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Privacy statement

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This privacy policy (“Privacy Policy”) is applicable to all processing activities of KADONATION (as defined below) as a data controller.

Please read this Privacy Policy together with our Cookie Policy. KADONATION may update this Privacy Policy in the future: the latest version can always be found on our Website.

1. ABOUT THIS PRIVACY POLICY
Due to, for example, your commercial rela­tion­ship or recent contact with KADONATION or due to a visit to or action on our ​“Website” (i.e. https://​kadonation​.com/, including related sub-domains) we may collect, store and otherwise process personal data relating to you or, if you are a company, your employees/​rep­re­sen­ta­tives (“your personal data”).

This Privacy Policy describes (i) how we collect, treat and store your personal data; (ii) the rights you can exercise in relation to your personal data; and (iii) the measures we take to protect it and to secure your personal data.

KADONATION respects your privacy and we always strive to act in accordance with the applicable privacy leg­is­la­tion, such as (non-exhaustive): (i) the General Data Protection Regulation 2016/679 of April 27, 2016 (“GDPR”); (ii) the Belgian Privacy Law of 30 July 2018; (iii) the Dutch General Data Protection Regulation Imple­men­ta­tion Act of 16 May 2018; (iv) the ePrivacy Directive 2002/58/EC of 12 July 2002, including future amendments and revisions thereof; and/​or (v) (future) national leg­is­la­tion regarding the imple­men­ta­tion of the GDPR (together: ​“Privacy Leg­is­la­tion”).

2. KADONATION IS THE DATA CONTROLLER
We are KADONATION NV, a limited liability company with registered office at Gor­dunakaai 61, 9000 Ghent, Belgium, registered with the Crossroads Database for Enter­pris­es under number BE0666.820.362 (“KADONATION” or ​“we / us”).

KADONATION is the developer and provider of the KADONATION solution as described and rep­re­sent­ed on the Website (“Solution”), the cor­re­spond­ing service of KADONATION (“Service”) and is the owner of the Website.

In light of the Privacy Leg­is­la­tion, KADONATION will act as the DATA CONTROLLER of your personal data for the purposes described in this Privacy Policy. This means we are in control of (and thus, respon­si­ble for) your personal data.

3. KADONATION’S PROCESSING ACTIVITIES

Which personal data we collect, store and process and the purpose for which we process this data may differ depending on your relation with KADONATION.

In particular, we identify six different scenarios:

  1. You are browsing on our Website;
  2. You (wish to) receive direct marketing (such as updates and newslet­ters) relating to KADONATION’s Solution and/​or Service;
  3. You are a prospect and/​or seeking a commercial rela­tion­ship with KADONATION;
  4. You are a private customer purchasing, redeeming or starting a group gift voucher;
  5. Your company is an active KADONATION customer and/​or seeking a commercial rela­tion­ship with KADONATION; or,
  6. You are | your company is a partner or a supplier of KADONATION.

3.1 You are browsing our website

Contacting KADONATION via the contact form:

Purpose:

To answer any questions you may have and/​or to initiate a con­ver­sa­tion
Personal data:

❑ Full name

❑ Country

❑ (work) email address

❑ Vol­un­tar­i­ly provided telephone number 

❑ Vol­un­tar­i­ly provided message

Legal ground:consent

Retention period:

Up until one (1) year after your last contact with KADONATION


Cookies
When browsing on our Website, we may also collect your personal data through cookies stored on your device(s) in order to optimize the func­tion­ing of the Website. Please consult our Cookie Policy for more infor­ma­tion.

3.2 You (wish to) receive direct marketing (such as updates and newslet­ters) relating to KADONATION’s Solution and/​or Services

Direct marketing:

Purpose:Providing more infor­ma­tion on (new features of) KADONATION, our Solution or related products/​Services
Personal data:❑ Full name
❑ (work) email address
❑ Vol­un­tar­i­ly provided infor­ma­tion
Legal ground:

Consent

Retention period:Until you have objected to the processing of your personal data for this purpose (cfr. Section 8- ​“Right to object”). You will be auto­mat­i­cal­ly unsub­scribed if we did not contact you for over five (5) years.

3.3 You are a prospect and/​or seeking a commercial rela­tion­ship with KADONATION

General com­mu­ni­ca­tion with KADONATION & prospect­ing by KADONATION:

Purpose:To have quality con­ver­sa­tions (via mail, telephone or business social media channels) in which KADONATION provides more infor­ma­tion on its Services
Personal data:❑ First name
❑ (Work) email address
❑ Last name
❑ Phone number
❑ Company name
❑ Country
❑ Type of industry
❑ Preferred Language
❑ Social media / business channel
❑ Vol­un­tar­i­ly provided infor­ma­tion
Legal ground:Legitimate interest
Retention period:Until you have requested to no longer be contacted by KADONATION or until six (6) months following your latest contact with KADONATION, whichever comes first ( + ver­i­fi­ca­tion period of six months)

