01

To whom does this Privacy Policy apply?

  • This Privacy Policy, which applies to all products and services offered by Brightfish nv to its business customers and prospects, informs you about which personal data we process and how it is used.

  • However, the processing of personal data of business customers only applies if the business customer is a natural person, or - if the business customer is a legal person - then the Privacy Policy only applies to the personal data of the natural persons that we use in the context of of their relationship with the business customer (such as contacts and delegates).

02

Who is responsible for the “processing” of personal data?

  • The personal data you provide on www.brightfish.be are collected and processed by or on behalf of Brightfish nv, with registered office at Eeuwfeestlaan 20, 1020 Brussels in Belgium (EU), company number BE0450523725.

  • Brightfish nv is the data controller for the personal data collected via the website, any mobile applications and other channels (e.g. via email).

03

What information do we collect about you?

Personal data is data that makes it possible to directly or indirectly identify a natural person. Although the processing takes place in the context of a B2B relationship, this of course does not mean that you as a contact person or visitor to the website would lose your rights as a natural person. Brightfish nv collects and processes the following categories of personal data in the context of its services:

  • If you visit our website without identifying yourself, we only keep the following information: the pages you visit, your IP address and the identification of your browser (version, computer type).

  • If you subscribe to our newsletter, or in another context ask us to send you emails, we will process your email address, name and language. The purpose of this is to provide you with the best possible information.

  • In principle, the data will not be collected from third parties, but will be requested from you, such as with a request for information, when purchasing a product or service, when participating in a survey or competition, when registering and managing your customers. account. In addition, certain publicly accessible information may be used to contact you.

  • If you provide us with personal data of persons within your company, you will therefore also have to ensure that you are entitled to do so, with due observance of the purpose for which Brightfish nv will process the personal data.

  • www.brightfish.be uses so-called cookies to optimize the online experience. These can be session cookies or permanent cookies. Partner and affiliate cookies may also be placed. The user has the option at all times to refuse the placing of cookies via the settings of his/her internet browser, which may adversely affect our services. Further information can be found in our Cookie Policy.

04

Why do we process this data? On what legal basis?

Brightfish nv collects, registers and processes personal data:

  • to inform you about products and services, including campaigns and promotions, that Brightfish nv offers or that are offered by our commercial partners (the latter only with your permission)

  • to provide you with customized information about Brightfish nv's products and services, using a profile that we have obtained based on your interests

  • to be able to monitor our performance and to answer your comments and/or questions regarding our services

  • for customer satisfaction survey

  • Brightfish nv may use your personal data to contact you directly, by post, telephone or electronically, such as by e-mail or SMS. When communicating by e-mail, you will always be offered the option to unsubscribe at any time (see below: regarding your rights as a data subject).

05

How long do we keep this information?

  • Brightfish nv only stores your personal data for as long as this is necessary for the described purposes. Your personal data will in principle be deleted 2 years after your last active interaction with us. In this way we also prevent irrelevant information from being stored.

  • Since the contractual liability claim only lapses after 10 years, we will archive certain personal data for this period – only for this purpose. If other legal obligations impose further retention (such as the retention of invoices), we will of course respect this legislation.

06

Who do we share this information with?

  • For the realization of the purposes described under article 3, Brightfish nv can engage so-called processors. These act exclusively on our instructions and will therefore only be able to process your personal data on our instructions.

  • For example, we use suppliers to provide marketing, communication, logistics and IT services, to personalize and optimize our service, to process credit card transactions and collections and to limit fraud in credit card transactions or other payment methods, to organize competitions, deliver the purchased products, help organize our events, provide customer service, collect debts, etc.. It is possible that these suppliers gain access to your personal data or other information when providing such services. We only authorize these companies to process your personal data to the extent necessary for the provision of their services. We also ensure that these processors ensure an adequate level of data protection security.

  • In addition to engaging such “processors” for the services described, we will only share personal data that you have expressly provided to us, such as your name, email address and other non-automated data, with other parties only if we have obtained your explicit consent to do so, unless we are obliged to do so on the basis of a legal provision, a request from a government authority or a court decision.

07

Are personal data transferred to countries that do not guarantee similar protection of personal data?

  • Brightfish nv collects your data in its databases and strives to protect this data in a manner that is in line with the market against any modification, loss or unlawful use.

  • Insofar as personal data is processed outside the European Union, we ensure through contractual or other measures that said data enjoys an adequate level of protection there, comparable to the protection they would enjoy in the European Union, in accordance with European regulations.

08

What rights can you exercise regarding your personal data?

  • Right of access, correction and erasure – Once your data has been collected and processed, you have the right to access this personal data, to demand correction if it is incorrect and, subject to justification, to request that the personal data be deleted. However, it should be taken into account that we cannot always delete all requested personal data, for example when processing it is necessary for the establishment, exercise or defense of legal claims.

  • Right to restriction – In addition, you also have the right to request that the processing be “restricted” (in cases where immediate deletion would be to your disadvantage, the personal data will then only be made inaccessible).

  • Right to data portability - If you wish to transfer your actively provided personal data to another service provider, this is also possible.

  • Right to object – Whenever the processing is based on a legitimate interest of Brightfish nv, you have the right to object to this processing. We will stop processing your personal data, unless the processing of the personal data is related to the establishment, exercise or defense of legal claims (for example, submitting a request to a court).

  • Right to withdraw consent – Where the processing is based on your consent, you always have the right to withdraw this consent, without this affecting the lawfulness of the processing based on the consent before this withdrawal.

  • Finally, you always have the right, without having to give a reason, to object to the use of your personal data for direct marketing purposes.

09

How can you specifically exercise these rights?

You can exercise your rights by sending an email to the following address: privacy@brightfish.be with your name, email and the data you want to see changed and/or deleted.

10

Changes to this document

This Privacy Policy may be amended from time to time, including to adapt it to changed services or changes in legal and regulatory requirements. We therefore recommend that you regularly consult the latest version of this Privacy Policy on our website.

11

Who can I contact you in case of ambiguities or complaints?

  • For general questions or comments, you can contact us by sending an e-mail to privacy@brightfish.be or by writing to Brightfish nv, Eeuwfeestlaan 20, 1020 Brussels, stating 'Attn GDPR responsible'

  • For complaints regarding the processing of your personal data by Brightfish nv, you can also contact the Data Protection Authority, Drukpersstraat 35, 1000 Brussels / +32 (0)2 274 48 00 / commission@privacycommission.be / www.privacycommission.be .

12

Document version

  • 2018-05-22: version 1.0

  • Changes to this document will always be accompanied by an adjustment of the version and date above.