Privacy Policy
1. Introduction
This privacy policy aims to inform you about how JARVISS (“we”, “us”, “our”, or “JARVISS”) collects and processes personal data via its website https://jarviss.nl/(the “Website“), our service desk available at https://portal.jarviss.nl/ (the “Service Desk“) and in the course of our client relationship. You are typically a Website-visitor, Service Desk-visitor or client of JARVISS.
JARVISS respects your privacy and is committed to protecting your personal data in accordance with the applicable Belgian and European data protection legislation (including the General Data Protection Regulation (“GDPR”)). Please read this privacy policy carefully. It describes not only your rights, but also the way in which you can exercise them.
By using our Website or Service Desk or disclosing your personal data you acknowledge the manner in which JARVISS collects and processes your personal data as described in this privacy policy.
2. Who we are and how to contact us?
JARVISS is a company incorporated under Belgian lawand acts as data controller in respect of the personal data collected via our Website, Service Desk or as otherwise set forth in this privacy policy:
| Company name | Jarviss NV |
| Registered office | Antwerpse Steenweg 19, 9080 Lochristi, Belgium |
| Company number | 0755.527.357 (RLE Ghent, division Ghent) |
We have appointed a Data Protection Officer, whom you can contact for questions about this privacy policy, your privacy and the processing of your personal data
| E-mail address DPO | wim.desmet@jarviss.nl |
3. What personal data do we process?
JARVISS processes different types of personal data; this depends on the functionalities you use on our Website, Service Desk, the services you wish to use and on the personal data you share with us.
If JARVISS processes your personal data, it will be personal data of one of the categories listed below:
- Identification and contact details (such as: name and first name, phone number, email address, company name, job title, (company) address, company registration and VAT number);
- Login-details (such as username and password);
- Account details (such as information about your order history and any other information uploaded in your account);
- Technical information (such as information about your computer, mobile and other devices (such as, your IP- address, user-ID, operating system, browser type);
- Usage information (such as information regarding your usage of our Website and Service Desk (such as, history, logs, date, time, location, frequency, duration of the pages you have viewed, consent preferences, information regarding consent(s) given by you (such as, the date and time of your consent)).
Your personal data originates from you directly or is automatically collected by us (in case of technical or usage information).
4. For which purposes do we process personal data, on which legal basis, and for how long?
4.1. General
Depending on your use of the Website, Service Desk and our services, JARVISS processes personal data for the purposes specified in this section 4 (if and to the extent applicable to your situation). Please note that our Website, Service Desk and services may evolve and more functionalities may be added from time to time. In such event, we will update the below table as necessary.
For certain processing purposes, JARVISS requires your consent. The consent you give is always free and you have the right to withdraw it at any time. You can withdraw your consent by sending an email to: wim.desmet@jarviss.nl .Your withdrawal of consent does not affect the processing of personal data prior to such withdrawal or our processing activities which are based on any other legal basis.
4.2 Data processing activities
| Purpose | Type of personal data | Legal basis | Retention period |
| To manage and respond to your contact requests and questions (such as after you have submitted a contact form). | Identification and contact details Any feedback and information you choose to share with us during our contact | Legitimate interest or performance of a contract (as applicable) | As long as necessary to contact you (with respect to a submitted contact request); Your identification and contact details will in any event be deleted no later than 3 years after our last contact. |
| Management and booking of appointments, demo sessions and other meetings and to ensure a proper follow up (by sending related (background) information such as commercial offers). | Identification and contact details Technical information Any feedback and information you choose to share with us during our meeting | Legitimate interest or performance of a contract (as applicable) | As long as necessary to contact you and manage our appointments and meetings; Your identification and contact details will in any event be deleted no later than 3 years after our last contact. |
| To carry out recruitment and selectionactivitiesforopenpositions at JARVISS. | Identification and contact details Any documents and information you choose to share with us during your application (such as CV, cover letter). | Legitimate interest or performance of a contract (as applicable) | Up to 5 years after notifying the last candidate that he/she is not retained for the job, unless a longer retention term applies in accordance with this policy. |
| To create your user account and to ensure that you can log in, access and use the Service Desk | Login details Identification and contact details Account details | Performance of a contract | As long as necessary for the execution of our contractual relationship. Your personal data will in any event be deleted 3 year after the expiry or termination of our client relationship |
| Usage of the Service Desk | Identification and contact details Account details Follow up on service desk tickets | Performance of a contract | As long as necessary for the execution of our contractual relationship. Your personal data will in any event be deleted 3 year after the expiry or termination of our client relationship |
