Legal
Terms of use and privacy policy
Data protection policy · Seen-apps SRL
This English text is provided for convenience. Only the French version of this page is legally binding.
Data protection policy
Seen-apps SRL (IT specialists and statisticians), with its registered office at Rue L. Brecht 5 4840 Welkenraedt and entered in the Belgian Crossroads Bank for Enterprises under number (BE) 0651.826.241 (hereinafter “Seen-apps”), offers its clients (hereinafter the “Client”, “you”) a web platform and “Deeptech” solutions built around emotional intelligence, to help those Clients and their organisations unlock their potential.
The data you entrust to us when you visit our website and use our solutions through our Web-App is, for the most part, personal data.
For the data you enter into the web-app while using our solutions, Seen-apps acts solely as a processor. Seen-apps does no more than make those solutions available to you and, on that basis, processes data in your name and on your behalf. The Client is then the data controller, because it determines the purposes and the means of the processing. As the GDPR requires, Seen-apps and the Client are bound by a processing agreement setting out the obligations and the rights of each party.
Seen-apps does, however, act as data controller for the personal data collected when you visit our website, contract with us for our services, and create an account to use those services.
In every case, Seen-apps cares about your privacy and about your rights in matters of personal data protection. Seen-apps processes your data in line with the applicable data protection rules, including European Regulation 2016/679 of 27 April on the protection of natural persons with regard to the processing of personal data (the “GDPR”) and the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.
Seen-apps keeps strictly to the law in this area, as in every other. Here is how:
Why do we process your data?
A. Browsing our website
You can visit our site and read about our services without giving us any personal information.
Some cookies are, however, needed for the site to work. For more on this, please see our cookie policy.
B. Communicating with you
Categories of data: Your surname, first name, email address and telephone number, together with anything else you may tell us in the course of our exchanges.
Purpose: We process this data when you contact us through the messaging form on our website, so that we can be in touch with you and answer your questions.
Legal basis: We need this data in order to answer your questions and to provide the service you have asked for. It is therefore essential to the performance of our contract. Without it, we cannot do our job.
Who receives the data: Your data may also be processed by the host of our website or by another IT provider, for the purposes strictly necessary to carry out the instructions we give them. They act as processors in this respect.
Retention period: The data is kept for 3 years after our last contact.
C. Requesting a demo
Categories of data: Your surname, first name, email address and telephone number.
Purpose: We process this data when you fill in the form under the “Demo” tab on our website to ask for more information about our services or for a quotation.
Legal basis: We need this data in order to take steps at your request before entering into a contract.
Who receives the data: Your data may also be processed by the host of our website or by another IT provider, for the purposes strictly necessary to carry out the instructions we give them. They act as processors in this respect.
Retention period: The data is kept for 3 years after our last contact.
D. Providing our services and creating an Account on our Platform
Categories of data: These may be:
- Identification data (name, email address, profile photo, sex, date of birth, age, marital status, telephone, organisation…)
- Log-in data (IP address, username, password, status and access rights…)
Purpose of the processing: Creating an account on our platform gives you access to our solutions and to the many features Seen-apps puts at your disposal.
Lastly, the data you send us is also processed so that we can answer your request and be in touch with you about it.
Legal basis: We need this data in order to provide the service you have asked for. It is therefore essential to the performance of our contract. Without it, we cannot do our job.
Who receives the data: Your data may also be processed by the host of our website or by another IT provider, for the purposes strictly necessary to carry out the instructions we give them. They act as processors in this respect.
Retention period: The data you entrust to us is kept for 10 years after the end of our contractual relationship, for tax and accounting reasons and also on grounds of liability.
As a general rule, data is kept for as long as our legal and regulatory obligations require.
E. Managing our contractual relationship
Categories of data: This may be your surname, first name, home or place of residence, telephone number, email address, organisation, billing details, and so on.
Purpose: Your contact details are used to invoice our services and to recover payment, and to tell you of any change to the Contract or to the Data Protection Policy (new purposes in particular).
Legal basis: The personal data processed is essential to the performance of the agreement and to our legal obligations. Without it, we cannot do our job.
Who receives the data: It is passed to the tax and social security authorities, to our payroll agency and to our accountant. It could also be passed to our legal adviser or to a bailiff if payment has to be recovered through the courts.
Your data may also be processed by the host of our website or by another IT provider, for the purposes strictly necessary to carry out the instructions we give them. They act as processors in this respect.
Retention period: The data you entrust to us is kept for 10 years after the end of our engagement, for tax and accounting reasons and also on grounds of liability.
