Privacy- and Cookie Statement INNDUCE.ME
This privacy- and cookie statement has been drawn up within the framework of a platform offered by INNDUCE.me. The platform (the "Platform") was developed in order to determine the innovation profile of individuals by means of a psychological simulation test that measures the innovation skills of users (the "Test").
The goal of INNDUCE.me is to help companies and individuals gain essential insights to build successful teams, recruit the right people, identify (innovation) talent and to develop a strategy that promotes innovation success through the use of the Platform.
2. Identity of controller(s)
INNDUCE.me, a limited liability company (“besloten vennootschap”) with registered office at Walle 113, 8500 Kortrijk, Belgium, registered with the Crossroads Bank for Enterprises under number 0566.941.937 (LER Ghent, division Kortrijk) acts as controller (the "Controller") within the meaning of the Privacy Laws and in that capacity we would like to inform you on the processing of your Personal Data (as both defined below).
"INNDUCE.me" or "we" take the measures set forth in this privacy- and cookie statement ("Privacy- and Cookie Statement") to protect your privacy.
The protection of the privacy of (i) users of the Platform and our website http://www.innduce.me (the "Website"), and (ii) participants to the Test, is required by law, as we want to clarify this, we have prepared this Privacy- and Cookie Statement.
By means of this Privacy- and Cookie Statement we want to inform you in the best possible way on (i) what Personal Data we collect, (ii) how we process your Personal Data, (iii) why we do so and how you control it, and (iv) what cookies or similar technologies we use on our Website and why we use them.
We will only use your Personal Data for the purposes set forth in this Privacy- and Cookie Statement, and we will not disclose your Personal Data in any way to any natural person, legal entity, or entity other than ourselves ("Third Party(ies)"), except as provided in Section 8 of this Privacy- and Cookie Statement.
Any processing of your Personal Data will always be in accordance with applicable privacy legislation, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (the "Privacy Laws"). We have made agreements with other companies that place cookies about the use of the cookies. However, we do not have full control over what they do with the cookies themselves. You should therefore also read their privacy and cookie statements to which reference is made in this Privacy- and Cookie Statement, if applicable.
3. Legal basis for processing of personal data
We will process your Personal Data based on your consent and to allow you to participate to the Test. We will ensure that your Personal Data is treated with the necessary care and confidentiality.
4. Collection and processing of personal data
4.1.1. We collect and process the following Personal Data through the Website:
- First name and surname;
- Email address;
- Function; and
4.1.2. We collect and process the following Personal Data through the Platform:
- First name and name of the potential participant to the Test;
- Email address of the potential participant to the Test;
- Company where the potential participant to the Test works;
- Professional position of the potential participant to the Test;
- Gender of the potential participant to the Test ;
- Educational level of the potential participant to the Test;
- Age of the potential participant to the Test; and
- Activity of the potential participant to the Test.
A cookie is a simple small file sent with pages of the Website and stored by your browser on your device's hard drive. The information stored in it can be sent back to our servers the next time you visit us.
When we talk about cookies in this Privacy- and Cookie Statement, we also mean similar (tracking) techniques, such as pixels.
A distinction is made between permanent and temporary cookies on the one hand and direct and indirect cookies on the other hand.
Permanent and temporary cookies
Cookies are permanent when they remain on the user's device, even after the user has closed the browser; temporary cookies disappear as soon as the user has closed the browser.
Through the use of a permanent cookie we can recognize you when you re-visit our Website. In this way, the Website can be adjusted to your specific preferences, such as your choice of language. We can also remember whether you gave your permission to place cookies, through the use of a cookie. This means that you do not have to repeat your preferences each time you visit our Website, saving you time and making it easier for you to use our Website. Permanent cookies can be deleted via the settings of your browser.
With the help of a temporary cookie, we can see which parts of the Website you have viewed during your visit. This enables us to adapt our service as much as possible to the browsing behaviour of our visitors. These cookies are automatically deleted as soon as you close your web browser.
Direct and indirect cookies
Based on the source of the cookies, we make a distinction between direct and indirect cookies. Direct cookies are sent by the Website itself; indirect or third party cookies originate from Third Parties.
Functional and analytical cookies
Functional cookies are necessary in order to provide a functionality explicitly requested by you, such as remembering your choice of language.
Analytical cookies should allow an analysis of information such as the number of visits to a Website.
