement, the Special Terms and Conditions and the Order Form (the “Contractual Documents”).

With respect to the Sites, this Privacy Policy applies to all pages hosted on the Sites and to registrations on the Sites. It does not apply to pages hosted by third parties to which Inoopa may link and whose privacy policies may differ. Inoopa is therefore not responsible for any data processed on or by these sites. 

Photos and videos may be taken and used in connection with Inoopa events and activities in which you participate. These photos and videos may be posted on social networks, our websites, and our communication and information materials. If you do not wish to be photographed or filmed at these events for the above purposes, please inform Inoopa when you register or participate in these events or activities. You can exercise your rights (access, rectification, deletion, etc.) by sending an e-mail to dpo@inoopa.com, also sending us a copy of the front of your identity card.

If we decide to change our Privacy Policy, we will post an updated version of the policy indicating the date of the update and highlight the changes made. If you would like us to stop using or storing your information in accordance with the revised policy, contact us at dpo@inoopa.com. Whenever this Privacy Policy is changed in substance, the “updated” notice will appear next to the “Privacy Policy” link in the footer of the pages of the www.inoopa.com and www.wink.inoopa.com websites (the “Sites”). The “updated” notice will be removed within 30 days. Please read our updated Privacy Policy before using our Sites or services. If you have any questions about our changes, contact us at dpo@inoopa.com.

This Privacy Policy is structured as follows:

1. WHO ARE WE?
2. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
3. WHY DO WE PROCESS YOUR PERSONAL DATA?
4. LEGAL BASIS FOR PROCESSING PERSONAL DATA
5. WILL INOOPA DISCLOSE MY PERSONAL DATA TO THIRD PARTIES?
6. WHERE DOES THE DATA COME FROM?
7. WHAT STEPS ARE TAKEN TO COLLECT (NON-PERSONAL) INFORMATION
8. RIGHTS OF THE PERSON CONCERNED
9. MINORS
10. SECURITY
11. DATA RETENTION
12. COMPLAINT TO THE SUPERVISORY AUTHORITY
13. VALIDITY OF THE CLAUSES, APPLICABLE LAW AND JURISDICTION

1. WHO ARE WE?

S.A. Inoopa (www.inoopa.com), registered at the Crossroads Bank of Enterprises under number 0649973640 and whose head office is located at Silversquare, Av. Arnaud Fraiteur 15-23 – 1050 Ixelles, Belgium (Tel: +32 478 888 398 and e-mail: dpo@inoopa.com) is a company based in Belgium offering companies the possibility to define their activities using advanced technologies to obtain information and actionable insights. INOOPA is active in machine learning, which allows it to have a strong expertise in semantic and image analysis. Inoopa’s official website is www.inoopa.com and Inoopa’s Saas platform is www.wink.inoopa.com. 

We are concerned that our operational activities are carried out in accordance with the applicable legislation, and in particular with Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, applicable since 25 May 2018 (hereinafter, the “GDPR”). 

We have designated a Data Protection Officer (more commonly referred to as “DPO”) as our single point of contact:

HUSSARD Law Practice, with company number 0866.095.578 and with registered office at Chaussée de Bruxelles 135/3, B-1310 La Hulpe.

The tasks of the data protection officer appointed by Inoopa are at least the following:

  1. inform and advise the controller or processor and the employees carrying out the processing on their obligations under the applicable data protection legislation; 
  2. to assist the data controller in monitoring compliance with the applicable legislation and Inoopa’s internal rules regarding the protection of personal data, including the allocation of responsibilities, awareness raising and training of personnel involved in the processing operations, and related audits
  3. Provide advice, upon request, regarding the data protection impact assessment and verify its execution;
  4. cooperate with the supervisory authority;
  5. act as a point of contact for the supervisory authority on matters relating to the processing, including prior consultation, and conduct consultations, as appropriate, on any other matter.

Any questions or requests regarding the processing of this data can be sent to the following address: dpo@inoopa.com.

2. WHAT PERSONAL DATA IS COLLECTED ABOUT YOU ?

We collect the information we deem necessary to provide the service. It is your responsibility to submit additional personal data to Inoopa.

