1. Who are we?

The protection of your personal data is of the highest importance to Introw BV. In this privacy statement, we describe the measures that are taken to guarantee the protection of your personal data in accordance with the European General Data Protection Regulation (GDPR). With this explanation, we want to clearly inform you how we take care of your personal data within Introw BV, what personal data we collect from you and why Introw BV does this.

Introw BV, with registered office at 9000 Gent and VAT number BE0798161431, is the controller for the processing of personal data in the various processes and systems applicable to or used by Introw BV.

As the controller, Introw BV takes the necessary technical and organisational measures to protect your personal data. These measures apply to all systems, employees and processes that constitute the information systems of Introw BV.

2. Activities of Introw BV

The activities of IntrowBV are specifically aimed at automating partnerships through relatingship-based sales.

3. What personal data do we collect?

Personal data means “any information relating to an identified or identifiable natural person”.

Introw BV collects and processes various personal data relating to you in connection with providing its service.‍

3.1 INTROW BV PROCESSES THE FOLLOWING DATA:

Personal identification data: full name, e-mail address, (personal) images, pictures, illustrations, avatars & photos, company name

The personal data we collect is adequate and relevant to our purposes. We limit our collection of your personal data to the minimum amount required for the purposes for which we process the personal data. Introw BV does not collect or process sensitive personal data.‍

3.2. THE FOLLOWING PERSONAL DATA ARE PROCESSED BY INTROW BV IF YOU VISIT OUR WEBSITE AS A USER:

The website is accessible anonymously. However, joining the waitlist requires users to provide their full name and e-mail address. This will be used to reach out to the user in a further stage and provide services, in which other personal identification data s mentioned in 3.1 can be requested.

4. Why do we collect your personal data?

Introw BV collects your personal and business data in order to automate your sales with partners.

We need this company data in order to conduct our standard business operations. In accordance with the GDPR, this corresponds to the "Legitimate Interest of the Data Controller". This means that you have not given us consent and we do not need it for the performance of our activities.

5. How do we collect your data?

Introw BV collects your data because you explicitly entered or transferred this data or because it is required to deliver the service.

Introw BV also collects your data on the one hand because you log in to our website or mobile application.

6. How long will your data be kept?

Introw BV will retain your personal data for as long as is reasonably necessary for the purposes described in this document. This means that your current active company data will be kept and offered for as long as our website is consultable by its users.

If you are registered with Introw BV with a subscription formula, we respect the statutory retention periods linked to this as stated in Article 12. If you have any further questions about this, please contact hellow@introw.io

7. With whom do we share your data?

7.1 IN ORDER TO OPERATE OUR DATABASE, WE MAY SHARE YOUR PERSONAL AND/OR BUSINESS DATA WITH OUR SOFTWARE SUPPLIERS AND PARTNERS WITH WHICH INTROW BV COLLABORATES. THIS MEANS THAT OUR SUPPLIERS PROVIDE SUPPORT FOR THE INFORMATION SYSTEMS, PERFORM UPDATES, OR THAT INTROW BV HAS INTEGRATIONS PERFORMED WITH SOFTWARE PACKAGES. IF INTROW BV IS EXPOSED TO AN INTERNAL AUDIT BY AN EXTERNAL PARTY, WE MIGHT HAVE TO SHARE YOUR PERSONAL AND/OR BUSINESS DATA WITH THIS EXTERNAL PARTY.

If Introw BV uses an external processor (suppliers and partners as described above), we will always ensure that your data is treated confidentially and used securely. The external processor will always be contractually bound to Introw BV. Thus, the processor will never be allowed to use your personal data on its own initiative.

Introw BV may be instructed to share your personal data with third parties if:

We are obliged to do so as part of a regulatory or legal procedure (see 7.2);We are requested to do so by legislative or judicial authorities (see 7.3);‍

7.2. A FULL OR PARTIAL REORGANISATION OR TRANSFER OF BUSINESS OF INTROW  BV, WHEREBY IT REORGANISES, TRANSFERS, CEASES ITS BUSINESS ACTIVITIES OR IF INTROW BV GOES BANKRUPT, MAY RESULT IN THE TRANSFER OF YOUR DATA TO NEW ENTITIES OR THIRD PARTIES THROUGH WHICH THE BUSINESS ACTIVITIES OF INTROW BV ARE WHOLLY OR PARTIALLY CARRIED OUT.

