1 General
This notice explains how, as a data controller, Wolters Kluwer Belgium SA (“we”, “us”, “our”, “Wolters Kluwer”) with offices at Motstraat 30, 2800 Mechelen, Belgium (tel: +32 15 36 10 00), processes personal data we collect from you through the codabox.com and zoomit.be websites and Codabox services.
2 Updates to this Privacy Notice
We reserve the right to modify this notice at any time, but will in any case do so in accordance with applicable laws and regulations. We will inform you, when possible, of any substantial changes to this notice.
This notice was last modified and revised on Nov. 2024.
3 Information We Collect
3.1 Customer Relationship
When you or your company becomes a customer of Wolters Kluwer, we collect the following types of personal data about you:
- Identification data: your name, email address, language preference and phone number, we will also assign you or your company a customer number;
- The products you or your company uses and invoicing information.
When you contact us through our website or via email, we collect the following types of personal data about you:
- Identification data: your name, phone number and email address;
- Information about your work: the name of the company you work for;
- The messages you are sending us.
When you give us a bank and teletransmission mandate as basis of the Codabox services, we collect the following types of personal data about you:
- Identification data: your name, phone number, email address and language preference;
- Information about your work: your job title, employer and work address;
3.2 Services Use
When you interact with the Zoomit services, we maintain activity logs; for this we collect your name, email address, IBAN, bank user ID and language preference.
3.3 Customer Support
When we initiate a screen sharing session with you, to support you in the use of our products, we collect the following types of personal data about you:
- Identification data: your name and email address;
- Any information shared during the screen sharing session (audio and video).
3.4 Marketing
When you register for and/or attend an event we organise, we collect the following types of personal data about you:
- Identification data: your name and title, email address and phone number;
- Information relating to your company: your company name;
- Any other information relating to the event.
We also collect personal data about you from other events organisers to which you have provided consent to share those personal data with us.
When you register for and/or attend a webinar we organise, we collect the following types of personal data about you:
- Identification data: your name, email address, phone number and IP address;
- Data relating to your company: its name and VAT number;
- Data relating to security: security logs, connection and activity logs, and the user agent of your web browser;
- The questions you may send during the webinar.
When you participate in one of our surveys, we collect the following types of personal data about you:
- Identification data: your name and email address;
- The responses you provided to the survey.
When you register to our newsletter, we collect the following types of personal data about you:
- Identification data: your name, professional email and language preference;
- Work information: your company name and address;
Your device and usage information are also collected when you read the newsletters.
3.5 Website browsing
While you browse our website, we collect the following types of personal data about you:
- Identification data: your IP address;
- Data relating to security: security logs, connection and activity logs, and the user agent of your web browser;
- When you allow us, we also collect data relating to your use of the website such as the pages you consulted or if you already visited our website in the past.
4 Processing purposes
Your personal data is processed for the following purposes:
- Where it is necessary for the performance of a contract between you and us or in order to take steps, at your request, to enter into a contract:
- To allow you and/or your company users to register and use our services.
- To obtain and maintain mandate access to banks’ data for your company.
- To obtain and maintain mandates for sending your data to your accounting company.
- To send you important communications relating to your use of the services.
- To provide you with the information you have requested and answer your questions when you contact us.
- To provide you with support when you face issues in your use our services.
- To manage the relationship between you, our customer, and us, Wolters Kluwer.
- To invoice your company or relying parties for the use of our services.
- To ensure the security of our services, including your data.
- To allow you to register to and attend our webinars or our events.
- Where you have given your consent:
- To contact you, as per your request, and provide you with more information about our services.
- To contact you, as per your request, and book an appointment with you.
- To allow us to send you promotional offers and information on our Wolters Kluwer products, in line with your choices.
- To send you surveys, allowing us to receive feedback allowing us to improve our products.
- To collect your feedback on our products and services.
- To initiate screen sharing session when you request it to obtain support.
- To place cookies on your browser and perform advanced statistics based on the information Those cookies provide us.
- Where necessary for our legitimate interests, as listed below, and where not overridden by your interests or fundamental rights and freedoms:
- To ensure the security of our Wolters Kluwer applications, services, processes, websites and databases.
- To allow for business correspondence and business meetings to take place.
- To allow review of past calls for training of agents and for quality control.
