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Privacy Policy

Last update: 6 December 2021

Deze privacyverklaring is momenteel enkel in het Engels beschikbaar. Wenst u een Nederlandstalige versie van deze privacyverklaring, gelieve dan contact op te nemen met legal@silverfin.com. Cette déclaration de confidentialité est actuellement disponible uniquement en anglais. Si vous souhaitez obtenir une version française de cette déclaration de confidentialité, veuillez contacter legal@silverfin.com.

This privacy policy (“Privacy Policy”) is applicable to all processing activities of Silverfin (as defined below) as a data controller.

Please read this Privacy Policy together with our Cookie Policy and our Terms of Use. Silverfin may update this Privacy Policy in the future: the latest version can always be found on our Website (as defined below).

You can find our archived Silverfin Privacy Policies in pdf format here.

ABOUT THIS PRIVACY POLICY

Due to, for example, your commercial relationship or recent contact with Silverfin or due to a visit to or action on our “Website” (i.e. www.silverfin.com; www.getsilverfin.com and www.silverfin.be), we may collect, store and otherwise process personal data relating to you or, if you are a company, your employees | representatives (“your personal data”).

This Privacy Policy describes (i) how we collect, treat and store your personal data; (ii) the rights you can exercise in relation to your personal data; and (iii) the measures we take to protect it and to secure your personal data.

Silverfin respects your privacy and we always strive to act in accordance with the applicable privacy legislation, such as (non-exhaustive): (i) the General Data Protection Regulation 2016/679 of April 27, 2016 (“GDPR”); (ii) the United Kingdom(UK) Data Protection Act 2018 (“UK GDPR”); (iii) the Belgian Privacy Law of 30 July 2018; (iv) the ePrivacy Directive 2002/58/EC of 12 July 2002, including future amendments and revisions thereof; and/or (v) (future) national legislation regarding the implementation of the GDPR (together: “Privacy Legislation”).

1. SILVERFIN IS THE DATA CONTROLLER

We are Silverfin NV, a limited liability company with registered office at Gaston Crommenlaan 12, 9050 Gent, registered with the Crossroads Database for Enterprises under number 0524.802.662 (“Silverfin” or “we | us”)

Silverfin is the developer and provider of the Silverfin platform as described and represented via www.silverfin.com (“Silverfin Platform”) and the corresponding online service of Silverfin (“Service”) and is the owner of the Website.

In light of Privacy Legislation, Silverfin will act as the DATA CONTROLLER of your personal data for the purposes described in this Privacy Policy. This means, we are in control of (and thus, responsible for) your personal data.

2.SILVERFIN’S PROCESSING ACTIVITIES

Which personal data we collect, store and otherwise process and the purpose for which we process this data may differ depending on your relation with Silverfin. In particular, we identify five different scenarios:

  • You are browsing on our Website;

  • You (wish to) receive updates and newsletters relating to Silverfin services and products (incl. the Silverfin Platform);

  • You are a prospect and/or seeking a commercial relationship with Silverfin;

  • Your company is an active Silverfin customer and/or you are an authorized user of the Silverfin Platform; or,

  • You are | your company is a partner or a supplier of Silverfin.

2.1 You are browsing on our Website

Contacting Silverfin via the contact form on the Website

Purpose:

To answer any questions you may have and/or to initiate a conversation

Personal data:

  First name

  Email address

  Last name

  Phone number

  Company name

  Country

❑  Nature of inquiry

  Voluntarily provided information

Legal ground:

Consent

Retention period:

Until one (1) year following your contact with Silverfin

Cookies

When browsing on our Website, we may also collect your personal data through cookies stored on your device(s) in order to optimize the functioning of the Website. Please consult our Cookie Policy for more information.

2.2. You (wish to) receive updates and newsletters relating to Silverfin services and products


The Silverfin newsletter | update

Purpose:

Providing more information on (new features of) the Silverfin Platform, our Service or related products/services

Personal data:

  First name

  Email address

  Last name

 

Legal ground:

Consent or, if you happen to be a customer or partner of Silverfin, legitimate interest

Retention period:

Until you have objected to the processing of your personal data for this purpose (cfr. Section 7 - “Right to object”)

2.3 You are a prospect and/or seeking a commercial relationship with Silverfin


Requesting a personal demo

Purpose:

To schedule your personal demo of the Silverfin Platform

Personal data:

  First name

  Email address

  Last name

  Phone number

  Company name

  Country

❑  Type of industry

  Preferred Language

Legal ground:

Consent

Retention period:

Until you have requested to no longer be contacted by Silverfin or until one (1) year following your latest contact with Silverfin, whichever comes first ( + verification period of six months)

General communication with Silverfin & prospecting by Silverfin

Purpose:

To have quality conversations (via mail, telephone or business social media channels) in which Silverfin provides more information on its Service and the Silverfin Platform

