Introduction
Waeg, an IBM Company refers to its global network of member firms and their related entities (collectively, “us”, “we” or “Waeg, an IBM Company”). At Waeg we value your privacy and are committed to protecting and processing your personal information responsibly.
This privacy statement describes how Waeg collects, uses, and shares personal information about consumers and other individuals within our clients, business partners, supplier and other organisations with which Waeg has or contemplates a business relationship. It applies to Waeg and its subsidiaries except where a subsidiary presents its own statement without reference to Waeg’s.
Where we provide products, services, or applications as a business-to-business provider to a client, the client is responsible for the collection and use of personal information while using these products, services, or applications. This collection and use is covered by the client’s privacy policy, unless otherwise described. Our agreement with the client may allow us to request and collect information about authorised users of these products, services, or applications for reasons of contract management. In this case, this privacy statement, or a supplementary privacy notice, applies.
We may provide additional data privacy information by using a supplementary privacy notice.
Personal Information We Collect and Use
This section describes the various types of information that we collect and how we use it.
It includes information on Waeg’s Website, Marketing, Contractual Relationships, Support Services, Recruitment and Former Employees, Conducting our Business Operations, Cookies and Similar Technologies, and Children.
The information that we collect and use may include profile information, interactions on webpages, marketing preferences, information to investigate malicious activities, recordings or transcripts of your conversations with us for support purposes, information to improve our business operations, and more.
Waeg Website
Our website offers to communicate with you about us, our products, and services. The information that we collect on websites is used to provide you with access to the website, to operate the website, to improve your experience, and to personalise the way that information is provided to you.
For more information on the technologies that we use to collect website information, see the Cookies section below.
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We collect information about your use of our websites, such as:
the webpages you view,
the amount of time you spend on pages,
the website URL that referred you to our pages,
your geographic information derived from your IP address,
and any hyperlinks you select.
We use this information to improve and personalise your experience with our websites, provide you with content that you may be interested in, create marketing insights, and to improve our websites, online services, and related technologies.
We also collect the information that your browser or device automatically sends, such as:
your browser type and IP address,
operating system, device type, and version information,
language settings,
crash logs,
and passwords.
We use this information to provide you with access to our web pages, improve the webpage view on your device and browser, adapt to your settings and language, and adapt content for relevancy or any legal requirements for your country. We also use this information to comply with system and network security requirements, and to provide support.
We prepare reports on the use of our websites to derive insights into trending topics and general market knowledge. These reports may be provided to third parties with details on how users interacted with or showed interest in the third-party products or services that were presented on our websites.
We accept no responsibility for the content provided on, or privacy practices, of third-party websites or applications.
Marketing
Subject to your preferences, we use the information that we collect to communicate with you about relevant products, services, and offerings. We also use this information to personalise your online experience with our content and advertisements and to develop internal marketing and business intelligence. You may also submit an opt-out request, or select Unsubscribe at the bottom of each marketing email. To review or set your preferences regarding the information that we collect about you online on our websites, select Cookie Preferences in the website footer.
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We use information that we collect for marketing purposes. This may include information:
Collected directly from you through your interactions with Waeg, such as attendance at events or submission of online registration forms,
Received from third-party data providers, subject to controls confirming that the third party legally acquired the information and has the right to provide the information to Waeg for use in our marketing communications,
Collected on our websites or from your interactions with Waeg emails and content, including content on third-party sites. For more information on the technologies that we use to collect this information, see Cookies and Similar Technologies.
Subject to your preferences, we may use this information to market to you regarding Waeg products, services, and offerings. For example, we may:
Contact you by using email, telephone, or postal mail
Personalise your experience with Waeg products and services, such as sharing more relevant content or pre-filling registration forms on our websites.
Deliver targeted Waeg advertisements on third-party websites based on information we or authorised third parties collect about your interactions with Waeg websites, our content, emails, or, in select geographies, activity linked to your hashed email address.
