Privacy statement

PAWESOME BV (hereafter referred to as: “Smoofl”) believes privacy and data protection are very important. With this privacy statement (hereafter referred to as “Privacy Statement”), Smoofl wants to inform you about how they process personal data. Smoofl will process your personal data with respect for your privacy and in compliance with the applicable data protection regulations.

We reserve the right to make changes to this Privacy Statement at any time. To remain informed of any changes, please consult this Privacy Statement regularly.

This Privacy Statement was last modified on: 13/11/2023.

Definitions

Processing of personal data: Processing is an operation or a set of operations related to personal data or a set of personal data, whether or not it is performed by means of automated procedures, such as the collecting, recording, classifying, structuring, storing, updating or modifying, retrieving, consulting, using, forwarding, distributing or otherwise making available, aligning or combining, shielding, deleting or destroying of the data. Personal data is all information about a natural person which can be used to directly or indirectly identity this person.

A processor: A processor is a natural person or legal entity, a governmental agency, a service or another institution that processes personal data on behalf of the Processing Controller.

A Processing Controller: A Processing Controller is a natural person or legal entity, a governmental agency, a service or another institution that determines, alone or in conjunction with others, the purpose and means of processing of personal data.

Who is covered by this privacy policy?

This Privacy Statement applies to all direct customers, visitors, suppliers, job applicants and all other persons who are not employees of Smoofl and whose personal data are processed by Smoofl in their function as a Processing Controller. Throughout the remainder of this Privacy Statement, we refer to an individual belonging to one of these groups as a “Concerned Party”.

Contact information

Name: PAWESOME BV
Company number: 0654 916 185
Address: 109 Boulevard Leopold II, 1080 Brussels Belgium
E-mail: hello@smoofl.com

Processing Controller

Only when Smoofl acts in the capacity of a Processing Controller are points 5 through 10 of this Privacy Statement applicable.

If you wish to exercise your rights as a Concerned Party, then you must contact the Processing Controller.

Which personal data does Smoofl process?

Based on the implementation of an agreement

Smoofl processes personal data, which is necessary for the implementation of an agreement in which you are a Concerned Party or in order to take measures at your request before the conclusion of an agreement.

When requesting a quotation
If you would like more information about the services or products offered by Smoofl, you may request a quotation via various channels (telephone, website, social media…). Smoofl processes personal identification information (such as your name and e-mail address) in order to generate as correct a quotation as possible.
When processing an order or following up on invoices and commercial agreements
When you order or deliver products or services from or to Smoofl, Smoofl processes personal identification data and professional data in order to correctly handle and follow-up on the order or delivery.
When applying for a job
Smoofl regularly looks for new enthusiastic and motivated employees. During the application process, Smoofl processes the following categories of personal data: personal identification data, personal characteristics (such as language, date of birth…), competencies, educational/training history, career history, curriculum vitae, images and work references.
When participating in an event
Smoofl organises events. When organising an event, we process personal identification data and professional data at the time of registration.

Based on your consent

When processing personal data based on your consent, you retain the right to withdraw this consent (see Section 10: What are your rights and how can you exercise them?) at any time.

When you subscribe to our newsletter
When you subscribe to our newsletter, you give us permission to send you a newsletter. Smoofl provides you the opportunity to unsubscribe from the newsletter.
When completing a customer satisfaction survey
Smoofl asks for permission to link personal data (identification data and professional data) with the results of a customer satisfaction survey. We use this information solely to improve our services. Smoofl will not use the data for any other purpose nor will it pass it on to third parties for their own use.
When creating a recruitment reserve
If Smoofl does not hire you after you apply for a job but would like to keep your CV on file for future opportunities, Smoofl will ask your permission to retain your CV.
When using targeted photos for the purposes of publicity
When publishing targeted images on social media and on the website, Smoofl will ask for your permission. Targeted images, in this case, refer to images in which the person is clearly recognizable (close-up, image focused on a particular person, posed photo…).

Based on legitimate interests

Smoofl processes personal data based on a legitimate interest over which Smoofl has weighed these interests.

When registering visitors to our offices
For security reasons, Smoofl would like to know who is present in our offices at all times. The employee with whom the visitor has an appointment will be informed of the visitor’s arrival. In these cases, Smoofl processes the following personal data: personal identification data (such as name, e-mail address and telephone number) and professional data (e.g. company you work for).
When handling a question, providing assistance or offering information upon your request
You can contact Smoofl via various channels (by telephone, correspondence, e-mail, contact form on website or social media). We use the personal data you provide solely to answer your questions.
When sending direct marketing
Smoofl sends direct marketing materials and, in doing so, processes personal identification data. Smoofl respects the accompanying regulations, which state that direct marketing materials that relate to products or services similar to those provided by Smoofl itself are sent only if a customer relationship already exists. You, as a Concerned Party, always have the option of unsubscribing.
When inviting a customer to participate in a customer satisfaction survey
Smoofl invites customers to participate in customer satisfaction surveys.
When retaining the contact details of acquaintances/family members of our employees for use in cases of emergency
We ask our employees to provide the contact details of an acquaintance and/or family member so that we can notify them in case of emergency.
When using images for public relations and/or journalistic purposes
When Smoofl organises a large company event, Smoofl has a legitimate interest in implementing public relations activities in order to attract new employees and/or new customers. The visitors at the event are informed in advance and have the opportunity to object to the taking of their photo. This objection can be lodged at the event itself to the photographer or after the event by sending an e-mail to hello@smoofl.com.
When improving the quality of the website
Smoofl uses tools to collect statistics about and gain insights into the use of the website. This information is anonymized and is not linked to your personal information. Analytical tools require cookies. These are text files that are placed on your computer and that collect standard internet logging and behaviour information. Please see our Cookie Statement for more information.

