Privacy Policy
Who we are?
We are Jackie Treehorn residing at Pyckestraat 48A 2018 Antwerpen Belgium with company registration number BE 0637.818.352 .
We care about your privacy and every time we deal with your personal data we do so in accordance with the provisions of the general data protection regulation and the national law relating to the processing of personal data.
We are required under data protection legislation to make the information contained in this privacy policy accessible to you. This privacy policy sets out which measures are taken to protect your privacy when using our services or products, and what rights you have in this respect.
When processing your personal data we are in most cases the "data controller". This means thatwe determine the purpose and means of the processing.
By using our services and/or products, you agree to the collection and processing of some of your personal data in accordance with the purpose described in our privacy policy. You are invited to read this privacy policy carefully and familiarise yourself with its content. EmelieVervecken is our Privacy Coordinator and you can reach them at support@rubey.be for any questions or to exercise your rights. Future amendments to this policy cannot be excluded. We therefore ask that you read the privacy policy from time to time.
Processing your personal data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed(anonymous data). We try to collect as little personal information as possible in order to achieve our goals. We comply with data protection laws which require that the personal information we process about you must be:
Collected only for valid purpose(s) that we have clearly explained to you.
Used lawfully, fairly and in a transparent way which means in a way that is relevant to the purpose(s) we informed you about, limited only to those purpose(s) and in no way incompatible with those purpose(s).
Accurate and kept up to date, kept only as long as necessary for the purpose(s) we have told you about and handled securely.
We may request certain information from you in order to enable you to use or purchase our services or products. If have processes in place to obtain your personal information in a different way, we will state this in this privacy policy. If you have any questions do contact our privacy coordinator.
More specifically we will collect any or all of the following data elements :
- Address
- Anti Money Laundering (AML) data
- Anti Terrorism data
- Bank account
- Birthday / Age
- Company Role
- Company address
- Company name
- Company registration number
- Consent
- Correspondence content
- Country
- Customer file
- Customer name
- Date & time
- Electronic identification data
- Email address
- Essential cookies
- Gender
- Home address
- ID card
- Involved party name
- Know Your Customer (KYC) data
- Languages
- Marital status
- Marketing cookies
- Nationality
- Payment History
- Payment balance data
- Payment card details
- Performance cookies
- Personal phone number
- Phone number
- Place of birth
- Signature
- Social media link
- Survey data
- Third party cookies
- Title
- Ultimate Beneficial Owner (UBO) data
- VAT number
We rely on you to provide us with correct data. If the data changes, we invite you to let us know, so we can keep the data up to date.
We process the data to allow us to deliver the services/products, and to continually improve the services/products available to you and adapt them to your needs. More specifically we perform the below processing:
Description: Corporate website for consultation by client or prospective client
Purpose: To inform client or prospective client
Legal basis: Legitimate interests
Retention period: As from termination of contract, retention during the legal period and/or period relevant for legal action
Data items: Consent, Third party cookies, Languages , Email address, Customer name, Marketing cookies, Performance cookies, Essential cookies, Electronic identification data
Data is processed in the EU
Description: Investor portal for private and public investors as hosted on Tokeny
Purpose: To support investor onboarding and management token portfolio
Legal basis: Contract
Retention period: As from termination of contract, retention during the legal period and/or period relevant for legal action
Data items: Essential cookies, Phone number, Consent, Anti Terrorism data, Know Your Customer (KYC) data, ID card, Bank account, Email address, Anti Money Laundering (AML)data, Marital status, Customer name
Data is processed in the EU
Description: Information regarding anti-fraud as required by law
Purpose: Ensure compliance with mandatory anti-fraud measures
Legal basis: Legal obligation
Retention period: As from termination of contract, retention during the legal period and/or period relevant for legal action
Data items: Place of birth, Email address, VAT number, Company name, Country, Phonenumber, Signature, Company Role, Anti Terrorism data, Ultimate Beneficial Owner (UBO)data, Anti Money Laundering (AML) data, Know Your Customer (KYC) data, Company address, Company registration number, ID card, Address, Gender, Nationality, Homeaddress, Birthday / Age, Bank account, Involved party name, Customer name
Data is processed in the EU
Description: Gathering of prospective customer information
Purpose: To communicate goods and services to prospective customers
Legal basis: Legitimate interests
Retention period: All prospects that have not converted to customers will be deleted after 2years
Data items: Consent, Third party cookies, Email address, Social media link, VAT number, Company name, Phone number, Survey data, Marketing cookies, Company Role, Performance cookies, Date & time, Company address, Company registration number, Essential cookies, Address, Title, Personal phone number, Customer name
Data is processed in the EU
Description: communication with customers in electronic or paper form
Purpose: To provide proper service to the client
Legal basis: Contract
Retention period: As from termination of contract, retention during the legal period and/or period relevant for legal action
Data items: Phone number, Marketing cookies, Performance cookies, Company address, Third party cookies, Essential cookies, Address, Email address, Correspondence content, Customer name
Data is processed in the EU
Description: Receiving and answering customer questions, complaints etc.
