1. Data controller

WE ARE THE WORDS srl (hereinafter “WAW” or the “Data Controller”)

Registered office address: 70 Rue aux Laines, 1000 Bruxelles

CBE/VAT number: 0468.354.206, registered with the Register of Legal Entities of Brussels

Website: wearethewords.com (hereinafter the “Site”)

Contact email address: hello@wearethewords.com

Telephone: +32 2 340 16 80

2. Introduction

WAW establishes this Privacy Policy, the purpose of which is to protect the data of our clients, service providers and suppliers (hereinafter the “Users”).

To this end, WAW determines and implements all the technical, legal and organisational means and purposes of the processing of the Users’ personal data. For this purpose, WAW undertakes to take all necessary measures to ensure that personal data are processed in compliance with the Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data and with the European Regulation of 26 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

3. Purpose

Our privacy policy aims to inform you of the nature of the data collected, their purpose and recipient, and their retention period, as well as of your rights. Mindful of the confidentiality of the data transmitted, we guarantee that your data are in no case transmitted to third parties, but are for the sole and exclusive use of WAW and its teams.

4. Nature and purpose of the data collected

The data collected meet the needs of our business relationships, our communication and our recruitment policy.

They may be identification information such as your surname, first name, title, email, telephone and/or mobile number, and the name of your organisation, in order to enable us to establish a quality business relationship.

They may also be log files, compiled from your browsing by means of cookies, for the sole purposes of aggregated statistics, the quality of your browsing experience and the personalisation of the content delivered to you.

In accordance with Article 13 of the Regulation, the purposes of the processing of personal data are communicated to the User and are as follows:

  • To ensure the performance, continuity and improvement of the Services;
  • To ensure the sending of useful information relating to the activities;
  • To ensure compliance with legal obligations;
  • To ensure the development of the business, and the expansion and maintenance of business relationships with clients and service providers;
  • To ensure accounting management and the management of data flows with suppliers;
  • To ensure the archiving and retention of data;
  • All other ancillary purposes relating thereto, and other purposes to which individuals or organisations may from time to time agree.

The personal data collected by WAW will only be stored and hosted on secure servers in the European Union.

5. Consent

By accessing and using the Site, the User declares that they have read and have freely, specifically, knowingly and unambiguously agreed to the processing of the personal data concerning them. This agreement covers the content of this Privacy Policy.

The User consents to the Data Controller processing and collecting, in accordance with the terms and principles contained in this Privacy Policy, the personal data that the User communicates on the Site or in connection with the services offered by WAW, for the purposes indicated above.

The User has the right to withdraw their consent at any time. The withdrawal of consent does not compromise the legitimacy of the processing based on consent previously given.

6. Collection and destination of your data

In the context of our business relationships, the sales and accounting teams are recipients of your data. They are all responsible and bound by confidentiality clauses included in their employment contract.

These data are collected:

  • During a business contact: contact information is entered into our CRM and then updated during our collaboration.
  • When you browse our website: via secure forms to get in touch with the agency or ask it a question.
  • In the context of our communication: browsing statistics are intended for our technical and communication teams and shared with the agency’s management.
  • When you browse our website (in particular via Google Analytics), via secure forms to get in touch with our teams, by sending an email or through a contact on social networks. You can deactivate this feature by downloading the browser add-on for deactivating Google Analytics at https://tools.google.com/dlpage/gaoptout/.
  • In the context of our recruitment: your applications are received and processed by our HR department, then shared with the operational staff who requested the recruitment.

7. Data retention period and deletion

WAW complies with the legislation in force (Article 13 §2 of the Regulation and of the Act) and applies the following retention periods:

  • Prospecting data: 36 months – prospects who have made contact to obtain commercial information. This information enables us to inform you about our market, our news (newsletter) and our commercial events (breakfasts, invitations…).
  • Client and partner data: 36 months – This information also enables us to inform about our market, news and commercial events, and also to guarantee a quality business relationship.
  • Recruitment data: 24 months – this information enables us to contact you again in the event of a new opportunity that matches your skills.

Note: deletion takes place at the end of the retention period if no new event has occurred during that period. Any new event restarts the retention period.

8. Security of the data collected

We attach great importance to the security of your data.

Appropriate technical and organisational measures are implemented so that the data are processed in a manner that guarantees their protection against accidental loss, destruction or damage that could undermine their confidentiality or integrity.

When developing and designing, or when selecting and using, the various tools that enable personal data to be processed, we make sure that they ensure an optimal level of protection of the data processed. That is why we implement all appropriate measures to prevent, as far as possible, any alteration or loss of your data, or any unauthorised access to them.

WAW thus implements measures that respect the principles of data protection by design and data protection by default for the data processed.

When we use a service provider, we only communicate personal data to it after obtaining from it a commitment and guarantees as to its ability to meet these security and confidentiality requirements.

In compliance with our legal and regulatory obligations, we conclude with our processors a contract that precisely defines the conditions and terms of their processing of personal data.

Likewise, WAW carries out annual audits of its own departments in order to verify the application of the data security rules.

9. Recipients of the data and disclosure to third parties

Personal data may be transmitted to WAW’s staff, service providers or suppliers who offer adequate data security guarantees and who work with WAW in the context of the marketing of products or the provision of services. They act under the direct authority of WAW and are, in particular, responsible for collecting, processing or sub-processing these data.

In all cases, the recipients of the data and those to whom these data have been disclosed respect the content of this Privacy Policy. WAW ensures that they will process these data solely for the intended purposes, discreetly and securely.

Should the data be disclosed to third parties for marketing, direct marketing or prospecting purposes, the User will be informed beforehand so that they may give or refuse their consent to the use of this personal data.

10. Users’ rights

You may at any time verify, update or delete the information concerning you. The General Data Protection Regulation gives you the possibility of consulting your personal data and of deleting your personal data held in our databases.

At any time, the User may exercise their rights of access, rectification, erasure, restriction of processing, data portability, objection and automated individual decision-making, and complaint, by sending an email to the following address: hello@wearethewords.com.

Finally, we inform you that, in the event of an unsatisfactory response, you may lodge a complaint with the Data Protection Authority at the following contact details:

Autorité de Protection des données (Data Protection Authority) Rue du Prince, 35 1000 Bruxelles +32 (0)2 274 48 00 +32 (0)2 274 48 35 contact@apd-gba.be

The User may also lodge a complaint with the Court of First Instance of their place of domicile if they consider that the processing of their personal data would cause them harm.

11. Amendments to this privacy statement

We will update this privacy statement, where necessary, to take account of client feedback and of changes made to our products or services. When we publish changes to this statement, we revise the “last updated” date at the top of the statement. We encourage you to consult this privacy statement regularly to find out how WAW protects your information.