The types of personal data we process, for the purposes mentioned in point 3, are as follows:

  1. If the Person concerned is an Internet user, 

When the user accesses the Inoopa websites (www.inoopa.com and www.wink.inoopa.com), the servers consulted automatically record certain data, such as

  • in the context of services requiring authentication, identification data, such as first and last name, title, e-mail address, date of birth, telephone numbers and addresses;
  • the type of domain with which the Internet user connects to the Internet;
  • the IP address that is assigned to the Internet user (when connecting);
  • the date and time of access to the Inoopa website and other traffic data;
  • location data or other communication data;
  • the pages that the user has visited on the Inoopa website;
  • the type of browser, platform and/or operating system used by the Internet user;
  • the search engine and the keywords used to find the site;
  • navigation preferences.

In order to facilitate the navigation of the Sites and to optimize the technical management, the Sites may use “cookies”. All information about cookies is contained in the Inoopa Cookie Policy.

No nominative data allowing the identification of the Internet user is collected through the cookies and servers consulted. This information is only kept for statistical purposes and to improve the Sites. 

  1. If the data subject is included in the B2B database of Inoopa

Inoopa focuses on understanding companies (legal and natural entities): what they do economically, how they behave and evolve. In this context, Inoopa collects contact information of companies and other data associated with professionals. Professional profile information is professional information similar to that found on business cards, company websites or email signatures. Inoopa’s database consists primarily of this business profile information. The types of data that Inoopa has in this database are:

  • Legal data: registration number, company names, business addresses, financial data, employment, etc.
  • Activity data: sector codes, company descriptions, semantic content on activities, keywords, etc.
  • Contact data: best company phone number, best cell phone number, email based on company role (info@…)

Inoopa’s intelligence is aimed at understanding companies, which is why all data and information marketed by Inoopa is always linked to a legal registration number.

  1. If the Data Subject is a member of Inoopa’s staff,  
  • identification data, such as name and surname, title, e-mail address, date of birth, telephone numbers and addresses, national register number;
  • personal, family and bank information necessary to fulfill legal obligations arising from Inoopa’s activities;
  • communications between the Data Subject and Inoopa;
  • photos and videos identifying him.
  1. If the Person concerned is a supplier, 
  • identification data, such as first and last name, title, e-mail address, date of birth, telephone numbers and addresses of contact persons;
  • (…)
  1. If the Data Subject is a contact person of a client,
  • Identification data, such as first and last name, title, e-mail address, date de naissancetelephone numbers and addresses, numéro de registre national ;
  • bank details (credit card number, IBAN and BIC/SWIFT);
  • personal and banking information necessary to fulfill legal obligations arising from Inoopa’s activities;
  • communications between the Data Subject and Inoopa.

The Data Subject also authorizes Inoopa to record and store, for the purposes mentioned in point 3 : 

  • information voluntarily provided by the Person concerned for a purpose specified in the Privacy Policy, the GTC, the TOU, the Cookie Policy, on the Sites or on any other communication medium used by Inoopa;
  • additional information requested by Inoopa from the data subject in order to identify him or her or to prevent him or her from violating any of the provisions of the Privacy Policy.

We also collect some of your data through third parties. This is the case, for example, when Inoopa processes data from various sources (public or third party) to better know and understand the business sectors of companies in Belgium (see points 4 and 6 below). 

3. WHY DO WE PROCESS YOUR PERSONAL DATA?

Generally speaking, Inoopa processes your data within the framework of its main activity which is to process data to better know and understand the sectors of activity of companies in Belgium and to update and maintain an exclusively BtoB database.

More specifically, we process your data for various purposes. For each processing operation, only the data relevant to the purpose in question are processed. Processing is any operation (manual or automated) on personal data. Inoopa collects, saves and uses the data of the persons concerned for the following purposes in particular

