Privacy Policy

Version 3.0

Introduction

Angevo BV undertakes to process personal data in accordance with the General Data Protection Regulation (GDPR — EU Regulation 2016/679), the Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data, as well as any other applicable regulation.

Use of the platform implies taking note of this Privacy Policy.

1. Data controller

Angevo BV, Excelsiorlaan 25, 1930 Zaventem (Belgium) — Company number: 1032.536.987.

For any question relating to this Privacy Policy or to the exercise of data protection rights, Angevo can be contacted at the address: privacy@angevo.com. This address constitutes Angevo's contact point for data protection matters.

2. Data subjects

This Privacy Policy applies to the personal data processed by Angevo concerning in particular:

  • customers and users of the application or the customer area;
  • partners and service providers using the partner area;
  • visitors to Angevo's presentation website;
  • persons contacting Angevo or registering via the website, the application or the platform;
  • beneficiaries of credit vouchers, codes or benefits offered via the Angevo ecosystem;
  • authorised users of the internal management environment operated by Angevo.

3. Categories of data collected

a) Data of customers and users of the customer area

  • identification data: surname, first name;
  • contact details: email address, telephone number, intervention address;
  • data linked to the user account;
  • data linked to bookings, assignments, histories and ratings;
  • location or geolocation data, when this feature is used;
  • data relating to exchanges with support;
  • data relating to payments and transactions via the payment provider;
  • photographs, descriptive elements or documents linked to the condition report or the intervention, where applicable;
  • visual data, images, measurements and technical data generated via certain features of the application, in particular when a measurement tool, a surface-estimation tool or a LiDAR-type technology is used.

b) Data of partners and service providers

  • identification data;
  • professional and administrative contact details;
  • company number, VAT number and information linked to professional status;
  • bank details or data necessary for the payment of amounts due;
  • verification documents, certificates and data relating to insurance;
  • availability, intervention zones, operational capacities;
  • assignment histories, response rates, acceptance rates, ratings, incidents or operational feedback;
  • communications via the partner area;
  • photographs, descriptive elements or documents taken or transmitted in the context of assignments.

c) Data of website visitors and of persons registering via the website

  • identification and contact data transmitted via the forms;
  • data linked to requests sent to Angevo;
  • technical data of connection, browsing or use of the website, the application or the platform;
  • data collected via cookies, trackers, SDKs or similar technologies, where applicable.

d) Data processed in Angevo's internal management environment

  • data relating to customer and partner accounts;
  • data of booking, payment, assignment, complaint or support;
  • histories of actions, validations, reports, exchanges or documents linked to the operation of the platform.

Certain data may be collected indirectly, that is, from a person other than the data subject: for example the data of a credit-voucher beneficiary communicated by the issuing professional customer, or certain information relating to a customer transmitted in the context of an assignment. In these cases, Angevo processes this data for the purposes described in this policy and informs the data subjects in accordance with the applicable regulation.

4. Purposes of the processing

Angevo processes personal data for the following purposes:

  • create, manage and secure user, customer and partner accounts;
  • enable registration and access to the services via the website, the application or the platform;
  • organise the connection between customers and partners;
  • manage bookings, allocation, performance, monitoring and closure of assignments;
  • manage payments, refunds, credits, credit vouchers, commissions, payouts and financial operations;
  • manage exchanges, requests, complaints, incidents, disputes and user support;
  • verify the identity, status, compliance and eligibility of partners;
  • document the condition report, quality monitoring and evidence, in particular through photographs or descriptive elements;
  • use geolocation to the extent necessary for the functioning of the service;
  • estimate the intervention surface, facilitate pricing and improve the accuracy of the services, in particular via technical measurement or LiDAR-type features;
  • send operational, technical, administrative, contractual or security communications;
  • improve the functioning, security, quality and user experience of the platform;
  • prevent fraud, abuse, circumvention and unlawful behaviour;
  • comply with applicable legal, regulatory, tax, accounting and administrative obligations.

5. Legal bases of the processing

Angevo processes personal data on the basis of the following legal grounds, depending on the nature of the processing concerned:

  • the performance of a contract or of pre-contractual measures: account creation, management of bookings, connection, performance of assignments, payments and payouts;
  • compliance with a legal or regulatory obligation: tax, accounting, administrative or compliance obligations;
  • Angevo's legitimate interest: security of the platform, fraud prevention, dispute management, improvement of the services, support, quality, operational management and defence of Angevo's rights;
  • the data subject's consent: for certain cookies, trackers, optional geolocation features or other processing lawfully based on this ground.

6. Data recipients and processors

Personal data may be accessible, communicated or processed, to the extent strictly necessary for the purposes pursued, by the following categories of recipients:

  • authorised members of the Angevo team;
  • partners and service providers, only for the data necessary for the performance of the assignments allocated to them;
  • Angevo's technical service providers and processors, involved in particular in hosting, maintenance, payment, sending of emails, notifications, geolocation, support, operational tools, storage or analysis;
  • the payment service provider used by the platform, in particular Stripe;
  • advisers, insurers, auditors or providers involved in the management of a dispute, an incident or a compliance obligation;
  • administrative, judicial or regulatory authorities where the law requires or authorises it.

Where necessary for the management of an assignment, certain data, documents, photographs or descriptive elements may be accessible to Angevo, the partner concerned and, where applicable, the customer concerned, according to the needs of the service, quality monitoring, evidence or the handling of an incident. Where partners access customer data for the performance of an assignment, this processing is governed by the General Terms of Use for Partners and by the applicable data protection obligations; the respective roles of Angevo and the partner with regard to the GDPR are defined by Angevo.

The exact technical tools used by Angevo may evolve. Angevo ensures that each processor presents sufficient guarantees as to the implementation of appropriate technical and organisational measures within the meaning of the GDPR.

7. Payments, Stripe and bank details

Payments made via the platform are processed by Stripe or by any other third-party payment provider used by Angevo. Angevo does not itself store all the sensitive bank data when it is processed directly by the payment provider.

The bank details of partners intended for the payment of amounts due are managed directly via Stripe or via the payment provider used by Angevo.

Certain data linked to the transaction, the payment status, the financial history, the supporting documents, the refunds, the credits, the credit vouchers, the payouts and the payment disputes may nevertheless be processed by Angevo to the extent necessary for the management of the platform, the contractual relationships, support, accounting, compliance and fraud prevention.

The processing carried out by the payment provider is also subject to its own contractual documentation and its own privacy policy.

8. Geolocation

Where the features of the platform or the application require it, Angevo may process location or geolocation data in order in particular to facilitate booking, identify relevant or nearby partners, organise or optimise the intervention, improve the user experience or secure certain features of the service.

Geolocation is used only to the extent necessary for the intended purposes, according to the technical settings and the authorisations granted on the device, in the application or via the features concerned. Where the processing of geolocation data is based on the user's consent, the user may withdraw this consent at any time via the settings of their device or of the application.

9. Photos, condition report and evidence

In the context of certain assignments, Angevo and/or the partners may be led to collect, transmit, store or process photographs, descriptive elements, findings or information linked to the condition report before, during or after an intervention.

These elements may be used to document the condition report, ensure the quality monitoring of the assignment, handle a complaint, an incident or a dispute, manage the exchanges with the customer or the partner, establish evidence, or protect the legitimate interests of Angevo, the customer or the partner. Access to them is limited to the persons who need it for the purposes concerned and may, as the case may be, include Angevo, the partner concerned and, where relevant, the customer concerned.

In the context of the continuous improvement of the quality of the services and of the products used on the platform, Angevo may also, subject to compliance with the GDPR and after putting in place an appropriate contractual framework, transmit to its suppliers and industrial partners technical data and photographs relating to the interventions, exclusively for the purposes of analysis, product diagnosis and improvement of the solutions used.

Prior to any transmission, Angevo ensures that the data is anonymised or pseudonymised as far as possible, in particular by masking the elements allowing the direct or indirect identification of persons, addresses or property. The recipients are contractually bound to confidentiality, to the limitation of purposes and to the security of the data. The Customer may object to this transmission at any time by contacting Angevo at the address privacy@angevo.com.

10. Data retention period

Personal data is not retained beyond the period necessary for the purposes for which it is processed, except where longer retention is required or permitted by law, by a regulatory obligation, by the management of a dispute, by the proof of a right or by Angevo's duly justified legitimate interest. The periods applicable to the main categories of data are as follows:

  • Active customer data — duration of the account (active contractual relationship).
  • Customer data after closure or inactivity — 3 years (Belgian contractual limitation).
  • Partner data after end of relationship — 5 years (general limitation, tax and accounting obligations).
  • Bookings, assignments, payments, financial operations — 7 years (Belgian legal accounting obligation).
  • Support exchanges, complaints, disputes — 3 years after closure (contractual limitation).
  • Photos, condition reports, evidence — 3 years or until closure of the file (evidence and legitimate interest).
  • Geolocation data — 90 days maximum after the assignment (proportionality).
  • Technical logs, security traces — 12 months (technical and regulatory standard).

11. Possible transfers outside the European Union

Angevo favours, as far as possible, hosting and technical solutions located in Europe.

However, in the context of the use of certain tools, services or processors, certain personal data may be processed or accessible outside the European Economic Area. Where such transfers take place, Angevo ensures that they are framed in accordance with the applicable regulation, in particular by means of appropriate safeguards such as the Standard Contractual Clauses approved by the European Commission, the Data Privacy Framework or any other legally permitted mechanism.

12. Rights of data subjects

Subject to the conditions provided for by the applicable regulation, every data subject has in particular the following rights:

  • right of access to their personal data;
  • right to rectification of inaccurate or incomplete data;
  • right to erasure in the cases provided for by law;
  • right to restriction of processing in the cases provided for by law;
  • right to object to the processing, where it is based on legitimate interest and within the limits provided for by the regulation;
  • right to data portability, where this right is applicable;
  • right to withdraw consent at any time, without affecting the lawfulness of the processing carried out before this withdrawal.

These rights may be exercised by contacting Angevo at the dedicated email address indicated in section 1. Angevo undertakes to respond to any request within a maximum period of one (1) month from its receipt, in accordance with the requirements of the GDPR.

13. Complaint to the competent authority

Every data subject has the right to lodge a complaint with the competent supervisory authority for data protection. In Belgium, this is the Data Protection Authority (DPA / GBA):

  • Address: Rue de la Presse 35, 1000 Brussels;
  • Website: apd-gba.be;
  • E-mail: contact@apd-gba.be.

14. Mandatory or optional nature of the data requested

Certain personal data is necessary for the creation of an account, the use of the platform, the performance of an assignment, the management of a payment, the verification of a partner or compliance with a legal or regulatory obligation.

Where the provision of certain data is mandatory, the failure to communicate this data may prevent Angevo from creating an account, processing a booking, allocating or performing an assignment, making a payment, responding to a request or, more generally, providing all or part of the services offered.

15. Data security

Angevo implements appropriate technical and organisational measures in order to protect personal data against destruction, loss, alteration, unauthorised disclosure, unauthorised access or any other form of unlawful processing.

These measures take into account in particular the nature of the data processed, the risks presented by the processing, the state of technical knowledge as well as the security requirements applicable to the platform, the applications, the website and the tools used. Angevo attaches particular importance to the security of sensitive data, in particular partners' bank details, geolocation data, payment data and identity documents, ensuring that access to it is strictly limited to authorised persons.

In the event of a personal data breach likely to give rise to a risk to the rights and freedoms of data subjects, Angevo takes the required measures and proceeds, where applicable, with the notifications provided for by the applicable regulation.

16. Automated decisions and profiling

In the context of the functioning of the platform, Angevo may use partially automated processing, in particular for the allocation and proposal of assignments, the evaluation of service quality, fraud prevention and the security of the platform. This processing may take into account, for example, location, availability, ratings, response and acceptance rates or reliability indicators.

This processing is not intended to take, with regard to data subjects, decisions producing legal effects or significant effects on the sole basis of automated processing, without human intervention. Where an important measure is likely to affect a partner (for example a limitation, a suspension or a delisting), the partner may obtain information on the reasons for the decision, express their point of view and contest it, under the conditions provided for in the General Terms of Use for Partners.

The precise arrangements for this processing may evolve with the platform and be the subject of additional clarifications.

17. Cookies, trackers, SDKs and similar technologies

The website, the mobile application, the platform or certain associated services may use cookies, trackers, SDKs or similar technologies for the purposes of technical functioning, security, authentication, memorisation of preferences, audience measurement, performance improvement, usage analysis and, where applicable, communication or marketing.

Where the applicable regulation requires it, the use of certain cookies, trackers or similar technologies is based on the user's consent. This consent may be managed via the cookie banner, the preference centre or any other mechanism made available by Angevo. Additional information may be specified in a dedicated cookie policy or in the settings of the website, the platform or the application.

18. Modifications of the Privacy Policy

Angevo reserves the right to modify this Privacy Policy in order to take account of the evolution of the platform, of the services, of the tools used, of the applicable regulation or of any other relevant development.

The most recent version is made available on the website, the platform or the application. In the event of a substantial modification, the users concerned are informed by appropriate means.