Angevo BV — Excelsiorlaan 25, 1930 Zaventem (Belgium) — CBE 1032.536.987 — VAT BE 1032.536.987 — privacy@angevo.com
Angevo BV undertakes to process personal data in accordance with the General Data Protection Regulation (GDPR — Regulation (EU) 2016/679), the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data, and any other applicable regulations.
This Policy applies to processing carried out in connection with the Angevo platform, its website and the Partner Portal. It supplements Angevo's contractual documents: the Customer Terms of Use, the Terms of Sale, the Provider Terms of Use, the Provider Commercial Terms and the Partner Terms.
Angevo BV, Excelsiorlaan 25, 1930 Zaventem (Belgium) — CBE 1032.536.987 — VAT BE 1032.536.987.
For any question relating to this Policy or to the exercise of data protection rights, Angevo can be contacted at: privacy@angevo.com.
a) Customers
The app does not access the location of the Customer's device.
b) Beneficiaries of an ANGEVO Voucher
Where the beneficiary creates an account and uses the Voucher, the data referred to in point a) also apply.
c) ANGEVO Providers and applicants
d) ANGEVO Partners, account managers and representatives
e) Website visitors
f) Technical data of the app
g) Internal management area
Indirect collection. The data of a Voucher beneficiary are provided to Angevo by the Partner creating the Voucher for them. Angevo informs the beneficiary of this, specifying that their contact details were provided by the Partner and referring to this Policy: in the e-mail containing the Voucher where it is delivered by e-mail, or by a short information e-mail, which does not contain the Voucher and has no commercial character, where the Partner hands over the Voucher in its printable version. The printable version also bears a short confidentiality notice.
Performance of a contract or pre-contractual measures
Legal obligation
Legitimate interest of Angevo, and where applicable of the Partner
Consent
The technical permissions requested by iOS or Android, in particular for location or notifications, are separate from the legal basis for processing within the meaning of the GDPR.
Data may be accessible to, disclosed to or processed by the following, within the limits strictly necessary for the purposes pursued:
Angevo uses in particular the following technical processors:
Angevo ensures that each processor provides sufficient guarantees regarding the implementation of appropriate technical and organisational measures within the meaning of the GDPR. The technical tools used may change.
Payments made via the platform and the Partner Portal are processed by Stripe or by any other payment service provider used by Angevo. Angevo does not itself store all sensitive banking data where such data are processed directly by the payment service provider.
Providers' bank details intended for the payment of sums due are managed via Stripe Connect or via the payment service provider used by Angevo.
Partners' payments for the Vouchers they fund, as well as the corresponding invoicing, give rise to the processing of the data necessary to issue the documents and comply with accounting and tax obligations.
Certain data relating to the transaction, payment status, financial history, supporting documents, refunds, store credits, Vouchers, payouts and payment disputes may be processed by Angevo to the extent necessary for the management of the platform, support, accounting, compliance and fraud prevention.
Processing carried out by the payment service provider is also subject to its own contractual documentation and its own privacy policy.
During the first configuration of their area, the app asks the Provider for access to the location of their device, in order to determine their position and configure their area of activity. This area is then used to present the nearest Assignments.
The exact GPS coordinates obtained on that occasion are not retained. After this configuration, the Provider may withdraw location permission in their device settings, without this preventing normal use of the app.
Angevo does not permanently track the Provider's position or movements.
The app does not access the location of the Customer's device.
Purposes. Photographs are in principle taken before and after each intervention, and may be taken during it, in order to document the condition before and after the intervention, ensure quality control, manage incidents and complaints, prevent and resolve disputes, establish evidence and defend the rights of Angevo, the Customer or the Provider. This processing is based on Angevo's legitimate interest.
Safeguards. Photographs are limited to what is necessary for the Service. Persons and private items unrelated to the Assignment are avoided as far as possible. They are not used for marketing purposes on this basis.
Storage and access. Photographs are hosted by Microsoft Azure. Access is limited to Angevo's authorised administrators, the Customer concerned and the Provider who accepted the Assignment. No photograph is disclosed to the ANGEVO Partner.
External technical advice. Where necessary to obtain technical advice, verify a product or method, or deal with an incident, Angevo may transmit to a supplier or manufacturer only the strictly necessary photographs and technical information, after minimisation. The Customer's identity, address and other data allowing them to be identified are not transmitted.
Right to object. The Customer may object to the photographic processing by writing to privacy@angevo.com. Their objection is subject to human review on a case-by-case basis. During this review, the taking of new photographs is suspended and photographs already taken are merely retained, without any further unnecessary use.
Angevo may only maintain the processing where it demonstrates, for the Assignment concerned, compelling legitimate grounds overriding the Customer's particular situation, or where the photographs are necessary for the establishment, exercise or defence of legal claims. The following may in particular be taken into account: the need to document the initial condition, a risk of damage or dispute, a restoration or decontamination service, an incident, a complaint or a specific evidential need. Mere operational convenience is not sufficient. In that case, the Customer is informed.
