Privacy and Cookie Policy

This version is in effect since May 24th, 2018

Chaomatic cares about your privacy and is committed to processing your personal information in accordance with Belgian law, the present Privacy and Cookie Policy (hereinafter the “Policy/Privacy Policy”) and the highest standards of fair information practices.

Please read this Privacy Policy carefully, whereas it describes how Chaomatic collects your personal data through her Website https://www.chaomatic.com/ (hereinafter the “Website”), as well as all related websites including our subdomains, applications, our platform consisting of a talent management solution that facilitates coaching to manage and improve employee engagement, knowledge and performance (the “Platform”) and other services provided by us (collectively, together with the Website, our “Services”), and in connection with our customer, vendor, and partner relationships. This document describes how Chaomatic uses this data, as well as the manner in which you can assert control over Chaomatic doing as such. By using the Website, the Services of Chaomatic, you accept with the Privacy Policy. If you do not accept this Privacy Policy, you are no longer allowed to use the Website, the Platform and/or the Services of Chaomatic.

Chaomatic can update this Privacy Policy from time to time, by posting a revised version on our Website. Therefore, we recommend you to regularly consult this Policy, to make sure that you are aware of any changes.

Article 1 – General

1.1 Chaomatic bvba, a private limited liability company incorporated under Belgian law “Chaomatic”, with registered offices at 3110 Rotselaar (Belgium), Heirbaan 34, registered with the Crossroads Bank for Enterprises under company number BE 0631.891.454, takes responsibility for the processing of your personal data as a “data controller”.

1.2 Chaomatic’s policy for the protection of your personal data is strictly compliant with the laws applicable in Belgium and the European Union:

  • the Belgian Privacy Law of 8 December 1992 on privacy protection in relation to the processing of personal data and the Belgian Law of 7 October 2012 laying down rules on electronic communications and/or
  • the EU Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC.

1.3 Visiting the Website implies your express approval (via handing us your personal information, or via opt-in) of this Privacy Policy, meaning that you consent to how Chaomatic collects, uses and process your personal information.

1.4 If you have questions about this Privacy Policy, or the manner in which Chaomatic collects, uses or processes your personal information, please contact us by sending an email to the following e-mail address: Michael@chaomatic.com or by letter to Chaomatic bvba, Heirbaan 34, 3110 Rotselaar (Belgium).

Article 2 – Personal Data Chaomatic Collects

2.1 Chaomatic does not collect sensitive information (e.g., data relating to race or ethnic origin, religious beliefs, criminal record, physical or mental health, or sexual orientation) from Visitors of the Website. Chaomatic shall, where necessary, obtain your explicit consent to collect and use such information.

2.2 Our Website collects only personally identifiable information that is specifically and voluntarily provided by you. Such information may consist of:

  • Category 1: Your IP-address
  • Category 2: Your name, (professional) email address, your (professional) contact details such as: telephone number, address, country and profile.
  • Category 3: Social media information such as your social media username(s), etc.
  • Category 4: Information about your use of the Website, such as the sections of the Website you visited, the date and time you have accessed the Website, and the materials posted to or downloaded from the Website.
  • Category 5: information about your use of the Platform and/or Services, such as your contact details (name, email address)
  • Category 6: information about your use of the learn module on the Platform, such as your course enrollments, session enrollments, quiz results and reviews, video engagement data, slide engagement data, text engagement data, your attributed badges and certifications..
  • Category 7: Data obtained by placing cookies (see art. 7 of this Policy)

2.3 Chaomatic can obtain personal data through different means:

  • by placing cookies;
  • during your use of our Website;
  • by filling out questionnaires (e.g. when you give us feedback);
  • Subscribing to the newsletter (via the Website or other means)
  • By filling out a contact form
  • via social media (e.g. when you like or contact us via Facebook)

2.4 You are not obliged to provide us with your personal data, however you must understand that the delivery of several Chaomatic Services is not possible in case you refuse to provide us with certain personal data.

Article 3 – To which ends will my personal data be used?

3.1 General Purpose

Chaomatic collects and processes your personal information for one overarching goal, i.e. to offer you a safe, comfortable and personalized experience each time you visit the Website.

The information we collect about you is primarily processed to help us ensure the proper technical functioning of our Website, if not for other system administration purposes, and to improve the quality and content of our Website – all based on the “legitimate interest” of Chaomatic to maintain and enhance her service.