  1. If the Person concerned is an Internet user, 
  • to conduct statistical surveys;
  • to analyze, adapt and improve the content of the Sites;
  • to allow the Person concerned to receive messages;
  • to facilitate the provision and use of the Sites;
  • to personalize the user’s experience on the Sites;
  • to inform them of the evolutions of the Sites and their functionalities; 
  • for any other purpose for which the Data Subject has expressly given his or her consent;
  • to carry out prospecting for its own account.
  1. If the Data Subject is a member of Inoopa’s staff, 
  • to ensure the follow-up of ongoing projects;
  • to properly manage any activities you may be registered for;
  • to establish, carry out and conduct the contractual relationship with the Data Subject;
  • to conduct statistical surveys;
  • to answer your information requests;
  • to inform you about Inoopa’s publications and activities;
  • to allow the Person concerned to receive messages;
  • for any other purpose for which the data subject has expressly given his or her consent.
  1. If the Person concerned is a supplier, 
  • to respond to requests for information and to enable the provision of the service;
  • for any other purpose for which the data subject has expressly given his or her consent.
  1. If the Data Subject is a contact person of our client,
  • for the provision of its services and to ensure proper monitoring and management of users/licensees registered on its Sites;
  • to broadcast Inoopa’s news;
  • to conduct statistical surveys;
  • to respond to requests for information;
  • to allow the person concerned to receive messages;
  • for any other purpose for which the data subject has expressly given his or her consent.

Inoopa may also process your data for marketing purposes:

  1. For Marketing Purposes: By registering for the Service, you agree that your contact information and information about your use of the Service may be used to offer you additional products or services. These promotional offers may be communicated to you via e-mail, telephone or direct mail. We will never send you promotional offers via text message (SMS).

    If you do not wish to receive commercial offers by e-mail or telephone, you may unsubscribe at any time byusing the unsubscribe link in the e-mail or by contacting us at dpo@inoopa.com or by making a request directly to an Inoopa representative.
  1. Internal Business Purposes: In order to improve the Service and develop new products and services, we may use your personal data for internal data analysis, to study how our Sites are used, to help us diagnose problems and secure the Service, identify usage patterns and determine the effectiveness of promotional campaigns. For example, we may determine how long visitors spend on each page of the Website and how they navigate the site. We will only use this information for the purpose of improving the Website.

Inoopa may, in its capacity as a subcontractor, at the request and on behalf of its customers, have the task of

  • collect and process company data in order to generate a list that meets the criteria and needs of its clients by detecting specific company terms using its advanced technology;
  • Generate a new list of company data based on specific criteria (such as no online presence), within a list of existing customer data belonging to the customer.

Inoopa’s customers therefore determine the purpose(s) of the processing.

4. LEGAL BASIS FOR PROCESSING PERSONAL DATA

Under European data protection legislation, any processing of personal data must be justified by a “condition” for processing. In the majority of cases, any processing will be justified on the grounds that:

  • you have consented to this processing;
  • the processing is necessary for the purposes of the contract with you (for example, processing your payments or creating your user account);
  • the processing is necessary to comply with a relevant legal obligation; or
  • processing is in our legitimate business interests, subject to your interests and fundamental rights.

Inoopa does not process any so-called “sensitive” data. sensitive “. If, however, the processing of “special categories of data” or “sensitive personal data” is carried out by Inoopa, this processing is only permitted if there is a relevant exemption. 

Data processing to better know and understand the sectors of activity of companies in Belgium:

Inoopa is also aware that if certain data have been made manifestly public by the data subjects, this does not exempt it from providing a legal basis. 

In order to base its processing on the legal basis of legitimate interest, Inoopa must balance its interest against the “interests or fundamental rights and freedoms of individuals” and must also take into account your “reasonable expectations” of those individuals. 

For the determination of the legitimate interest as a legal basis, Inoopa based itself on the recommendations of the authorities and on the factual elements by applying the three-step test, as recommended by the case law of the Court of Justice of the European Union. 

5. WILL INOOPA DISCLOSE MY PERSONAL DATA TO THIRD PARTIES?


Inoopa will not disclose your personal data to third parties under conditions other than those specified in the Charter, for the purposes set out in point 3 or as required by law.

  1. With our clients:
  1. With our suppliers and service providers: We use the services of a number of reputable third parties, who perform various tasks for us, under the protection of appropriate agreements. 

Access to data may, in some cases, be granted to certain categories of external recipients, such as technical service providers, courier services, hosting providers, IT companies, legal advisors, communication agencies, expert reviewers, research funding agencies, and research project hosts.

For example, we use leading third-party platforms to process your payments (primarily (…., PayPal), to provide us with storage services (primarily Amazon and Google Cloud), to assist us with marketing and advertising, consumer research analysis, development of new algorithms and services, fraud prevention, security, and processing customer support requests. 

3) In certain legal or privacy circumstances: when required by law or in legal proceedings, or for fraud and cybercrime prevention purposes.

The updated list of these recipients can be requested from the Data Controller at any time. 

