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Privacy Policy

This policy describes our general privacy practices that
apply to the personal data we collect, use and share.

 
 
 
General
This privacy policy is applicable to the processing of your personal data by Tengu - Qrama nv by public means. This privacy policy does not cover any processing of data by third parties. Tengu - Qrama nv is not responsible for privacy statements or privacy practices of any third party.

This privacy statement describes our general privacy practices that apply to personal data collected, used and shared. This privacy statement will explain when and why we collect your personal data and how it is used. Personal data is any information relating to an identified or identifiable natural person (data subject). We value that you are fully aware of our policies and practices regarding privacy and data processing. Therefore, we encourage you to read this privacy statement carefully.

We recognize the importance of protecting your personal data and are committed to processing it responsibly and in accordance with applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 (hereinafter: “GDPR”).

Who is processing your data?
Tengu - Qrama nv is the controller with regard to your personal data, which means we are responsible for the processing. The term 'processing' is broad and covers, among other things, collecting, recording, organizing, storing, updating, modifying, retrieving, consulting, using, distributing or making available in any way, bringing together, combining, archiving, erasing or eventually destroying of that data.

You can contact us using the contact details below:
  • Name: Tengu - Qrama nv
  • Company address: Oktrooiplein 1 bus 201, 9000 Gent, Belgium
  • Company registration number: 0660.556.043
  • Telephone number: +32 (0)9 39 63 202
  • Email: info@tengu.io or dpo@qrama.io.
What data is being processed? How do we process your data?
We collect and process the following categories of personal data, depending on your level of interaction with the organisation (customer, onsite visitor, website visitor, etc.):
  • internal personal data: information about an individual's preferences or interests.
  • external personal data: information that uniquely or semi-uniquely identifies a specific individual (name, user name, unique identifier, employer, job title).
  • social personal data: communication: information communicated from or to an individual (email).
  • tracking personal data: like your computer device: information about a device that an individual uses for personal use (IP address).
  • contact: information that provides a mechanism for contacting an individual (email address, physical address, telephone number).
We also automatically collect and process anonymous and electronic information regarding your use of our website and the products and services of Tengu - Qrama nv. We automatically log which sections of the website you visit, which web browser you use, which (other) website(s) you visited when you obtain access to our website, your IP address. This allows us to draw up statistics regarding your use of the website(s) and to send targeted communication.

Your personal data are collected in the context of:
  • you showing interest in our (software) products and services and contacting Tengu - Qrama nv (e.g. after exchange of business cards);
  • you visiting our website and you filling out the contact form on the website;
  • your request for free trials, eBooks, white papers and/or an offer;
  • the (license) agreements between you and Tengu - Qrama nv;
  • your use of the products and services used by Tengu - Qrama nv;
  • you agreeing to receiving updates and exclusive emails from us and/or subscribing to our newsletter;
  • the (incoming and outgoing) correspondence and communication between you and Tengu - Qrama nv.
  • we only process the personal data you provide to us and which are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Currently we are working with a CRM and marketing automation tool that automatically tracks if you open the email we sent you and click on certain links. You can always contact us to get more detailed information about this.

For which purposes do we process your data?
Tengu - Qrama nv processes your personal data for:
  • responding to your request(s) for information, quote(s), order(s) or support: when you contact us (via our website or otherwise) with a request for information, to order products or services of Tengu - Qrama nv, we collect and process your personal data to (be able to) contact you, to fulfill your request, to grant you access to our products and/or services or to provide you with support;
  • access and use of our website(s) – optimizing quality, management and content of our website(s): when you visit our website(s) or use one of our online services, we shall process information necessary to provide you with access and for the operation of our website(s). We also process information about your activities during your visit in order to improve your website experience and improve and further develop our website(s);
  • improvement or development of our products and/or services;
  • your use of our free trials / demo application;
  • preparation, management and performance of the contract(s) with you, delivery of our products and services to you, issuing invoicing, collecting payment, administration / management in relation to your subscription;
  • (direct) marketing: sending information and/or targeted marketing and advertising, updates, newsletters and promotions by email, telephone or postal mail about our products or services;
  • legal obligations.
What is the legal basis for processing your data?
The processing of your personal data in connection with a request, order, transaction or agreement (or preparing for the same) or to provide products and/or services to you, is necessary for the performance of an agreement with you.

