GENERAL PRIVACY POLICY

Updated July 6, 2019

This Privacy Policy governs the processing of your personal data by LeadFabric whenever you:

visit our website https://www.leadfabric.com;
communicate with us via e-mail, telephone and social media (“Social Media Channels”, such as Facebook, LinkedIn, Instagram and so on) or
want to interact with us at fairs and events.

If you would like to receive information on how we process personal data in the context of your application for a position at LeadFabric, please refer to our Applicant Privacy Policy. If you would like to receive information on how we process personal data through cookies, please refer to our Cookie Policy.

1. GENERAL

1.1.	Your personal data are processed by LeadFabric, acting in the capacity of data controller. Our contact details are: LeadFabric with registered seat at Lambroekstraat 5A, 1831 Machelen, Belgium, VAT 0832.917.125. In case you have any remarks or questions, please contact our Data Privacy Officer.
1.2.	The terms within this Privacy Policy must be interpreted in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC).
1.3.	We reserve the right to modify or amend this Privacy Policy on our own initiative. Each change or modification shall be communicated via our website.

2. GENERAL INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA

2.1.	Whenever you use our website and/or Social Media Channels, we collect: technical information associated with the device you use, such as your IP address, browser type, geographical location and operating system; information concerning your browsing behavior, such as how long you visit, what links you click on, what pages you visit and how many times you visit a page.
2.2.	When you fill out the contact form on our website or contact us to receive our newsletter, we collect: basic identity information, such as your name, e-mail address, phone number; your preference in terms of salutation; the country where you are located; your company name and job title; the content of your communication and any other personal data you choose to provide us with.
2.3.	When you contact us via e-mail, phone or Social Media Channels with a concrete question, complaint or information, we collect: the basic identity information you provide us with, such as name, e-mail address, address, phone number; the content of your communication and the technical details of the communication itself (with whom you correspond at our end, date and time, etc.); publicly available information of your profile on Social Media Channels and any other personal data you choose to provide to us.
2.4.	When we organize fairs and events where you are present, we collect: the basic identity information you provide us with, such as name, e-mail address, correspondence address, telephone number; details regarding your professional career, such as your current employment, job title and a photograph of you when we take pictures at a fair or event.
2.5.	Whenever you give us your business card or interact with us at fairs and events at which we are present, we collect: the basic identity information you provide us with, such as name, e-mail address, address, phone number, the company you work for, your job title (i.e. when such information is provided by you or shown on your business card) and a picture of you.
2.6.	When we have a business relationship with your employer, we collect: your basic identity information such as name, e-mail address, address, phone number, the company you work for, your job title and information regarding the business agreement.

3. WHY DO WE PROCESS YOUR PERSONAL DATA AND WHAT IS OUR LEGAL BASIS?

3.1.

LeadFabric may process your personal data to make it possible to respond to your complaint and/or request or to communicate with you after a fair or event.

⇒	The processing activity is necessary to pursue our legitimate interest, namely to be able to respond appropriately to you and to communicate with you.

3.2.

LeadFabric may process your personal data to perform statistical analyses so that LeadFabric may improve its website, Social Media Channels, products and services or develop new products and services.

⇒	This processing activity is necessary to pursue our legitimate interest, namely to continuously improve the LeadFabric website, the Social Media Channels, products and services.

3.3.

LeadFabric may process your personal data in order to be able to defend LeadFabric in judicial or other proceedings.

⇒	This processing activity is necessary to pursue our legitimate interest, namely to defend us in the event of a dispute.

3.4.

LeadFabric may process your personal data for the preservation of the legitimate interests of LeadFabric, its partners or a third party if the use of the website, Social Media Channels or other communication channels can be considered (a) a violation of any applicable terms of use or the intellectual property rights or any other rights of a third party, (b) a threat to the security or integrity of the website, (c) a danger to the website or any of LeadFabric’s or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.

⇒	This processing activity is necessary for to pursue our legitimate interest and the legitimate interest of third parties, namely to protect our website and Social Media Channels from misuse and illegal activities.

3.5.

LeadFabric may process your personal data to inform any third party in the context of a possible merger with, acquisition from/by or demerger by that third party, even if that third party is located outside the EU.

⇒	This processing activity is necessary to pursue our legitimate interest and the legitimate interest of third parties, namely to be able to investigate or carry out normal business or merger and acquisition transactions.

3.6.

LeadFabric may process your personal data to perform the business agreement between LeadFabric and your employer.

⇒	This processing is necessary to pursue our legitimate interest and the legitimate interest of your employer, namely to properly and efficiently perform the business agreement.

3.7.

LeadFabric may process your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities. Your personal data may be transferred upon LeadFabric’s own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through the use of the website, our Social Media Channels or other communication with us.

