The protection of your privacy is important to Be Greator. Therefore, this privacy policy applies to (i) our website http://begreator.com, (ii) all relationships (including commercial relationships) between Be Greator and its Customers, Prospects, Partners, Users and any other natural person who comes into contact with Be Greator through its communication channels. This privacy policy contains the various information on the personal data collected by Be Greator, how we use and process them in accordance with the Belgian Privacy law of 30 July 2018 concerning the protection of the privacy of natural persons with regard to the processing of personal data, as well as Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 concerning the protection of individuals with regard to the processing of personal data and on the free movement of such data repealing Directive 95/46/EC (hereinafter referred to as the 'General Data Protection Regulation' or 'GDPR' or 'Regulation'), as well as all Belgian and future laws concerning the implementation of the said Regulation. This privacy policy is established by the limited liability company Be Greator S.R.L. with a registered office at 56 Van Ooststraat, 1030 Schaerbeek under the company number BE 0752 903 211.

By browsing the Website, you accept the terms and conditions of the Privacy Policy. Be Greator is therefore responsible for the processing of personal data in the context of the operation of the Website.

If you have any questions or remarks regarding our privacy policy, please do not hesitate to contact our Data Protection Officer by e-mail at leila@begreator.com, or by post at 'Be Greator SRL', 56 Van Ooststraat, 1030 Schaerbeek, BELGIUM.

Finally, we attach great importance to your privacy and to the subjects that interest you within Be Greator. To this end, a 'notification center' is at your disposal and is accessible via our website (in a small tab at the bottom left). This allows you to control the information we send you. Through this interface, you will be able to choose the processing that we can perform on your personal data. You will have direct control over your personal data, allowing you to update it.

BEGREATOR AND YOUR DATA

1. Definitions

• 'The company', 'we', 'us' or 'our' refers to the limited liability company Be Greator with registered office at 56 van Oost Street, 1030 Schaerbeek under company number BE 0752 903 211;
• 'Website' refers to the website located at the following address http://begreator.com;
• 'Web App' refers to the platform found at the address http://app.begreator.com and allowing access to our services;
• 'Customer' refers to any legal or natural person who uses the services of Be Greator;
• 'Prospect' refers to any Potential Customer;
• 'User' refers to any visitor, user or person browsing our Website or person connected to Be Greator through our Website or any other communication channel;
• 'Regulation' or 'GDPR' refers to the Regulation (EU) 2016/679 of the European Parliament and of the Council 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 repealing Directive 95/46/EC.

2. Presentation of the data controller and its activities - Who collects and processes my data?

The company supports its Customers in their digital transformation by offering products and services to democratise technology careers and bridge the digital skills gap.

3. Types of data collected and processed – How is my data obtained? What data is collected specifically?

We process some of your data during our business. This data may be collected in different ways.

3.1. How do we collect them?

• Through communication by the user: when you contact us via our online form, when you register for one of our events, when you fill in evaluations on our Website, when you subscribe to our alerts or newsletter, for example, you provide us with certain personal data which may be used;
• By automatic data collection when using our services: when you visit or use our website, we collect information through cookies and other means (see our 'Cookie Policy');
• By transmission of data through partners or third parties: where you have consented, we may receive various types of personal data from our partners or third parties;
• During any cooperation, call for services, request for an offer or correspondence with Be Greator (via social networks or any other communication channel).

3.2. What data is collected?

Personal data that you provide to us, such as:

• personal identification data: surname, first name, company name, e-mail address, telephone number;
• non-personal data: no longer personal data, we may collect non-personal data that does not directly or indirectly identify a natural person. This non-personal data may then be used for any purpose such as improving our Website, Web App, or products, targeting our advertising, or improving the services we offer.

4. Processing and transfer of personal data – How is my data used?

We aim to better target information, offers, products, services to your personal interests and needs. To do this, the data we collect may be enriched by publicly available data or available from our partners who will ensure that this data is transferred to us legally and in compliance with the laws mentioned above.

• personal identification data: surname, first name, company name, e-mail address, telephone number;
• non-personal data: no longer personal data, we may collect non-personal data that does not directly or indirectly identify a natural person. This non-personal data may then be used for any purpose such as improving our Website, Web App, or products, targeting our advertising, or improving the services we offer.

4.1. Lawfulness of processing

Any processing is permitted if it is based on a lawful basis as set out in the Regulation, namely, the consent of the data subjects, the necessity for the performance of a contract, compliance with a legal obligation or the pursuit of a legitimate interest.