Where the objection is upheld, photographs already taken are deleted or anonymised, unless their retention remains necessary because of an incident, damage, a complaint or the defence of rights; they are then retained only for that purpose and for the necessary period.
Objection expressed during the intervention. Where the Customer expresses their objection directly to the Provider, the Provider immediately suspends the taking of new photographs and contacts Angevo. The Provider does not rule on the request themselves; only Angevo examines it and decides on it.
The consequences of an objection for the course of the intervention are governed by the applicable contractual terms.
Creation and delivery. The ANGEVO Partner creates each Voucher directly for a specific beneficiary, providing Angevo only with the beneficiary's first name, surname, e-mail address and language of communication, as well as, where applicable, its own file reference. No telephone number or address of the beneficiary is provided by the Partner. The Voucher is delivered in one of the following two ways: either Angevo sends it to the beneficiary by e-mail, this e-mail stating that their contact details were provided by the Partner and referring to this Policy; or the Partner downloads the printable version of the Voucher and itself hands it over to the beneficiary. In the latter case, unless sending by e-mail is subsequently requested, no e-mail containing the Voucher is sent to the beneficiary; Angevo automatically sends them a short information e-mail, of no commercial character, stating that their contact details were provided by the Partner and referring to this Policy. The printable version bears a short confidentiality notice. Whatever the delivery method, it is the same Voucher, with the same code; it may be reprinted or subsequently sent by e-mail without a new code.
Code and confidentiality. The Voucher is embodied in a unique code. Before its first use, any person holding the code can technically use it; the beneficiary is therefore asked to keep it confidential.
Follow-up and history. Angevo records the status of the Voucher (Available, Reserved or Redeemed, as well as administrative states such as suspended, invalidated or expired) and the history of the actions carried out on the Voucher, in particular its creation, its sending and resending by e-mail, the downloads of its printable version, its reservation, redemption, reinstatement, temporary suspension, invalidation and replacement. An invalidated Voucher is not deleted: its record and history are retained.
Use. Upon validation of an Order using the Voucher, Angevo processes the data enabling the Voucher to be linked to the account concerned and to the Order, in order to ensure follow-up, traceability, accounting and fraud prevention.
Information to the Partner. The information accessible to the Partner is limited to that indicated in section 6. Where a Voucher is reinstated following the cancellation of an Order, the Partner sees only its current status.
No marketing use. The beneficiary's data are not used for any automatic marketing on the basis of legitimate interest.
Objection by the beneficiary. The beneficiary may object to the processing of their data based on legitimate interest. Their objection is subject to human review; during this review, processing is limited to what is necessary. Angevo may only continue the processing if it demonstrates compelling legitimate grounds overriding the beneficiary's interests, rights and freedoms, or if the processing is necessary for the establishment, exercise or defence of legal claims. Where the objection is upheld before any linking and any use of the Voucher, Angevo ceases the active administration of the Voucher for that beneficiary and deletes or anonymises their data when no longer necessary, subject to legal obligations, evidential needs and the defence of rights. The Partner may then, under the conditions set out in the Partner Terms, request the designation of a new beneficiary.
The app may offer the Provider a link to Novatio's Pro Shop. Mere access to this link does not entail any transmission of data by Angevo. Purchases there are concluded directly with Novatio, under its own terms and its own privacy policy; Angevo is not a party to them.
Where the Provider asks Angevo to facilitate the opening of a professional account with Novatio, Angevo transmits only the information necessary for that opening: company name, address, VAT number and contact person. If the Provider already has a Novatio account, they order directly from Novatio, without Angevo's involvement.
Each time a contractual document is accepted, Angevo records the user or Partner concerned, the type of document, the exact identifier of its version, the language, and the date and time of acceptance.
These data make it possible to demonstrate acceptance of the contractual documents, identify the version and language accepted, manage disputes and establish, exercise or defend Angevo's rights.
Angevo does not retain data beyond the period necessary for the purposes for which they are processed. No single period applies to all data: the retention period depends on the category of data and the purpose concerned.
Where the data are no longer necessary for any of the purposes described in this Policy and no legal obligation precludes it, they are deleted or anonymised.
13.1 Operational account and relationship data
Data relating to the account of a Customer, Provider or Partner, as well as to operational exchanges, are retained for the duration of the relationship, then for as long as necessary to settle remaining contractual obligations, in particular pending Orders, Assignments, Vouchers, payouts or adjustments, and finally only for the period required by applicable legal obligations.
The contractual right granted to the Provider to request, for twelve (12) months following the end of the relationship, the communication of certain of their financial and Assignment data is separate from the retention period: its purpose and effect are not to set that period.
13.2 Assignment data and photographs
Assignment data and photographs are retained for the period necessary for the performance and follow-up of the Assignment, then for the period necessary to handle any complaint, incident or dispute.
Once they are no longer necessary for these purposes, they are deleted or anonymised. In the event of a pending proceeding, complaint or dispute, retention is limited to the data necessary for handling it, until its final resolution.
13.3 Location
The exact GPS coordinates obtained during the initial configuration are not retained. Only the area of activity configured by the Provider is retained, together with their account data, under the conditions of section 13.1.
