This Privacy Policy governs the processing of your personal data by Juyo Analytics BV, a company registered in the Belgian Crossroads Bank for Enterprises under number 0552.628.004, with registered offices at 4 Rue Saint Lazare, 1210 Brussels, Belgium (hereinafter referred to as “Juyo”, “we”, “us” or “our”).

The privacy and security of your (hereinafter referred to as “you” or “your”) personal data are very important to us. The purpose of this Privacy Policy is to specify which categories of personal data we collect through our various activities.

Article 1              General information

Our Privacy Policy categorizes the personal data we collect and explains how such data may be processed. We furthermore set out whether or not the personal data will be disclosed to third parties and the restrictions and safeguards to which we subject such transfers. To the extent desirable, the Privacy Policy also sets out the different measures we have implemented in order to safeguard the security and confidentiality of the personal data we may collect and process.

We may receive your personal data directly from you via our website as well as our platform. Its subdomains and directories (collectively referred to as the “Website”), any other means relating to information or communication technology, including emails and voice calls, or via any in-person interactions we might engage in.

For the purpose of this Privacy Policy, we are to be considered the controller of your personal data. This means that the applicable data privacy legislation imposes certain obligations on us. The aforementioned legislation includes in particular, the Belgian Act of 30 July 2018 on the protection of natural persons in relation to the processing of personal data, the Act of June 13th 2005 on the electronic communication, the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016), including future adaptations and revisions of the previous (hereinafter collectively referred to as the “Applicable Data Protection Legislation”).

Should you have any questions regarding this Privacy Policy, or should you feel that your interests are not represented or are inadequately represented, please address your questions to us at karin@juyoanalytics.com

In addition, you have the right to lodge a complaint at or to request more information from the competent Data Protection Authority in accordance with article 12 of this Privacy Policy. Should you ever have any questions or complaints, we invite you to first contact us in order for us to resolve any issues you might encounter.

Article 2              Personal data we collect and process

In what follows, we provide you with a general overview of the most important categories of personal data we might collect and process about you.

1. Basic contact and identification data

This includes basic identifying and/or professional information such as your first name, surname, date of birth, your company name, and your function. This category furthermore includes contact data such as your e-mail address and telephone number and might refer to demographic information such as your address and certain preferences and interests you may have.

1. Service data

We may collect and process personal data in the form of transactions, your purchase history, order and contract information, delivery data and invoicing  data.

1. Marketing specific data

We collect data about your interests in our services, as you may make known to us via you visit to our Website, book a demo, or any other means of communication by which you reach us.

This data may additionally include your subscription to our newsletter, blog updates, downloads, etc.

1. Usage and technical data

We collect and store full IP addresses, unique device identifiers, your browser type, time zone settings, operating system, and the specifications of the hardware you use to access our Website and social media accounts. We may furthermore collect personal data when you access our Wi-Fi network and other electronic services. Please note that the concerning data may among others be collected by automated means, such as for example cookies. Please refer to our Cookie Policy for more information relating to our processing of personal data via cookies and similar technologies.

Article 3              How we use personal data

In the next part, we set out the specific purposes for which your personal data might be collected and processed. In addition to explaining why and how we might use your personal data, we will provide you with the legal bases on which we base ourselves to legitimately make use of your personal data.

Please contact us in the manner described under article 10 of this Privacy Policy, should you have any questions in relation to our collection and processing of your personal data.

1. Interactions with us

We may collect and process personal data in the form of basic contact and identification data about you when you exchange communications with us, whether or not related to the performance of our services or any support services linked to them.

Please note that the processing under this section includes interactions in an offline environment. This means that information, such as personal data on a business card you exchanged with us, will also be processed by us.

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For the collection and processing of your personal data in relation to our interactions, we base ourselves on ourlegitimate interest to provide you with the best possible interactions, among others in our provision of services, in answering to your requests and by providing you with proper response times.

