SynaptiQ Privacy Notice
1. Scope
This privacy notice is addressed to the users (‘you’, ‘your’) of 3E NV/SA’s (‘we’, ‘us’, ‘our’) software as a service solution “SynaptiQ” and related services (‘services’). It applies when you access such services via 3esynaptiq.com, our Application Programming Interface(s) - API(s) or other interfaces (mobile app, marketing dashboards, etc.). The objective of this document is to inform you of what personal data we collect and how we use them (‘process’, ‘processing’), in compliance with the applicable laws.
2. Who is the data controller of your personal data?
3E NV/SA, with registered office at Kalkkaai (Quai à la Chaux) 6, B-1000 Brussels, Belgium, KBO (Crossroads Bank for Enterprises) number BE 0465 755 594, acts as the data controller when the personal data specified in this document are processed.
As a data controller, we are aware of the legal obligations with respect to the processing of your personal data. The rights that you have and that you can exercise against us are described further down in this document.
You can send any questions or requests relating to the processing of your personal data at privacy@3e.eu.
3. What type of personal data do we collect and how?
We process the personal data that you send us via 3esynaptiq.com, our API(s) or other interfaces, or otherwise when you use our services. We may also collect and process personal data that is generated when you use our services.
We may collect the following categories of personal data and process them for the purposes stated below:
- Identification data (such as first name and last name, work position/role);
- Contact details (such as email, telephone or mobile number, fax number, company name and work address):
- Login details (username and password);
- Data relating to your use of our services (such as application browsing activity, session data, session replays, login history, IP address);
- Device information (such as device identifiers, operating system, IP address);
- Data collected using cookies (please read our cookie policy to find out more).
4. Why do we collect these data, on what legal basis and for how long we retain them?
We collect the personal data mentioned above for a variety of purposes:
- Providing you with access to our services;
- Providing you with certain service features (such as displaying the location of a plant on maps);
- Fulfilling your service requests and incident management;
- Answering your queries;
- Debugging and identification of non-functional features;
- Internal development of our services;
- Improving user friendliness and ergonomics of the interfaces.
The processing operations described in this document are necessary for us to pursue our legitimate interests related to our services, or because your organisation or another entity has purchased the services you are using from us. We ensure that these interests are not overridden by your interests or fundamental rights and freedoms in relation to your personal data.
If any processing operation requires your consent, we will collect it before the processing, and you will be free to withdraw it at any time.
We keep your personal data for the time necessary to pursue the purposes identified above. The applicable retention period varies depending on the purpose for which the processing is intended. In most cases, it is of twelve months after the end of the contract by which your organisation or another entity has purchased the services you are using from us. The period might be longer, also to comply with the legal obligations which we are subject to or due to a legal necessity (such as a litigation).
5. Will your data be shared?
We may share your personal data with selected third parties (our subsidiaries and affiliated companies, in-house or external contractors and suppliers) that assist us in the provision of our services. Some examples of third-party suppliers include providers of development & infrastructure services, internal collaboration tools, support desk & ticketing services, data analysis and statistics services, localisation services.
These third parties have access to your personal data only when this is required to perform their tasks or activities in relation to the services.
We may disclose your personal data to comply with our legal obligations or for the purposes of legal enforcement in any country where we or our subsidiaries or affiliates are located. We may follow up a request from a law enforcement agency, regulatory authority or government agency. We may also disclose personal data in connection with legal claims, or to protect our property, safety, people or other rights and interests.
We will not sell or lease your personal data to third parties.
6. Will your personal data be transferred outside the European Economic Area?
For some of the purposes described above, we may transfer certain of your personal data to third parties located in States outside the European Economic Area.
Some of these States offer an adequate level of protection of personal data, according to a decision taken by the European Commission. In the other cases, the transfers occur subject to appropriate safeguards
7. Your rights as data subject
The applicable data protection legislation provides various rights for you as data subject, to ensure that you have sufficient control over the processing of your personal data.
a. Right of access/inspection
You are entitled to receive confirmation from us of whether we process your personal data. If we do process your personal data, you are entitled to request access to your personal data and certain information about it.
We will produce a copy of the personal data relating to you in our records upon request. Should you make repeated and disproportionate requests for copies of the said data, we reserve the right to charge you a reasonable fee.
b. Right of rectification
Should you determine that the personal data in our records is incomplete or incorrect, you are entitled to notify us in order for the necessary steps to be taken to complete or rectify the said data.
c. Right to erasure
You are entitled to request that we erase your personal data in certain circumstances. There are certain exceptions where we may not be under the obligation to comply with your request for erasure, for example when retention of your personal data is necessary to comply with legal obligations or in connection with legal claims.
d. Right to restriction of processing
You are entitled to request that we limit the processing of your personal data in certain circumstances, for example for the time necessary for us to establish if your personal data is accurate.
e. Right to data portability
You are entitled to receive the personal data that you have provided to us in a structured, standard and machine-readable format. You are entitled to request that we transfer the personal data to another data controller (directly from us). This is an option when the processing is based on your consent and the processing is carried out via an automated procedure.
f. Right to object
Where your personal data is processed to pursue our own, or a third party’s, legitimate interests or for direct marketing purposes (including profiling), you remain entitled to object to the said processing. However, we may be entitled to continue processing the said data based on compelling legitimate grounds or in connection with legal claims.
g. Automated individual decision-making, including profiling
You are entitled not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you significantly. There are certain exceptions to this right, for example where the decision is authorised by an applicable law.
h. Right to withdraw consent
If you have consented to the processing of your personal data for a specific purpose of processing, you are entitled to withdraw your consent by sending us an email at privacy@3e.eu.
i. Right to lodge a complaint with a supervisory authority
In case you consider that the processing of your personal data infringes the General Data Protection Regulation, you have the right to lodge a complaint with the supervisory authority in the European Union Member State where you have your habitual residence or place of work, or of the place of the alleged infringement.
j. Procedure to exercise rights and other provisions
We can request that you verify your identity to ensure that your request is lawful and that we are sending the reply to a person entitled to make such a request and to receive the requested personal data.
Please note that we may refuse access to your personal data or may not be able to grant your request under specific circumstances, when we are entitled to do so under the applicable data protection legislation.
8. Security
We make every effort to guarantee the security of your personal data. We have implemented reasonable technical and organisational measures to guarantee your personal data against accidental or unlawful destruction, loss, modification, unauthorised disclosure and/or unauthorised access to the data transmitted, saved or otherwise processed.
9. Third-party websites
The SynaptiQ interfaces may include links to third-party websites, services or applications. We will not be held liable for the content of these websites, services or applications, nor for the privacy standards and practices of the corresponding third party that do not process personal data on our behalf. You must read and understand the relevant third-party website, services and privacy/cookie policies before accepting cookies, accessing a website, service or application to ensure that your personal data is sufficiently protected.
10. Amendments to this notice
We may amend or update this notice to ensure that the information on how we process your personal data at that time is accurate. Any updated version of this notice will be available on this same webpage and will take effect upon publication. Please consult this document regularly to ensure you remain up to date on how we collect and process your personal data, how and under what circumstances we use your personal data and when we share your personal data with third parties.
11. How to contact us
For further information on the collection and processing of your personal data in relation to the use of our services, and to exercise your rights, please contact us at privacy@3e.eu.