Privacy Policy

Privacy policy concerning the processing of customer and website user personal data

MultiMinds BV (hereinafter ‘we’, ‘us’ and ‘our’) understands the importance of the privacy of its customers and users of its website visitors and the protection of their personal data. This policy sets out how we handle and process your personal data.


This document was last updated on October 14, 2024.


Table of contents
  1. Scope
  2. What type of personal data do we collect?
  3. Why do we collect these data and on what legal basis?
  4. How will your data be used and shared?
  5. Transfer of your personal data outside the European Economic Area
  6. Rights of the data subject
  7. Terms and conditions of use and liability
  8. Applicable legislation and jurisdiction
  9. Amendments to this policy
  10. Exercise your rights

1. Scope

MultiMinds BV, with its registered office at Hertshage 10 (4th Floor), 9300 Aalst, Belgium, KBO (Crossroads Bank for Enterprises) number 0554.690.837, acts as the data controller when we process our customers’ and website users’ personal data.


We committed to creating and maintaining an environment where our customers can trust that their data will not be misused. We adhere to the applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (GDPR”) and the Belgian Data Protection Act of 30 July 2018. These regulations are designed to protect your personal data and grant you specific rights over how your data is used.


This policy explains the types of personal data we collect and how we use this information.


This Privacy Policy applies when you visit our website, use our other digital platforms, or attend our events. Any terms and conditions other than those outlined in this Privacy Policy are prohibited unless expressly approved by us in writing beforehand. If such approval is granted, this policy will still apply in conjunction with the specific agreement. Access to and use of our website, platforms, and all content are strictly conditional upon full compliance with this policy.

2. What type of personal data do we collect?

Applicants


Legal Basis: legitimate interest


From applicants we collect the full name, e-mail address, telephone number and CV. If the applicant has also sent his/her photo and cover letter, these will also be archived. An overview of language knowledge and skills will be saved. Finally, answers to screening questions are also registered. Your information will be stored for the duration of the recruitment process. If you opt to be included in our candidate reserve, your data will be retained for one year.


Special Category Data: Consent is always mandatory.


Customers, prospects and website visitors


Legal Basis for Processing:


  • Contractual Necessity: Processing is required to fulfill a contract or take steps prior to entering a contract.
  • Legitimate Interest: Processing is necessary to pursue our legitimate business interests, provided that these interests are not overridden by your rights.
  • Consent: Where required, we obtain your explicit consent to process your personal data for specific purposes.


We collect and process the following categories of personal data for the purposes described below:


  • Name (First and Last Name)
  • Contact details (Email, Telephone Number);
  • Company Name
  • Company Address / Location
  • Job Function


The above data may be provided when you fill out forms on our website, when we communicate with you (via phone, email or at trade fairs and events), or through other direct interactions.


In addition, we collect data when you interact with our website or use devices connected to it. The following data may be collected.


  • Location Data: This may be gathered through social media, the IP address of your device or GPS signals from your mobile device.
  • Automatically Collected Data: We may gather information via cookies, web beacons or similar techniques. This can include data about the website you visited before or after navigating to ours, the pages you view on our website, your IP address, bowser type, access time and operating system. For more details on how we use cookies, please refer to our Cookie Policy.


We may also collect data form publicly accessible sources to verify information we have previously collected or to enhance and expand our business operations.

3. Why do we collect these data and on what legal basis?

We collect and process the above data to create a profile that allows us to better understand your needs and improve the services we offer. This data may be used for the following specific purposes:


  • Responding to Inquiries: To address your questions or requests related to our services.
  • Service Delivery: To provide and deliver the services you have ordered or requested.
  • Identity and Payment Verification: To verify your identity and financial information for payment processing related to our services.
  • Service Improvement: To enhance and optimise our services based on your feedback and usage patterns.
  • Complaint Resolution: To investigate and resolve any complaints you may have regarding our services or website.
  • Legal and Regulatory Compliance: To fulfill our legal obligations and comply with regulatory requirements.
  • Marketing Communications: To send you periodic emails with updates and information about our services, with your consent when required.
  • Market Research: To contact you occasionally for market research purposes, using email or telephone, to better understand your needs and preferences.
  • Specific Purposes: To process your personal data for any specific purpose as outlined in specific forms on our website, or as communicated via written notification or email.


We process the personal data based on the following legal grounds as outlined in Articles 6.1 (a), (b), (c) and (f) of the GDPR:


  • Consent (Article 6.1(a))
  • Contractual Necessity (Article 6.1 (b))
  • Legal Obligation (Article 6.1 (c))
  • Legitimate Interest (Article 6.1 (f))


Contractual Obligations


We process your personal data to fulfill contractual obligations, such as delivering services in line with our agreements. This includes actions such as invoicing and communicating with you. Personal data processed for this purpose will be stored for 10 years after the end of our commercial relationship, in accordance with applicable legal retention periods.


Legal Obligations


In certain cases, we are legally required to process and share personal data with third parties such as government authorities, to comply with regulations (e.g., anti-money laundering legislation or other governmental requirements).