That said, your personal data will only be processed for the following (internal) purposes:

  • To provide Chaomatic services such as support, via the Website or via Social Media channels –, or to enable Chaomatic to execute an agreement which you initiated (category 1, 2, 3, 4)
  • To reach out to potential new Chaomatic Team Members. As such Chaomatic processes your personal data to employ recruitment strategies taking optimum advantage of opportunities to create a Chaomatic workforce able to thrive within an intense, fast paced, goal oriented environment (category 1, 2, 3, 4)
  • To inform you about other services that Chaomatic provides, via targeted advertising, promotional offers or updates (category 2, 3, 4)
  • To capture your opinion and for statistical purposes to maintain and enhance her service (category 1, 2, 3, 4)
  • To create your account to have access to the Platform, its modules and the thereto related Services (category 5).
  • To organize online training, in this way our Platform can keep track track of all courses offered to you and your enrollments in those courses (category 6).

3.2 Direct marketing

Your personal data will only be used for direct marketing purposes given you agreed to our Privacy Policy.

Also, upon such consent Chaomatic can transfer your personal data to her partners for marketing purposes. To that end, Chaomatic will create anonymous statistics regarding user demographics and the use of our Website and provide those statistical reports to third parties. Yet, none of the information in those statistics is connected to the personal data of individual users.

At all times, you are free to change your mind at any time, and we don’t expect you to give any motivation thereto. You can do this by clicking the unsubscribe button below every promotional e-mail or any form of direct marketing.

3.3. Transfer to third parties

In order to process your personal data, we provide access to our employees.

Chaomatic will not disclose your personal data to third parties, unless it is necessary in the context of providing our services and/or optimising them. To that end, Chaomatic will appeal to third parties in order to:

  • send you newsletters
  • capture your opinion on our products and services
  • be easily addressed – e.g. social media channels
  • optimize your experience on our Website
  • reach out and cater to potential new Chaomatic Team Members – e.g. providing information about job offerings and facilitate the engagement between Chaomatic and these potential new Chaomatic Team Members

These third parties will be obliged to only use your personal data if they can guarantee conformance with terms that are alike to those as set out this Policy.

Consequently, Chaomatic won’t sell, hire out or pass on your personal data to third parties, except in the situations provided for in this policy or unless you explicitly and preliminary consent.

It is however possible that Chaomatic will disclose your personal data:

  • If Chaomatic is obliged to do so, following a court order or to comply with imperative laws and/or regulations, or to safeguard and defend our rights.
  • In case of whole or partial reorganization or cession of Chaomatic’s activities, whereby Chaomatic reorganizes, transfers, ceases her business activity or in case Chaomatic goes bankrupt, your personal data may be transferred to new entities or third parties.
    Chaomatic will, if reasonably possible, try to inform you in advance of such transfers, unless revealing this information is subject to legal constraints. Additionally, you must be aware that informing you beforehand is not always possible technically, nor commercially.

Article 4 – How long will we hold your data?

Chaomatic only processes your personal information for as long as necessary. This means that we do keep a record of your data for as long as this is required or justified by the law or by another legal obligation, or for the period for which this would be necessary for the aforementioned purposes.

  • Category 1: Your IP-address will be stored for the duration of your visit to our Website.
  • Category 2: Your name, email address, telephone number, country and profile will be stored for the duration of your relationship with Chaomatic and the subsequent 5 years thereafter.
  • Category 3: Social media information such as your social media username(s), etc will be stored for the duration of your relationship with Chaomatic and the subsequent 5 years thereafter.
  • Category 4: Information about your use of the Website will be stored for further statistical research, without being linked to your identity. Thus, the personal data will be anonymized, so it becomes impossible to identify you based on this data.
  • Category 5, 6: as long as the company uses Chaomatic’s Platform and Services. Afterwards in an pseudonymized or anonymized form to further improve our Platform and Services.
  • Category 7: Data obtained by placing cookies (see art. 7 of this Policy) The deletion is comparable to deleting files on your computer using the ‘trash bin’, allowing us to recover the data to a certain extent for some time.

Article 5 – Your rights as a data subject

5.1. Right of access and right to obtain a copy

You have the right to freely obtain at any moment access to your personal data, as well as to be informed about the purpose of the processing by Chaomatic.

5.2. Right to rectification, erasure or restriction

You have the choice to share your personal data with Chaomatic. You also have the right to request Chaomatic to rectify or have your personal data erased.

You can also request the processing of your personal data to be restricted.

You acknowledge that when you refuse to share data, or when you demand us to erase your personal information data, this will prevent us from providing you with several Chaomatic services.

5.3. Right to object:

You have the right to object to the processing of your personal data when you have serious and legitimate reasons to do so.

You also have the right to object to the use of your personal data for purposes of direct marketing. In such case specific reasoning will not be requested.

5.4. Right to data portability:

You have the right to obtain your personal data which is processed by Chaomatic in a structured, commonly used and machine-readable format and/or to transfer this data to another data controller.

5.5. Right to withdraw consent:

When the processing is based on prior consent you have the right to withdraw this consent.

5.6. Automated decisions and profiling:

The processing of your personal data does not include profiling, nor shall you be subjected to automated decisions.

