The website https://www.conundra.eu/ (hereafter: the "Website") and the OptiFlow routing Software as a Service application (hereafter: the "Application") are offered by: 

Conundra BV (hereafter "CONUNDRA", "We" and "Us")

Voordries 41

9860 Oosterzele

Oost-Vlaanderen

Belgium

Company number (VAT-BE): 0502.400.612
E-mail: data-protection@conundra.eu 
Phone: +32 9 311 52 17

Feel free to contact us should you have any privacy-related questions. We promise to reply soon!

Why this Privacy Statement?

Every person who visits our Website (hereafter the "Visitor") or uses our Application (hereafter the "User") will almost inevitably disclose a certain amount of personal data. The personal data is information which allows CONUNDRA to identify you as a natural person, regardless of whether we actually do this. You are identifiable as soon as it is possible to create a direct or indirect link between one or more personal data and you as a natural person.

We promise to only use and process your personal data in accordance with the GDPR and any replacement legislation, or any similar regulation under any applicable law, and any regulatory requirements or codes of practice governing the use, storage or transmission of personal data. Every reference in this Privacy Statement to the ‘GDPR’ is a reference to the Regulation of 27 April 2016 on the Protection of Natural Persons with regard to the Processing of Personal Data and on the Free Movement of such Data (General Data Protection Regulation).

Through this Privacy Policy, every Visitor and User is informed of the processing activities CONUNDRA may carry out with his or her personal data. CONUNDRA reserves the right to modify this Privacy Policy at all times. We advise all Visitors and Users to consult this document regularly. Users will be clearly informed of substantial changes.

Who is responsible for the processing of your personal data?

Controller

CONUNDRA is responsible for the processing of the personal data of Visitors and Users and decides alone or in cooperation with others which personal data is being collected as well as the purposes and the technical and organisational means with regard to the processing of those personal data. As a consequence, CONUNDRA is qualified as a "data controller" within the meaning of the GDPR towards Visitors and Users.

CONUNDRA has taken appropriate technical and organizational measures to protect the personal data of its Visitors and Users. CONUNDRA uses a variety of adequate security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. CONUNDRA secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.

Processor(s)

CONUNDRA relies on carefully selected data processors for the processing of the personal data of Visitors and Users. A processor is the natural or legal person who processes your personal data upon request and on behalf of the data controller. The processor is required to ensure the security and confidentiality of the data. The processor shall always act on the instructions of the data controller.

CONUNDRA relies on the following categories of "processors":

• Companies we have engaged for hosting purposes;
• Companies we have engaged for administrative purposes;
• Companies we have engaged for communication purposes;

With a view to the optimal protection of the personal data of the Users, CONUNDRA has made the necessary contractual arrangements with the aforementioned data processors to ensure that they apply the same privacy standards as CONUNDRA.

On what legal grounds are your personal data processed?

In accordance with the GDPR we process personal data on the following legal grounds:

• On the basis of the execution of the contract agreed upon with you or the execution of pre-contractual steps taken at your request; or
• On the basis of compliance with legal or regulatory provisions with regard to the management of the contractual relationship, invoicing in particular;
• On the basis of our legitimate interest (e.g. when sending information and newsletters to our customers, and when contacting potential customers and partners for the first time;
• On the basis of your consent (e.g. for sending promotional offers, direct marketing and adding contact details of potential customers and partners to our CRM system).

Which personal data is being processed?

The personal data of Visitors is collected when they fill out a form on our Website. The personal data of Users is collected at the time of their registration on the Application. The collection and processing of this data is necessary for the provision of our services. The amount of personal data collected depends on your use of the Website and the functionalities of the Application.

CONUNDRA commits to only collect and process adequate, relevant and limited to what is necessary for the purposes for which they are processed. The following categories of personal data are processed by CONUNDRA:

• Visitors:
• Personal identification data (name, first name, address);
• Contact details (telephone number and e-mail address);
• Electronic identification data (IP address);

We also use cookies in order to recognise the returning Visitor and to offer the Visitor a personalised user experience, to remember technical choices, and to detect and correct any errors which might be present on the Website. For more information concerning the use of cookies, we kindly refer you to our Cookie Policy.

