This version is in effect since November 11th, 2019
Article 1 – General
1.1. Convexable - Nakama HR BVBA, a private limited liability company incorporated under Belgian law “Nakama”, with registered offices at 1930 Zaventem (Belgium), Da Vincilaan 1, registered with the Crossroads Bank for Enterprises under company number 0723.614.753, takes responsibility for the processing of your personal data as a "data controller".
1.2. Nakama’s policy for the protection of your personal data is strictly compliant with the laws applicable in Belgium and the European Union:
Article 2 – Personal Data Nakama Collects
2.1 Nakama does not collect sensitive information (e.g., data relating to race or ethnic origin, religious beliefs, criminal record, physical or mental health, or sexual orientation) from Visitors of the Website. Nakama shall, where necessary, obtain your explicit consent to collect and use such information.
2.2 Our Website collects only personally identifiable information that is specifically and voluntarily provided by you. Such information may consist of:
2.3 Nakama can obtain personal data through different means:
2.4 You are not obliged to provide us with your personal data, however you must understand that the delivery of several Nakama Services is not possible in case you refuse to provide us with certain personal data.
Article 3 – To which ends will my personal data be used?
3.1 General Purpose
Nakama collects and processes your personal information for one overarching goal, i.e. to offer you a safe, comfortable and personalized experience each time you visit the Website.
The information we collect about you is primarily processed to help us ensure the proper technical functioning of our Website, if not for other system administration purposes, and to improve the quality and content of our Website – all based on the “legitimate interest” of Nakama to maintain and enhance her service.
That said, your personal data will only be processed for the following (internal) purposes:
3.2 Direct marketing
At all times, you are free to change your mind at any time, and we don’t expect you to give any motivation thereto. You can do this by clicking the unsubscribe button below every promotional e-mail or any form of direct marketing.
3.3. Transfer to third parties
In order to process your personal data, we provide access to our employees. Nakama will not disclose your personal data to third parties, unless it is necessary in the context of providing our services and/or optimising them. To that end, Nakama will appeal to third parties in order to:
These third parties will be obliged to only use your personal data if they can guarantee conformance with terms that are alike to those as set out this Policy. Consequently, Nakama won’t sell, hire out or pass on your personal data to third parties, except in the situations provided for in this policy or unless you explicitly and preliminary consent. It is however possible that Nakama will disclose your personal data:
Nakama will, if reasonably possible, try to inform you in advance of such transfers, unless revealing this information is subject to legal constraints. Additionally, you must be aware that informing you beforehand is not always possible technically, nor commercially.
Article 4 – How long will we hold your data?
Nakama only processes your personal information for as long as necessary. This means that we do keep a record of your data for as long as this is required or justified by the law or by another legal obligation, or for the period for which this would be necessary for the aforementioned purposes.
Article 5 – Your rights as a data subject
5.1. Right of access and right to obtain a copy
You have the right to freely obtain at any moment access to your personal data, as well as to be informed about the purpose of the processing by Nakama.
5.2. Right to rectification, erasure or restriction
You have the choice to share your personal data with Nakama. You also have the right to request Nakama to rectify or have your personal data erased. You can also request the processing of your personal data to be restricted. You acknowledge that when you refuse to share data, or when you demand us to erase your personal information data, this will prevent us from providing you with several Nakama services.
5.3. Right to object:
You have the right to object to the processing of your personal data when you have serious and legitimate reasons to do so.
You also have the right to object to the use of your personal data for purposes of direct marketing. In such case specific reasoning will not be requested.
5.4. Right to data portability:
You have the right to obtain your personal data which is processed by Nakama in a structured, commonly used and machine-readable format and/or to transfer this data to another data controller.
5.5. Right to withdraw consent:
When the processing is based on prior consent you have the right to withdraw this consent.
5.6. Automated decisions and profiling:
The processing of your personal data does not include profiling, nor shall you be subjected to automated decisions.
5.7. Exercising your rights:
You can exercise the above mentioned rights by sending an e-mail - enclosing a copy of your identity card - to firstname.lastname@example.org.
5.8. Right to file a complaint:
If you have any complaints about the way Nakama collects, uses and/or processes your personal data, you have the right to file a complaint with the Belgian Privacy commission:
Commission for protection of personal life, Drukpersstraat 35, 1000 Brussels, Tel +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35, e-mail:email@example.com.
This does not affect a procedure before the civil court. If you have suffered damages caused by the processing of your personal data, you can file a claim for damages.
Article 6 – Safety and Confidentiality
6.1 Nakama undertakes all reasonable efforts to prevent (i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data, by using physical, administrative and technological measures to protect the information maintained.
6.2 Unfortunately, no one – including Nakama – can guarantee 100% security when it comes to transmission or forwarding over the internet, or any method of electronic storage. In case of particular security concerns about certain personal information, it is up to you to decide not to transmit that information over the Internet.
6.3 Nevertheless, you are responsible for the provision of personal data to Nakama and can exercise a degree of control thereto. If certain information is incomplete or seemingly incorrect, Nakama reserves the right to, temporarily or permanently, postpone certain actions or other services.
Article 7 – Cookies
7.1 What is a cookie?
A “cookie” is a small text file that is sent from the server of Nakama and is stored on your computer’s hard drive. This way we can remember your preferences when visiting our Website. The information stored through these cookies can only be read by Nakama and only for the duration of your visit to the Website.
As a result of recent amendments of the law, all websites focusing on certain parts of the European Union are obligated to ask for your permission in order to use or save cookies and similar technologies on your computer or mobile devices. This policy clearly and completely informs you about the cookies we use and their purpose.
7.3 Kind of cookies
Cookies can be subdivided based on their offspring, function and durability. Our Website only uses the following cookies:
• Strictly necessary cookies: As the name suggests these cookies are strictly necessary to enable you to move around the Website or to provide certain features that you have requested.
• Functionality cookies: These cookies enhance the functionality of the Website by storing the Visitor’s preferences.
• Tracking cookies: These cookies will outlast user sessions. If a persistent cookie has its max-age set to 1 year, then, within that year, the initial value set in that cookie will be sent back to the server every time you visit the server. This is used to record a vital piece of information such as how a Visitor initially came to this Website. For this reason, they are also called tracking cookies. For example, once you have selected your preferred language, our Website will record this preference in a persistent cookie set on your browser. When you revisit the Website, it will use that persistent cookie to ensure that the content is delivered in your preferred language.
• Third party cookies: For cookies set by third parties (Google Analytics, Linkedin, Facebook, HubSpot) we kindly refer you to the statements set forth by these parties on their respective websites.
7.4. Your permission
When you first visit our Website, you express your implicit approval to accept our different kinds of cookies.
You can block Cookies by activating your browser settings which allows you to refuse the cookies. The rejection of these cookies may have the effect of not allowing you to use some functionalities on the Website.
More information on cookies can also be found via the following link: http://www.allaboutcookies.org information on online behavioural advertising and online privacy can be found via the following link: http://www.youronlinechoices.eu
8 – Applicable Law and Jurisdiction