• Your consent: When you consent to the processing of your personal data, Be Greator may therefore process it.
• Necessity for the performance of a contract: when the processing is necessary for the performance of a contract to which you are a party (such as invoice generation for example).
• Fulfillment or performance of a legal obligation: the processing may be necessary to fulfill or comply with a legal obligation to which the company is subject (such as the generation of invoices for example).
• Pursuit of a legitimate interest: processing may be necessary for a legitimate interest. In such cases, a balancing of interests will be carried out to determine whether the legitimate interest pursued outweighs the rights and freedoms in question, including reasonable expectations. For example, business prospecting is considered a legitimate interest.

5. For what purposes are the data processed or transferred? – For what purpose is my data collected and used?

The company may collect and process personal data for certain specific purposes. The company will ensure that only necessary and relevant personal data is processed. Indeed, Be Greator may process such data in the context of and for purposes such as complying with our legal obligations or contractual relations, when you have consented to it, or for legitimate interests.

5.1. Consent

Where we have no contractual relationship or where the processing is not necessary for the further performance of a contract, we may still process personal data if you give us your consent.

For example, when you sign up for our newsletter, when you complete the contact form, when you sign up for our email alerts or an event, when you authorize us to contact you or pass on your data to our partners, or any other situation, we may collect your consent to process your personal data. Consent can be collected, for example, through a 'ticking' of a box. This box is a request for consent for us to process your personal data.

Where we have obtained your consent, we may process your personal data in different situations and for different purposes:

• To ensure that we respond to your enquiries: when you contact us about our Website, web app or any other product, we use the data we have collected from an event or email alert you have subscribed to to respond to you;
• In order to send you emails based on the notifications you wish to receive: you can subscribe and unsubscribe via the 'notification centre' in your settings. This allows you to manage the information we send according to your interests;
• To contact you to evaluate our services, for example as part of a satisfaction survey;
• To personalise our services and contacts so thaat you have a better understanding of our services. For example, based on your profile and interests, we use your data to provide you with more personalised services.

5.1.1 Notification Center

As mentioned above, Be Greator attaches great importance to respecting your privacy. To this end, we have provided you with a notification center accessible via our web site (in the form of a round tab at the bottom left of the screen). This center should allow you to control the information we send you. Via this interface, you will have the possibility to choose the processing that we can carry out on your personal data. You will have direct control over your personal data that will allow you to update it.

5.1.2 Withdrawal of consent

You are of course free to withdraw your consent regarding our various services. This withdrawal will be done via the notification center as simply as when you provided it. Another possibility is to withdraw your consent via the 'unsubscribe' link that is below our communications.

5.2 In the context of our legitimate interests

The concept of legitimate interest is specific to each company according to its activities and needs. Nevertheless, a fair balance must be struck between those interests and the rights and freedoms.

As one of our company's goals is to support consultants in their learning and development journey, we have developed partnerships with training centers to offer training to our community. Therefore, and in order to continue to offer these trainings through our web platform and other sources of information, we must ensure the visibility of our partners. This visibility takes many forms and includes advertising insertions in our email alerts and on our platform.

5.2.1 Withdrawal of consent

The GDPR requires that when we process your personal data, we balance your rights and interests with our legitimate interests. It is important that you understand why we believe we can process your personal data based on our legitimate interests. For this, we would like to inform you about the different criteria we use to believe that we can process your personal data based on our legitimate interests. The purposes for which we process your data based on our legitimate interests are:

• Identifying and managing users on our Website;
• Personalizing our services according to your profile and interests;
• Prospecting and prospect management;
• The elaboration of studies, models (risk, marketing and others) and statistics, by favoring anonymisation and/or pseudonymisation techniques;
• The preservation of the security of goods and persons, the fight against fraud or attempted intrusion, abuse or other offences;
• Training our staff by using real-life situations for illustration purposes (using data anonymisation techniques where possible);
• Analysis of your previous searches to better tailor our service offerings to your preferences and interests;
• To improve the quality of service for people who have an account on our website or who have subscribed to an alert and who are not bound by a contract;
• Keeping a list of consultants who no longer wish to be contacted;
• Improving existing services and the user experience of our Website;
• To manage your requests related to the application of your rights;
• To recognise, exercise, defend and preserve our rights.

5.2.2 Future treatment and compatibility with current treatment

In the event that we carry out processing for purposes not already set out in this policy, we may use your personal data for as long as those purposes are compatible with the purposes for which we originally collected the data. In doing so, we will take into account, among other things, any relationship between the original purposes, the subsequent purposes and the context in which the data was collected (our relationship, the nature of the data and the consequences for you). If we consider that the purposes are not compatible with the original purposes, we will contact you before processing the data for the new purposes so that you can consent to it or not.