Personal data:

  First name

  Email address

  Last name

  Phone number

  Company name

  Country

❑  Type of industry

  Preferred Language

❑  Social media / business channel

  Voluntarily provided information

Legal ground:

Legitimate interest

Retention period:

Until you have requested to no longer be contacted by Silverfin or until one (1) year following your latest contact with Silverfin, whichever comes first ( + verification period of six months)

 

Registering for | attending a Silverfin (network) event

Purpose:

To have an overview of the participants to the event (e.g. Fast Forward; webinar | seminar; contest) as well as  to have a  follow-up communication after the event

Personal data:

  First name

  E-mail address

  Last name

  Company

Legal ground:

Consent

Retention period:

Until you have requested to no longer be contacted by Silverfin or until one (1) year following your latest contact with Silverfin, whichever comes first ( + verification period of six months)

2.4 Your company is an active Silverfin customer


Please note that your company is the data controller for all personal data which is provided or submitted to Silverfin by your company during the use of the Service / Silverfin Platform. In such a case, Silverfin is merely a facilitator of the Service / Silverfin Platform. In that light, please consult our Data Processing Addendum.

General communication and (technical) support

Purpose:

To enable communication  with & to provide  support to customers

Personal data:

  First name

  Email address

  Last name

  Preferred Language

  Job function

  Voluntarily provided information

 

  Phone number

 

 

Legal ground:

Necessary for the performance of the agreement

Retention period:

Until one (1) year following the termination of the commercial relationship between your company and Silverfin

Billing

Purpose:

To prepare invoices for the Service | use of the Silverfin Platform

Personal data:

  First name

  Company

  Last name

  Email address

  Address

  VAT-number

  Job function

 

Legal ground:

Necessary for the performance of the agreement

Retention period:

Until one (1) following the termination of the commercial relationship between your company and Silverfin

Quotes | proposals

Purpose:

To draw up (additional) quotes | proposals

Personal data:

  First name

  Company

  Last name

  Email address

  Address

  VAT-number

Legal ground:

Legitimate interest

Retention period:

Until one (1) year following the termination of the commercial relationship between your company and Silverfin

Creating your Silverfin account

Purpose:

To set up your Silverfin Platform account

Personal data:

  First name

  Email address

  Last name

  Phone number

  Company

  Login

Legal ground:

Necessary for the performance of the agreement

Retention period:

Until one (1) year following the termination of the commercial relationship between your company and Silverfin

2.5. You are | your company is a partner or supplier of Silverfin

General communication and provision of services

Purpose:

To communicate with you in the scope of our commercial relationship

Personal data:

  First name

  Email address

  Last name

  Phone number

  Company

  Preferred Language

  Job function

  Voluntarily provided information

Legal ground:

Necessary for the performance of the agreement

Retention period:

For the duration of your commercial relationship with Silverfin and in any event accordance with any (data processing) agreements concluded with Silverfin

Billing

Purpose:

To pay your invoices for the services provided (incl. corresponding communication)

Personal data:

  First name

  Company

  Last name

  Email address

  Address

  VAT-number

  Job function

 

Legal ground:

Necessary for the performance of the agreement

Retention period:

For the duration of your commercial relationship with Silverfin and in any event accordance with any (data processing) agreements concluded with Silverfin

3. LEGAL GROUNDS


You can find more information on the applicable ground for each of the identified processing activities in Section 2 above.

In case the legal ground for processing happens to be legitimate interest, Silverfin shall always (i) assess whether this is in proportion with the purpose for which your personal data was collected and used; and, (ii) take your reasonable expectations into account and ensure a balance with your fundamental rights and freedoms. If we cannot guarantee this, we will stop storing | using your personal data or we will determine a new legal ground.

4. RETENTION PERIODS

You can find more information on the retention period of your personal data for each of the identified processing activities in Section 2 above.

5. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

5.1 Silverfin affiliates. Silverfin may disclose your personal data to its affiliates in the scope of support(ing) services:


Name

Territory

Implemented Safeguards

Silverfin Software Ltd.

United Kingdom (London)

European Commission adequacy decision for UK

Silverfin Software B.V.

The Netherlands (Amsterdam)

N/A (within EEA)

Silverfin Software ApS

Denmark (Copenhagen)

N/A (within EEA)

Boltzmann B.V.

Belgium (Ghent)

N/A (within EEA)

5.2 Other third parties.


Silverfin shall not disclose your personal data to other third parties, unless it is necessary to achieve the purposes described in this Privacy Policy. In this respect, (some of) your personal data may be disclosed to:

  • Payment providers (e.g. to process the payment or detect/prevent money laundering or fraud);

  • Software and cloud providers (to facilitate hosting of (the data in) the Silverfin Platform | Service); and,

  • Freelancers or other service providers (e.g. to help develop the Silverfin Platform | Service)

Of course we have made sure that the necessary contracts or similar legal binding acts are in place to ensure that these third parties treat your personal data in accordance with the Privacy Legislation (e.g. Article 28 GDPR).