1. Business administration

We collect and process the basic contact and identification data and service data of individuals acting in their capacity of representatives of their organisations, across the relevant sectors and fields of expertise, and of those people who are or might be our clients, business partners, or service providers.

This personal information may be used for the provision of services, billing of services, customer support, the fixing of meeting dates and events.

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For the collection and processing of your personal data in relation to our business administration we base ourselves on the contract concluded with the applicable client or service provider.

However, should there not be a contract in place, for example when the personal data only relates to potential service providers, then we mya base ourselves on our legitimate interest to store information on potential partners and/or service providers.

1. Marketing Communications

We may use your personal data, such as basic contact and identification data and marketing specific data, for the purpose of providing you with information relating to our products and services, newsletters, etc.

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For the collection and processing of your personal data in relation to the marketing communications, we base ourselves on your consent to receive such communications.

If you are a client or otherwise engage(d) our services, we may send you marketing communications based on the services we provided you with. This marketing communication is based on our legitimate interest to keep you informed on related services and evolutions of our business.

When you receive marketing communications from us, either on the basis of your consent, or on the basis of our legitimate interest, you retain at all times the right to opt-out from our receiver list by sending us an email to karin@juyoanalytics.com or by clicking the unsubscribe button at the bottom of a specific marketing communication.

1. Compliance and enforcement

We use your basic contact and identification data specific to our legal obligation, and usage and technical datafor our own compliance with the legal and regulatory obligations imposed on us. This includes among others our compliance to sectoral standards to which we must comply and any additional requirements imposed on us by judicial or governmental requests.

We may additionally process your personal data under this section for our own establishment and enforcement of claims or defences of a legal, administrative, or jurisdictional nature.

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For the collection and processing of your personal data for compliance with specific legal, regulatory, or deontological obligations, we base ourselves on our necessity to comply with the legal obligations to which we are subject.

Where we process the personal data for the purpose of establishing or enforcing our own claims or defences, we base ourselves on our legitimate interest to protect our commercial, financial and legal interests as permitted by law.

1. Client insights, analytics, security and IT management

We may analyse the information including the personal data necessary for us to directly identify you in relation to other personal data, such as your interactions on the Website, social media, and your communications with us. This information relates in particular to your basic contact and identification data and the usage and technical data. This personal data may furthermore be used for the purpose of ensuring the effective and secure functioning of our information security systems and more generally the online environment that we put at your disposal

The gathering and analysis of such information may be performed by using cookies, web beacons, pixel tags, log files, and similar technologies used to gather personal data from the hardware and software you use to visit our Website, including from any mobile devices you may use. For more information regarding cookies, web beacons, and pixel tags used on our Website, please refer to our Cookie Policy.

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For the collection and processing of your personal data for client insights and analysis, we base ourselves on our legitimate interest to use your personal data for the continuous improvement of our services, in order to provide you with the best possible experience, among others on our Website and social media profiles.

For the collection and processing of your personal data for the purpose of securing and ensuring the effective functioning of our online environments, we base ourselves on our legitimate interest to monitor how our Website is used and to detect and prevent fraud, criminal activities, and general misuse of our services.

Article 4              How long we retain your personal data

Our policy is to only retain your personal data for as long as it is required to satisfy the purposes for which we collected it or for which you provided it to us. Where such processing is based on your consent, we will process the personal data for as long as you have not withdrawn your consent. In what follows we seek to give you the necessary tools in order for you to assess how long your personal data may be retained by us.

As a base rule, we will de-identify or delete any personal data that is no longer considered necessary for the purposes described above or when the retention period as described below has been surpassed. This deletion will happen without further notice or liability on our part. However, please note that your personal data will never be de-identified or deleted when such personal data is to be retained by us in the application of an obligation of legal, administrative, or jurisdictional nature. Such an obligation would effectively forbid us or make it impossible for us to remove your personal data. Nevertheless, such data will only be stored for the purpose of our compliance and will no longer be processed for any other purpose.