Our Website uses the following analytical cookies or similar techniques:
Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
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We use Google Analytics to track how users use the Website and to get reports on this. Cookies are placed for the latter purpose. Google uses this information to keep track of how our Website is used in order to provide us with reports on the Website. We ensure that Google treats any Personal Data resulting from the use of its services in accordance with the Privacy Laws.
We have installed Google Analytics in a privacy friendly way. Among other things, the IP address is pseudonymised before it is passed on to Google. In addition, we have concluded a data processing agreement with Google, under which Google is permitted/prohibited to pass this data on to third parties or to use it for other Google services.
The maximum retention period of the cookies used through this service is set by us to 24 months. This means that at the end of this period the data can no longer be read.
5. Purposes of data collection and processing
We will collect and process your Personal Data for the following purposes (the "Processing Purposes"):
- In case of collection of Personal Data through the Website:
- to contact you;
- In case of the collection of Personal Data through the Platform:
- to assess your innovation skills;
- to prepare and send a personal tailor made psychological report with an innovation profile based on your Test;
- to give you tips and tricks in order to improve your innovation profile;
- to offer you certain coaching courses based on your personal report;
- to be able to assemble teams based on your Test; and
- to develop your innovation strategies.
Furthermore, we have free access to your Personal Data, and may store and disclose your Personal Data freely in the following cases:
- to comply with applicable laws or regulations;
- if officially requested to do so by a law enforcement authority or other public body;
- for the investigation of suspicious or actual fraudulent or illegal activities; and
- to protect your safety and/or your rights or ours.
6. Storage OF and access to personal data
We will ensure that your Personal Data is not kept longer than necessary to fulfill the above Processing Purposes.
Personal data collected in the context of your use of the Website or Platform will be stored in anonymised form for 5 years after completion of the Test in order to meet scientific and statistical purposes.
All Personal Data will be retained for their retention period in accordance with the provisions of this Privacy- and Cookie Statement.
7. Security of your personal data
We take appropriate and necessary organizational and technical security measures to protect your Personal Data and your privacy in order to prevent the loss, unlawful use or alteration of information we receive. Such measures include (i) log-on protection of the Personal Data, (ii) encryption of the Personal Data, (iii) anti-virus systems, (iv) anonymization of Personal Data; and (v) confidentiality obligations applying to all employees involved.
8. Transfer of personal data to third parties
Unless otherwise set forth in this Privacy- and Cookie Statement, we will not transfer, transmit or otherwise disclose your Personal Data to Third Parties without your prior express consent unless necessary for the Processing Purposes set forth in this Privacy- and Cookie Statement or unless we are required to do so by law.
Such Third Parties will only have access to the Personal Data they need to perform their tasks, and may not use such data for other purposes. The Third Parties to whom the Personal Data is transferred are also subject to an obligation of confidentiality, and must provide the necessary guarantees that appropriate organizational and technical security measures are taken to protect your Personal Data and privacy.
9. Transfer of personal data outside the european economic area
In the event that we use processors outside the European Economic Area, your Personal Data may be transferred, stored and processed outside the European Economic Area. This transfer, storage and processing can only be carried out with the prior written consent of INNDUCE.me and subject to compliance with Chapter V of the Privacy Laws.
10. What are my rights as a data subject?
We want to ensure safe and lawful processing of your Personal Data, and we assure you that your Personal Data will be processed fairly and lawfully. This means that Personal Data will only be processed for the above Processing Purposes. We also ensure that Personal Data will always be processed in an adequate, relevant and non-excessive manner.
10.1. My right of access
You have the right to be informed whether we are processing your Personal Data and, if so, to obtain access to such Personal Data and to receive the following information:
- the Processing Purposes;
- the categories of Personal Data concerned;
- the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organisations;
- the period for which the Personal Data will be stored or the criteria for determining such storage period;
- if we obtain Personal Data from Third Parties, information regarding the source of such Personal Data; and
- the existence of automated decision-making (including profiling) regarding your Personal Data, and where applicable, useful information about the underlying logic, as well as the importance and possible consequences of such automated decision-making.
Furthermore, you also have the right to receive a copy of the Personal Data that you have provided to us in a structured, common and machine-readable format (via the email address that you have provided us with) so that you can pass it on to another data controller or so that we can pass it on to another data controller at your request and if technically possible. Requesting a copy is free of charge. If you request additional copies of your Personal Data, we may charge a reasonable fee to cover administrative costs.