Purpose: To solve problems and optimise the functioning of the company
Legal basis: Contract
Retention period: As from termination of contract, retention during the legal period and/or period relevant for legal action
Data items: Performance cookies, Phone number, Consent, Marketing cookies, Third party cookies, Essential cookies, Email address, Correspondence content, Customer name
Data is processed in the EU
Description: Receiving and answering customer questions, complaints etc.
Purpose: To solve problems and optimise the functioning of the company
Legal basis: Contract
Retention period: As from termination of contract, retention during the legal period and/or period relevant for legal action
Data items: Performance cookies, Phone number, Consent, Marketing cookies, Third party cookies, Essential cookies, Email address, Correspondence content, Customer name
Data is processed in the EU
Description: Sales and / or delivery of goods or services to customers
Purpose: To ensure proper sales and or delivery of goods or service, enable track & trace and feedback
Legal basis: Contract
Retention period: As from termination of contract, retention during the legal period and/or period relevant for legal action
Data items: Anti Terrorism data, Anti Money Laundering (AML) data, Know Your Customer(KYC) data, Phone number, Consent, Marketing cookies, Third party cookies, Essential cookies, Customer file, Bank account, Email address, Address, Customer name
Data is processed in the EU
Description: Processing payments through debit card, credit card or payment App
Purpose: To ensure proper payment
Legal basis: ContractRetention period: As from termination of contract, retention during the legal period and/or period relevant for legal action
Data items: Email address, Signature, Date & time, Payment card details, Customer name
Data is processed in the EU
Description: Calculating the fee owed, sending out invoices and ensuring payment
Purpose: To ensure proper payment
Legal basis: ContractRetention period: As from termination of contract, retention during the legal period and/or period relevant for legal action
Data items: Email address, VAT number, Company address, Payment History, Bank account, Payment balance data, Customer name
Data is processed in the EU
Description: Keeping your clients up to date about what your company has to offer
Purpose: As long as the user remains subscribed to the newsletter
Legal basis: Legitimate interests
Retention period: As from termination of contract, retention during the legal period and/or period relevant for legal action
Data items: Survey data, Marketing cookies, Performance cookies, Third party cookies, Essential cookies, Consent, Email address, Customer name
Data is processed in the EU
Description: Communicating with customers and vendors to plan meetings and events and group bookings
Purpose: Event planning and running
Legal basis: ContractRetention period: As from termination of contract, retention during the legal period and/or period relevant for legal action
Data items: Email address, Company name, Consent, Marketing cookies, Performance cookies, Date & time, Third party cookies, Essential cookies, Customer name
Data is processed in the EU
In the above processing we are the data controller.
Where you provided consent, you have the right to revoke it. You have the right to withdraw your consent at any time.
In case you object to the processing of your data, please contact us so we can evaluate together if a contractual relationship is possible and a continuation of the use of our services is possible.
We also handle supplier data. When we collect, process and store supplier data, we want to make sure we only collect, process and store data we really need and are entitled to handle in this way. In dealing with our suppliers we typically collect, process and store the name, work email and work phone of the person(s) interacting with us. We also collect, process and store the VAT number of our suppliers. If we provide parking space or access to our business area to suppliers' vehicles, we might collect, process and store the licence plate number and timing of the visit for purposes of organisation and security. Our security measures are functionally and technically in line with industry best practices. We retain the information during the legal period and/or period relevant for legal action.
Processing personal data on your behalf
The specific nature of the work that we perform for you means that we may have to make declarations, filings, notifications, etc. for you based on personal data of others that you provide to us. In that case we are the processor and you are the controller. We will carry out your instructions for the processing, possible subcontracting, the fate of the data at the end of the agreement and the possible transfer of data. We will also take the necessary security measures and assist you in fulfilling your obligations under the GDPR.
Transfer of personal data
In order to provide certain services or products we might work with third parties such as IT partners, insurance partners, accounting partners, legal advisors. More specifically we reserve the right to transfer your personal data to our partners.
