LEGAL
1. Introduction
This privacy policy (“Policy”) describes how Unblock SRL processes personal data of persons outside the company (e.g. customers and potential customers, suppliers, website users and applicants).
The Policy may be amended at any time and the latest version is available on the website unblock.io. This Policy was last updated on July 19, 2023.
The website unblock.io uses cookies. For more information on this subject, the data subject can consult the Cookie policy.
2. Controller
The controller for the processing operations defined below is the company Unblock SRL, with registered office at Avenue Louise 231, 1050 Ixelles, registered at the Crossroads Bank of Enterprises under number 0795.333.583 - RPM Brussels (“Unblock”).
Unblock can be contacted at any time
by post to the address of its registered office, or
by email to legal@unblock.io
3. Specific processing
Unblock carries out the various processing operations below, applicable according to the status of the data subject.
Customers
Customer management (service delivery, customer relationship management, communication, invoicing, collection,...)
Need to perform the contract (art. 6. 1(b) GDPR)
Maximum 10 years after the end of the business relationship
Direct marketing
Legitimate interest to better serve the data subject as a customer and to promote the products and services of Unblock (art. 6.1 (f) GDPR)
Maximum 10 years after the end of the business relationship
Potential Customers
Prospection
Need to take pre-contractual measures, if the data subject wishes to become a customer or asks a question (art. 6. 1(b) GDPR). Legitimate interest in identifying business opportunities, if Unblock has received the data subject’s details from a third party (art. 6.1 (f) GDPR)
Maximum 10 years after the data subject has become inactive as a potential client
Direct marketing
Consent (art. 6.1 (a) GDPR)
Until the data subject withdraws consent.
Suppliers
Supplier management
Need to perform the contract (art. 6. 1(b) GDPR)
Maximum 10 years after the last delivery or service
Website users
Customer management (access to the website platform when using the services)
Need to perform the contract (art. 6. 1(b) GDPR)
Maximum 10 years after the end of the business relationship
Responding to a question or complaint
Need to perform the contract or take pre-contractual measures (art. 6. 1(b) GDPR)
Maximum 10 years after the issue or complaint has been dealt with
Placing and reading cookies
Consent (art. 6.1 (a) GDPR). Legitimate interest in providing a functional website (Art. 6.1 (f) GDPR)
In accordance with Cookie Policy
Research and development, improvement of services and user experience
Legitimate interest in improving the website and services (Art. 6.1 (f) GDPR)
Until the data is anonymized, after which it can be used indefinitely
Applicant for a job
Candidate management
Need for pre-contractual measures (art. 6. 1(b) GDPR)
2 years after the end of the application procedure
Recruitment reserve
Legitimate interest in being able to contact the candidate at a later stage if other positions become available (art. 6.1 (f) GDPR)
5 years after the end of the application procedure, unless there is an objection
In all cases
Detect, prevent and combat fraud and abuse
Legitimate interest in combating fraud and abuse (art. 6.1 (f) GDPR)
Maximum 10 years, unless the detection, prevention and combating of fraud and abuse require longer retention
Litigation management
Legitimate interest in being able to safeguard Unblock’s rights in the event of a dispute (art. 6.1 (f) GDPR)
Maximum 10 years, unless litigation management requires longer retention
Statistics
Legitimate interest to improve the services and operation of the company (art. 6.1 (f) GDPR)
Until the data is anonymised, after which it can be used indefinitely
4. Recipients and transfer of data
In the context of the processing detailed in section 3, Unblock may transfer personal data to its subsidiaries or any other subcontractors that process personal data on its behalf, including business partners (e.g. sales agents), technical providers (e.g. IT providers), professional advisors (e.g. accountants, etc.). In this case, Unblock concludes data processing agreements with these processors in accordance with Article 28 of the GDPR.
When they are not located in the country of residence of the data subject, the above-mentioned recipients are generally located in the European Economic Area and/or in countries that ensure an adequate level of protection of personal data, in particular because they have been the subject of an adequacy decision of the European Commission. Where applicable, Unblock shall ensure that the transfer of personal data to a country that has not been subject to such an adequacy decision is regulated by entering into the latest version of the European Commission’s standard contractual clauses with the relevant processor. The data subject can request a copy of the guarantees taken by Unblock via the contact details stated in section 2.
5. Data subject's rights
1.1 The data subject’s rights
Data subject have a number of rights under the personal data protection legislation. They have:
1. the right of access to their personal data, allowing them to check which personal data Unblock processes about them.
2. the right to rectify personal data, allowing them to correct or complete incorrect or incomplete personal data that Unblock processes about them.
3. the right to erasure of their personal data, allowing them to permanently delete the personal data that Unblock processes about them.
Unblock is not always obliged to delete personal data at the request of the data subject - this right only applies in cases and to the extent provided for by law.
4. the right to restrict the processing of personal data concerning them, allowing them to freeze the use of the personal data by Unblock without deleting them.
Unblock is not always obliged to restrict the processing of personal data at the request of the data subject - this right only applies in cases and to the extent provided for by law.
5. the right to object to the processing of their personal data, allowing them to object to the further processing of their personal data.
Unblock is not always obliged to honour the data subject’s objection - this right only applies if Unblock processes personal data on the basis of its legitimate interest.
6. the right to withdraw their consent at any time where the processing of their personal data takes place on the basis of their consent.
7. the right to object to the processing of their personal data for direct marketing purposes.
This right can always be exercised by the data subjects.
8. the right to data portability allowing them to easily transfer, copy or move personal data from one controller to another.
This right can only be exercised if the processing is based on the consent of the data subjects or on a contract concluded with them.
Data subject can exercise their rights by contacting Unblock via the contact details stated in section 2 above.
1.2 Complaints
For any questions or complaints regarding the processing of personal data, the data subject can contact Unblock via the contact data stated in section 2 above.
The data subject may also lodge a complaint with the supervisory authority of the place where he or she lives. In Belgium this is the Data Protection Authority, Rue de la Presse 35, 1000 Brussels, which can be contacted via contact@apd-gba.be or +32 2 247 48 00. https://www.autoriteprotectiondonnees.be/
6. Provision of personal data
In some cases, the provision of personal data by the data subject is voluntary. In some circumstances, Unblock may be required by law to process personal data in order to comply with applicable legislation. In other cases, even where the collection of data is not required by law, Unblock must collect the data because it is a contractual requirement or a necessary requirement to enter into the contract. Thus, if the data subject refuses to provide his/her necessary personal data, Unblock will not be able to conclude the contract.