The processing of your personal data for (direct) marketing purposes, improvement or development of our website(s), products and/or services or for purposes other than in connection with your agreement or request, is on the basis of your consent or a legitimate interest of Tengu - Qrama nv.

When relying on this second lawfulness, the ‘weighing of interests’ is not only assessed at the start of the processing activity, but we also make sure the balance remains at all times in the benefit of the controller during the processing period.
 
Disclosure of your data to third parties
We shall not disclose your personal data to third parties, unless necessary for the provision of our products and/or services (in which case the third party is required to use your personal data in accordance with this privacy statement).

It is possible that Tengu - Qrama nv discloses your personal data to:
  • the competent authorities if we are obliged to do so under law or legal proceedings and/or to safeguard and defend our rights;
  • If we, or the majority of our assets, are taken over by a third party, in which case your personal data shall be one of the transferred assets.
In all other cases, we will not disclose your personal data to third parties, except with your consent and if we have concluded a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and protection of your personal data.

Transfer of your data outside the EEA/EU
In the exceptional case that customer data is transferred to countries outside the European Economic Area (EEA) or European Union (EU) and for which the European Commission has not decided it ensures an adequate level of protection, this shall be governed by the provisions of a data transfer agreement containing the necessary standard contractual clauses of the European Commission or any other appropriate safeguards.

Some American parties with whom we work together have registered under the Privacy Shield that offers sufficient protection (Atlassian, Google, Hubspot, Microsoft), they also vow to respect GDPR stated in their privacy policy on their respective website. Personal data may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
 
Retention period(s)
We shall not retain nor store your personal data longer than necessary to fulfill the purposes for which your data are processed, unless a longer storage period is required or justified:
  • (i) by law or any legal or regulatory obligation (e.g. audit, accounting and/or statutory retention terms);
  • (ii) for handling disputes or
  • (iii) for the exercise or defense of legal claims. We will delete your personal records if they are no longer required.

Your rights
As a data subject you can exercise the following rights:
  • Right to information: you can request access to the personal data we possibly have from you;
  • Right to rectification, completion or update of your personal data;
  • Right to delete your personal data;
  • Right to limit the processing of your personal data;
  • Right to data portability: you can request your data to be transferred to another company or entity;
  • Right to object to or to oppose the processing of your personal data.
If you no longer wish to receive information and/or targeted marketing and advertising, updates, newsletters and promotions you can unsubscribe (opt-out) at any time by clicking the link at the bottom of the mail or by sending an e-mail to our Data Protection Officer via dpo@qrama.io.

If a processing is based on your consent, you have the right to withdraw your consent at any time.

You have the right to file a complaint with the (Belgian) data protection authority:
  • Name: Gegevensbeschermingsautoriteit
  • Company address: Drukpersstraat 35, 1000 Brussel (Brussels), Belgium
  • Telephone number: +32 2 274 48 00
  • Fax number: +32 2 274 48 35
If you wish to invoke your rights, as defined above, you can contact us by sending an e-mail to dpo@qrama.io. We have the right to verify your identity and ask for a copy of the front side of your identity card (ID) before handling your request.

Updates to our privacy statement
Tengu - Qrama nv is entitled to update from time to time this privacy statement by publishing an updated version on its website(s).

Our Cookie Policy will become a stand-alone policy. It provides information about what type of internal and third-party cookies we use and what kind of data is collected.

Contact details
If you have any questions about this privacy policy, do not hesitate to contact us by sending an email to info@tengu.io or contact our DPO via dpo@qrama.io.

Still have questions about this policy?

Don't hesitate to contact us, we're happy to reply upon all your remaining questions or concerns.