To set or update your preferences with regards to marketing activities using your email address, phone, or postal address, can be addressed to Waeg, an IBM Company's security officer by: - Post: Avenue Louise 65 bte 11, 1050 Brussel, Belgium - Email: privacy@waeg.com
Requests regarding the collection, processing and use of personal data, further information as well as the right to request information according to Clause 4 of this privacy statement can be addressed to Waeg, an IBM Company's security officer by: - Post: Avenue Louise 65 bte 11, 1050 Brussel, Belgium - Email: privacy@waeg.com.
To opt out of the use of your hashed email for personalisation or targeted advertising, you can withdraw your email consent by using any of these options.
To review or set your preferences regarding the information that we collect about you online on our websites, select Cookie Preferences in the website footer.
We also use this information to develop marketing and business intelligence, which is essential for our business operations. For example, we may:
Combine the information we collect to better understand your interests and potential business needs,
Use aggregated data to measure effectiveness of our marketing campaigns and events, and to proceed to informed business decisions and investments,
Aggregate the information that is collected about Waeg website visitors for the purposes of developing and modelling marketing audiences.
Contractual Relationships
A contractual relationship is created when you order a trial, or a product or service from us. While we mainly provide our products and services to businesses, individuals may also enter into an agreement with us directly as a client. We may collect any information that is reasonably necessary to prepare for, enter, and fulfil the contractual agreement.
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The information collected in a contractual relationship may include the business contact information of the requester, and the order details. Information that is required for shipment and payment, for the implementation of services, or to grant access to the product or service may also be collected.
This information may be collected for various purposes, depending on the nature of the products or services, for example, for contractual management and compliance, to provide support, for the improvement or development of our products and services, to contact you for customer satisfaction surveys, and to generate technical and market insights.
The information collected in a contractual relationship is not used for the purposes of marketing and advertising without obtaining consent before processing.
Support Services
When you contact us to request support, we collect your contact information, problem description, and possible resolutions. We record the information that is provided to handle the support query, for administrative purposes, to foster our relationship with you, for staff training, and for quality assurance purposes.
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The information that we collect may include any information exchanged during our phone conversations. This may include a recording or transcript of your conversations with us. We may use this information to inform you of products or services that are related to your support request. This can include product updates or fixes, and we may combine the information that is collected through other interactions with you or your organisation to provide more valuable suggestions in relation to product support, such as any available training regarding the issue.
While we handle the support case, we may have incidental access to information that you have provided or information that is on your system. This information may contain information about you, your organisation's employees, customers, or other relevant parties. The conditions regarding the handling and processing of this information is covered by the applicable Terms of Use or other agreements between your organisation and Waeg, such as the Terms of Use for Exchanging Diagnostic Data.
Protecting You and Waeg
We may collect and use information to protect you and Waeg from IT security threats and to secure the information that we hold from unauthorised access, disclosure, alteration, or destruction. This includes information from our IT access authorization systems, such as log-in information.
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The security solutions we use to protect your information, our infrastructure, and our networks may collect information such as IP addresses and log files. This is necessary for the functionality and utility of security programs to enable the investigation of any potential security incidents and generate insights on security threats.
We may use specialised tooling and other technical means to collect information at access points to, and in, IT systems and networks to detect unauthorised access, viruses, and indications of malicious activities. The information we collect may be used to conduct investigations when unauthorised access, malware or malicious activities are suspected, and to remove or isolate malicious code or content.
Recruitment and Former Employees
We are constantly searching for new talent for our organisation, and we collect information about job applicants or prospective candidates from several sources. When an employee leaves Waeg, we continue to process information that is related to them for any remaining business, contractual, employment, legal, and fiscal purposes, including the management of pensions to the extent handled by Waeg.
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Regarding recruitment, we may look for prospective candidates with the help of recruitment intermediaries and may use publicly available information on social media platforms to identify prospective candidates for a specific function.
When an employee leaves Waeg, we retain basic information from the former employee about their employment at Waeg.
After an employee retires, we process information about the retiree for fulfilling the pension obligations toward the retiree. Information about the processing of pension information, or other retirement programs, can be found with the local organisation responsible for pensions. In some countries, this may be an independent organisation. In some cases, retirees may still participate in Waeg-organised initiatives or programs, such as volunteer and social responsibility programs. Such participation is voluntary, and more information is provided on the relevant websites or information pages for those initiatives.