Introw BV will try, to a reasonable extent, to inform you in advance of the fact that Introw BV will disclose your data to said third parties, but you also acknowledge that this is not technically or commercially feasible in all circumstances.‍

7.3. IN RARE CASES, INTROW BV MAY BE REQUIRED TO DISCLOSE YOUR PERSONAL DATA AS A RESULT OF A COURT ORDER OR TO COMPLY WITH OTHER MANDATORY LAWS OR REGULATIONS. INTROW BV WILL MAKE REASONABLE EFFORTS TO INFORM YOU IN ADVANCE IN THIS RESPECT, UNLESS THIS IS SUBJECT TO STATUTORY RESTRICTIONS.

8. Access to third parties

In order to process your personal data, we grant access to your personal data to our employees. We guarantee a similar level of protection by establishing a contractual agreement between Introw BV and the employee. The employees of Introw BV are obliged to follow our GDPR - awareness training and to stay up to date regarding GDPR knowledge.

9. Social media

Introw BV has a company page on LinkedIn to inform you about our services, current topics, events, working at Introw BV, etc. You are free to follow Introw BV or not on these social media.

Introw BV informs its users via newsletters. If you want to unsubscribe, you can do so in the mail of the newsletter (unsubscribe link at the bottom).

10. How do we secure your personal data?

Your personal data is considered as strictly confidential. We have therefore implemented the necessary technical and organizational measures to guarantee the security of your personal data.

Introw BV makes every effort to thoroughly secure its network against unauthorized access and to protect the confidentiality of the personal and business data of its users. The Introw BV website uses a secure SSL certificate to ensure that your personal data do not fall into the wrong hands. Encryption of information during storage, firewalls and similar measures are some of the security measures Introw BV has implemented in its information systems.

In terms of organisation, we have a privacy statement and clear responsibilities and powers. The necessary processes and procedures are also in place to optimally implement and follow this policy.

11. What are your rights and how can you enforce them?

As a data subject you have several rights, these are listed in the GDPR and include.‍

11.1 RIGHT OF ACCESS AND INFORMATION:

You have the right to access your personal data at any time, free of charge, as well as with the processing of your personal data.‍

11.2 RIGHT TO RECTIFICATION, ERASURE AND RESTRICTION OF PROCESSING:

You always have the right to ask us to rectify or complete your personal data. Furthermore, you can ask for your personal data to be deleted only if Introw BV no longer needs this personal data for the purposes for which we initially collected it. If legal obligations, administrative or judicial orders prevent us to delete your personal data, we cannot comply with your request, but you will of course be informed of this. You can also ask to limit the processing of your personal data.‍

11.3 RIGHT TO OBJECT:

You always have the right to refuse the use of personal data for direct marketing purposes. In such case you do not have to give any reasons.‍

11.4 RIGHT TO FREE TRANSFER OF DATA:

You have the right to receive your personal data processed by Introw BV in a structured, accessible and machine-readable form and/or to transfer them to other responsible parties.‍

12.5 RIGHT TO WITHDRAW CONSENT:

To the extent that the processing is based on your prior consent, you have the right to withdraw that consent. This consent may be withdrawn at any time, without justification and free of charge, for example by clicking on the unsubscribe link provided for this purpose at the bottom of each promotional email and/or newsletter.‍

12.6 EXERCISE OF YOUR RIGHTS:

You can exercise your rights by contacting us, by e-mail to hellow@introw.io or by letter to Introw BV, Poel 16 - 9000 Ghent. These rights can be exercised free of charge by submitting a clear request via our email address mentioned above. This request specifies which right you want to appeal to, with an explanation, a copy of your identity card (make sure to leave your photo and social security number unread) and how we can contact you. Introw BV will respond to your request within 30 days. If you repeatedly submit the same request, which can be considered as a disruption for Introw BV, we are allowed to charge an administrative fee that covers the costs.‍

12.7 RIGHT TO COMPLAIN (DATA PROTECTION AUTHORITY DECLARATION):

You have the right to lodge a complaint with the Belgian Data Protection Authority: Drukpersstraat 35 1000 Brussel Tel +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35 e-mail: contact@apd-gba.be https://gegevensbeschermingsautoriteit.be/contact

13. Data Protection Officer?

Introw BV has a Data Protection Officer (DPO). Our data protection officer assists Introw BV in our processing activities relating to personal data. If you have any questions for our DPO, you can always contact us via the following email address: hellow@introw.io

The Dutch text of the privacy policy website has priority over other translations into other languages.

14. How to handle changes in our privacy policy?

This statement may be updated or supplemented by Introw BV if we consider it necessary. We encourage you to periodically review this statement to stay informed about how we process and protect your personal data.

This privacy policy was last updated in February 2023.