The communication of such information to the above-mentioned persons shall, in all circumstances, be limited to what is strictly necessary or required by applicable regulations.

Transfers outside the European Economic Area

Inoopa will only transfer data to a country outside the European Economic Area if that country provides an adequate level of protection in accordance with the applicable legislation and, in particular, in accordance with the GDPR, or within the limits permitted by the applicable legislation, for example by ensuring data protection through appropriate contractual provisions. 

Information controlled by Inoopa will be transferred or transmitted, or stored and processed, for example, in other countries outside the country where you live, for the purposes described in this Charter. These data transfers are necessary to provide the services or to carry out the processing set out in the Charter. We use standard contractual clauses approved by the European Commission and we rely on the European Commission’s adequacy decisions regarding certain countries. If you have any questions in this regard, please contact us at dpo@inoopa.com. 

6. WHAT IS THE ORIGIN OF THE DATA?

Inoopa processes data from a variety of sources (public or third party):

  1. References in the Official Journal and the central database for companies (ECB/KBO)
  2. Company websites and public directories, such as the land register, the National Bank’s annual accounting system, publications of VAT institutions, institutions and the Social Security Office
  3. Open databases like Statbel, university publications, etc.
  4. Other sources accessible to all, such as information made public by the company on Google My Business, social media (Facebook) or other websites (the analysis goes through Google)
  5. Private partners (such as Trends in Belgium and Graydon in the Netherlands) offering analysis on company finances, size, activities and other value-added insights for the purpose of Inoopa 
  6. The foreign equivalents of the above sources.

7. MEASURES TAKEN FOR THE COLLECTION OF (NON-PERSONAL) INFORMATION

In general, we implement and maintain a reasonable level of security appropriate to the nature of the personal data we collect, use, store, transfer or otherwise process. 

– Collection:

Inoopa focuses on understanding companies (legal and natural entities): what they do economically, how they behave and evolve. In this context, Inoopa collects company contact information and other data associated with professionals. The artificial intelligence developed by Inoopa is aimed at understanding companies, which is why all data and information marketed by Inoopa is always linked to a legal registration number.

– Actions taken

Inoopa aims to provide only company-related data and to avoid as much as possible the collection and storage of personal and non-business-related data of individuals, employees, company managers, etc. 

To this end, Inoopa has put in place mitigating processes to respect the privacy of individuals. The measures Inoopa has put in place are as follows: 

  1. Company related phone numbers 

In order to prevent individuals from receiving unwanted calls related to their business, we have put in place certain mitigation measures and processes prior to collection. We have developed our own algorithm to define our “Company Best Phone”. Using our various data sources and cross-referencing with active public sources, we keep the most reliable business phone number related to the company. As a result, the phone numbers are linked to the business entity and not to an individual. In addition, our phones are synchronized daily with the DoNotCallMe list. 

  1. Company emails 

Inoopa only holds and cdommunicates only so-called “role-based” emails. These are emails such as info@, marketing@, contact@, etc. These email addresses are all associated with registration numbers and cannot be linked to an individual. 

  1. Business partners 

Inoopa collaborates with various business partners to enhance its own technologies and knowledge. Inoopa pays scrupulous attention to their sources, processing and any data that would fall under the GDPR. We ask them to be as transparent as possible and refer to their privacy publications for more information.

  1. Inoopa’s servers are located in the EEA
  2. Conducting an impact analysis (“DPIA”)

Inoopa has carried out a Data Protection Impact Analysis (“DPIA”) in the context of its data enrichment activities. This analysis was carried out, among other things, in the context of the adoption of the legal basis. 

The analysis confirmed that the processing of company profile information by Inoopa can be based on the legal basis of legitimate interest. The analysis also determined that this legitimate interest did not override the fundamental rights and freedoms of the data subjects.