Conducting our Business Operations
We collect and use information to improve our business operations, systems, and processes. For example, information may be used to conduct, maintain, audit, and optimise our operations, to protect our assets and employees, for product development, and to defend our rights.
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We collect information about our business operations to make informed decisions about the organisation, the business, and to report on performance, audits, and trends. For example, we use this information to analyse the costs and quality of our operations. Where possible, this is done by using aggregated information, but may use personal information.
We collect and use information from our business systems, which may include personal information, to:
protect or enforce our rights, including to detect fraud or other criminal activities (for example, by using information in payment systems)
handle and resolve disputes
answer complaints and defend Waeg in legal proceedings
and comply with legal obligations in the countries where we do business
We collect information from the use of our business processes, websites, cloud and online services, products, or technologies. This information may include personal information and is used for product and process development. For example, we may use this information to increase efficiency, decrease costs, or improve services by developing automated processes and tools, or to develop or improve the technologies on which these are based.
Cookies and Similar Technologies
When you visit our websites, cloud and online services, software products, or view our content on certain third-party websites, we collect information regarding your connection and your activity by using various online tracking technologies, such as cookies, web beacons, Local Storage, or HTML5. Information that is collected with these technologies may be necessary to operate the website or service, to improve performance, to help us understand how our online services are used, or to determine the interests of our users. We use advertising partners to provide and assist in the use of such technologies on Waeg and other sites.
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When you visit our websites, cloud and online services, software products, or view our content on certain third-party websites, we collect information regarding your connection and your activity by using various online tracking technologies, such as cookies. Information that is collected with these technologies may be necessary to operate the website or service, to improve performance, to help us understand how our online services are used, or to determine the interests of our users. We use advertising partners to provide and assist in the use of such technologies on Waeg and other sites.
A cookie is a piece of data that a website may send to your browser, which may be stored on your computer and can be used to identify your computer. These technologies may be used to provide connected features across our websites or display targeted Waeg advertising (subject to your cookie preferences) on other websites based on your interests.
Session cookies can be used to track your progression from page to page so that you are not asked for information that you have already provided during the current session, or information that is needed to be able to complete a transaction. Session cookies are erased when the web browser is closed. Persistent cookies store user preferences for successive visits to a website, such as recording your choice of language and country location. Persistent cookies erase their data within 12 months.
You can use the Waeg Cookie Manager to learn more about the online tracking technologies we use and to review or set your preferences regarding the information that we collect about you on our websites. The Waeg Cookie Manager is either presented as a notification window when you first visit a webpage or opened by selecting Cookie Preferences in the website footer. The Waeg Cookie Manager does not address all types of tracking technologies (for example, email pixels). When using mobile apps, use the options on your mobile device to manage settings.
Blocking, disabling, or rejecting Waeg cookies may cause services to not function properly, such as in connection with a shopping cart, or block the use of websites or services that require you to sign in. Disabling cookies does not disable other online tracking technologies, but prevents the other technologies from accessing any details stored in cookies.
Our websites offer the possibility to use third-party social media options. If you elect to use these options, these third-party sites may log information about you, such as your IP address, access time, and referring website URLs. If you are logged in to those social media sites, they may also link collected information with your profile information. We accept no responsibility for the privacy practices of these third-party services and encourage you to review their privacy policies for more information.
For information on cookies and how to remove these technologies by using browser settings, see https://www.allaboutcookies.org/.
Children
Unless otherwise indicated, our websites, products, and services are not intended for use by children or minors as specified by law in their jurisdiction.
Sharing Personal Information
We may share your personal information internally and externally with suppliers, advisors, or Business Partners for Waeg’s legitimate business purposes, and only on a need-to-know basis. This section describes how we share information and how we facilitate that sharing.
How We Share Personal Information
When sharing personal information, we implement appropriate checks and controls to confirm that the information can be shared in accordance with the applicable law.