13.4 ANGEVO Vouchers
Data relating to an ANGEVO Voucher, including invalidated Vouchers, the history of status changes and the history of actions carried out on the Voucher, are retained for the Voucher's period of validity and use, then for as long as necessary to prove transactions, manage complaints, prevent fraud and comply with applicable legal and accounting obligations.
13.5 Accounting and tax data
Documents and data falling within the scope of Belgian accounting and tax obligations, in particular invoices, proofs of payment, self-billing documents and accounting books, are retained for ten (10) years, in accordance with the retention period applicable in Belgium.
This period applies only to the data covered by these obligations and is not automatically extended to other personal data.
13.6 Complaints, incidents and disputes
The data necessary to handle a complaint, incident, dispute or request for review are retained for the duration of the handling, then for the period necessary to defend the rights of Angevo or of the data subject, within the limits of the applicable limitation periods. Data relating to a withdrawal statement and its acknowledgement of receipt, including the date and time of the statement, are retained for as long as necessary to establish the exercise of the right of withdrawal, process the corresponding refund and manage any dispute, without prejudice to section 13.5.
13.7 Acceptance of contractual documents
These data are retained for as long as they are necessary to establish acceptance of the applicable document and to allow Angevo or the user to assert or defend their rights.
13.8 Technical, security, diagnostic and audience measurement data
Technical logs and security traces are retained for the limited period necessary for platform security, incident detection and fraud prevention. Diagnostic and audience measurement data collected on the basis of consent are retained for the limited period necessary for those purposes.
The platform's main hosting is located in the European Union.
Certain processors, however, belong to groups established outside the European Economic Area or may access the data from there. Where such transfers take place, Angevo ensures that they are governed in accordance with applicable regulations, in particular by means of appropriate safeguards such as the standard contractual clauses approved by the European Commission, the EU–US Data Privacy Framework or any other legally recognised mechanism.
These rights may be exercised by contacting Angevo at the address given in section 1. Angevo undertakes to respond to any request within a maximum of one (1) month of its receipt, in accordance with the requirements of the GDPR.
Every data subject has the right to lodge a complaint with the Belgian Data Protection Authority (APD / GBA): Rue de la Presse 35 / Drukpersstraat 35, 1000 Brussels — apd-gba.be — contact@apd-gba.be.
Certain data are necessary to create an account, use the platform, perform a Service, manage a payment, verify a Provider or Partner, or comply with a legal or regulatory obligation.
Where the provision of certain data is mandatory, failure to provide such data may prevent Angevo from creating an account, processing an Order, allocating or performing an Assignment, making a payout, validating a Partner account, responding to a request or, more generally, providing all or part of the services offered.
Angevo implements appropriate technical and organisational measures to protect data against destruction, loss, alteration, unauthorised disclosure, unauthorised access or any other form of unlawful processing.
These measures take into account the nature of the data processed, the risks presented by the processing, the state of the art and the applicable security requirements. Angevo pays particular attention to bank details, payment data, Voucher codes and identity documents, access to which is strictly limited to authorised persons.
In the event of a personal data breach likely to result in a risk to the rights and freedoms of data subjects, Angevo takes the required measures and, where applicable, makes the notifications provided for by the applicable regulations.
The platform uses partially automated processing to present Assignments to Providers. The default display order is based on the distance between the Assignment and the Provider's area of activity; the Provider may also sort Assignments by remuneration or by time.
The acceptance or refusal rate of Assignments is recorded for operational follow-up purposes, but is used neither for allocation, nor for ranking, nor for any evaluation of the Provider, and has no effect on their access to Assignments.
No restriction, suspension, delisting or termination affecting a Provider's access is decided by an automated system: any such measure is validated by an authorised person at Angevo before taking effect. The Provider may obtain information on the reasons for the decision, submit their observations and request a review, under the conditions set out in the Provider Terms of Use.
The activation of a Partner account is subject to manual validation by Angevo.
Website angevo.com. The website displays a banner allowing non-strictly necessary cookies to be accepted or refused. The choice made is stored for twelve (12) months on the user's device. The Google Analytics 4 audience measurement tool is only loaded after prior consent; if consent is refused, it is not loaded.
Partner Portal. No third-party audience measurement tool is used.
App. No audience analytics tool is used in the app. Crash and performance reports are only collected after the user's agreement; refusing them does not prevent use of the app. No name, e-mail address, telephone number, address or Angevo account identifier is intentionally added to them.
Notifications. Notifications sent by the app are exclusively operational and service-related; no marketing or advertising is sent through this channel. Permission to receive notifications, requested by the operating system, may be refused or withdrawn without preventing access to the service. Important information is not communicated exclusively through this channel.
No advertising or behavioural tracking tool is used.
Angevo reserves the right to amend this Policy to take account of changes to the platform, the services, the tools used, applicable regulations or any other relevant development.
The most recent version is made available on the website, the platform, the Partner Portal or the app. In the event of a substantial change, the users concerned are informed in an appropriate manner.