Purpose: To support investor onboarding and management of token portfolio
Legal basis: Contract
Data items: Customer name, Nationality, Address, Anti Money Laundering (AML) data, Know Your Customer (KYC) data, Anti Terrorism data
Data is processed in the EU
Tokeny sarl receives the data
Purpose: To manage business
Legal basis: Legitimate interests
Data items: Staff member name, Customer name, Home address Customer file, Emailaddress Data is processed in the EU
Privacy Office Onfido Limited receives the data
Purpose: Legal & regulatory administration
Legal basis: Legal obligation
Data items: Know Your Customer (KYC) data, Anti Money Laundering (AML) data, Anti Terrorism data
Data is processed in the EU
JTC Group receives the data
Purpose: To send and receive payments
Legal basis: Contract
Data items: Staff member name, Bank account, Customer name, Home address, Involved party name, Date & time
Data is processed in the EU
Alpha FX Limited receives the data
Purpose: To process payments
Legal basis: Contract
Data items: Customer name, Payment card details, Home address, Signature
Data is processed in the EU
Payconiq International S.A. receives the data
Purpose: To manage business
Legal basis: Legitimate interests
Data items: Staff member name, Customer name, Home address, Customer file, Email address
Data is processed in the EU
Google Ireland Limited receives the data
Purpose: To manage business
Legal basis: Legitimate interests
Data items: Staff member name, Customer name, Home address, Customer file, Email address
Data is processed in the EU
Slack Technologies Limited receives the data
Purpose: To promote the company and its services
Legal basis: Legitimate interests
Data items: Pictures / images, Electronic identification data, Electronic localisation data, Date & time
Data is processed in the EU
META PLATFORMS IRELAND LIMITED (ex-Facebook) receives the data
Purpose: To promote the company and its services
Legal basis: Legitimate interests
Data items: Pictures / images, Electronic identification data, Electronic localisation data, Date & time
Data is processed in the EU
LinkedIn Ireland Unlimited Company receives the data
Purpose: Measuring website & commercial performance
Legal basis: Legitimate interests
Data items: Electronic identification data, Electronic localisation data, Essential cookies, Third party cookies, Date & time, Performance cookies, Marketing cookies
Data is processed in the EU
Google Ireland Limited receives the data
Purpose: Event invitation management software
Legal basis: Consent
Data items: Essential cookies, Third party cookies, Date & time, Performance cookies, Marketing cookies, Consent, Email address
Data is processed in the EU
INVITEDESK nv receives the data
Purpose: To manage business
Legal basis: Legitimate interests
Data items: Staff member name, Customer name, Home address, Customer file, Email address
Data is processed outside the EU
The Rocket Science Group LLC (Mailchimp) receives the data
If we receive personal data from a third party referring you to us, we assume this data is obtained directly from you or with your consent. If this is not the case, please advise us immediately.
These third parties will generally act as data processor. Please do note that social media platforms, commerce platforms and structural sales partners are often regarded as joint controllers.
If you participate in an online call, meeting, conference, ... do note that any data you choose to share will be visible and/or audible to the other participants. Please consider this before sharing your personal details, video, audio or any other data.
In case you object to the transfer of your data, please contact us so we can evaluate together if a contractual relation is possible and a continuation of the use of our services is possible.
Please do note that we may be required by law to process certain data and, as the case may be, to transmit them to the relevant authorities. As this is a legal obligation you can not object this transfer.
Security & confidentiality
We undertake to keep your personal data secure & confidential and have established security procedures to avoid any loss, abuse or alteration to this personal data in line with industry best practices.
Website & cookies
Navigation on our website may result in cookies being saved to your computer. They simplify the visit and improve your experience. When visiting our website you will be informed of the cookies being used and we will ask you for your consent. Furthermore, each time you visit our website, the webserver automatically processes your IP address and/or your domain name.We may publish links to websites owned and operated by third parties. If you click on such a link you will navigate to another website. Please make sure you read and understand the privacy policy of that website, as it may differ from our policy and is outside of our control. If you feel unsure or cannot agree with the policy, we suggest you leave that website.
Social media
If you use the social media functions such as eg “like” or “share” button that may be on our website, or if you visit our social media page, please know that your personal data will be processed by the social media platform. In this processing, the European regulator considers us and the social media platform both to be joint data controllers, which means that we jointly determine why and how your personal data is processed. You can find out how we process your personal data in this privacy statement. You can find information about the processing by the relevant social media platform in their privacy statement. We ask you to read the privacy statement of the social media platform carefully before visiting the social media items on our page or our page on the social media platform.
If we hold an event such as a client network event, opening event, premiere etc. we might have photographers or videographers present. The photos and videos they shoot are purposed to be used in marketing materials and / or published on our social media pages. When you are not the main subject of these materials the data protection authority's guidance is that your GDPR explicit consent is not required. However, should you oppose to us using materials where you are depicted, please let us know.
Exercising your rights
In accordance with the general data protection regulation you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Withdraw your prior consent to processing at any time.
- The right to object to a decision based solely on automated processing, including profiling.
- The right to receive your personal data in a structured, commonly used and machine-readable format and have transmit those data to another controller (commonly known as a"data portability request").
We sometimes need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
You can exercises your rights by contacting our Privacy Coordinator Emelie Vervecken via support@rubey.be or at the below company address:
Jackie Treehorn
c/o Emelie Vervecken
Pyckestraat 48A 2018 Antwerpen BelgiumData protection authority
You can direct any complaints and comments to the competent data protection authority at the below address:
GegevensbeschermingsautoriteitDrukpersstraat 35, 1000 Brussel http://gegevensbeschermingsaut...