If we decide to sell, buy, merge, or otherwise reorganise businesses in some countries, such a transaction may involve disclosing some personal information to prospective or actual business purchasers, or the collection of personal information from those selling such businesses.
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Internally, personal information is shared for our business purposes: to improve efficiency, for cost savings, and internal collaboration between our subsidiaries. For example, we may share personal information such as managing our relationship with you and other external parties, compliance programs, or systems and networks security.
Our internal access to personal information is restricted and granted only on a need-to-know basis. Sharing of this information is subject to the appropriate intracompany arrangements, our policies, and security standards. For more information, see the Legal Basis section in this statement.
Externally,
Our business with suppliers may include the collection, use, analysis, or other types of processing of personal information on our behalf.
Our business model includes cooperation with independent Business Partners for marketing, selling, and the provision of Waeg products and services. Where appropriate (for example, when necessary for the fulfilment of an order), we share business contact information with selected Business Partners.
We may share personal information with professional advisors, including lawyers, auditors, and insurance companies to receive their services.
We may share contractual relationship information with others, for instance, our Business Partners, financial institutions, shipping companies, postal, or government authorities, such as the customs authorities that are involved in fulfilment.
We may share personal information with third parties, such as advertising technology partners, data analytics providers and social networks engaged by Waeg to deliver targeted Waeg advertisements on their platforms, to aggregate information for analysis, and to track engagement with those advertisements.
In certain circumstances, personal information may be subject to disclosure to government agencies in accordance with judicial proceedings, court orders, or legal processes. We may also share personal information to protect the rights of Waeg or others when Waeg believes that such rights may be affected, for example to prevent fraud.
Facilitating International Transfer
Your personal information may be transferred to or accessed by Waeg subsidiaries and third parties globally. Waeg complies with laws on the transfer of personal information between countries to keep your personal information protected, wherever it may be.
We have implemented various safeguards including:
Contractual Clauses, such as those approved by the EU Commission and accepted in several other countries. You can request a copy of the EU Standard Contractual Clauses (EU SCCs) by contacting Waeg, an IBM Company's security officer by Post: Avenue Louise 65 bte 11, 1050 Brussels, Belgium - Email: privacy@waeg.com
Controller and Representative Information
Waeg does business through its subsidiaries worldwide. The privacy laws in some countries consider a Controller to be the legal entity (or natural person) who defines the purposes for which the processing of personal information takes place and how that information is processed. Parties that are involved in processing operations on behalf of a Controller may be designated as Processors. Designations and associated obligations differ, depending on the jurisdiction.
Waeg BVcan be contacted at: by post: Avenue Louise 65 bte 11, 1050 Brussels, Belgium - Email: privacy@waeg.com.
Information Security and Retention
To protect your personal information from unauthorised access, use, and disclosure, we implement reasonable physical, administrative, and technical safeguards. These safeguards include role-based access controls and encryption to keep personal information private while in transit. We also require our Business Partners, suppliers, and third parties to implement appropriate safeguards, such as contract terms and access restrictions, to protect information from unauthorised access, use, and disclosure.
We only retain personal information as long as necessary to fulfil the purposes for which it is processed, or to comply with legal and regulatory retention requirements. Legal and regulatory retention requirements may include retaining information for:
audit and accounting purposes,
statutory retention terms,
the handling of disputes,
and the establishment, exercise, or defence of legal claims in the countries where we do business.
We retain any contractual relationship information for administrative purposes, legal and regulatory retention requirements, defending Waeg rights, and to manage Waeg's relationship with you. The information that is provided in a supplementary privacy notice may provide more detailed information on applicable retention terms.
When personal information is no longer needed, we have processes in place to securely delete it, for example by erasing electronic files and shredding physical records.
Your Rights
You have certain rights when it comes to the handling of your personal information. You can contact Waeg, an IBM Company's security officer by post: Avenue Louise 65 bte 11, 1050 Brussels, Belgium - Email: privacy@waeg.com. You may do this to:
request access to the personal information that we have on you, or have it updated or corrected. Depending on the applicable law, you may have additional rights concerning your personal information.
Request to obtain your personal information in a usable format and transmit it to another party (also known as the right to data portability).