| To improve our Website, Service Desk, your user experience thereof and our product and service offering in general by gathering technical, analytical and statistical insights. | Usage information Technical information Any feedback you choose to provide us | Consent You have the right, at any time and free of charge, to object to the processing of your personal data for direct marketing purposes, by sending an email to: wim.desmet@jarviss.nl. | The retention period varies from as long as the duration of a Website- or Service Desk-visit, to as long as your consent is not withdrawn (as applicable); Technical information, will in any event be pseudonymized or deleted (i) upon your withdrawal of consent; and (ii) three months after the collection of the data. Reference is made to our https://jarviss.nl/cookie-policy/. |
| To review your feedback and improve your customer experience. | Identification and contact details Feedback you choose to provide us | Legitimate interest | Feedback (and related personal data) will be retained for 3 years. |
| For direct marketing purposes (such as to send promotional emails and newsletters about our products and services, including about new features, functionalities, special offers and other information which we think might interest you). | Identification and contact details Technical information | You have the right, at any time and free of charge, to object to the processing of your personal data for direct marketing purposes, by sending an email to: wim.desmet@jarviss.nl. | As long as your consent is not withdrawn; In any event as soon as JARVISS notes that the contact details are out of use. Reference is made to our https://jarviss.nl/cookie-policy/. |
| To comply with our legal obligations (including to respond to data subject requests, to respect your (consent) preferences, to protect the rights of others). | Identification and contact details Usage information Technical information Any additional information you provide us or required to adhere to our legal obligations | Legal obligation | The retention term varies from as long as the duration of a Website- or Service Desk-visit to as long as required by law; Your personal data will in any event be deleted ten (10) years after the expiry or termination of our (client) relationship. |
| To execute our business administration (such as to manage our (client) relationship and to address potential complaints). | Identification and contact details Information related to ordered products, software and services Any additional information you provide us or which relates to our relationship | Legitimate interest | As long as necessary for JARVISS’ legitimate interest(s); Your personal data will in any event be deleted ten (10) years after the expiry or termination of our (client) relationship. |
For more details about the retention period, you can always send an email to: wim.desmet@jarviss.nl .
5. Personal data of third parties
If you disclose any personal data of third parties to us, you guarantee that you have informed those third parties and you have received all necessary consents to communicate the third parties’ personal data to JARVISS.
6. Cookies
Our Website and Service Desk use cookies and similar technologies. For more information, we refer to our cookie policy.
7. Disclosures of Personal Data
JARVISS may share your personal data, as required for the purposes set forth in section 4, with:
- third-party service providers (such as IT service providers, security providers, suppliers, communication and other software providers or hosting providers);
- professional advisers (such as lawyers or auditors);
- affiliated entities; and
- third parties to whom we intend or choose to sell, transfer or merge (parts of) our shares, business or assets.
Upon request, JARVISS shall, as soon as possible after the request, inform you of the third parties with whom your personal data have been shared by providing you a more detailed list.
In addition, we may disclose your personal information if required by law, or if we believe in good faith that such disclosure is necessary to comply with a judicial investigation, court order or to defend or safeguard our rights.
Processors and sub-processors of JARVISS always act under the responsibility of JARVISS. If JARVISS engages (sub-)processors, this will always be done in accordance with a data processing agreement that meets the requirements of the GDPR. We require all our (sub-)processors to take appropriate technical and organizational (including security) measures to protect your personal data. In the event we disclose your personal data as described above, we will implement appropriate safeguards to ensure the integrity and confidentiality of your personal data.
Your personal data will only be made available to (sub-)processors, employees and other third parties on a “need-to-know” basis, limited to the extent necessary to perform their services.
8. International transfers
In principle, JARVISS does not transfer your personal data to third countries located outside the European Economic Area (“EEA“) unless you are located outside the EEA and are visiting our Website or Service Desk from outside the EEA. It is possible that JARVISS -through its (sub-)processors- does transfer your personal data to countries outside the EEA. In this event, JARVISS will only transfer your personal data outside the EEA in accordance with the applicable data protection legislation and subject to appropriate safeguards.
Please contact us if you want further information on the specific mechanism(s) used when transferring personal data outside the EEA.
9. Direct marketing
JARVISS may use your personal data for direct marketing purposes (including profiling). This enables JARVISS to keep you informed about its products, updates, events, etc. You give your explicit consent for this, but you may at any time, free of charge, withdraw your consent and object to the processing of your personal data for direct marketing purposes (including profiling), to the extent that it relates to such direct marketing.
You shall have the right at any time to object to the processing of your personal data for direct marketing purposes (including profiling) to the extent that it is related to such direct marketing, free of charge, by sending an email to: wim.desmet@jarviss.nl .
10. Data security
JARVISS is committed to trying to make sure that your personal data is secure and makes all reasonable and appropriate efforts to protect your personal data. We have implemented appropriate technical and organizational measures, safeguards and assurances to process your personal data in accordance with the GDPR, in particular to protect your personal data against loss, misuse, or unauthorized alteration or destruction.