We distinguish the following retention periods:

• All basic contact and identification data will be kept and stored for as long as they are in use for the purpose of our communication with you and for the building of a historical archive of our past communications. The storing of such information is particularly important for later interactions, in that it allows us to revert to earlier communications should you come to us with new questions, requests, comments, or other input.
• All service data will be kept for the duration of the contract you have concluded. We may retain such data for an additional ten (10) years thereafter.
• All marketing specific data will be stored and processed for as long as you choose to remain subscribed to any of our marketing services.
• The usage and technical data are stored for a duration of three (3) months after their initial collection. After such a period they will be de-identified or deleted.

Article 5              With whom we share your personal data

In order to provide our services to you and in order to make our Website available to you, we may share your personal data with third-party contractors and/or other data controllers. We have identified the following main categories of third-party recipients of your personal data:

• Our professional advisers;
• Professional indemnity or other relevant insurers;
• Third parties and tools to whom we outsource certain services such as, without limitation, confidential waste disposal, IT systems or software providers, IT support service providers, documents and information storage providers;
• Third-party service providers who assist us with client insights and analytics, such as Google Analytics.

Whenever third parties falling under one or more of the abovementioned categories should be considered a sub-processor under the Applicable Data Protection Legislation, we confirm that we have concluded the necessary agreements in order to safeguard the transfers and processing of your personal data.

Feel free to contact us as set out under article 10 of the Privacy Policy, should you have any questions regarding the third pary recipients of your personal data and the safeguards we have implemented in that regard.

Article 6              International data transfers

We are based in Belgium with offices registered in Belgium only. As a principle, your personal data will be stored and processed in Belgium. However, for the purposes set out in article 4 of this Privacy Policy, we may have to transfer personal data to other jurisdictions outside the European Economic Area. When we transfer your personal data to third parties residing in such jurisdictions, we implement appropriate safeguards in our agreement with those third parties in order to provide your personal data the benefit of an adequate level of data protection and at least a level of data protection equivalent to the level to which you are entitled under the General Data Protection Regulation.

For this purpose, we assess the level of data protection in the country of transit or destination, among others taking into account the adequacy decisions taken by the European Commission. Additionally, we may make use of the Standard Contractual Clauses approved by the European Commission and any other appropriate solutions as required or permitted by the Applicable Data Protection Legislation.

Feel free to contact us as set out under article 10 of the Privacy Policy, should you have any questions regarding the international transfers of your personal data and the safeguards we have implemented in that regard.

Article 7              Your data protection rights

Under the Applicable Data Protection Legislation, you are entitled, free of charge, to exercise certain rights in relation to your personal data collected and processed by us:

Withdrawal of consent. You have the right to withdraw your consent in relation to all processing activities for which you have previously given us your consent.

Right of access. You are entitled to request a copy of the data we process and hold on you. If we process and/or hold personal data about you, you will receive a copy of the information in an understandable format together with an explanation of why and how we hold and use it.

Right of rectification. You have the right to ask us to correct your personal data. This includes the right to have us correct spelling mistakes or change an address, email addresses, phone numbers, etc.

Right of erasure. You have the right to request the deletion of the personal data we process or hold on you. We can object to the deletion of your personal data if the processing is done to comply with legal obligations, for reasons of public interest, or for the establishment, exercise, or defence of our legal claims.

Right to restrict the processing. Under certain circumstances, you have the right to ask us to restrict our processing of your personal data. Please note that in exercising this right, the relevant personal data will remain stored in our possession, but we will not be able to further process it. You can ask us to restrict the processing of your personal data where (i) you believe that the personal data we process on you is inaccurate, (ii) our processing of your personal data should be unlawful, or (iii) you object to our processing of your personal data as set out below, but you do not want us to delete your personal data.

Right to object to the processing. In those instances where we process and collect your personal data based on our legitimate interest, you have the right to object to our processing of such data. Please note that if you decide to exercise your right to object to our processing of your personal data, we have the right to provide you with our legitimate grounds on which we base ourselves in order to continue the processing of your data.

Right to data portability. You are entitled to receive the personal data we process or hold on you in a structured, commonly used, and machine-readable format. Furthermore, you mayb have the right to have this personal data transmitted to another data controller.

If you would like to be supplied with further information on your rights or wish to exercise them, please write to us at karin@juyoanalytics.com We ask of you to properly identify yourself when exercising your data protection rights in order to enable us to execute your request within due delays.

In those cases where we deem your request to exercise your rights manifestly unfounded or excessive, we reserve the right to charge you an administrative fee for the execution of your request, or even to refuse to act on your request. You will always be informed within the abovementioned timeframes of our decision.

Article 8              Security of your personal data

We use generally accepted and reasonable technical and organisational methods consistent with current technological developments with regard to operational security to offer protection against loss, abuse, alteration, or destruction of all personal data we store and process.

Our technical and organisational measures are frequently updated in order to adapt these measures to new technical and organisational procedures and to ensure the continued safety of your personal data.

Please note that our Website and social media accounts may contain links to other websites or internet resources which may also collect personal data, through cookies or other technologies. We carry no responsibility, liability for, or control over those other websites or internet resources or their collection, use, or disclosure of your personal data. We recommend that you review the privacy policies of these other websites and internet resources in order to understand how they collect and process your personal data.

Article 9              Amendments to the Privacy Policy

We may bring adaptations and improvements to the Privacy Policy from time to time. You will find the revision date on top of this Privacy Policy, so that you remain informed which information we collect and process at a certain date. The continued use our Website and/or services after a revision of the Privacy Policy will be considered as your consent to any changes to this policy.

Article 10           How to reach us

You undertake to communicate accurate personal data to us. You may at any time modify the personal data at our disposal by sending us an email. We cannot be held responsible for any failure of our services related to incorrect information that has been provided by you.

Should you have any questions about this Privacy Policy or should you have the feeling that your interests are not or inadequately represented, you can address all your questions to us at the following email address: karin@juyoanalytics.com

Article 11           Dispute resolution

This Privacy Policy shall be governed by – and construed in accordance with – the Belgian privacy legislation.

You have the right to file a complaint with the competent data protection authority, being the authority in the Member State of your habitual residence, your place of work, or the place of the alleged infringement of the Applicable Data Protection Legislation. Notwithstanding the previous, the lead data protection authority is the Belgian Data Protection Authority (“Autorité de protection des données” or “Gegevensbeschermingsautoriteit”), which can be reached via the following means of communication:

• by following the instructions and filling in the form accessible via this link;
• by sending a letter to Drukpersstraat 35, 1000 Brussels, Belgium;
• by calling the following number +32 (0)2 274 48 00;
• by faxing to +32 (0)2 274 48 35; or
• by sending an email to contact@apd-gba.be.

Cookies

Juyo uses cookies for functional and analytical purposes. Cookies are small, locally stored, files that websites use to track information about users. For more information about cookies, please visit: https://cookiesandyou.com.

The main purpose of cookies placed by our website is to track user experience throughout the website. We save data about how users navigate the website, but are strict to never collect personally identifiable data. This means we don’t collect data like exact locations, ip-addresses and keystrokes. We collect the minimum amount of data required for our purposes and will never sell any of it to third parties. We do not use cookies to retarget, remarket or identify users in any way.

To effectively and safely process data collected we work with one data-processors (Google). Google is restricted from processing data without explicit request and prohibited from becoming a controller and processing and sharing the data any further, outlined in our Data Processing Agreement.

Our partner in the web area, both in construction and data collection, is OWOW (https://owow.agency)an agency based in Eindhoven. We collaborate to build a data stream that collects and processes important data efficiently and safely for us.

In the table below, you can find an overview of the Cookies we use, their function and the period they are active.