6 Profiling and automated processing

In order to ensure a better user experience, we may use profiling techniques in order to be able to associate personal data with different preferences. Profiling consists of any form of automated processing of personal data consisting in the use of such data to evaluate certain personal aspects relating to a natural person, to analyse or predict elements relating to professional performance, economic situation, health, personal preferences, interests, reliability, behaviour, the location or movements of that natural person. In cases where we may use your personal data to carry out profiling, no decision with legal effects or significant impact will be taken based on such processing. If you believe that you are the subject of a decision based solely on an automated process, you can therefore object to this as indicated below.

7 Recommendations

Through our Website, your relations have the possibility to share our content with you. For example, via our Website, your acquaintances may share with you a job description if they think you might be interested. In this case, they provide us with some of your personal data (including your email address, for example) so that we can send you the information. For this purpose, we keep this data in our database so that we can contact you if your acquaintances request it. If you are already in our database, we will add this information to your customer profile. If you are not on our database, we will simply keep the information you have provided.

8 Retention time for personal data – How long do we keep your data?

We take care not to keep your personal data longer than is necessary for the purposes for which it was collected. Specifically, there are several situations in which we may determine how long we keep your personal data:

• If you are registered on our Website and our email alerts: we keep your personal data for the duration of your registration in order to offer you the best possible service and to inform you of news related to our services;
• You have unsubscribed from our Website and/or e-mail alerts: in this case, we keep your data for three years from the date of your unsubscription.

At the end of the retention period, we will make every effort to ensure that the personal data is made unavailable and inaccessible.

9 Changes to the Privacy Policy

We reserve the right to make changes to our privacy policy at any time. Should this occur, you will be notified in advance by posting a notice on our home page of the Website. To this end, it is your responsibility to check this page regularly to stay informed of the steps we are taking to respect your right to privacy.

OUR COOKIE POLICY

What is a “cookie”?

When you use the Website, certain information relating to your browsing and your terminal (computer, smartphone, etc.) may be recorded by means of small text files called 'cookies'. These cookies are installed on your terminal via your web browser and according to the terms you choose in terms of cookies. These cookies consist of information stored on your various terminals that allow us, for example, to remember your preferences when you visit our Website. This information will be read by Be Greator and only for the duration of your visit to the Website.

How do we use these cookies?

Our Website uses cookies and other similar technologies to enhance the browsing experience of our users. The data collected is used solely to distinguish your preferences from those of other users and to optimise our website. Cookies can have different functions and durabilities. We only use the following cookies:

• Strictly necessary cookies: these are essential and necessary for users to move around the Website or provide certain requested functionality.
• Functionality and analytical cookies: these are used to improve the functionality of the Website and to store user preferences. These make it possible to improve the performance of our Website and therefore offer a more optimal user experience based on general behavioural analysis, for example (duration of visit, number of pages consulted, etc.).
• Tracking and targeting cookies: these record analytical information in an anonymous way about how you visit our Website in order to improve the Website, the user experience and the targeting of advertisements. These cookies may be set by our advertising partners via our Website. They may be used by these companies to create a profile of your interests and show you relevant advertisements on other websites and/or platforms.
• Performance cookies: these are used to improve the performance of our Website and therefore provide a more optimal user experience based on general behavioural analysis for example (length of visit, number of pages viewed, etc).
• Third party cookies: some cookies are set by third parties (such as Google Analytics, LinkedIn, Facebook) and therefore we have no influence on them. We therefore refer you to their respective cookie policies.
• Persistent cookies: each of the types of cookies listed above may be a persistent cookie. These remain on your terminal (computer, smartphone, etc.) for a predetermined period of time and are activated each time you visit our Website;
• Persistent cookies: each of the types of cookies listed above may be a persistent cookie. These remain on your terminal (computer, smartphone, etc.) for a predetermined period of time and are activated each time you visit our Website;
• Session cookies: any of the above types of cookies may be a session cookie. Session cookies are temporary and remain on your terminal only during your visit to our Website until you close your browser. Session cookies are deleted when you close your browser.

How do we collect your permission and how can you object to it?

When you first visit our website (or any other website), you are expressing your implicit agreement to accept our various types of cookies by simply visiting us. However, you can block these cookies by changing your browser settings to refuse them. Unfortunately, refusing these cookies may mean that you will not be able to use some or all of the features of the Website.