⇒	This processing activity is necessary to comply with our legal obligations.

3.8.

LeadFabric may process your personal data for marketing purposes i.e. to provide you with targeted communications, promotions, offerings and other advertisements of LeadFabric.

⇒	We only process your personal data for this particular processing activity if you give your consent to do so.
⇒	If you are an existing customer who has already purchased similar goods or services from us, the processing activity will not be based on consent, but on the necessity to pursue our legitimate interest and the legitimate interest of third parties, namely to enable the marketing and promotion of our products and services and the successful commercialisation thereof.

4. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

4.1.

As a general principle, we keep your personal data for as short as possible and no longer as necessary to achieve the purposes described in article 3. When your personal data are no longer necessary, they will be safely deleted.

We would like to emphasize that we provide the necessary appropriate safeguards for the security and integrity of your personal data.

5. WHO RECEIVES YOUR PERSONAL DATA?

5.1.	Except for the situation described in clause 5.2, LeadFabric does not send your personal data in an identifiable manner to any third party without your explicit consent to do so. You understand, however, that if you use our Social Media Channels, your personal data is also processed by the social media providers. You can find more information on how these social media providers process your personal data in their respective privacy policies.
5.2.	LeadFabric relies on third parties such as IT service providers and marketing service providers to provide you with the website, to allow LeadFabric to advertise and to process your personal data for LeadFabric’s benefit. These third-party processors may only process your personal data on LeadFabric's behalf on the basis of explicit written instructions from LeadFabric. LeadFabric is known to work with top notch companies. This also applies to its choice of processors. Hence, it goes without saying that LeadFabric guarantees that all external processors are selected with due care and obliges them to respect the security and integrity of your personal data. In principle, your personal data will only be processed within the European Economic Area (i.e. the European Union, Norway, Iceland and Liechtenstein).
5.3.	Should the aforementioned purposes require that your personal data is processed outside the European Economic Area, we ensure that your personal data will be protected to the fullest extent possible.

6. WHAT ARE OUR QUALITY ASSURANCES?

6.1.	Personal data are considered by LeadFabric as confidential information and are treated as such.
6.2.	LeadFabric will take appropriate technical and organisational measures to protect your personal data against the loss, alteration or unauthorised disclosure of, or access to, transmitted, stored or otherwise processed data, whether accidentally or unlawfully.
6.3.	LeadFabric will de-identify your personal data when they are no longer necessary for the purposes outlined in the purpose for processing, if appropriate.
6.4.	Access by personnel of LeadFabric or its third-party processors will only be on a need-to-know basis and subject to strict confidentiality obligations.
6.5.	You understand, however, that safety and security are best efforts obligations only, which can never be guaranteed. If a breach of security or confidentiality of your personal data occurs and this breach poses a high risk to your rights and freedoms, we will notify you of this breach as soon as possible.

7. WHAT ARE YOUR RIGHTS?

7.1.	You have the right to request access to all personal data processed by LeadFabric pertaining to you. You must always specify the processing activities in respect of which you wish to exercise your right to access. You have the right to a free copy of the personal data LeadFabric processes about you. If you request additional copies, we will charge you a reasonable fee based on our administrative costs.
7.2.	You have the right to request that any personal data pertaining to you that are inaccurate or incomplete, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.
7.3.	You have the right to request the erasure of your personal data, i.e. we are obliged to delete your personal data without unreasonable delay if you so wish, if the personal data are no longer necessary for the purposes described above, if (a) you withdraw your consent, (b) you object to the processing, (c) your personal data have been unlawfully processed or (d) the law prohibits us from deleting them.
7.4.	You have the right to request the restriction of processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate, (c) the data are no longer needed for the purposes which are outlined above, but you need them to defend yourself in judicial proceedings or (d) object the processing.
7.5.	You have the right to data portability in a structured, commonly used and machine-readable format or the transmission of those data to another controller, if the processing is based on your consent or on the performance of our contract and if the processing is carried out by automated means.
7.6.	If we process your personal data in order to protect our legitimate interest or the legitimate interest of a third party, you have the right to object to this processing.
7.7.	You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal consequences for you or similarly affects you.
7.8.	You have the right to withdraw your consent. This only applies to situations where the processing is based on your consent.
7.9.	To exercise your rights as described in this Privacy Policy, you can contact our Privacy Officer. You must submit a written request to this effect to our DPO, stating the right to which your request relates and the reasons for your request. In addition, you must add a copy of your valid identity card, on which the validity date and your signature are clearly visible, in order to prevent illegal or fraudulent requests. As soon as your request is received by our Privacy Officer, you will receive an acknowledgement of receipt. Your request will then be dealt with within a reasonable period of time. If you have any questions, you can contact our Privacy Officer. If you are still dissatisfied, you can contact the Data Protection Authority.