Compatible purpose

If we collected your personal data for a legitimate interest or in function of an agreement, then we may also use this information in the future for another purpose that is compatible with the original purpose. When doing so, we consider the following points:

the relationship between the original purpose and the new/future purpose;
the context in which the data is collected (what is the relationship between you and Smoofl?);
the type and nature of the data (is it sensitive data?);
the possible consequences of the intended further processing (what are the consequences for the Concerned Party?);
the existence of appropriate safeguards (such as encryption or pseudonymisation).

With whom do we share your personal data?

Smoofl does not share your personal data with third parties, unless:

Smoofl has received your prior consent to do so;
Smoofl is obliged to do so in the context of a regulation or legal procedure;
Smoofl is requested to do so by legislative or judicial authorities;
Smoofl organises an event together with partners or suppliers. The list of participants is then also shared with the partners or suppliers;
Smoofl is wholly or partially acquired or split up. In that case, Smoofl will impose the third party’s obligation to process the personal data in accordance with the provisions of this Privacy Statement.

Smoofl relies on certain subcontractors, such as consultants, research agencies (e.g. for implementing satisfaction surveys) and tools (e.g. CRM systems, mailing tools), for the purposes of outsourcing part of our services to them. These subcontractors are not considered third parties; they are considered processors. We ensure that these subcontractors take the necessary technical and organizational measures to process your personal data legally and lawfully and to, under no circumstances, disclose it to third parties.

Security of your personal data

Smoofl acknowledges that the security of personal data is part of data protection. Therefore, Smoofl takes appropriate technical and organizational measures to protect your personal data from unauthorized processing or access in order to prevent misuse.

In case of any transfer of personal data to a processor outside the European Economic Area (EEA), Smoofl will always do so in accordance with the terms of this Privacy Statement, and Smoofl will also adhere to the applicable data protection laws and regulations to ensure adequate safeguards.

Retention of your personal data

Smoofl will only retain your personal data for the minimum period necessary to fulfill the objectives set out in this Privacy Statement, unless (i) a longer retention period is required for resolving disputes or (ii) a longer retention period is required by law. Non-personal information may be stored without time limitations in function of statistical purposes.

Cookies

Cookies are text files that are placed on your computer to collect standard internet logging information and behaviour information. This information is used to track the behaviour of website visitors and to compile statistical reports on the website.

For more information about our cookie policy, visit https://smoofl.com/cookie-policy/.

What are your rights and how can you exercise them?

What are your rights?

Right of access
You may ask us which of your personal data we process, why we process it, which categories of personal data we process, with which categories of third parties we share your personal data, what the origins are of the processed data and – when applicable – what the logic is that we apply to the automatic processing of personal data.
Right to rectification
If information is not correct, you may ask us to correct it.
Right to delete your data
If data is not lawfully processed or if your data is no longer necessary for the purpose for which it was collected, you may ask us to delete your data.
Right to limit data processing
By limiting the processing of your personal data, your personal data can still be kept but its use will be limited. When you have requested a processing limitation, we may only store your data. This means that your data can no longer be used to carry out other operations.
Right of objection
You have the right to object to the fact that your data will be processed if that processing is based on a general interest or on a legitimate interest of the entity processing your data. In addition, you may also assert this right of objection if your personal data is processed for direct marketing purposes. This right of objection also applies to profiling which forms the basis for processing for direct marketing purposes.
Right to withdraw consent
If the processing of your personal data is based on consent, you have the right to withdraw this consent at any time.
Right to transferability of the data
You have the right to obtain the personal data provided by you in a commonly accepted, structured and machine-readable form, and you have the right to transfer this personal data to another Processing Controller if the processing is based on legal consent or a contractual relationship.

The aforementioned rights are only a summary and remain subject at all times to the limitations of applicable data protection laws.

How can you exercise your rights?

You can exercise your rights by sending an email to hello@smoofl.com. To prevent any unauthorized disclosure of your personal data, Smoofl may request additional information to verify your identity.

Smoofl has one month to answer your request. This period begins once Smoofl receives your request and has collected all the information needed to fulfil your request. This one-month period may be extended after this is communicated and explained by Smoofl.

Smoofl will provide the requested information free of charge. If requests are unfounded or excessive, due, in particular, to their repetitive nature, Smoofl may charge reasonable compensation for the request or refuse the request.

If for some reason you believe that Smoofl did not process your request correctly, you may contact Smoofl again and we will work together with you to find a solution.

For the sake of completeness, we want to inform you that if Smoofl does not respond to your request, refuses your request or if our response does not meet your expectations, you always have the right to lodge a complaint with the Data Protection Authority, Drukstraat 35, 1000 Brussels, Tel +32 (0)2 274 48 00, or via the e-mail address contact@apd-gba.be.

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