By accessing your browser settings, you can choose to accept, restrict, disable, or even delete some or all cookies. You can also activate the function that notifies you when cookies are placed on your terminal and asks you to accept them or not. To do this, we invite you to consult the information contained in the 'help' menu of your browser (each browser has different functions and settings).

YOUR RIGHTS AND PROCEDURES UNDER THE GDPR

What are your rights under the GDPR in terms of personal data protection?

Various rights are enshrined under the Regulation and must be respected. You therefore benefit from various prerogatives, such as:

• The right to withdraw your consent: your consent may be withdrawn at any time. This will not affect the lawfulness of the processing based on this consent that will have been given before the withdrawal.
• The right of access to your data: you have the right to request confirmation as to whether or not your personal data is being processed and to request details of the data being processed, our purposes and the recipients of your data. You may also request a copy of any personal data we process about you.
• The right to rectify your data: you have the right to request that inaccurate or incomplete data be corrected or completed at any time.
• The right to erasure ('right to be forgotten'): you can obtain the erasure of your personal data for various reasons :
• The data may no longer be necessary for the purpose of the processing;
• You may decide to withdraw your consent to the processing of your data, even though we base this processing solely on the legal basis of your consent;
• You can object to the processing;
• We have processed your personal data unlawfully;
• In the event that the data we hold is incomplete, inaccurate or out of date;
• We need to erase your personal data to comply with a legal obligation (under EU or Member State law) to which we are subject.
• Please note that some services may no longer be accessible or can no longer be provided if you request the deletion of certain personal data that is required.
• The right to restriction of processing: you have the right to object to the processing of your data at any time, unless there are legitimate grounds for the processing which override your own (for example, in the exercise of a right or our legal defence).
• The right to data portability: in the context of processing on the basis of a contract or your consent and the processing is automated, you can ask us to transfer all or part of your personal data.
• The right to restriction of processing: in certain cases, you may also ask us to restrict the processing of your personal data. The situations in which you can ask us to limit the processing of your personal data are as follows:
• If you dispute the accuracy of personal data when we can verify the accuracy of that data;
• If we process your personal data unlawfully and you prefer that we restrict this processing rather than the erasure of your personal data.
• Of course, if the restriction of processing is no longer applicable, we will inform you.
• The right to object: as mentioned above, we ask for your consent to send you commercial information, advertisements or personalised proposals (through direct marketing or e-mail alerts). You therefore have the right, if you do not wish or no longer wish us to send you such communications, to object to the processing of your personal data for these purposes.
• The right not to be subject to automated processing, including profiling: you have the right not to be subject to a decision that has legal effects or significantly impacts you, based on a fully automated decision (without any human intervention). Note that such decisions are possible if they are necessary for the conclusion or performance of a contract between you and us or if you have explicitly consented to them. In addition, if the law allows us to do so, we may take to process your data in an automated way. However, at Be Greator we make every effort to ensure that no such decisions are made. If you feel that you have been the subject of such a decision, please contact us so that we can get back to you with an explanation.

How to exercise your rights?

If you so wish, you have the right to lodge a complaint or appeal on account of the way in which your personal data is processed with the competent Data Protection Authority of the country of the European Union in which you reside, work or in which you consider that a violation of your rights has occurred. You can therefore exercise your rights to protection of personal data and respect for the right to privacy by contacting us at leila@begreator.com or by contacting the competent entity in this respect.

In order to assist you in asserting your rights, we may ask you to verify your request with additional information (to the extent that we cannot identify you with the information we have). For example, we may ask you for a copy of your identity card for this purpose.

We undertake to reply as soon as possible, and at the latest within one month of your request. However, we may have to extend this period to two months if your request appears to be complex and we are faced with an excess of requests. If such a situation occurs, we will inform you of the reasons for our delay.

As this Privacy and Cookie Policy is administered, interpreted and enforced in accordance with Belgian law, the latter applies exclusively to any potential and future disputes. The court designated as competent will therefore be the court of Be Greator's registered office for any type of disagreement that may arise from the interpretation or execution of this privacy policy.

Contacting Be Greator

If you have any questions or remarks regarding our privacy policy, the personal data collected or the way we handle the personal data collected, please do not hesitate to contact our data protection officer at the following e-mail address leila@begreator.com or by mail at 'Be Greator SRL', 56 Van Ooststraat, 1030 Schaerbeek, BELGIUM.

If you are not satisfied with the way Be Greator has handled your questions and/or remarks or if you have complaints about the way Be Greator collects, uses and/or processes your personal data, please note that you have the right to file a complaint with the competent data protection authority at the following address.

For more information on complaints and possible remedies, please see the information available on the Data Protection Authority's website here.