Privacy Policy

Last updated: October 21, 2024

Contents

1. Introduction

Clipido cares about your privacy and treats your personal data as confidentially as possible.

The protection of your privacy and your personal data is an extremely serious matter for us. We only collect, store and use your personal data in accordance with the content of this privacy policy ("Privacy Policy") and the applicable data protection provisions, in particular the provisions of the European General Data Protection Regulation ("GDPR") and national data protection provisions.

This Privacy Policy explains what personal data is collected and processed, for what purposes, how long we retain personal data, what your rights are in this regard and how you can contact us.

This Privacy Policy applies to, among other things, (i) our websites and platforms www.clipido.com and app.clipido.com (hereinafter our "Websites"), and the services and activities associated with them and (ii) all relationships via any other means of communication between you and us.

2. General information applicable to all our personal data processing

2.1. Who is the data controller?

Clipido BV, with registered office at Haagdoornlaan 23, 3511 Hasselt and registered in the Crossroads Bank for Enterprises under company number 0800.987.297 (hereinafter "Clipido" or "we"), is responsible for processing your personal data as described in this Privacy Policy.

We point out that Clipido is the data controller for the processing of your personal data, which means that we have direct responsibility to you regarding the processing of your personal data. This Privacy Policy exclusively relates to our relationship with you as data controller.

It is important to note in this context that Clipido is in principle not a data controller with respect to the personal data processed in the context of our Clipido services (cloud storage) that we offer to customers. With respect to that personal data, the customer is the data controller and we are a processor. For more information about the processing of your personal data in the context of these service(s), we refer you to the privacy policy of the relevant customer(s).

2.2. How do we receive your personal data?

Personal data is data that can be used to directly or indirectly identify an individual person. We may collect and process personal data in different ways, e.g. when:

  • you contact or have contacted us;
  • we provide or have provided our services to you;
  • you visit one of our Websites;
  • etc.

Usually you provide us with your personal data yourself, e.g.:

  • when you provide your contact details to ask a question via our contact form;
  • when you register and create an account as a customer/user of Clipido;
  • etc.

We may also find, update, supplement and improve your contact details through public sources and social networks.

2.3. Do we share your personal data outside the European Union?

In principle, we only use your personal data to provide the services you request. If we use external service providers to provide these services, these service providers also only have access to your personal data exclusively in the context of their service provision. We have taken the necessary technical and organizational measures to ensure that data protection provisions are complied with and also require external service providers to do so. We have concluded data processing agreements with the third parties involved, which contain the necessary guarantees regarding the confidentiality and compliance with the privacy of your personal data.

Notwithstanding the foregoing, however, it is possible that Clipido discloses your personal data to the competent authorities (i) if Clipido is required to do so by law or legal proceedings and (ii) to protect and defend our rights.

We generally store your personal data on IT systems in the European Economic Area (EEA).

If personal data is nevertheless transferred to countries or organizations outside the EEA, an appropriate safeguard will always be provided. Any transfer of personal data outside the EEA to a recipient in a country that is not subject to a European Commission decision to provide an adequate level of protection is, however, subject to the provisions of a data transfer agreement that (i) contains the model contract clauses issued by the European Commission, or (ii) any other mechanism in accordance with the GDPR, or any other regulation relating to the processing of personal data.

2.4. What are your rights as a data subject?

You have various rights:

  • You always have a right of access to your personal data. This allows you to check what personal data we process about you;
  • You always have a right to rectification of your personal data. This allows you to correct or complete inaccurate or incomplete personal data that we process about you;
  • You have a right to erasure of your personal data. This allows you to permanently delete personal data that we process about you. We are not always obliged to delete your personal data at your request - this right only applies in the cases and to the extent provided by law;
  • You have a right to restriction of processing of personal data relating to you. This allows you to freeze the use of your personal data by us, without deleting it. We are not always obliged to restrict your personal data at your request - this right only applies in the cases and to the extent provided by law;
  • You have a right to object to the processing of your personal data. This allows you to oppose the further processing of your personal data. We are not always obliged to honor your objection - this right only applies when we process your personal data based on our legitimate interest;
  • You always have the right to withdraw your consent when the processing of your personal data is based on your consent;
  • You always have the right to object to the processing of your personal data for direct marketing purposes;
  • You have the right to data portability. This allows you to easily move, copy or transfer personal data from one data controller to another. This right can only be exercised when the processing is based on your consent or on a contract with you.

