Privacy Policy - 31/05/2021

Who Are We?

We are Web ex Machina, headquartered at 40 rue de Bruxelles, 69100 Villeurbanne, under the number 812 020 519 (hereinafter referred to as "Web ex Machina"). In the course of our activities, we collect, store, transfer, or otherwise process personal data. Under applicable privacy laws, we are considered a "data controller" regarding the personal data we process.

Why Is This Privacy Policy Important?

We place great importance on your right to privacy and always strive to protect your personal data in accordance with applicable data protection legislation, particularly the European General Data Protection Regulation (GDPR).

In this Privacy Policy, we explain how we collect your personal data, how and for what purposes we process this data, and to whom your personal data may be disclosed.

This Privacy Policy also contains important information about your rights regarding the processing of your personal data. We therefore advise you to read this policy carefully.

From time to time, it may be necessary to modify this Privacy Policy. In such cases, we will endeavor to notify you by email where possible. The most recent version of this Privacy Policy is always available on our website confidentialité.html.

Attention: When you share your personal data with us, we expect that you have first read this Privacy Policy carefully.

Note: This does not mean that we need your "permission" to process your personal data. We do not process your personal data based on your consent unless specifically indicated otherwise (for example, for sending a possible electronic newsletter).

Whose Personal Data Do We Collect?

In the course of our activities, we may collect personal data from our customers, visitors to our website, individuals who fill out a contact form on our website, individuals who have subscribed to an electronic newsletter, and individuals who are in contact with us in another manner (for example, by providing their names and contact details as employees or representatives of our clients, suppliers, or business partners).

How Do We Collect Your Personal Data?

We may collect information about you in several ways:

  • Directly from you when you provide us with your personal data in the course of our business activities;
  • Directly from you when you visit our website, when you fill out a contact form on our website, and/or when you subscribe to an electronic newsletter;
  • Through your employer with whom we have a contract or partnership (for example, when you are the contact person for our clients, suppliers, or business partners); and
  • From third parties and official sources.

What Personal Data Do We Collect?

We may collect the following data about you:

  • Personal identification data: name, address, phone number, mobile number, email address;
  • Electronic identification data: IP addresses, information gathered through cookies.

Whenever certain information must be mandatorily completed and other information is optional, this will be clearly indicated to you.

For What Purposes Do We Use This Data?

We use this data for the following purposes:

  • For our customer management;
  • For the management of our website;
  • To provide you with the information you have requested, for example, if you have asked a question using the contact form on our website;
  • For marketing purposes, for our paper mailings as well as for an electronic newsletter (if you are subscribed).

For complete information, below you will find the relevant legal bases for these processes:

  • We base the processing of your personal data for our customer management or to provide certain information to our customers on the necessity for the performance of a contract;
  • In all other cases, we base the processing of your personal data for the management of our website or to provide you with certain information (for example, after you have contacted us via our website or when sending paper mail) on the necessity to represent our legitimate business interests as a company (in particular the interest in being able to contact prospects and potential customers),
  • We process your personal data for the purposes of electronic direct marketing (sending our electronic newsletter) based on your opt-in consent. Only if you have clearly indicated that you wish to receive our electronic newsletter (you are entirely free to do so) will we subscribe you to this newsletter.

Please note that you have the right to withdraw your consent at any time, without charge from us and without negative consequences for you. You can do this using the opt-out option that will be offered by Web ex Machina with each mailing, by unsubscribing on the site, or by sending an email with the request to delete your data to contact@webexmachina.fr.

With Whom Do We Share Your Personal Data?

  • With our service providers ('processors'):

In the course of our activities listed above, we sometimes share your personal data with third parties, particularly service providers (for example: IT/cloud service providers or public relations/marketing providers who organize direct mail campaigns for us) who act as processors for us.

  • With our business partners:

We may also share your personal data with our business partners (so that they can contact you).

  • With your employer and your contacts in the course of your professional activities.
  • With public services:

Furthermore, we may also share your data with authorities, police services, or courts if there is a legal obligation to do so.

We always ensure that appropriate protective measures are in place when we transfer your personal data to third parties. For example, we will conclude a processing agreement, if applicable, establishing restrictions on the use of your personal data and obligations regarding the security of your personal data.

Your personal data and your profile will not be lent or sold to third parties for marketing purposes without your prior explicit consent.

Your personal data will not be transferred to countries outside the European Economic Area (EEA).