Please contact us if you would like more information on the specific measures taken.
Despite the above measures taken by us, you should be aware that there are always risks associated with sending personal data over the internet. The security and protection of your personal data can never be fully guaranteed, nor can we guarantee that unauthorized third parties will never be able to defeat those measures or use your personal data for improper purposes.
11. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes determined in section 4 of this privacy policy, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Afterwards it is still possible that your personal data can be found in our back-ups or archives, but they will no longer be actively processed in a file. Such back-ups or archives will be deleted automatically in accordance with our back-up and archiving policies.
The applicable retention periods are set out in the table under section 4.
12. Your legal rights
Within the limits defined in Articles 15-22 of the GDPR, you have the following legal rights in relation to your personal data:
- Right of access: you have the right to obtain confirmation from us as to whether or not we are processing your personal data, to access that personal data and receive information on how and why it is being processed, as well as to receive a copy of that personal data.
- Right to rectification: you have the right to obtain a rectification of your personal data or to request that we complete your personal data when you become aware that we are processing incorrect or incomplete data about you.
- Right to erasure (“right to be forgotten”): you have the right to obtain erasure of your personal data in certain specific cases.
- Right to restriction: you have the right to have the processing of your personal data restricted in certain specific cases.
- Right to portability: you have the right to obtain the personal data you have provided to us in a structured, commonly used and machine-readable form, and to transfer (have transferred) that personal data to another controller.
- Right to object: you have the right to object to the processing of your personal data on the basis of our legitimate interest for reasons relating to your specific situation.
You can exercise these rights by sending an email to: wim.desmet@jarviss.nl .
The exercise of these rights is in principle free of charge. Only in the event of unreasonable or repeated requests we may charge a reasonable administrative fee. JARVISS will inform you of the applicable fee before charging it.
In your request, make sure to clearly specify which right you wish to exercise so we can help you as efficient as possible. Please note that in some case we may require you to give more information about yourself to ensure that we are dealing with the correct person.
If you contact us to exercise your rights we will respond within 1 month. Exceptionally this may take longer (up to 3 months), but then we will inform you within 1 month of the reasons why.
13. Right to lodge a complaint with a supervisory authority
If and to the extent provided for in the applicable data protection legislation, you have the right to file a complaint with the competent supervisory authority if you consider that our processing of your personal data violates the applicable regulations. In Belgium the competent authority is the Data Protection Authority (“Gegevensbeschermingsautoriteit”):
www.gegevensbeschermingsautoriteit.be
Drukpersstraat 35, 1000 Brussels, Belgium
+32 (0)2 274 48 00
We would, however, appreciate the chance to deal with your concerns before you approach the authority, so please contact us in first instance.
14. Third party links
Our Website and Service Desk may contain links to third party websites and/or applications. JARVISS is not responsible for the content of these websites and applications and is not responsible for the privacy standards and practices of such third parties. We recommend you to read the relevant privacy policies of these third parties and their websites before you accept their cookies and visit their website to ensure yourself that your personal data is sufficiently protected. Nonetheless, we seek to protect the integrity of our Website and Service Desk and welcome any feedback about these websites and/or applications.
15. Liability
If JARVISS has legitimately transmitted your personal data to a third party (not being its (sub-)processor), JARVISS shall not be liable for any unlawful processing or unlawful use by that third party.
JARVISS is in any case only liable for the damage caused by the processing of personal data if it did not comply with its specific obligations under the GDPR and JARVISS’ liability shall not exceed an amount equal to the amounts actually paid out by our insurer for the damage causing event. JARVISS shall in no event be liable for any special, incidental, indirect or consequential losses or damages.
The foregoing exclusions and limitations shall only apply to the maximum extent permitted by applicable law.
16. Changes to this privacy policy
JARVISS may amend this privacy policy at all times. Any changes we may make to our privacy policy will be indicated on the Website The date of the most recent version is shown below. Please review JARVISS’ privacy policy periodically to stay informed of changes that may affect you.
Amended versions of this privacy policy take effect ten (5) days after their publication on the Website, and/or other form of announcement and, if necessary, will always be submitted for approval, unless such modifications are necessary to comply with a legal requirement. In the latter case, such changes will take effect immediately.
17. Applicable law and competence
This privacy policy shall be governed, interpreted, and implemented in accordance with Belgian laws.
The Ghent courts (division Ghent) are exclusively competent to decide on any dispute that may arise from the interpretation or implementation of this privacy policy, without prejudice to the consumer’s right to present a dispute before a competent court on the basis of a mandatory statutory provision.
Last updated: 17 November 2023