1. Controller
CleverUpps CommV, Zemst, Belgium, enterprise and VAT number BE 0724.738.765, is the controller for the processing described here. Contact: info@cleverupps.be or +32 484 05 23 10. We have not appointed a data protection officer; the founder handles privacy requests personally.
2. Data we collect
Contact data you give us: name, company, email address, phone number and the content of your message when you email, call, WhatsApp or write to us. Business data: when we work together, the data needed to deliver the service and to invoice (contact persons, addresses, VAT number, bank details, project information). Application data: if you apply for a role or an internship, your CV, motivation letter and the information you provide. Technical data: our hosting provider records standard server logs (IP address, browser type, requested URL, date and time, referrer) for security and operations. This website sets no analytics, marketing or tracking cookies; see the cookie policy.
3. Why we use it and on which legal basis
To answer your question or request: legitimate interest (Art. 6(1)(f) GDPR) or steps prior to a contract at your request (Art. 6(1)(b)). To deliver, manage and invoice services: performance of a contract (Art. 6(1)(b)) and legal obligations such as accounting and tax law (Art. 6(1)(c)). To assess applications: steps prior to a contract (Art. 6(1)(b)). To keep the website secure and available: legitimate interest (Art. 6(1)(f)). To send occasional news about CleverUpps and its ventures: only with your consent (Art. 6(1)(a)), which you can withdraw at any time through the link in each message or by emailing us. We do not use automated decision-making or profiling.
4. How long we keep it
Enquiries without follow-up: up to 12 months after the last contact. Client and supplier data: for the duration of the relationship and afterwards as long as Belgian accounting and tax law requires (in principle 7 years for invoices and supporting documents). Applications: until the end of the selection procedure, or up to 12 months with your consent so we can contact you for later roles. Server logs: kept by the hosting provider for a limited period for security purposes. Consent-based mailings: until you withdraw consent.
5. Who receives your data
We do not sell or rent personal data. We share it only with processors who work for us under a data processing agreement: Hostinger (website and e-mail hosting, EU data centres), Microsoft 365 (business e-mail and documents), our accountant and invoicing tools (for financial administration) and, where a project requires it, sub-contractors bound by confidentiality. We disclose data to authorities only when the law obliges us to. If a provider processes data outside the European Economic Area, we rely on an adequacy decision or the EU standard contractual clauses.
6. Security
We protect your data with appropriate technical and organisational measures: encrypted connections (HTTPS), access limited to the people who need it, multi-factor authentication on our accounts, and regular updates and backups. No system is perfectly secure; if a breach ever affects your rights, we will inform you and the supervisory authority as the GDPR requires.
7. Your rights
You can ask us at any time for access to your data, rectification, erasure, restriction of processing, data portability, and you can object to processing based on our legitimate interest. Where processing is based on consent, you can withdraw that consent without affecting earlier processing. Send your request to info@cleverupps.be; we answer within one month. You can also lodge a complaint with the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit, Drukpersstraat 35, 1000 Brussels, gegevensbeschermingsautoriteit.be).
8. Children
This website and our services are aimed at businesses and adults. We do not knowingly collect data from children under 16. If you believe a child has given us personal data, contact us and we will delete it.
9. Links to other websites
cleverupps.be links to the websites of our ventures and to third-party sites such as LinkedIn. We are not responsible for their content or privacy practices; read their policies before sharing data with them.
10. Changes to this policy
We update this policy when our website or our processing changes. The current version and its effective date are always published on this page. Substantial changes will be announced on the website.
11. Contact
CleverUpps CommV · Zemst, Belgium · info@cleverupps.be · +32 484 05 23 10 · VAT BE 0724.738.765.