If you wish to exercise any of the above rights, please contact us by email at hello@clipido.com or by mail using the details below (under section 2.5).

When you submit a request to exercise your rights, we will first verify your identity through the appropriate and least privacy-intrusive means. We do this to prevent your data from falling into the wrong hands.

The exercise of your rights is in principle free of charge. When your request is manifestly unfounded or excessive, we may charge you a reasonable fee in light of the administrative costs incurred by us. In that same case, however, we may also choose not to respond to your request. You will always be informed of the reasons for this.

In any case, we will always inform you of the follow-up to your request within a period of one month at the latest. For complex or multiple requests, this period may be extended by two months, but we will also inform you of this necessary extension within the month.

2.5. Want to exercise your rights, have questions or a complaint?

To exercise your rights, for any questions or complaints regarding the processing of personal data, you can always contact us:

1. Via email: hello@clipido.com2. Via mail: Haagdoornlaan 23, 3511 Hasselt, Belgium (Clipido BV)

You can also always file a complaint with the supervisory authority of where you live. For Belgium, this is:

1. Via website: dataprotectionauthority.be2. Via email: contact@apd-gba.be3. Via phone: +32 2 247 48 004. Via mail: Rue de la Presse 35, 1000 Brussels (Data Protection Authority)

For more information regarding complaints and possibilities for redress, we invite you to consult the website of the Data Protection Authority: https://www.dataprotectionauthority.be/citizen/actions/lodge-a-complaint.

3. Specific processing that may apply to you

Under what circumstances Clipido collects, uses or otherwise processes different types of personal data about you, for what purpose, on what legal basis, for what period and with whom they are shared, is described below.

3.1. Are you a customer of our Clipido service (for businesses)?

Clipido offers you as a customer a media management platform with which you can group and organize media files using intelligent tags.

Clipido may collect and process one or more of the following personal data from you as a customer:

  • contact information: e.g. name, first name, profession and position, phone and mobile number, email address and other contact information;
  • correspondence and other forms of communication: e.g. letters, emails and other (forms of) communication (e.g. your feedback, experiences, expectations, etc.);
  • billing and administrative data: e.g. bank account numbers, and all other information about payments.

However, we will never collect more personal data about you than is strictly necessary to achieve the purposes for which we have collected your personal data.

Clipido processes the above personal data for the following purposes:

  • to provide you with more information about our services at your request or on our initiative, if this is deemed necessary to accurately perform our services for you;
  • to offer you our services (including our platform) as agreed with you;
  • to handle any contact request, complaint and feedback;
  • to make or collect payments;
  • to maintain a business relationship with you as a customer;
  • to share your experiences with our platform and services.

Clipido processes the above personal data on the basis of the following legal grounds:

  • the processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contract (purposes I through IV above);
  • the processing is necessary for the purposes of the legitimate interests pursued by Clipido or by a third party (purpose V above). Our legitimate interest consists of serving you better as a customer by keeping you informed of our activities and services and improving our platform and services for the future;
  • the customer has given consent for the processing of his/her personal data (purpose VI above).

We keep your personal data until:

  • 1 month after sending the activation email if you do not activate your account;
  • 1 year after completion of the service, unless Clipido is legally required to retain the data longer.

In the context of achieving these purposes, we may share your personal data with:

  • subcontractors who process personal data on our behalf (processors) e.g. regarding hosting, mailing, cybersecurity and marketing initiatives. They process your personal data only through our written instructions and according to an agreed processor agreement;
  • judicial, police or administrative authorities, if required by law or legal proceedings.