8. RIGHTS OF THE PERSON CONCERNED

You have the following rights:

  • Right to be informed about the purposes of the processing and about the identity of the controller.
  • Right of access: The data subject may at any time access the data that Inoopa holds on him or her or check whether he or she is included in the database of Inoopa. 
  • Right of Correction: We take all reasonable steps to ensure that the data we hold is up to date. We encourage you to access your account (if applicable) from time to time or to check with us to ensure that your data is up to date. If you find that your data is inaccurate or incomplete, you have the right to request that we correct it.  
  • Right of objection: The Data Subject may at any time object to the use of his/her data by Inoopa and its partners.
  • Right of deletion: The Data Subject may at any time request the deletion of his or her personal data, with the exception of data that Inoopa is legally obliged to retain. 
  • Right to restrict processing: the Data Subject may, in particular, obtain the restriction of processing when he or she has objected to the processing, when he or she disputes the accuracy of the data, or when he or she considers that the processing is unlawful.
  • Right of portability: the Data Subject has the right to receive the personal data he or she has provided to Inoopa and may also request Inoopa to transfer this data to another controller.

In order to exercise his or her rights, the Person concerned shall send a written request, accompanied by a copy of the front of his or her identity card, to the person responsible for the processing:

  • by e-mail: dpo@inoopa.com 
  • by mail: 

Silversquare, 

Av. Arnaud Fraiteur 15-23

1050 Ixelles,

Belgium

Inoopa will then take the necessary steps to comply with this request as soon as possible and in any case within one month after receipt of the request. If necessary, this period may be extended by two months, depending on the complexity and number of requests. 

9. MINORS

Persons under the age of 18 and persons who do not have full legal capacity are not allowed to use the Sites. Inoopa requests that they do not communicate their personal data to Inoopa via the Sites or any other medium. Any violation of this provision must be reported without delay to the following address: dpo@inoopa.com  

10. SECURITY

Inoopa has taken the appropriate organizational and technical measures to ensure a level of security appropriate to the risk and to ensure that the servers hosting the processed personal data prevent, as far as possible : 

  • unauthorized access to or modification of such data;
  • improper use or disclosure of such data; 
  • unlawful destruction or accidental loss of such data. 

In this respect, the employees of Inoopa who have access to this data are under a strict obligation of confidentiality. 

While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable security program for such data, none of these programs is infallible; in other words, not all risks can be reasonably eliminated and it cannot be assumed that the occurrence of any incident or breach would result from our failure to implement and maintain reasonable security.

You agree not to engage in any conduct that would be contrary to the Contractual Documents or, generally, to the law. You are responsible for maintaining the confidentiality of your password to the Service. Inoopa requests that you do not share your password with any third party. Inoopa requests that you do not use the password you use for Inoopa for any other service.

11. DATA RETENTION

Inoopa keeps the personal data of the data subjects for as long as is necessary for the fulfilment of the purposes (see point V.) and for the provision of the Services in accordance with the General Terms and Conditions.

The retention periods may vary from one processing operation to another, depending on the purpose and the legal basis for the retention periods.

Inoopa may also continue to hold certain personal data about the de-registered data subject, including any correspondence or requests for assistance addressed to Inoopa, in order to be able to respond to any questions or complaints addressed to Inoopa after the processing, to ensure the proper conduct of Inoopa’s business and to comply with any applicable laws, including tax or other legal requirements.

12. COMPLAINT TO THE SUPERVISORY AUTHORITY

The Data Subject is informed that he/she has the right to lodge a complaint with the Data Protection Authority (DPA) whose contact address is

Data Protection Authority
Rue de la Presse, 35, 1000 Brussels

Tel : +32 (0)2 274 48 00

E-Mail : contact@apd-gba.be

13. VALIDITY OF THE CLAUSES, APPLICABLE LAW AND JURISDICTION 

Inoopa’s failure to rely on any provision of the Privacy Policy at any time shall not be construed as a waiver of any subsequent rights under the Privacy Policy.

The nullity, the lapse or the unenforceability of all or part of one of the preceding or following provisions will not involve the nullity of the whole Privacy Policy. The provision that is wholly or partially invalid, void or unenforceable shall be deemed unwritten. Inoopa undertakes to replace such a provision with another provision which, as far as possible, serves the same purpose.

The validity, interpretation and/or execution of the Privacy Policy are subject to Belgian law, to the fullest extent permitted by the applicable rules of private international law.

In the event of litigation relating to the validity, the interpretation or the execution of the Charter Privacy, the Courts and Tribunals of the judicial district of Brussels are exclusively qualified, in all the measurement allowed by the applicable rules of private international law.

Before taking any steps towards the judicial resolution of a dispute, the Person concerned and Inoopa undertake to try to resolve it amicably. To this end, they will first contact each other, before resorting, if necessary, to mediation, arbitration, or any other alternative dispute resolution method.

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