In order to exercise your right of access, and to prevent any unauthorized disclosure of your Personal Data, you must provide us with proof of your identity. When exercising your right of access, we therefore ask you to add a copy of the front side of your identity card to your written request by email or post.
10.2. My right to rectification and completion
You have the right to have your Personal Data corrected or have inaccuracies rectified free of charge if your Personal Data is incomplete or inaccurate or is processed in an unlawful manner. Furthermore, you also have the right to complete incomplete Personal Data, including by providing a supplementary statement.
10.3. My right to erasure of data ("right to be forgotten")
You have the right to request the deletion of your Personal Data as collected by us in the following cases:
- your Personal Data is no longer required for the Processing Purposes set forth in this Privacy- and Cookie Statement;
- you revoke your previous consent for the processing of your Personal Data and there is no other legal basis on which we can rely for the (further) processing of your Personal Data;
- you object to the processing (or further processing) of your Personal Data and there are no compelling legal grounds for the processing of your Personal Data by us;
- your Personal Data has been processed unlawfully;
- your Personal Data must be deleted in order to comply with a legal obligation incumbent upon us;
- your Personal Data was collected when you were a minor.
In the event of a deletion request, you should be aware that we need to retain certain Personal Data in order to comply with our legal obligations.
10.4. My right to restriction of further processing
Furthermore, you also have the right to have the processing of your Personal Data restricted when:
- you contest the accuracy of this Personal Data (in this context, the use of your Personal Data shall be limited during a certain period of time in order for us to verify the accuracy of your Personal Data);
- the processing of your Personal Data is unlawful and instead of its deletion, you request us to limit the processing of your Personal Data and its use;
- we no longer need your Personal Data for the Processing Purposes as described above, but you need this Personal Data for the initiation, exercise or substantiation of a legal claim;
- when after exercising your right to object to the processing of your personal data and as long as no decision has been made on the exercise of such right, you request us to limit the use of your Personal Data.
Furthermore, you have the right to revoke your consent to the processing of your Personal Data at any time without prejudice to the lawfulness of the processing prior to the revocation of your consent.
10.5. My right to file a complaint
If you have a complaint on the processing of your Personal Data or on the exercise of your rights, please send an e-mail to firstname.lastname@example.org. We undertake to respond to any request to exercise the aforementioned rights within thirty (30) calendar days.
Furthermore, you always have the right to lodge a complaint or initiate proceedings with the data protection supervisory authority ("Data Protection Authority" or “Gegevensbeschermingsautoriteit”) with the following contact details: Data Protection Authority (GBA), rue de la Press 35, 1000 Brussels, +32(0)2 274 48 00/+32(0)2 274 48 35; email@example.com; https://www.dataprotectionauthority.be.
11. Deletion and disablement of cookies
Most Internet browsers are set up to accept cookies automatically. However, the browser settings on your device allow you to delete cookies that have already been installed and to refuse the installation of new cookies. How this is done differs from browser to browser. If needed, consult the help function of your browser or use these links to go directly to the manual of your browser: Internet Explorer, Mozilla Firefox, Chrome and Safari.
On https://www.youronlinechoices.com/be-nl/ you can indicate which companies are and which are not allowed to record your browsing behaviour.
12. Exercise of your rights
If you wish to exercise the above rights, this will be possible by email to firstname.lastname@example.org.
We undertake to reply to any request to exercise the aforementioned rights within thirty (30) calendar days.
13. Data breaches
In the event of a data breach, we will report this to the Data Protection Authority in time. A data breach constitutes a breach of the security of your Personal Data. As a result, all parties involved will also be informed about this data breach and the risks that may arise or be run by you as a result of this data breach will be identified as a matter of urgency.
If you are aware of a data breach, or if you suspect a data breach, we ask you to report this immediately by sending an e-mail to email@example.com.
14. Modification of privacy and cookie statement
We may make improvements, additions or changes to this Privacy- and Cookie Statement for a variety of reasons. We will post a notice of those changes on our Website.
This version was drawn up on 8 May 2020.
Older versions of this Privacy- and Cookie Statement will be stored in our archive and can be retrieved at any time by sending an email to firstname.lastname@example.org.