Last updated on 10/06/2020

This Privacy & Cookie Policy applies to your use of Alundi, a user-friendly app that uses the platform for internal communication of Alundi bv. Alundi includes an online platform for the management and a free app for the users. Before using Alundi in any way, we would like to ask you to read this Privacy & Cookie Policy carefully. It contains essential information about how we process your personal data, which cookies we use, the rights you can exercise and the measures we take to protect your personal data.

By using Alundi, you declare to have read this Privacy & Cookie Policy and you explicitly agree with its content.

The controller of the processing of your personal data is the company with which you have concluded an employment contract for an indefinite or fixed term (hereinafter: "your employer").

We, Alundi bv, are a processor in the sense of the General Data Protection Regulation (hereafter: GDPR) and will only process your personal data in accordance with the instructions of your employer.

TABLE OF CONTENTS

Article 1 - What data we process about you

Article 2 - What we use your personal data for

Article 3 - How we share your personal data with third parties

Article 4 - How long we retain your personal data

Article 5 - Your rights

Article 6 - How we secure your personal data

Article 7 – Cookies

ARTICLE 1 WHAT DATA WE PROCESS ABOUT YOU

By order of your employer, Alundi bv collects and processes different categories of personal data related to you within the framework of the use of Alundi:

• Category 1 - With each use of Alundi, based on cookies and similar technologies, different personal data about you may be collected, in particular your IP address, date and time of use of Alundi, type of device, general location, operating system and browser.
• Category 2 - When you use the functionalities of Alundi, we may collect information about you, in particular your surname, first name, mobile number, employee number, national register number, date of entry and exit, date of birth, gender, function, language, campaign history, communication preferences, contact history, surveys and feedback, profile picture, authentication data, account information, geo-location, viewing and behavioral data, logging and monitoring data, content data including all forms of content uploaded, stored and transferred by you and any other data you transmit to us.
• Category 3 - When you use the functionalities of Alundi, we may also collect sensitive data about you, in particular medical data.
• Category 4 - If you call, email or request support from us, we may collect the following personal data: your name, email address, telephone number, as well as the data you provide yourself.

ARTICLE 2 WHAT WHE USE YOUR PERSONAL DATA FOR

Alundi bv will use your personal data exclusively on behalf of your employer:

• Category 1 - To maintain and improve Alundi and to include personal data in anonymous statistics from which the identity of specific persons cannot be traced, with as legal basis your explicit prior consent at the time of your first visit to Alundi.
• Category 2 - To create and manage a user profile for you, in order to provide you with access to Alundi and for the personnel management, with the execution of our agreement with you as a legal basis, the fulfilment of a legal obligation and/or your explicit, prior consent to the extent required by law.
• Category 3 - Personnel management, with as legal basis your explicit prior consent and/or legitimate interest
• Category 4 - To be able to deal with and answer your question, request or other report, with as legal basis your explicit, prior consent online and our justified interest in telephone contact.

ARTICLE 3 HOW WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES

1. Your employer uses Alundi bv as a third party service provider. If this is necessary for their services, your employer can transfer your personal data to Alundi bv. Alundi bv is a processor in the sense of the GDPR and will only process your personal data in accordance with the instructions of your employer.
2. Alundi may call upon third parties who keep personal data outside the European Economic Area. We take all possible measures to guarantee the security of your data and expect these third parties to keep your data as secure as we do ourselves. We also comply with the data export obligations imposed on us by the GDPR.
3. If we ever cease our activities or transfer them to someone else, for example because we go bankrupt or sell our activities, this may mean that your personal data will be transferred to third parties who will take over all or part of our activities. In that case, we will always inform you in advance to the extent possible, but you understand that this is not technically or commercially feasible under all circumstances.
4. In rare cases, we may be required to disclose personal data to competent authorities on the basis of a court order or in order to comply with other mandatory laws or regulations. We will try to inform you in advance to the best of our ability, unless we are unable to do so for legal reasons.