- To retain traces of actions taken during screen sharing sessions.
- To send existing customers information on the evolution of Wolters Kluwer products; you may request these communications to stop at any time via an unsubscribe link present at the bottom of every communication.
- To improve our services and develop new commercial offers by identifying e.g. trends, recurrent issues, customer behaviours, through your use of our services;
- To advertise our services towards existing customers.
- To get non-nominative information on the visitors that consult Wolters Kluwer websites.
- To create a database of trusted combinations of IBAN numbers and account owners that will be used for fraud prevention purposes.
For these purposes, we have conducted a balancing test, as the law requires, and have determined that, taking into account the limited personal data collected, the processing performed and your reasonable expectations, our legitimate interest in conducting these processing activities is not overridden by your interests or fundamental rights and freedoms.
- Where it is necessary for us to comply with our legal obligations, such as reporting crime or crime intent, or tax reporting.
5 Sharing your personal information
To be able to provide you the best possible Services and further our business operations, we may share certain information internally or with selected third parties. There might also be a certain statutory or legal obligation that we believe in good faith requires us to disclose your personal information externally. Parties we might share data with include:
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- other Wolters Kluwer affiliates or subsidiaries, e.g. for customer data management or providing underpinning technology to support the Services we are delivering;
- our service providers, e.g. for managing or hosting services and/or underpinning technology for the Services we are providing;
- our business partners and advertisers, e.g. if you have purchased or expressed interest in a product or service, or have been delivered or viewed an advertisement, of such a business partner, interacted with them or otherwise authorized the sharing of your personal information with such a business partner;
- subscribing, accrediting or professional organizations, e.g. for providing utilization information to organizations that provide you with access to our Services and/or sharing tracking and redeeming credits for professional accreditation;
- organizations involved in business transfers, e.g. to a purchaser or successor entity in the event of a sale or any other corporate transaction involving some or all of our business;
- other parties, e.g. as needed for external audits, compliance, risk management, corporate development and/or corporate governance related matters; or
- governmental authorities, regulators and other third parties, in response to a legal request, court orders and/or as otherwise necessary to comply with applicable law.
Whenever we share personal information internally or with third parties in other countries, we have appropriate safeguards in place in accordance with the applicable data protection laws, including as applicable the EU Model clauses or other transfer safeguard specified in the applicable data protection laws such as binding corporate rules, a mutual agreement or derogations. As required under the applicable law, third parties are required to use appropriate safeguards to protect personal information, and they can only access the personal information that is necessary for performing their specific tasks.
6 How long do we keep your personal information?
Your personal information will be processed to the extent necessary for the performance of our obligations, to comply with legal obligations, and for the time necessary to achieve the purposes for which the information is collected, in accordance with our data retention policies and the applicable data protection laws. When we no longer need your personal information, we will take all reasonable steps to remove it from our systems and records or take steps to properly anonymize it so that you can no longer be identified from it.
7 Children
Users of Codabox services must be at least 18 years old.
8 Automated decision-making and profiling
No automated decisions will be taken about you as part of the processing described in this notice.
A profile of your behaviour when you use our website will be created by Wolters Kluwer if you accept our advertising and tracking cookies to be placed on your computer.
9 your rights
You have the right to ask us for a copy of your personal data, to ask us to correct, delete or restrict (stop any active) processing of your personal data and to obtain the personal data you provided us in a structured, machine-readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular when we do not have to process your personal data to meet a contractual or other legal requirement).
Where we have asked for your consent, you may withdraw this consent at any time; however, this will not affect processing that has already taken place before the withdrawal. You may withdraw your consent, linked to our use of cookies, by deleting the cookies linked to our domain.
You may exercise the above-mentioned rights by contacting us as described in the “Contact us” section below.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information that we are required to keep by law or that we have a compelling legitimate interest to keep.
If you have unresolved concerns, you have the right to complain to the Data Protection Authority: https://www.dataprotectionauthority.be/.
10 Contact us
If you have any questions about this Privacy Notice or wish to contact us for any reasons in relation to the processing of your personal data, please contact our Data Protection Officer, by sending an email to wkbe-gdpr@wolterskluwer.com, or by sending a dated and signed request to Wolters Kluwer Belgium NV, Motstraat 30, 2800 Mechelen, Belgium (tel: +32 15 36 10 00).