Legitimate Interest


We process personal data based on legitimate interest to operate our business, contact your regarding our products, services, promotions, or events, and ensure ongoing communication. Personal data in this context will be retained for up to one year after termination of our commercial relationship.


Consent


If you are not an existing customer, we will request your explicit consent before sending you information about our and services for promotional purposes. After consent is provided, we will retain your personal data for up to one year, unless you withdraw your consent earlier.


PurposePersonal DataLegal GroundRetention Period
Direct Marketing (customers)Name and contact details (e-mail address)Legitimate InterestUp to one year after the termination of the commercial relationship
Direct Marketing (non-customers)Name and contact details (e-mail address)
Consent

Up to one year after consent is granted, or until consent is withdrawn

Customer Relationship Management

Name and contact details (e-mail address, telephone number, job position, work address)
  • Contractual Necessity (required for the execution of an agreement)
  • Legitimate Interest (manage our customer relationships)



Up to ten years after the termination of the commercial relationship


For more information about the cookies we use, visit our cookie policy.

4. How will your data be used and shared?

We may share your personal data with the following:



Based on our legitimate interest, we may share your personal data with third-party service providers who assist us in providing our services. Examples include web hosting, data analysis, marketing support, and customer service. These third parties will only access your personal data as necessary to perform their specific tasks, and we always enter into Data Processing Agreements (DPAs) with them to ensure they comply with GDPR requirements and do not use your data for other purposes.


Your personal data will not be sold or leased to third parties.


We may disclose your personal data to enforce our policies, comply with legal obligations, or act in the interest of public safety and legal enforcement, regulatory authorities, or government agencies. Additionally, we may share data in connection with ongoing or anticipated legal proceedings, or to protect our property, safety, personnel, or other rights and interests.


If MultiMinds BV is sold or merges with another company, your personal data may be accessible to the advisors of the potential buyer and transferred to the new owners of the company. In such cases, we will implement appropriate measures to ensure the integrity and confidentiality of your personal data. The use of your personal data will remain subject to this Privacy Policy.

5. Transfer of your personal data outside the European Economic Area

We may transfer your personal data to third parties located outside the European Economic Area (EEA), such as the United States, for services like hosting through Microsoft Dynamics. Such transfers are lawful if the recipient is in a country that the European Commission has deemed to provide an adequate level of data protection.


In cases where the country does not have equivalent data protection laws, we will ensure that appropriate safeguards are in place, such as using Standard Contractual Clauses (SCCs) approved by the European Commission. Where required, we will also seek your explicit consent before transferring your personal data outside the EEA.


For further details on how we manage data transfers, please refer to the "Rights of the Data Subject" section.

6. Rights of the data subject

Data protection legislation grants data subjects various rights to ensure they have control over how their personal data is processed. These rights empower individuals to manage and protect their personal data.


You are entitled to:

a) Right of access/inspection

You are entitled to receive confirmation from us as to whether we are processing your personal data. If we are, you are entitled to access and view the personal data we hold about you.


If not included in this policy, we will provide you with the following information upon request:


  • the purposes of the data processing;
  • the categories of personal data involved;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed;
  • any transfer of personal data to recipients in third countries or international organisations;
  • where possible, the intended retention period for the personal data, or if not possible, the criteria used to determine that period;
  • your rights regarding your personal data, as outlined in this section;
  • where the personal data was not collected directly from you, any available information regarding the source;
  • the existence of automated decision-making, including profiling, along with relevant information about the underlying logic, the significance, and the potential consequences of such processing for the data subject.


Upon request, we will provide you with a copy of your personal dat. However, if you We will produce a copy of the personal data relating to you in our records upon request. Should you make repeated and disproportionate requests for copies of the said data, we reserve the right to charge you a reasonable fee.


b) Right to rectification

Should you determine that the personal data on our records is incomplete or incorrect, you are entitled to notify us via privacy@multiminds.eu in order for the necessary steps to be taken to rectify or add to the said data.

c) Right to be forgotten

You are entitled to request we delete your personal data should the processing not be in accordance with the data protection legislation or should the said processing not fall within the limitations laid down by law.

d) Right to restriction of processing

You are entitled to request we limit the processing of your personal data if:


  • the accuracy of the personal data has been called into question during the period required to check the accuracy thereof
  • the processing is unlawful, and you do not wish the data to be deleted;
  • we no longer require the data, but you do not request we delete the data because the data is required for the pursuance or defence of legal claims
  • an objection is made to the processing pending an explanation of the legitimate interests that outweigh your interests.

e) Right to data portability

You are entitled to receive the data you have provided to us in a structured, standard and machine-readable format. You are entitled to request we transfer the personal data to another data controller (directly from us). This is an option when the processing is based on your consent and processing via an automated procedure.

f) Right to object

Where your personal data is processed for direct marketing purposes (including profiling), you remain entitled to object to the said processing.


You are entitled to object to the processing based on a specific situation related to the data subject. The organisation will no longer process the personal data unless the organisation demonstrates compelling legitimate grounds for the processing which outweigh your interests or the interests of the pursuance or defence of legal claims.

g) Automated individual decision-making

The data subject is entitled not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, such as the evaluation of personal aspects related to performance at work, reliability, creditworthiness, etc.