F. Exercising your rights
Purposes: When you exercise the rights the GDPR gives you and which are set out in this data protection policy (right of access, to rectification, and so on), we keep the data strictly necessary to show that we did act on your request.
Legal basis: We keep this data under the legal obligation imposed by Article 5(2) of the GDPR, namely the accountability requirement.
Categories of data: Your surname, first name, the request itself, and evidence of the steps Seen-apps took in response.
Who receives the data: This data is passed to no one other than the Data Protection Authority.
Retention period: We keep your data for this purpose for as long as we could be held liable for failing to act on a request, that is to say for a maximum of 10 years.
G. Proof that your data has been erased
Purposes: When you exercise your right to erasure, we keep the data needed to show that the erasure did take place. This is done for evidential purposes only and covers no more than what is strictly necessary to prove the erasure.
Legal basis: Keeping proof of erasure follows from the legal obligation imposed by Article 5(2) of the GDPR, namely the accountability requirement. That provision constitutes a legal obligation within the meaning of Article 17 of the GDPR and can justify an exception to the complete erasure of the data. Keeping this data is also justified by our legitimate interest in being able to prove that we have met our legal obligations under the GDPR.
Categories of data: Your surname, first name, the erasure request, the date on which the erasure actually took place, and the database erasure logs.
Who receives the data: The data held in the erasure register is passed to no one other than the supervisory authority for data protection.
Retention period: We keep your data for this purpose for as long as we could be held liable for failing to act on an erasure request, that is to say for a maximum of 10 years.
H. Social media
Categories of data: This may be data linked to your account, to the content you share, or to the exchanges you have with other people.
Purposes: The data you give when visiting our social media pages is, or may be, processed jointly by the social network and the administrator of the page for the following purposes:
- collecting certain data by means of cookies;
- improving the social network’s advertising system;
- producing audience statistics for the page.
The page administrator processes this data only under its legitimate interest in obtaining statistics about visitors to its page, so that it can promote the page properly. The audience statistics produced by the social network are passed to the page administrator in anonymised form only.
Who receives the data: We may need to share it with our employees, subsidiaries, suppliers, external providers or consultants in order to fulfil this purpose.
Retention period: This data is, or may be, processed for as long as the page exists and you visit it.
Each social network’s personal data policy can be found by following these links:
- Facebook and Instagram,
- Youtube,
- LinkedIn,
I. Anonymisation for statistical and scientific research purposes
Purposes: We anonymise your data so that we can then draw statistics from it, or pass the anonymised data to third parties for use in surveys or scientific research.
Legal basis: Anonymising your data is itself a form of processing. It is carried out on the basis of your consent.
Categories of data: Your surname, first name, age, sex, home or place of residence, telephone number, email address, organisation, and so on.
Who receives the data: Your personal data is passed to no third party for as long as it can still be read in identifiable form.
It is shared only once anonymised. At that point it can no longer identify you and may be shared with third parties for statistical and scientific research purposes.
Retention period: Your personal data is deleted once Seen-apps has anonymised it. We therefore keep only the data that has become anonymous and is no longer personal data.
Changes
This policy may be corrected, added to or amended at any time and for various reasons. The most recent version is always available on our website. We encourage you to check it from time to time.
Third-party websites
Our website contains links to third-party websites and information about them. We have no control over those sites and are not responsible for their privacy policies, which we encourage you to read.
Where your data is held
As a rule, your personal data is stored solely on servers located within the European Union.
What are your rights?
Information: This right is met through the present document. If the data processed includes data about your staff, you undertake to bring this document to their attention.
Access and rectification: You have the right to access your data and to have it corrected where needed.
Objection: You can object to any processing of your data that we carry out on the basis of our legitimate interest.
Withdrawing your consent: Where data is processed on the basis of your consent, you can change your mind at any time, without calling into question the processing already carried out.
Erasure: You can have your data erased, or have the processing restricted, under the conditions set out in Articles 17 and 18 of the General Data Protection Regulation.
Data portability: The data you have provided to us can be sent to you, or passed to a third party of your choice, in electronic format.
For more on your rights: https://www.autoriteprotectiondonnees.be/citoyen/vie-privee/quels-sont-mes-droits
Who to contact
The controller of your data, Seen-apps SRL, whose registered office is at Rue L. Brecht 5 4840 Welkenraedt, and its data protection officer are at your disposal for any question and for any request concerning the rights set out above (tel. +32 4 229 20 10; email: seenapps@lexing.be).
If you would like more information, or if you wish to lodge a complaint, you can contact the Data Protection Authority (Rue de la Presse 35, 1000 Brussels, tel. +32 2 274 48 00, https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte).