Politique de confidentialité
Parts and purpose
Inoopa S.A. (hereinafter "Inoopa S.A." or the "Data Controller")
Rue des Houblonnières, 52 - 4020 Liège, Belgium
BCE / VAT: BE 0649973640
Telephone: +32 478 888 888 398
I. Inoopa Business data
Inoopa focuses on understanding companies (legal and natural entities): what they do, how they behave and evolve. In its purpose, Inoopa collects data from many different sources:
- References in the Official Gazette and the Central Database for Enterprises (BCE/KBO);
- Company websites and public directories, such as the cadastre, the National Bank’s annual accounting system, the publications of the VAT institutions and the Office for Social Security;
- Open databases like Statbel, universities publications, etc;
- Other sources which are accessible to anyone, such as information made public by the company on social or other media;
- Private partners offering analysis on companies financial’s, size, activities and any other insights of added value in Inoopa’s purpose;
- Foreign equivalents of the sources here above.
Based on its sources, Inoopa develops its own AI technologies and products that are marketed. Those are containing different categories of data:
- Legal data: registration number, legal names, professional addresses, financials, employment, etc.
- Activity data: sectoral codes, company descriptions, semantic content about activities, keywords, websites, etc.
- Contact data: company best phone, company role-based email (info@...)
Inoopa’s intelligence aims at understanding companies, that is why every data and insight marketed by Inoopa is always linked to a legal registration number.
II. Individual data
For all its purposes, Inoopa delivers only business-related data, where GDPR does not apply.
However, we are well aware that business and individuals data sometimes interferes with each other, and so the need to anticipate mitigation processes in order to respect individual’s privacy and regulations while treating data.
- Company phones
In order to best serve our customers and avoid individuals to receive undesired calls related to their business, we have developed our own algorithm to define a “Company Best Phone”. Using our different sources of data and cross-checking with public active sources, we keep track of the most reliable business phone linked to the company. Our phones are, once again, linked to the company number and not to any individual. Next to that, our phones are synchronized with DoNotCallMe list on a daily basis.
- Company emails
Inoopa only holds and markets so-called role-based emails. Those are emails like info@, marketing@, contact@, etc. They are all matched with company numbers and cannot be linked to an individual.
- Business partners
Inoopa works with different business partners to enrich its own technologies and insights. Inoopa pays scrupulous attention to their sources, processes and any data that would fall under GDPR. We ask them to be as transparent as possible and refer to their privacy publications for more information.
III. Treatment and deletion of personal data in Inoopa’s technologies
While not sharing personal data with its customers and partners, Inoopa algorithms treat semantic & public data, such as the content of a website, where personal data may be present (eg. a non role-based email of a contact person). Doing so, Inoopa must ensure that data processed is compliant with GDPR regulation.
The purpose of gathering public data such as the semantic content of a website is the development of its services and technologies, and is considered as a legitimate interest for Inoopa.
However, Inoopa ensures adequate technical and organisational measures are in place to delete all personal data from its database as soon as treated, such as the recognition of an email that would not be role-based.
Inoopa works with a quality management system that guarantees a consistent service level which meets the customer’s as well as any legislative and regulatory requirements.
IV. Personal data on Inoopa website
V. Data Protection Officer
Inoopa is the controller for the processing of personal data as described above, and is supported by an external DPO.
The Data Protection Officer (hereinafter: ‘DPO’), within Inoopa is Xavier De Cock. The DPO is tasked with enforcing compliance with data protection legislation and regulations. If you want to contact the DPO, you can send an e-mail to: email@example.com.
VI. More information
For more information, please contact us via email at: firstname.lastname@example.org.
This document was last updated on April 2nd, 2021.
Annex - Use of personal data on the website
- 1. Processing of personal data
The use of the Site by Users may result in the disclosure of personal data. The processing of this data by Inoopa S.A., in its capacity as Data Controller, or by service providers acting in the name and on behalf of Inoopa S.A., will comply with the Law and Regulation.
Personal data will be processed by Inoopa S.A., in accordance with the purposes mentioned below, via:
- The registration procedure for the contact form
- Purpose of the processing of personal data
In accordance with Article 13 of the Regulation, the purposes of the processing of personal data are communicated to the User and are as follows:
- Ensure the execution of the services offered and agreed upon on the site
- Answer user questions
- Personal data likely to be processed
Users' information by filling in the contact form : Name, email, phone, company name.
The User has the right to withdraw his consent at any time. The withdrawal of consent shall not affect the lawfulness of the processing operation based on prior consent given.
- Storage periods for Users' personal data
In accordance with Article 13 §2 of the Regulation and the Law, the Data Controller shall keep personal data only for a reasonable period of time to enable the purposes, for which they are processed, to be fulfilled.
This duration is in the cases less than : 2 years.
- Receiver of data and disclosure to third parties
Personal data may be transmitted to presuppositions, employees, subcontractors or suppliers of Inoopa S.A. who offer adequate data security guarantees, and who collaborate with Inoopa S.A. in the context of the marketing of products or the provision of services. They act under the direct authority of Inoopa S.A., and are responsible in particular for collecting, processing or subcontracting this data.
In the event that the data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed in advance so that he/she can express his/her consent to the use of this personal data.
- Users' rights
At any time, the User may exercise his rights by sending a message by e-mail to the following address: email@example.com or a letter by post addressed to him, attaching a copy of his identity card to the following address: Rue des Houblonnière, 52 - 4020 Liège, Belgium.
- Right of access
In accordance with Article 15 of the Regulation, Inoopa S.A. guarantees the User's right of access to his personal data. The User has the right to obtain access to the said personal data as well as the following information:
- the purposes of the processing operation;
- the categories of personal data concerned;
- the receiver or categories of receivers to whom the personal data have been or will be disclosed, in particular receivers established in third countries or international organisations;
- when possible, the proposed storage period for personal data or, when this is not possible, the criteria used to determine this period;
- the existence of automated decision-making, including profiling, as referred to in Article 22 §1 and §4 of the Regulation, and, at least in such cases, relevant information concerning the underlying logic, as well as the importance and expected consequences of such processing for the data subject.
The Data Controller may require the payment of a reasonable fee based on administrative costs for any additional copies requested by the User.
When the User submits this request by electronic means (e. g. via the e-mail address), the information is provided in an electronic form in common use, unless the User requests otherwise.
The copy of his data will be communicated to the User at the latest within one month after receipt of the request.
- Right of rectification
Inoopa S.A. guarantees the right to rectify and delete personal data to the user.
In accordance with Article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User first makes the necessary changes himself from his user/other account, unless they cannot be made independently, in which case the request can be made to Inoopa S.A.
In accordance with Article 19 of the Regulation, the controller shall notify each receiver to whom the personal data have been disclosed of any rectification of the personal data, unless such rectification proves impossible or requires disproportionate efforts. The controller shall provide the data subject with information on these receivers if the data subject so requests.
- Right to erase
The User has the right to obtain the deletion of his personal data as soon as possible in the cases listed in Article 17 of the Regulation.
Where the Data Controller has made the personal data public and is required to erase them pursuant to the preceding paragraph, the Data Controller, taking into account the available technologies and the costs of implementation, shall take reasonable measures, including technical measures, to inform other controllers who process such personal data that the data subject has requested the erasure by such controllers of any link to such personal data, or of any copy or reproduction of them.
The two preceding paragraphs shall not be applied to the extent that such processing is necessary:
- the exercise of the right of freedom of speech and information;
- to comply with a legal obligation requiring processing under Union law or the law of the Member State to which the controller is subject, or to carry out a task in the public interest or in the exercise of official authority vested in the controller;
- the establishment, exercise or defence of legal claims.
In accordance with Article 19 of the Regulation, the controller shall notify each receiver to whom the personal data have been disclosed of any deletion of personal data or any limitation of the processing carried out, unless such disclosure proves impossible or requires disproportionate effort. The controller shall provide the data subject with information on these receivers if the data subject so requests.
- Right to limit processing
The User has the right to obtain a limitation of the processing of his personal data in the cases listed in Article 19 of the Regulation.
In accordance with Article 19 of the Regulation, the controller shall notify each receiver to whom the personal data have been disclosed of any limitation on the processing carried out, unless such disclosure proves impossible or requires disproportionate effort. The controller shall provide the data subject with information on these receivers if the data subject so requests.
- Data portability right
In accordance with Article 20 of the Regulation, Users have the right to receive from Inoopa S.A. personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transmit this data to another controller without Inoopa S.A. hindering it in the cases provided for in the Regulation.
When the User exercises his right to data portability pursuant to the preceding paragraph, he has the right to have personal data transmitted directly from one controller to another, where this is technically possible.
The exercise of the right of data portability is without prejudice to the right to erase. This right shall not apply to processing necessary for the performance of a task in the public interest or in the exercise of official authority vested in the Data controller.
The right of data portability does not affect the rights and freedoms of third parties.
- Right of opposition and automated individual decision-making
The User has the right at any time to object to the processing of his or her personal data on the grounds of his or her particular situation, including the automation of data by Inoopa S.A. In accordance with Article 21 of the Regulation, Inoopa S.A. will no longer process personal data, unless there are legitimate and compelling reasons for the processing that prevail over the interests and rights and freedoms of the User, or for the establishment, exercise or defence of legal rights.
When personal data are processed for prospecting purposes, the User has the right to object at any time to the processing of personal data concerning him/her for such prospecting purposes, including profiling insofar as it is related to such prospecting.
Where the data subject objects to the processing for the purpose of canvassing, personal data shall no longer be processed for that purpose.
- Right of complaint
The User has the right to file a complaint concerning the processing of his personal data by Inoopa S.A. with the Data Protection Authority, competent for the Belgian territory. Further information can be found on the website: https://www.autoriteprotectiondonnees.be
Complaints can be submitted to the following addresses:
Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Phone + 32 2 2 274 48 00
Fax + 32 2 2 274 48 35
The User may also file a complaint with the court of first instance of his domicile.
- Limitation of the controller's liability
The website may contain links to other websites owned by third parties not linked to Inoopa S.A. The content of these websites and their compliance with the Law and Regulations are not the responsibility of Inoopa S.A.
The holder of parental authority must give his or her express consent for the minor under 16 years of age to disclose personal information or data on the website. Inoopa S.A. strongly advises persons exercising parental authority over minors to promote responsible and safe use of the Internet. The Data Controller may not be held liable for having collected and processed personal information and data from minors under 16 years of age whose consent is not effectively covered by that of their legal parents or for incorrect data - in particular concerning age - entered by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he/she is under 16 years of age.
Inoopa S.A. is not responsible for the loss, corruption or theft of personal data caused in particular by the presence of viruses or as a result of computer attacks.