Privacy Policy
This privacy policy (“Privacy Policy”) is applicable to all processing activities of Alice as a data controller. Please read this Privacy Policy together with our Cookie Policy. This is the first and only Privacy Policy we have. Alice may update this Privacy Policy in the future; the latest version can always be found on our Website.
1. About this Privacy Policy
Due to, for example, your commercial relationship or recent contact with Alice or due to a visit to or action on our “Website” (https://www.alice.law including related sub-domains) we may collect, store and otherwise process personal data relating to you or, if you are a company, your employees/representatives (“your personal data”).
This Privacy Policy describes (i) how we collect, treat and store your personal data; (ii) the rights you can exercise in relation to your personal data; and (iii) the measures we take to protect it and to secure your personal data.
Alice respects your privacy and we always strive to act in accordance with the applicable privacy legislation, such as (non-exhaustive): (i) the General Data Protection Regulation 2016⁄679 of April 27, 2016 (“GDPR”) and (ii) the Belgian Privacy Law of 30 July 2018; (together: “Data Protection Legislation”).
2. Alice is the data controller
We are Alice BV, a limited liability company with registered office at 8200 Brugge (Belgium), Diksmuidse Heerweg 126, registered with the Crossroads Database for Enterprises under number 1019.819.101 (“Alice” or “we/us”). Alice is the developer and provider of the solution as described and represented on the Website (the “Solution”), the corresponding service of Alice (“Service”) and is the owner of the Website. In light of the Data Protection Legislation, Alice will act as the data controller of your personal data for the purposes described in this Privacy Policy.
3. Alice's processing activities
Which personal data we collect, store and process and the purpose for which we process this data may differ depending on your relation with Alice. In particular, we identify five different scenarios: (i) You are browsing on our Website; (ii) You (wish to) receive direct marketing (such as updates and newsletters) relating to Alice’s services and products (inc. the Solution); (iii) You are a prospect and/or seeking a commercial relationship with Alice; (iv) Your company is an active Alice customer and/or seeking a commercial relationship with Alice; or (v) You are | your company is a partner or a supplier of Alice.
3.1 You are browsing on our Website
Contacting Alice via the contact form/bot on the Website.
Purpose: to answer any questions you may have and/or to initiate a conversation.
Personal data: first name, voluntarily provided information, last name, (work) email address, nature of inquiry
Legal ground: Consent.
Retention period: Up until one (1) year after your last contact with Alice.
Cookies: when browsing on our Website, we may also collect your personal data through cookies stored on your device(s) in order to optimize the functioning of the Website. Please consult our Cookie Policy for more information.
3.2 You (wish to) receive direct marketing (such as updates and newsletters) relating to Alice services and products
Direct marketing
Purpose: providing more information on (new features of) the Solution, our Service or related products/services.
Personal data: first name, (work) email address, last name.
Legal ground: consent.
Retention period: Until you have objected to the processing of your personal data for this purpose (cfr. Section 8- “Right to object”). You will be automatically unsubscribed if we did not contact you for over a year.
3.3 You are a prospect and/or seeking a commercial relationship with Alice
Requesting a personal demo
Purpose: to schedule your personal demo of the Alice Solution.
Personal data: first name, (work) email address, last name.
Legal ground: consent.
Retention period: Until you have requested to no longer be contacted by Alice or until one (1) year following your latest contact with Alice, whichever comes first.
General communication with Alice & prospecting by Alice
Purpose: to have quality conversations (via mail, telephone or business social media channels) in which Alice provides more information on its Service and the Alice Platform.
Personal data: first name, (work) email address, last name, phone number, company name, country, type of industry, preferred Language, social media/business channel, voluntarily provided information.
Legal ground: legitimate interest to ensure promotion of Alice’s activities.
Retention period: Until you have requested to no longer be contacted by Alice or until one (1) year following your latest contact with Alice, whichever comes first.
Registering for | attending an Alice (network) event
Purpose: to have an overview of the participants in the event (e.g. after work, webinar, seminar, contest) as well as to have a follow-up communication after the event.
Personal data: first name, (work) email address, last name, company.
Legal ground: Consent.
Retention period: Until you have requested to no longer be contacted by Alice or until one (1) year following your latest contact with Alice, whichever comes first.
3.4 Your company is an active Alice customer
If you read this Policy as an employee of a company (“End-User”) relying on Alice, please note that your employer (“Customer”) is to be considered your data controller (as your employer decided to rely on the Solution, choses if you get an account, etc.). To set up the Solution, your employer might have provided us with some of your personal information (e.g. your name, your email-address, etc.). In this context, Alice has adopted a Data Processing Policy. For more information regarding the Solution, you can always directly contact your employer. Nevertheless, in some exceptional cases, Alice will act as your data controller. More specific, Alice will act as your data controller the following purposes:
General communication and (technical) support
Purpose: to enable communication with & to provide support to customers.
Personal data: first name, (Work) email address, Last name, Preferred language, Job function, Voluntarily provided information, Phone number.
Legal ground: In relation with the Customer: necessary for the performance of the agreement. In relation with the End-Users: legitimate interest to solve (technical) issues as quick as possible and to communicate with those designated by the Customer.
Retention period: Until one (1) year following the termination of the commercial relationship between your company and Alice.
Billing
Purpose: to prepare invoices for the Service | use of the Alice Platform.
Personal data: First name, Company, Last name, (Work) email address, Address, VAT-number, Job function.
Legal ground: Necessary for the performance of the agreement.
Retention period: Until one (1) following the termination of the commercial relationship between your company and Alice.
Quotes | proposals
Purpose: to draw up (additional) quotes | proposals
Personal data: First name, Company, Last name, (Work) email address, Address, VAT-number, Job function.
Legal ground: Legitimate interest to send necessary information prior to concluding an agreement.