3.4 3.4 You are a private customer

General com­mu­ni­ca­tion and (technical) support via the support chat:

Purpose:To assist you with possible issues and/​or answer any questions you may have and/​or to initiate a con­ver­sa­tion
Personal data:❑ Full name
❑ Vol­un­tar­i­ly provided infor­ma­tion
❑ (Work) email address
❑ Infor­ma­tion about the enquiry
Legal ground:Necessary for the per­for­mance of the agreement
Retention period:Up until two (2) years after your last contact with KADONATION

Creating of your account:

Purpose:To make use of KADONATION Services or its Solution
Personal data:❑ Full name
❑ (Work) email address
❑ Country
❑ Password
❑ Date of birth
❑ Telephone number (optional)
Legal ground:Necessary for the per­for­mance of the agreement
Retention period:Until two (2) years following the ter­mi­na­tion of the commercial rela­tion­ship between you and KADONATION ( + ver­i­fi­ca­tion period of six months)

Starting a group gift/​giving a gift voucher:

Purpose:To make use of KADONATION Services or its Platform
Personal data:❑ Full name
❑ Other vol­un­tar­i­ly provided infor­ma­tion
❑ Email address
❑ Photo of your choice (optional)
❑ Name receiver (optional)
Legal ground:Necessary for the per­for­mance of the agreement
Retention period:Until two (2) years following the ter­mi­na­tion of the commercial rela­tion­ship between you and KADONATION

3.5 Your company/​employer is an active KADONATION customer

If you read this Policy as an employee of a company relying on the KADONATION Solution, please note that your employer is to be considered your data controller (as your employer decided to rely on the Solution, choses if you get an account, etc.). Your employer might have provided us with some of your personal infor­ma­tion (e.g. your name, your email-address, etc.). In this context, KADONATION has adopted a Data Processing Policy.

Nev­er­the­less, in some excep­tion­al cases, KADONATION will act as your data controller. More specific, KADONATION will act as your data controller for the following purposes:

General com­mu­ni­ca­tion and (technical) support

Purpose:To enable com­mu­ni­ca­tion with & to provide support to customers
Personal data:❑ Full name
❑ (Work) e‑mail address
❑ Company infor­ma­tion (name, VAT-number)
❑ Telephone Number
❑ Billing address
Legal ground:In relation with the customer: necessary for the per­for­mance of the agreement

In relation with the end-users: legitimate interest
Retention period:Until one (1) year following the ter­mi­na­tion of the commercial rela­tion­ship between your company and KADONATION

Small business orders (<500 vouchers) placed via the Website

Purpose:To make use of KADONATION Services or its Platform
Personal data:❑ Full name
❑ (Work) e‑mail address
❑ Company (name, VAT-number)
❑ Telephone Number (optional)
❑ Billing address
❑ Delivery address (only in case of physical gift vouchers)
Legal ground:Necessary for the per­for­mance of the agreement
Retention period:Until one (1) year following the ter­mi­na­tion of the commercial rela­tion­ship between your company and KADONATION


Billing

Purpose:To prepare invoices for the Service | use of the KADONATION Platform
Personal data:❑ First name
❑ Company
❑ Last name
❑ (Work) e‑mail address
❑ Address
❑ VAT-number
❑ Job function
Legal ground:Necessary for the per­for­mance of the agreement
Retention period:Until two (2) years following the ter­mi­na­tion of the commercial rela­tion­ship between your company and KADONATION with an additional period of 7 years for book­keep­ing reasons.


Quotes/​proposals

Purpose:To draw up (additional) quotes | proposals
Personal data:❑ First name
❑ Company
❑ Last name
❑ (Work) e‑mail address
❑ Address
❑ VAT-number
Legal ground:Legitimate interest
Retention period:Until one (1) year following the ter­mi­na­tion of the commercial rela­tion­ship between your company and KADONATION

3.6 3.6 You are or your company/​employer is a supplier or partner of KADONATION

General com­mu­ni­ca­tion and provision of services:

Purpose:To com­mu­ni­cate with you in the scope of our commercial rela­tion­ship
Personal data:❑ Full name
❑ Email address
❑ Last name
❑ Phone number
❑ Company
❑ Preferred Language
❑ Job function
❑ Vol­un­tar­i­ly provided infor­ma­tion
Legal ground:Necessary for the per­for­mance of the agreement
Retention period:For the duration of your commercial rela­tion­ship with KADONATION and in any event accordance with any (data processing) agreements concluded with KADONATION

Billing:

Purpose:To pay your invoices for the services provided (incl. cor­re­spond­ing com­mu­ni­ca­tion)
Personal data:❑ First name
❑ Company
❑ Last name
❑ (Work) e‑mail address
❑ Address
❑ Financial data (e.g. bank account number)
❑ Job title
❑ VAT-number
Legal ground:Necessary for the per­for­mance of the agreement
Retention period:For the duration of your commercial rela­tion­ship with KADONATION and in any event accordance with any (data processing) agreements concluded with KADONATION

4. LEGAL GROUNDS

You can find more infor­ma­tion on the applicable ground for each of the identified processing activities in Section 3 above.