• Users:
• Personal identification data (name, first name, address, login details);
• Contact details (telephone number and e-mail address);
• Electronic identification data (IP address);

CONUNDRA also collects anonymous data via the Application, i.e. technical data that is used solely for internal purposes to obtain an image of user navigation on the Application. The information collected may be sent to third parties for external analysis, but only to the extent that we have previously anonymised this data.

We do not, under any circumstances, collect sensitive personal information, such as information about your race, political opinions, health, religious or other beliefs, sexual orientation, etc.

The Visitors and Users provide the personal data to CONUNDRA themselves and therefore retain a certain degree of control. When certain data is incomplete or apparently incorrect, CONUNDRA has the right to postpone some expected actions temporarily or permanently.

For which purposes are your personal data being used?

CONUNDRA collects your personal data for the sole purpose of offering every Visitor and every User a safe, optimised and personal user experience. CONUNDRA reserves the right to suspend or cancel certain operations if personal data is missing, incorrect or incomplete.

The processing of your personal data is essential for the proper functioning of the Website and the Application as well as for the provision of our services. CONUNDRA commits to solely process your personal data for the following purposes:

1. Visitors:
   1. Responding to information requests;
   2. Sending newsletters, if you have expressly requested this;
   3. Activating free trials of the Application.
2. Users:
   1. Customer management: customer administration, subscription management, account management, invoicing, support, complaint monitoring and sending newsletters;
   2. Dispute management;
   3. Protection against fraud and infringements;
   4. Personalized marketing and advertising if you have expressly agreed to it. In that case, you are free to withdraw your consent at any time.

Who receives your personal data?

Your personal data is processed for internal use within CONUNDRA only. Your personal data will not be sold, passed on or communicated to any third parties, except in case you have given us your explicit prior consent or in case the transmission is necessary for the performance of the contract or is legally required.

How long do we store your personal data?

Your data is stored as long as necessary to achieve the ends pursued. The data will be erased from our database as soon as they are no longer necessary for the purposes pursued or if you validly exercise your right to erasure.

What are your rights?

Guarantee of a legitimate and secure process of your personal data

Your personal data is always processed for the legitimate purposes explained in point 5. They are collected and processed in an appropriate, relevant and non-excessive manner, and are not kept longer than necessary to achieve the intended purposes.

Right to access

If you can prove your identity, you have the right to obtain information about the processing of your data. Thus, you have the right to know the purposes of the processing, the categories of data concerned, the categories of recipients to whom the data is transmitted, the criteria used to determine the data retention period, and the rights that you can exercise on your data.

Right to rectification of your personal data

Inaccurate or incomplete personal data may be corrected. It is primarily the responsibility of the User to make the necessary changes in his "user area" himself, but you can also request us in writing.

Right to erasure (or "right to be forgotten")

You also have the right to obtain the erasure of your personal data under the following assumptions:

• Your personal data is no longer necessary for the intended purposes;
• You withdraw your consent to the processing and there is no other legal ground for processing;
• You have validly exercised your right of opposition;
• Your data has been illegally processed;
• Your data must be deleted to comply with a legal obligation.

The deletion of data is mainly related to visibility; it is possible that the deleted data is still temporarily stored.

Right to limitation of processing

In certain cases, you have the right to request the limitation of the processing of your personal data, especially in case of dispute as to the accuracy of the data, if the data is necessary in the context of legal proceedings or the time required to CONUNDRA to verify that you can validly exercise your right to erasure.

Right to object

You have the right to object at any time to the processing of your personal data for direct marketing purposes. CONUNDRA will stop processing your personal data unless it can demonstrate that there are compelling legitimate reasons for the processing which prevail over your right to object.

Right to data portability

You have the right to obtain any personal data which you have provided us in a structured, commonly used and machine readable format. At your request, this data may be transferred to another provider unless it is technically impossible.

Right to withdraw your consent

You may withdraw your consent to the processing of your personal data at any time, for example for direct marketing purposes.

How to exercise your rights?

If you wish to exercise your rights, you must send a written request and proof of identity by registered mail to CONUNDRA, Slochtestraat 4, 1770 Liedekerke, Belgium or by email to info@conundra.eu. We will respond as soon as possible, and no later than one (1) month after receipt of the request.info@conundra.eu. We will respond as soon as possible, and no later than one (1) month after receipt of the request.

Possibility to file a complaint

If you are not satisfied with the processing of your personal data by CONUNDRA, you have the right to file a complaint with the competent Data Protection Authority (for Belgium: https://www.privacycommission.be/).