The said right not to be subjected to such automated decision-making processes does not apply where the process is allowed on the basis of a mandatory legal provision.


The data subject is not entitled to invoke this right when the decision is required to enter into, or to execute, an agreement between the data subject and the organisation or is based on the explicit consent of the data subject. In the latter two cases, the data subject is entitled to human intervention by a member of the organisation staff and is entitled to notify the organisation of their position and to contest the automated decision.

h) Right to withdraw consent

If you have consented to the processing of your personal data for a specific purpose of processing, you are entitled to withdraw your consent by sending an email to privacy@multiminds.eu.


If you opted to receive newsletters from us when you registered on the website, you can unsubscribe via the button that is always at the bottom of the email if you change your mind.

i) Procedure to exercise rights and other provisions

We can request you verify your identity to ensure your request is lawful and that we are sending the reply to a person entitled to make such a request and to receive the data.


Please note that we may refuse access to your personal data or may not be able to grant your request under specific circumstances when we are entitled to do so under the applicable data protection legislation.


For further information on the processing of your personal data or if you wish to exercise your rights, please contact us at privacy@multiminds.eu.


You are entitled to lodge a complaint with the competent supervising authority (for data protection). In Belgium, the Data Protection Authority, Drukpersstraat 35, 1000 Brussels (contact@apd-gba.be).

Security

We make every effort to guarantee the security of your data. We have implemented reasonable technical and organisational measures to guarantee your personal data against accidental or unlawful destruction, loss, modification, unauthorised disclosure and/or unauthorised access to the data transmitted, saved or otherwise processed. Please note that the internet is an open network; we cannot therefore guarantee that unauthorised third parties will not be able to circumvent these measures or use your personal data for inappropriate purposes.


This website may include links to third-party websites. We will not be held liable for the content of these websites, nor for the privacy standards and practices of the corresponding third party. You must read and understand the relevant third-party and website privacy policies before accepting cookies and visiting a website, to ensure your personal data is sufficiently protected.

7. Terms and conditions of use and liability

a) Rights to the website and materials – Permitted usage

Our website and the materials available thereon (for example texts, images, videos, data, software, brands and trademarks and other data) are protected by intellectual property rights and other rights vested in us.


Visitors to the website are permitted to consult the website. This right of use is non-exclusive and non-transferable and we reserve the right to revoke this right at any time and without justification. Any other use of any element of the website (i.e. reproduction, changes, publication or any other form of distribution) is prohibited, unless we and/or the licensors have provided advance express permission in writing.

b) Prohibited use of the website and material

You undertake as follows: not to use the website (1) illegally and/or for illegal purposes; (2) not to damage, modify, interrupt, stop it or impair its efficiency; (3) to disseminate or install computer viruses nor to disseminate or install material that is insulting, obscene, threatening or otherwise not in accordance with the intended use of the website; (4) not to infringe third-party or our rights to privacy, protection of personal data or intellectual property; (5) to disseminate or install material for marketing or advertising purposes without requesting our prior approval and only insofar as the recipient has requested the said material.

c) Liability

We shall make every effort to ensure the information we add to our website is as complete, correct and current as possible, although we cannot guarantee that the information provided does not include any errors. The information contained therein is not aimed at specific people or organisations and may therefore not be complete, relevant or accurate.


The information must not be considered professional or legal advice (an expert should always be consulted for these purposes). The user is responsible for the use of the website and their data. We waive all liability for any damage caused by any errors on this website.


We make every reasonable effort to limit technical malfunctions. Errors and malfunctions may however occur when using the website, which may hinder the availability or operation thereof. The website and the content thereof is provided “as is” and we do not accept any liability for issues resulting from the use of our website or the content thereof.


The website pages may contain links to external websites for whose content we neither assume nor will assume any liability with regard thereto. We will not be held liable for material and information added by users to the website. The user is obliged to indemnify or compensate us for all damage attributable to the material and information.

8. Applicable legislation and jurisdiction

Belgian law is applicable to our website, this policy and disputes that may arise with regard to these. In the event of a dispute, only the courts of Dendermonde shall have jurisdiction.

9. Amendments to this policy

MultiMinds may amend or update this policy to ensure the provision of information on how we process your personal data at that time. The updated version of this policy is available on the same website and will take effect upon publication. Please visit this webpage regularly to ensure you remain up-to-date on how we collect and process personal data, how and under what circumstances we use your personal data and when we share your personal data with third parties.

10. Exercise your rights

Contact details DPO (data protection officer)

Any questions, concerns or complaints regarding this Privacy Policy or our processing of your personal data? If you would like to contact us to understand more about this policy or wish to contact us concerning any matter relating to individual rights and your personal Information, you may fill in the contact form below, send an email via our contact form or to privacy@multiminds.eu or write a letter to Hertshage 10, 9300 Aalst.

Details about your application

We will provide the requested information by email (in PDF).
If you want to receive the information in another way, please indicate this in the comments field.

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