How Long Do We Keep Your Personal Data?

Your personal data will not be kept longer than necessary for the purposes for which they were collected and processed (as described above). Subsequently, they may still be found in our backups or archives, but they will no longer be actively processed in a file.

More specifically, the following retention periods apply:

Retention period for customer data: All data that is part of the contractual relationship with customers or suppliers will be kept for 10 years after the end of the contractual relationship. This period corresponds to the statute of limitations for contractual claims.

Direct marketing retention period: data will be used until:

  • The data subject unsubscribe,
  • Web ex Machina receives the message that the email address is no longer used,
  • Web ex Machina decides to no longer send mailings.

We will not retain your personal data for a longer period unless we are legally obliged to do so or if this is necessary to defend our interests in the context of legal proceedings (for example, in case of a dispute).

How Do We Protect Your Personal Data?

We take the necessary administrative, technical, and organizational measures to ensure a level of security appropriate to the specific risks we have identified.

In this way, we best protect your personal data against destruction, loss, alteration, unauthorized disclosure, or unauthorized access to personal data sent, stored, or otherwise processed.

Additionally, we always strive to ensure the accuracy and updating of your personal data. We therefore ask you to inform us of any changes to your personal data (such as a change in your contact details).

More information about our security measures is available upon request.

What Are Your Rights and How Can You Exercise Them?

You have the right (under certain conditions):

  • To information and access to your data;
  • To the correction of your personal data;
  • To the deletion of your personal data (the "right to be forgotten");
  • To the restriction of processing;
  • To object to the processing of your personal data;
  • To obtain your personal data in a structured, commonly used, and machine-readable form, and to transfer (or have transferred) this personal data to another responsible party.

For more information on these rights and the circumstances in which you can exercise them, particularly your right to object (this is your right to opt-out of our electronic newsletter), please refer to the appendix of this policy. In principle, you can exercise these rights free of charge. Only in the case of unreasonable or repeated requests may we charge reasonable administrative fees.

We will always strive to respond to your requests or questions as quickly as possible. It is also possible that we may first ask you for proof of identity to verify your request.

Finally, you also have the right to file a complaint regarding the processing of your personal data with the Belgian data protection authorities.

Contact

If you have any questions, comments, or complaints regarding this Privacy Policy or our processing of your personal data, please do not hesitate to contact us at contact@webexmachina.fr.

Appendix - Further Information Concerning Your Legal Rights

Right to Information and Access to Your Data

You can request more information from us about our processing activities and the data we hold about you.

Right to Correction of Incorrect or Incomplete Data

You can ask us to correct or complete incorrect or incomplete personal data.

Right to Deletion of Your Personal Data ("Right to Be Forgotten")

Upon written request, we will delete your personal data:

  • If they are no longer necessary for the purposes for which they were collected or processed, or
  • If the processing was based solely on your consent, which you now withdraw; or
  • If you have reasonable grounds to object to the processing of your personal data; or
  • If the personal data have been unlawfully processed; or
  • If the personal data must be erased to comply with a legal obligation.

Exceptionally, we may refuse to delete your data (i) to exercise the right to freedom of expression and information; (ii) to comply with a legal obligation; or (iii) to establish, exercise, or defend a legal claim.

Right to Restriction of Processing

You have the right to obtain restriction of processing if one of the following situations applies:

  • For a period allowing us to verify the accuracy of the personal data if they are contested; or
  • If you request it, instead of deletion of the data; or
  • If we no longer need the personal data, but you need them to establish, exercise, or defend a legal claim; or
  • If you have objected to processing based on our legitimate interests.

Right to Object to the Processing of Your Personal Data

You have the right at any time, depending on your specific situation, to object to the processing of your personal data based on our "balancing of legitimate interests." In this case, we will no longer process these data unless there are compelling legitimate grounds for processing that override or are related to the establishment, exercise, or defense of a legal claim.

When personal data are processed for direct marketing purposes (in particular for sending our electronic newsletter or personal advertising by regular mail), you have the right to object at any time or to withdraw your consent. You also have the right not to be subject to profiling for marketing purposes.

Right to Data Portability

In certain cases, you have the right to obtain your personal data in a structured, commonly used, and machine-readable form, and to transfer (or have transferred) these personal data to another responsible party. This right applies:

  • If the processing is based on the legal basis of consent or on the necessity to perform a contract, and
  • When the processing is carried out by automated means.