Retention period: Until one (1) year following the termination of the commercial relationship between your company and Alice.
3.5 You are | your company is a partner or supplier of Alice
General communication and provision of services
Purpose: to communicate with you in the scope of our commercial relationship.
Personal data: First name, Email address, Last name, Phone number, Company, Preferred Language, Job function, Voluntarily provided information.
Legal ground: In relation with the Customer: necessary for the performance of the agreement. In relation with the End-Users: legitimate interest to communicate with those designated by the Customer.
Retention period: for the duration of your commercial relationship with Alice and in any event accordance with any (data processing) agreements concluded with Alice.
Billing
Purpose: to pay your invoices for the services provided (incl. corresponding communication).
Personal data: First name, Company, Last name, (Work) email address, Address, Financial data (e.g. bank account number), Job title, VAT-number.
Legal ground: necessary for the performance of the agreement.
Retention period: for the duration of your commercial relationship with Alice and in any event accordance with any (data processing) agreements concluded with Alice.
4. Legal Grounds
You can find more information on the applicable ground for each of the identified processing activities in Section 3 above. In case the legal ground for processing happens to be legitimate interest, Alice shall always (i) assess whether this is in proportion with the purpose for which your personal data was collected and used; and, (ii) take your reasonable expectations into account and ensure a balance with your fundamental rights and freedoms.
5. Retention Period
Unless a longer storage period is required or justified (i) by law or (ii) through compliance with another legal obligation, Alice shall only store your personal data for the period necessary to achieve and fulfil the purpose in question.
6. Disclosure of Personal Data to Third Parties
Alice shall not disclose your personal data to other third parties, unless it is necessary to achieve the purposes described in this Privacy Policy. In this respect, (some of) your personal data may be disclosed to:
- Processors acitng on our behalf (meaning partners, suppliers, subcontractors, external service providers engaged by Alice, …), such as software and cloud providers, marketing agencies, freelancers, web hosting companies, analytics tool suppliers, translation agencies, etc. Alice concludes a processing agreement with the parties that have access to personal data for the performance of their services;
- Marketing and communications consultants;
- IT service providers providing technical support;
- External lawyers and advisers: in certain cases, we may disclose your personal data (including your email correspondence) to lawyers and external advisers where this is necessary to provide us with advice or to pursue our or you rights;
- Bookkeepers, accountants, insurance brokers and insurers of Alice;
- Supervisory authorities and other authorities: in certain cases, we may disclose your personal data to supervisory authorities, police, judicial or other authorities if we believe that we are obliged to do so under appliable laws or regulations or on the basis of another lawful request or order;
- To the buyer (or potential buyer) of any business or assets we sell (or are considering selling).
7. Cross-Border Processing of Personal Data
In case any of the above-mentioned third parties or other recipients are located in a country outside the European Economic Area, Alice will ensure that one or more of the listed EU-approved safeguards are in place: (i) European Commission adequacy decision; (ii) Data transfer agreement (cfr. the Standard Contractual Clauses as provided in the European Commission Implementing Decision (EU) 2021/914 of 4 June 2021, including the performance of a transfer impact assessment); (iii) Binding corporate rules; or, Certification mechanisms.
8. Your Data Protection Rights
The Data Protection Legislation (e.g. GDPR) gives you certain rights over your personal data vis-à-vis Alice. You can exercise these rights by contacting us, as specified in Section 11, and by using the data subject’s rights form.
- Access: you can ask for confirmation of whether or not personal data that relates to you is being processed. If so, you can ask us to give you copies of your personal data. We may charge you a small fee for this service:
- Rectification: you can ask us to correct | complete any information you believe is inaccurate | incomplete;
- Erasure: you can ask us to erase your personal data, under certain conditions. Please be aware that in this context certain services will no longer be accessible and/or can no longer be provided.
- Objection: You can object to us processing your personal data without substantiation in the case of direct marketing at any time, or with substantiation in other cases.
- Restriction of processing: you can ask us to restrict the processing of your personal data, unless we have legitimate interests for the processing of your personal data that prevail over your interests.
- Data portability: you can ask us to transfer your personal data to another organization, or directly to you in a commonly used structured format readable by automatic device.
You have the right to request not to be the subject of profiling, and you may object to the processing of your personal data, without giving reasons in the case of direct marketing, or on grounds relating to your particular situation in other cases.
If the processing of your personal data is based on your consent, you may withdraw your consent at any time. Withdrawal of your consent does not affect the lawfulness of the processing based on consent before your withdrawal. Please note that in such cases it will no longer be possible to render our services to you.
You can send your dated and signed request based on the above rights to hello@alice.law. Alice cannot handle your request without proof of your identity. Please note that the applicable legislation may include exceptions to and impose conditions on the exercising of the above rights.
You also have the right to lodge a complaint with the authorized supervisory authority (i.e. the Belgian Data Protection Authority or the data protection authority of (i) your residence or (ii) your workplace) should you consider that the processing of your personal data infringes the Privacy Legislation. You can send an email to the Belgian Data Protection Authority at contact@apd-gba.be or any other email address provided by the Belgian Data Protection Authority (https://www.dataprotectionauthority.be/citizen/actions/contact).
9. Security
Alice undertakes to take reasonable, physical, technological and organizational precautions in order to avoid (i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data.
10. Updates
We are entitled to update this Privacy Policy by posting a new version on the Website whereby we will indicate the revision date at the top of this Privacy Policy. As such, it is strongly recommended to regularly consult the Website and the page displaying the Privacy Policy, to make sure that you are aware of any changes.
11. Notifications and Questions
Notifications under this Privacy Policy (such as, exercising your rights as a data subject) and/or any questions or concerns with regard to the provisions of this Privacy Policy must be directed to hello@alice.law.