5.7. Exercising your rights:

You can exercise the above mentioned rights by sending an e-mail – enclosing a copy of your identity card – to michael@chaomtic.com.

5.8. Right to file a complaint:

If you have any complaints about the way Chaomatic collects, uses and/or processes your personal data, you have the right to file a complaint with the Belgian Privacy commission:

Commission for protection of personal life,

Drukpersstraat 35, 1000 Brussels,
Tel +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35,
e-mail: commission@privacycommission.be.

This does not affect a procedure before the civil court.

If you have suffered damages caused by the processing of your personal data, you can file a claim for damages.

Article 6 – Safety and Confidentiality

6.1 Chaomatic undertakes all reasonable efforts to prevent (i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data, by using physical, administrative and technological measures to protect the information maintained.

6.2 Unfortunately, no one – including Chaomatic – can guarantee 100% security when it comes to transmission or forwarding over the internet, or any method of electronic storage. In case of particular security concerns about certain personal information, it is up to you to decide not to transmit that information over the Internet.

6.3 Nevertheless, you are responsible for the provision of personal data to Chaomatic and can exercise a degree of control thereto. If certain information is incomplete or seemingly incorrect, Chaomatic reserves the right to, temporarily or permanently, postpone certain actions or other services.

6.4 Please note that Chaomatic assumes no responsibility regarding the privacy policy of the websites or digital platforms that are hyperlinked with the Website. Moreover, Chaomatic shall not be liable in any way for direct or indirect damages caused by a wrongful or improper use of the personal data by a third party.

Article 7 – Cookies

7.1 What is a cookie?

A “cookie” is a small text file that is sent from the server of Chaomatic and is stored on your computer’s hard drive. This way we can remember your preferences when visiting our Website. The information stored through these cookies can only be read by Chaomatic and only for the duration of your visit to the Website.

7.2 Why do we use cookies?

Our website primarily uses Cookies and similar technologies to enhance the surfing experience on our Website. All data Chaomatic retrieves from their cookies is only used to distinguish your preferences from those of the other users of our Website. This allows us to offer you a better experience when you visit our Website and to optimize our Website in the meantime.

As a result of recent amendments of the law, all websites focusing on certain parts of the European Union are obligated to ask for your permission in order to use or save cookies and similar technologies on your computer or mobile devices.

This policy clearly and completely informs you about the cookies we use and their purpose.

Once a new cookie policy will be implemented, your consent regarding the use of the cookies will be requested again.

7.3 Kind of cookies

Cookies can be subdivided based on their offspring, function and durability.

Our Website only uses the following cookies:

  • Strictly necessary cookies
    As the name suggests these cookies are strictly necessary to enable you to move around the Website or to provide certain features that you have requested.
  • Functionality cookies
    These cookies enhance the functionality of the Website by storing the Visitor’s preferences.
  • Tracking cookies
    These cookies will outlast user sessions. If a persistent cookie has its max-age set to 1 year, then, within that year, the initial value set in that cookie will be sent back to the server every time you visit the server. This is used to record a vital piece of information such as how a Visitor initially came to this Website. For this reason, they are also called tracking cookies. For example, once you have selected your preferred language, our Website will record this preference in a persistent cookie set on your browser. When you revisit the Website, it will use that persistent cookie to ensure that the content is delivered in your preferred language.
  • Performance cookies
    These cookies help to improve the performance of the Website, providing a better user experience. Chaomatic uses Google Analytics, a popular web analytics service provided by Google, Inc. Google Analytics uses cookies to help Chaomatic to analyse how visitors use the Website. It registers the number of visitors and tells things about their behaviour overall – such as the typical length of a visit on the Website or the average number of pages a Visitor views.
  • Third party cookies
    For cookies set by third parties (Google Analytics, Linkedin, Facebook) we kindly refer you to the statements set forth by these parties on their respective websites. Beware, we do not have any influence on the content of these statements nor on the content of the cookies of these third parties:

7.4. Your permission

When you first visit our Website, you express your implicit approval to accept our different kinds of cookies.

You can block Cookies by activating your browser settings which allows you to refuse the cookies. The rejection of these cookies may have the effect of not allowing you to use some functionalities on the Website.

More information on cookies can also be found via the following link: http://www.allaboutcookies.org/

More information on online behavioural advertising and online privacy can be found via the following link: http://www.youronlinechoices.eu/

Article 8 – Applicable Law and Jurisdiction

This Privacy and Cookie Policy is managed, interpreted and executed in accordance with Belgian law which exclusively applies to every potential dispute.

The competent courts of the registered office of Chaomatic shall have exclusive jurisdiction in relation to any kind of disagreement that could arise from the interpretation or execution of the present Privacy Policy.