3.2. Are you a supplier or subcontractor of Clipido?

Clipido may collect and process one or more of the following personal data:

  • contact information: name, title, function, phone and mobile number, email address, office address and other contact and/or company information;
  • correspondence and other forms of communication: letters, emails and other (forms of) communication;
  • information about the delivery of the product/service and all information about our commitment with the supplier/subcontractor, bank account numbers and all other information about payments.

However, we will never collect more personal data about you than is strictly necessary to achieve the purposes for which we have collected your personal data.

Clipido processes the above personal data for the following purpose:

  1. To purchase and use your services and/or products for the benefit of the development and use of our platform and services.

3.3. Are you a visitor to the website?

Clipido may collect and process one or more of the following personal data:

  • contact information: name, first name, company, function, address, phone and mobile number, email address;
  • correspondence and other forms of communication: including questions asked via chat function and in a contact request;
  • technical information: IP address, browser type, device type, operating system.

However, we will never collect more personal data about you than is strictly necessary to achieve the purposes for which we have collected your personal data.

In the context of achieving these purposes, we may share your personal data with:

  • possibly third parties that would be mentioned in the Cookie Policy.

3.4. Are you a participant in one of Clipido's activities (events, webinars, etc.)?

Clipido may collect and process one or more of the following personal data:

  • contact information: name, first name, company, function, address, phone and mobile number, email address, address and payment details;
  • correspondence and other forms of communication: including questions asked via chat function during webinars and in a contact request;
  • in case of events: business cards, dietary restrictions, photos, videos, etc.

However, we will never collect more personal data about you than is strictly necessary to achieve the purposes for which we have collected your personal data.

Clipido processes the above personal data for the following purposes:

  1. the organization of the Clipido activity;
  2. conducting surveys;
  3. direct marketing: to invite participants to our Clipido activities and have them participate in them;
  4. marketing: placing photos and videos on Clipido's Website(s) and social media (e.g. Facebook, LinkedIn) to promote our services and activities.

Clipido processes the above personal data on the basis of the following legal grounds:

  • the processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contract (purpose I above);
  • the processing is necessary for the purposes of the legitimate interests pursued by Clipido or by a third party (purposes II and III above). Our legitimate interests consist of improving the quality of activities and webinars (purpose II); and serving you better (if you are an existing customer of Clipido or have previously participated in a Clipido activity) by keeping you informed of other Clipido activities (purpose III);
  • the data subject has given consent for the processing of his/her personal data (purpose IV).

Clipido does not retain your personal data longer than necessary for the above purposes for which they were collected or until consent is explicitly withdrawn.

In the context of achieving these purposes, we may share your personal data with:

  • subcontractors who process personal data on our behalf (processors).

3.5. Are you a (potential) job applicant at Clipido?

Clipido may collect and process one or more of the following personal data:

  • contact information: name, first name, function, phone and mobile number, home address, email address, social media account and other contact information;
  • correspondence and other forms of communication: letters, emails and other (forms of) communication;
  • other information related to recruitment: gender, date of birth, photo, application form, CV, notes from job interviews, and other information about work history.

However, we will never collect more personal data about you than is strictly necessary to achieve the purposes for which we have collected your personal data.

Clipido processes the above personal data for the following purposes:

  1. to assess to what extent the (potential) applicant is suitable and to start an application procedure and for the evaluation of the application;
  2. to keep applicants informed of our vacancies;
  3. to invite applicants to our Clipido activities and have them participate in our activities.

Clipido processes the above personal data on the basis of the following legal grounds:

  • the processing is necessary to take steps at the applicant's request prior to entering into a contract to which the applicant becomes party (purpose I above);
  • the applicant has given consent for the processing of his/her personal data (purposes II and III above).

Clipido will delete applicants' personal data no later than 4 weeks after the end of the application procedure, unless the applicant has explicitly given consent to retain his/her data for a longer period. In that case, Clipido will retain the personal data for a period of 1 year, after which the applicant will be asked whether he/she wants to extend his/her consent.

In the context of achieving these purposes, we may share your personal data with:

  • subcontractors who process personal data on our behalf (processors).

4. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Therefore, we recommend that you consult it regularly so that you are aware of any changes.

Last updated on October 21, 2024.

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