In case the legal ground for processing happens to be legitimate interest, KADONATION shall always (i) assess whether this is in proportion with the purpose for which your personal data was collected and used; and, (ii) take your reasonable expec­ta­tions into account and ensure a balance with your fun­da­men­tal rights and freedoms. If we cannot guarantee this, we will stop storing / using your personal data or we will determine a new legal ground.

5. RETENTION PERIODS

Unless a longer storage period is required or justified (i) by law or (ii) through compliance with another legal obligation, KADONATION shall only store your personal data for the period necessary to achieve and fulfil the purpose in question.

6. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

KADONATION shall never sell your personal data to third parties. In addition, KADONATION shall never disclose your personal data to other third parties, unless it is necessary to achieve the purposes described in this Privacy Policy. In this respect, (some of) your personal data may be disclosed to:

  • Software and cloud providers
  • Printing Services

Of course we have made sure that the necessary contracts or similar legal binding acts are in place to ensure that these third parties treat your personal data in accordance with the Privacy Leg­is­la­tion (e.g. Article 28 GDPR).

In addition, we might transfer your personal data:

  • To competent author­i­ties: for instance, because (i) we are obliged to provide your personal data under law or in the scope of (future) legal pro­ceed­ings, or (ii) this is necessary to safeguard our rights; or,
  • In M&A context: meaning, if KADONATION or the majority of its assets, is taken over by a third party, in which case your personal data – which KADONATION has collected – may be one of the trans­ferred assets.

7. CROSS-BORDER PROCESSING OF PERSONAL DATA

In case any of the above mentioned third parties or other recipients are located in a country outside the European Economic Area, KADONATION will ensure that one or more of the listed EU-approved safeguards are in place:

  • European Commission adequacy decision;
  • Data transfer agreement (cfr. the Standard Con­trac­tu­al Clauses as provided in the European Commission Imple­ment­ing Decision (EU) 2021/914 of 4 June 2021, including the per­for­mance of a transfer impact assessment);
  • Binding corporate rules; or,
  • Cer­ti­fi­ca­tion mechanisms.

8. YOUR PRIVACY RIGHTS

The Privacy Leg­is­la­tion (e.g. GDPR) gives you certain rights over your personal data vis-à-vis KADONATION. You can exercise these rights by contacting us, as specified in Section 11, through compliance@​kadonation.​com.

Access:you can ask for con­fir­ma­tion of whether or not personal data that relates to you is being processed. If so, you can ask us to give you copies of your personal data. We may charge you a small fee for this service;
Rec­ti­fi­ca­tion:you can ask us to correct | complete any infor­ma­tion you believe is inaccurate | incomplete;
Erasure:you can ask us to erase your personal data, under certain conditions. Please be aware that in this context certain services will no longer be accessible and/​or can no longer be provided.
Objection:you can object to us processing your personal data, under certain conditions.
Restric­tion of processing:you can ask us to restrict the processing of your personal data, unless we have legitimate interests for the processing of your personal data that prevail over your interests
Data porta­bil­i­ty:you can ask us to transfer your personal data to another orga­ni­za­tion, or directly to you in a commonly used structured format readable by automatic device, under certain conditions.

9. SECURITY

KADONATION undertakes to take reasonable, physical, tech­no­log­i­cal and orga­ni­za­tion­al pre­cau­tions in order to avoid (i) unau­tho­rised access to your personal infor­ma­tion, and (ii) loss, abuse or alteration of your personal data.

10. UPDATES

We are entitled to update this Privacy Policy by posting a new version on the Website whereby we will indicate the revision date at the top of this Privacy Policy. As such, it is strongly rec­om­mend­ed to regularly consult the Website and the page displaying the Privacy Policy, to make sure that you are aware of any changes.

11. NOTI­FI­CA­TIONS AND QUESTIONS

Noti­fi­ca­tions under this Privacy Policy (such as, exercising your rights as a data subject) and/​or any questions or concerns with regard to the provisions of this Privacy Policy must be directed at our DPO, via compliance@​kadonation.​com.

12. COMPLAINTS?

You are not satisfied with the manner in which we collect, store or otherwise treat or secure your personal data? We are sorry to hear that and are prepared to take all measures to remedy this situation. Please do contact us!

You also have the right to lodge a complaint with the following super­vi­so­ry author­i­ties:

The Belgian Data Protection Authority
Email: contact@​apd-​gba.​be

Telephone number: +32 (0)2 274 48 00

Address: Rue de la Presse 35, 1000 Brussels, Belgium


The Dutch Data Protection Authority
Telephone number: +31 (0)70 888 85 00

Fax: +31 (0)70 888 85 01

Postal Address: PO box 93374, 2509 AJ Den Haag, the Nether­lands