Whistleblowing Policy

WorxInvest cares deeply about your privacy. Therefore we only process data that we need to offer (and improve) our services and we handle the information we have collected about you and your use of our services very cautiously. We never make your data available to third parties for commercial purposes.

This privacy policy applies to the use of the website and the services provided by WorxInvest. The starting date for the validity of these conditions is 12/04/2018. With the publication of a new version the validity of all previous versions expires. This Privacy Policy describes which personal data we collect, what this data is used for and with whom and under which conditions this data can possibly be shared with third parties. We also explain to you how we store your data and how we protect your data against misuse and which rights you have with regard to the personal data you provide us.
If you have any questions about our privacy policy, please contact our privacy contact person. You can find the contact details at the end of our privacy policy.

About data processing

Below you can read how we process your data, where we save it, which security techniques we use and who has access to the data.

Webhosting

We use web hosting services from SiteGround. SiteGround processes personal data on our behalf and does not use your data for its own purposes. However, this party can collect metadata about the use of the services. These are not personal data. SiteGround has taken appropriate technical and organizational measures to prevent loss and unauthorized use of your personal data. SiteGround is obliged to observe secrecy on the grounds of the agreement.

Emails and mailing lists

Sparkpost

We send our transactional emails via Sparkpost. Sparkpost will never use your name and e-mail address for its own purposes. Sparkpost reserves the right to use your data for the further improvement of the services and to share information with third parties in this context.

Purpose of data processing

General purpose of the processing

We only use your data for the benefit of our services. This means that the purpose of the processing is always directly related to the assignment you provide. We do not use your data for (targeted) marketing. If you share information with us and we use this information to contact you at a later date – other than at your request – we will explicitly ask your permission. Your information will not be shared with third parties, other than to comply with accounting and other administrative obligations. These third parties have all been kept confidential on the basis of the agreement between them and us or an oath or legal obligation.

Automatically collected data

Data that is automatically collected by our website is processed with the aim of further improving our services. This information (eg your IP address, web browser and operating system) is not personal data.

Participation in tax and criminal investigation

In some cases, WorxInvest can be held on the basis of a legal obligation to share your data in connection with government tax or criminal investigations. In such a case, we are forced to share your data, but we will oppose this within the possibilities that the law offers us.

Retaining personal data

We keep your information as long as you are our client. This means that we keep your customer profile until you indicate that you no longer wish to use our services. If you indicate this to us, we will also consider this as a request to be forgotten. On the basis of applicable administrative obligations, we must keep invoices with your (personal) data, so we will keep this data for as long as the applicable term runs. However, employees no longer have access to your client profile or to documents that we have produced in connection with your assignment.

Your rights

On the basis of the applicable Belgian and European legislation, you as a data subject have certain rights with regard to the personal data processed by or on behalf of us. We explain below which rights these are and how you can invoke these rights.
In principle, in order to prevent abuse, we will send copies and copies of your data only to your already known email address. In the event that you wish to receive the data at another email address or for example by post, we will ask you to identify yourself. We keep records of completed requests, in the case of a request to be forgotten we administer anonymous data. You will receive all copies and copies of data in the machine-readable data format that we use within our systems.
You have the right to file a complaint with the Dutch Data Protection Authority at any time if you suspect that we are using your personal data in the wrong way.

Right of inspection

You always have the right to inspect the data that we process or have processed that relate to your person or that can be traced back to you. You can submit a request to that effect to our privacy contact person. You will receive a response to your request within 30 days. If your request is granted, we will send you a copy of all data with an overview of the processors who have this data, with the email address known to us, stating the category under which we have stored this data.

Right to rectification

You always have the right to adjust the data that we process or have processed that relate to your person or that can be traced back to this. You can submit a request to that effect to our privacy contact person. You will receive a response to your request within 30 days. If your request is granted, we will send you a confirmation that the details have been changed on the email address known to us.

Right to limiting the processing

You always have the right to limit the data that we process or have processed related to your person or that can be traced back to you. You can submit a request to that effect to our privacy contact person. You will receive a response to your request within 30 days. If your request is granted, we will send you a confirmation to the email address known to us that the data until you cancel the restriction will no longer be processed.

Right to portability

You always have the right to have the data that we process or have processed and that relate to your person or that can be traced back to you, performed by another party. You can submit a request to that effect to our privacy contact person. You will receive a response to your request within 30 days. If your request is granted, we will send you copies or copies of all information about you that we have processed or that have been processed by us by other processors or third parties on the email address known to us. In all likelihood, we will no longer be able to continue the service in such a case, because the secure linking of data files can then no longer be guaranteed.

Right of objection and other rights

In certain cases you have the right to object to the processing of your personal data by or on behalf of WorxInvest. If you object, we will immediately stop the data processing pending the settlement of your objection. If your objection is well-founded, we will provide you with copies and / or copies of data that we process or have processed and then permanently discontinue the processing.
You also have the right not to be subject to automated individual decision making or profiling. We do not process your data in such a way that this right applies. If you are of the opinion that this is the case, please contact our contact person for privacy matters.

Cookies

Google Analytics

Through our website, American company Google places cookies as part of the “Analytics” service. We use this service to track and get reports on how visitors use the website. This processor may be obliged to provide access to these data on the basis of applicable laws and regulations. We have not allowed Google to use the obtained analytics information for other Google services.

Cookies from third parties

If any third-party software makes use of cookies, this is stated in this privacy statement.

Changes to the privacy policy

We reserve the right to change our privacy policy at any time. On this page you will always find the most recent version. If the new privacy policy affects the way in which we process already collected data relating to you, we will notify you by e-mail.

In case of any questions contact Gert Beeckmans, Chief Risk & Security Officer: gert.beeckmans@sdworx.com.

Whistleblowing

As part of the WorxInvest group, WorxInvest Horizon is always committed to acting ethically and in line with laws and regulations. We encourage all our internal and external stakeholders to report illegal or unethical behavior within WorxInvest. Reporting this (whether anonymously or not) can be done through the WorxInvest whistleblowing portal which can be accessed via the following link: https://worxinvest.sdwhistle.com/en/home

Your reports will be treated confidentially and the European rules on whistleblowing will apply.