huapii Online Privacy Statement (huapii platform)
Your privacy is very important for huapii. This privacy policy explains how we collect, use, process
and disclose your personal information and how you can access, change or delete your personal
information.

To which services does this Online Privacy Statement applies?
Scope:
This Online Privacy Statement applies to all huapii websites and portals that give access to our online
services and link to this Online Privacy Statement. For the purposes of this notice, “huapii” refers to
Huapii BV Brouwersvliet 2, 2000 Antwerp, member of SD Worx Group NV.
The huapii website or portal you visit is your data controller, and is as such responsible for the
collection, use, disclosure, retention and protection of your personal information in accordance with
our privacy standards, this Online Privacy Statement, as well as any applicable national laws.

Out of scope:
The personal information that we process for your employer as a huapii customer regarding the HR
services we deliver is governed by a separate Data Processing Agreement that we have concluded
with your employer. Such Data Processing Agreement is an integral part of the services agreement
with your employer and guarantees you that we collect and process your personal information only
as instructed by our customer (your employer). Your employer remains the data controller for these
activities, and therefore your employer will provide you with a privacy statement that applies to
these activities. For questions on the personal information that your employer provides to us as part
of the HR services that we deliver or your privacy rights as an employee, please contact your
employer’s HR department.

What information do we collect from you?
Information you or your employer provide to us
We collect personal information that you provide to us when you use our platform or websites, or
when you otherwise correspond with us.
We also collect your personal information when we create a user account for you to access our
online platform.

Personal information that you give us or that your employer gives includes:
● Identification information such as your name and username;
● Contact information that allows us to communicate with you such as email address, phone
number;
● Information that we use to secure access to our online services such as your password or
other authentication credentials;
● Other content that you generate or provide us with connected to your account (such as a
picture on your user account page, communication preferences or support requests).

Information we automatically collect:

● Behavioral information
If you provide us your personal information, we may track your interactions with huapii websites,
landings pages & emails. Our technology respects the Do Not Track feature in browsers, so if you
don’t want to be tracked you can enable this feature in your browser.

● Cookies
We also use “cookies” (small text files sent by your computer each time you visit our website) to
capture or store data. When we use cookies, we use session cookies (that last until you close
your browser) or persistent cookies (that last until you or your browser delete them). For
example, we use cookies to store your language preferences or other settings so you don‘t have
to set them up every time you visit our websites, portals or applications. Some of the cookies we
use are associated with your account (including information about you, such as your email
address) and other cookies are not. For more detailed information about how we use cookies
and how you can disable cookies, please visit our Cookie Statement.

● Device information
We collect information about the device you are using when visiting our websites, portals and
applications. This includes information like the type of device, operating system, version, … This
information helps us to provide the best support in case of problems and support the most
commonly used browsers and operating systems.

● Security information
We will log user activity to timely detect unauthorized or malicious behavior such as user logon
and logoff events, password resets or changes in access rights.

How do we use this information?
We use your personal information for different business purposes and according to different legal
bases of processing including to fulfil the contract with your employer and provide you with our
services, to comply with our legal obligations, to pursue our legitimate interests or based on your
consent.
To personalize your experience on our websites, portals and applications
We use your personal information to personalize our websites, portals and applications based on your usage and preferences to make sure you get a good experience.

To improve our websites, portals and applications
We collect aggregated analytics data of our websites, portals and applications to continuously
optimize our digital platforms. We make sure that all data we collect for this purpose is anonymized.

To carry out analysis and market research
We also use aggregated data to carry out analyses like trend analysis, market research and predictive
analytics.

To give access to our secured portals and applications and keep our online services secure and
operational
We use your personal information like email address and password to give you access to the portals
and applications you are entitled to. We take the necessary measures to make sure that this type of
information is protected properly and to prevent that unauthorized persons get access to your
account (e.g. via two-factor authentication). Furthermore, we use the information in our security logs
to monitor the security of our online services and to timely detect any unauthorized or malicious
activity.

How to access, control & delete your personal data?
We respect your right to access and correct your personal information and to request deletion or
request restriction of our usage of your personal information as required by applicable law:
● You have the right to know what personal information we keep process
● You can request to update your information if your personal information is incomplete or
incorrect
● You can request to delete or restrict the use of your personal information
● You can object to the processing of your personal information
To access, control or delete other types of information, you can contact your HR

How long do we keep your personal data?
We keep your information only as long as it is relevant for our commercial and operational activities
or for other essential purposes such as complying with our legal obligations, resolving disputes, and
enforcing our policies. This is also the case for anyone that we share your information with and who
carries out services on our behalf.

The following criteria can influence the effective retention periods:
● How long is the personal information needed to provide our online services? This includes
maintaining and improving the performance of our products, keeping our systems secure,
and maintaining appropriate business records.
● Are we obliged for legal, contractual, or similar reasons to retain your personal information?
Examples can include mandatory data retention laws, government orders to preserve data
relevant to an investigation, or personal information retained for the purposes of litigation.
● Have you provided consent for a longer retention period? If so, we will retain data in
accordance with your consent.

When we no longer need to retain your personal information, we’ll either remove it from our
systems or depersonalize it so that we can’t identify you.

With whom do we share your personal information?
We may disclose your anonymized information to other members of the SD Worx group and to third
parties.

We only share data with third party organizations that we engage to process information on our
behalf (data processors) based on our instructions and in compliance with the applicable legislation
and this Online Privacy Statement. In disclosing personal information, we will attempt to minimize
the amount of personal information we disclose to what is directly relevant and necessary to
accomplish the specified purpose.
We will never sell or share your data with third parties for their marketing and advertising purposes
without your consent.

We may share information if we believe that disclosure is reasonably necessary to comply with a law,
regulation or legal request:
● to law enforcement, governmental agencies or authorized third parties in response to a
verified request or legal process relating to a criminal investigation or alleged or suspected
illegal activity or any other activity that exposes us, you, or any other of our users to legal
liability.
● to third parties involved in a legal proceeding, if they provide us with a subpoena, court order
or substantially similar legal basis, or we otherwise believe in good faith that the disclosure
of information is necessary to prevent imminent physical harm or financial loss or to report
suspected illegal activity.

How do we protect your information?
We are committed to keeping your data safe and have employed a team of security specialists that
monitor the security measures we take. We have an information security program and continuously
implement and update administrative, technical, and physical security measures to help protect your
personal information against unauthorized access, loss, destruction, or alteration. This includes
safeguards such as firewalls and data encryption, physical security and information access controls.
huapii uses the same two-factor authentication as your employer, but please beware that you also
should take steps to protect your personal information online. We will never ask you for your
password in an unsolicited phone call or in an unsolicited e-mail. Also remember to sign out of the
website and close your browser window when you have finished your work.

Changes to this Online Privacy Statement
huapii reserves the right to modify this Online Privacy Statement from time to time to reflect changes
in privacy practices or new privacy practices in accordance with this provision. If we make changes to
this Online Privacy Statement, we will post the revised statement on our websites and update the
“Last Updated” date at the top of this Online Privacy Statement.

Escalate to the supervisory authority
You have the right to lodge a complaint with the relevant supervisory authority when you believe
that we haven’t complied with data protection laws. For Huapii BV, you can direct yourself to the
Belgian Data Protection Authority, Drukpersstraat 35, 1000 Brussels, +32 (0)2 274 48 00
commission@privacycommission.be – www.privacycommission.be

Contact
If you have any questions or complaints about this privacy policy or this topic, you can contact us via
support@huapii.com.
If you are a customer, and you have privacy related questions, you can contact your contact person
at huapii.