ARTICLE 4 HOW LONG WE RETAIN YOUR PERSONAL DATA

We will retain your personal data for as long as this is necessary in accordance with the purposes of processing and statutory regulations. Six months after your employment contract is terminated, all your personal data will be rendered anonymous.

ARTICLE 5 YOUR RIGHTS

You have the right to access your personal data and the use we make of those personal data free of charge at any time. You have the right to request us to correct, supplement or remove your personal data. In a number of cases listed in the GDPR, you may also ask us to limit the processing of your personal data. You have the right to object to the processing of your personal data if you have serious and legitimate reasons beyond our need to process your data. You also have the right to object at any time to the use of personal data for direct marketing purposes, even without having to give a reason. You have the right to request your personal data in digital and readable form and/or to have them transferred to another service provider of your choice.  Insofar as our processing is based on your prior consent, you have the right to revoke that consent.

You can exercise your rights by sending an e-mail to hello@alundi.eu. You can also exercise your rights at any time with your employer's HR department.

You have the right to lodge a complaint with the Belgian Data Protection Authority:
Rue de la Press 35
1000 Brussels
Tel : +32 (0)2 274 48 00
contact@apd-gba.be.

If necessary, you can also go to the civil court to claim damages.

ARTICLE 6 HOW WE SECURE YOUR PERSONAL DATA

We have taken the appropriate technical and organizational security measures to ensure the safety of your personal data. In addition to intensive awareness training for everyone who has access to personal data, we also provide the necessary checks. Firewalls, data encryption and anti-virus software are always up to date in order to guarantee the highest form of security.

Under no circumstances can Alundi bv be held responsible for any direct or indirect damage resulting from an erroneous or unlawful use of personal data by a third party.

ARTICLE 7 COOKIES

Alundi uses cookies and similar technologies. This helps us to offer you a better user experience when using Alundi and also allows us to optimize Alundi. Without your prior consent, we only place the purely functional cookies that are necessary for Alundi to work correctly. For all other cookies, we first ask for your consent.

The cookie list below gives you an overview of the cookies Alundi uses.

Cookie list

A cookie is a small text file containing data that a website (when a user visits it) wants to store on your device in order to remember information about you, such as your language preference or login information. These cookies are set by us and are called internal cookies. We also use external cookies, i.e. cookies from a different domain than where you are located. We use cookies and other tracking technologies for the following purposes:

Strictly necessary cookies

These cookies do not store any personally identifiable information, but are necessary for Alundi to work and cannot be disabled for that reason. In most cases, these cookies are only used when you request a service, for example, register your privacy settings, log in to Alundi or fill out a form. You can set to block these cookies or to warn you about them, but some parts of Alundi will not work.

Name	Origin	Function	Retention Time
Session	Alundi	Keeps data for the current login session	Up to 30 minutes after last activity

Functional cookies

These cookies allow Alundi to offer additional features and personal settings. They can be set by us or by external service providers that we have placed on our pages. If you do not allow these cookies, these or some of these services may not work correctly.

Name	Origin	Function	Retention Time
Preferences	Alundi	Maintains preferences, e.eg. filters and table sizes	18 months

If you find that other cookies are placed through Alundi, we thank you to notify us immediately so that we can make the necessary adjustments.

We will give you as much information as possible about cookies placed by third parties. However, if you would like to know more, please refer to the privacy statements of these parties on their respective websites. Please note that we have no influence on the content of those statements, nor on the content of the cookies of these third parties.

On your first visit to Alundi, you will be asked to accept our cookies. You can then manage your choices at any time.

If you have any further questions or comments regarding the processing of your personal data, please contact us by e-mail at hello@alundi.eu. You can also contact your employer's HR department at any time.

More information about cookies can also be found at: http://www.allaboutcookies.org/.

More information about online behavioural advertising and online privacy can be found here: http://www.youronlinechoices.eu/.