Request to delete the personal information we hold about you.
Opt-out of specific personal information processing types, such as targeted advertising.
ask questions related to this Privacy Statement and privacy practices. Your message is forwarded to the appropriate member of Waeg’s Data Privacy Team, including the responsible Data Protection Officers.
submit a complaint to Waeg if you are not satisfied with how Waeg is processing your personal information.
Data Rights Request Details:
When you submit a Data Rights (DR) request, you provide us with personal information, including your name and contact details, which we use to respond to your request. In some circumstances, to verify your identity and to ensure we disclose the personal information to the correct individual, we may also request a copy of your photo ID, which is deleted immediately after verification of your identity.
Upon your DR request, your personal information is processed for handling and fulfilling your DR request, in line with Waeg’s legal obligations and commitments related to DRs.
The data relevant to your DR request is retained for a minimum of three years from the date of your last DR-related communication with Waeg, to address any request you may have in relation to it, and for Waeg's compliance and recording purposes.
For more information about how we process your data, see the section entitled: Personal Information We Collect and Use.
Your rights may be subject to limitations and exceptions resulting from applicable laws. For example, there may be situations where we cannot share certain information that you seek if disclosing this means disclosing information about others.
To set or update your marketing communications preferences, you can contact Waeg, an IBM Company's security officer by post: Avenue Louise 65 bte 11, 1050 Brussels, Belgium - Email: privacy@waeg.com. You can also submit an opt-out request, or select Unsubscribe at the end of each marketing email.
Legal Basis
In some jurisdictions, the lawful handling of personal information is subject to a justification, sometimes referred to as legal basis. The legal bases that we rely on for the lawful handling of your personal information vary depending on the purpose and applicable law.
The different legal bases that we may use are:
Necessary for the performance of a contract with you:
We rely on this legal basis when we need to process certain personal information, such as your contact details, payment details, and shipment details, to perform our obligations or to manage our contractual relationship with you.
Examples:
When fulfilling a contract, you may need to receive support services, for which we will need to collect your contact information.
We need personal information to consider job applicants or manage the pension entitlements of retirees (see the section in this statement entitled: Recruitment and Former Employees).
Necessary for the purposes of Waeg’s or third party’s legitimate interest:
Legitimate interests relate to being able to conduct and organise business, which includes the marketing of our offerings, protecting our legal interests, securing our IT environment, or meeting client requirements. Examples:
We capture your use of, and interaction with our websites to improve them.
Where we have a contractual relationship with the organisation that you are working for, we have a legitimate interest to process your personal information used to manage this contract.
We process your business contact information (see the section in this statement entitled: Your Account) in combination with other business-relevant information to tailor our interactions with you and promote our products and services. We may process your contact information together with details of a Waeg event you attended to develop Marketing and business intelligence.
We process the personal information of applicants based on our legitimate interest to source suitable talent (see the section in this statement entitled: Recruitment and Former Employees).
We have to keep our general business operations functional. To this end we may, for example, processes the login information of our IT systems and networks, or CCTV footage at Waeg locations for security and safety purposes.
We may also process personal information where it is necessary to defend our rights in judicial, administrative, or arbitral proceedings. This also falls under the legal basis of legitimate interest in countries where they are not a separate legal basis.
We process personal information for credit protection, which is a specific legal basis under Brazilian law (LGPD) but is also covered under the legal basis of legitimate interest in other countries.
Consent
The processing is based on your consent where we request this. Example:
the optional use of Cookies and Similar Technologies or email of Marketing materials.
Legal Obligation
Where we need to process certain personal information based on our legal obligation. Example:
We may be obliged to ask for a government-issued ID for certain transactions, such as for a financing transaction (see the section in this statement entitled: Contractual Relationship)
Privacy Statement Updates
If a material change is made to this Privacy Statement, the effective date is revised, and a notice is posted on the updated Privacy Statement for 30 days. By continuing to use our websites and services after a revision takes effect, it is considered that users have read and understand the changes.
Previous versions of the statement are available on request by contacting: privacy@waeg.com.
Credits:
Icon ilustrations by @Freepik.