In addition, we might transfer your personal data:

  • to competent authorities: for instance, because (i) we are obliged to provide your personal data under law or in the scope of (future) legal proceedings, or (ii) this is necessary to safeguard our rights; or,

  • in M&A context: meaning, if Silverfin or the majority of its assets, is taken over by a third party, in which case your personal data – which Silverfin has collected – may be one of the transferred assets.

6. CROSS-BORDER PROCESSING OF PERSONAL DATA

In case any of the above mentioned third parties or other recipients are located in a country outside the European Economic Area, Silverfin will ensure that one or more of the listed EU-approved safeguards are in place:

  • European Commission adequacy decision;

  • Data transfer agreement (cfr. the Standard Contractual Clauses as provided in the European Commission Implementing Decision (EU) 2021/914 of 4 June 2021, including the performance of a transfer impact assessment);

  • Binding corporate rules; or,

  • Certification mechanisms.

     

7. YOUR PRIVACY RIGHTS

The Privacy Legislation (e.g. (UK) GDPR) gives you certain rights over your personal data vis-à-vis Silverfin. You can exercise these rights by contacting us, as specified in Section 10, and by using the Data Subject’s Rights Form (see at the end of this Section 7).

Access:

you can ask for confirmation of whether or not personal data that relates to you is being processed. If so, you can ask us to give you copies of your personal data. We may charge you a small fee for this service;

Rectification:

you can ask us to correct | complete any information you believe is inaccurate | incomplete;

Erasure:

you can ask us to erase your personal data, under certain conditions. Please be aware that in this context certain services will no longer be accessible and/or can no longer be provided.

Objection:

You can object to us processing your personal data, under certain conditions.

Restriction of processing:

you can ask us to restrict the processing of your personal data, unless we have legitimate interests for the processing of your personal data that prevail over your interests

Data portability:

you can ask us to transfer your personal data to another organization, or directly to you in a commonly used structured format readable by automatic device, under certain conditions.

Updates | Newsletters. You can always change your communication preferences in the Silverfin Communication Preference Centre (you can find a unique link in the footer of every Silverfin communication). If you no longer wish to receive any of our Silverfin communications, you can object to these direct marketing communications by either (i) using the Data Subject’s Rights Form (as indicated above); or (ii) by indicating “Yes, I object” in our Communication Preferences Centre (as indicated above). Upon receipt of your objection, we will stop processing your personal data for Silverfin communications. This is done free of charge.

You can download the “Data Subject Rights Form” here.

You can find your unique link to the “Communication Preferences Centre” in the footer of every Silverfin communication.

8. SECURITY


Silverfin undertakes to take reasonable, physical, technological and organisational precautions in order to avoid
(i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data. Please consult Silverfin’s “Security Policy” for more information on the security measures taken.

Notwithstanding Silverfin’s Security Policy, the checks it carries out and the actions it proposes in this context, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the internet, or any method of electronic storage is 100% secure, we are not in a position to guarantee absolute security.

Finally, the security of your account will also partly depend on the confidentiality and complexity of your password. Silverfin will never ask for your password, meaning that you will never be required to communicate it personally. Silverfin therefore strongly advises you, if you observe that someone has accessed your account, to immediately change your password and contact us.

9. UPDATES


We are entitled to update this Privacy Policy by posting a new version on the Website whereby we will indicate the revision date at the top of this Privacy Policy. As such, it is strongly recommended to regularly consult the Website and the page displaying the Privacy Policy, to make sure that you are aware of any changes.

10. NOTIFICATIONS AND QUESTIONS

Notifications under this Privacy Policy (such as, exercising your rights as a data subject) and/or any questions or concerns with regard to the provisions of this Privacy Policy must be directed at legal@silverfin.com.

11. COMPLAINTS?


You are not satisfied with the manner in which we collect, store or otherwise treat or secure your personal data? We are sorry to hear that, and are prepared to take all measures to remedy this situation. Please do contact us as specified above.

You also have the right to lodge a complaint with the authorized supervisory authority (i.e. the Belgian Data Protection Authority or the data protection authority of (i) your residence or (ii) your workplace) should you consider that the processing of your personal data infringes the Privacy Legislation. You can send an email to the Belgian Data Protection Authority at contact@apd-gba.be or any other email address provided by the Belgian Data Protection Authority (https://www.dataprotectionauthority.be/contact-us).  

Relevant links to related documents

You can consult our Cookie Policy here.
You can consult our Security Policy here.
You can download the Data Subject Rights Form here.
You can consult our Data Processing Addendum here.