Privacy & Cookies Notice

1 General

This statement explains how Wolters Kluwer Belgium NV (“we”, “us”, “our”, “Wolters Kluwer”) with offices at Motstraat 30, 2800 Mechelen, Belgium (phone: +32 15 36 10 00), as data controller, processes personal data that we collect from you through the codabox.com and zoomit.be websites, and through Codabox services.

2 Updates to this privacy statement

We reserve the right to modify this privacy statement at any time, but will do so in each case in accordance with applicable laws and regulations. We will notify you, if possible, by email of any significant changes to this statement.

This statement was last amended and revised in Nov. 2024.

3 Information we collect

3.1 Customer relationship

When you or your company becomes a Wolters Kluwer customer, we collect the following types of personal information about you:

1. Identification data: your name, e-mail address, language preference and phone number, also we assign you or your company a customer number;
2. The products you or your company use and billing information.

When you contact us through our website or via email, we collect the following types of personal data about you:

1. Identifying information: your name, phone number and e-mail address;
2. Details about your work: the name of the company you work for;
3. The messages you send us.

When you give us a banking and teletransmission mandate based on the Codabox services, we collect the following types of personal data about you:

1. Identifying information: your name, phone number, e-mail address and language preference;
2. Details about your work: your job title, employer and work address;

3.2 Use of services

When you interact with Zoomit services, we keep activity logs; to do so, we collect your name, email address, IBAN, bank user ID and language preference.

3.3 Customer Support

When we initiate a screen sharing session with you to assist you in using our products, we collect the following types of personal information about you:

1. Identifying information: your name and e-mail address;
2. All information shared during the screen sharing session (audio and video).

3.4 Marketing

When you register for and/or attend an event we host, we collect the following types of personal data about you:

1. Identifying information: your name and title, e-mail address and phone number;
2. Data related to your company: your company name;
3. Any other information related to the event.

We also collect personal information about you from other event organizers to whom you have consented to share that personal information with us.

When you register for and/or participate in a webinar that we host, we collect the following types of personal data about you:

1. Identifying information: your name, e-mail address, phone number and IP address;
2. Data related to your company: name and VAT number;
3. Data related to security: security logs, connection and activity logs, and your Web browser’s user agent;
4. The questions you can submit during the webinar.

When you participate in one of our surveys, we collect the following types of personal information about you:

1. Identifying information: your name and e-mail address;
2. The answers you provided to the survey.

When you sign up for our newsletter, we collect the following types of personal information about you:

1. Identifying information: your name, professional e-mail and language preference;
2. Work details: your company name and address;

Your device and usage information are also collected when you read the newsletters.

3.5 Website browsing

As you browse our website, we collect the following types of personal information about you:

1. Identification data: your IP address;
2. Data related to security: security logs, connection and activity logs, and your Web browser’s user agent;
3. When you give us permission, we also collect data related to your use of the website, such as the pages you have accessed or if you have visited our website in the past.

4 Processing purposes

Your personal data will be processed for the following purposes:

1. Where it is necessary for the performance of a contract between you and us or to take steps to enter into a contract at your request:
   1. To enable you and/or your business users to register and use our services.
   2. To obtain and maintain mandates to access your company’s banking information.
   3. To obtain and maintain mandates to send your data to your accounting firm.
   4. To send you important messages regarding your use of the Services.
   5. To provide you with the information you request and answer your questions when you contact us.
   6. To provide you with support when you experience problems using our services.
   7. To manage the relationship between you, our customer, and Wolters Kluwer.
   8. To bill your company or trusted parties for use of our services.
   9. To ensure the security of our services, including your data.
   10. To enable you to register for and participate in our webinars or our events.
2. Where you have given your consent:
   1. To contact you at your request and provide you with more information about our services.
   2. To contact you at your request and make an appointment with you.
   3. To enable us to send you promotional offers and information about our Wolters Kluwer products, in accordance with your choices.
   4. To send you surveys to receive feedback so we can improve our products.
   5. To collect your feedback on our products and services.
   6. To start a screen sharing session when you request it to get support.
   7. To place cookies on your browser and perform advanced statistics based on the information these cookies provide us.
3. Where necessary for our legitimate interests, as noted below, and where not overridden by your interests or fundamental rights and freedoms:
   1. To ensure the security of our and other Wolters Kluwer applications, services, processes, websites and databases.
   2. To facilitate business correspondence and business meetings.
   3. To allow review of previous calls for agent training and quality control.
   4. To preserve traces of actions taken during screen sharing sessions.
   5. To send existing customers information about the evolution of Wolters Kluwer products; you may request to stop these communications at any time via an unsubscribe link present at the bottom of each communication.
   6. To improve our services and develop new commercial offers for the whole group by e.g. trends, recurring problems, customer behavior, by your use of our services;
   7. To advertise our services to existing customers.
   8. To obtain non-nominative information about the visitors who consult Wolters Kluwer websites.
   9. The creation of a database of reliable combinations of IBAN numbers and account holders, which will be used for fraud prevention.
      For these purposes, we have performed a balancing test, as required by law, and have determined that, taking into account the limited personal data collected, the processing performed and your reasonable expectations, our legitimate interest in performing these processing activities is not overridden by your interests or fundamental rights and freedoms.
4. Where it is necessary for us to comply with our legal obligations, such as reporting crime or attempted crime, or tax returns.

5 Sharing your personal information

To be able to provide you the best possible Services and further our business operations, we may share certain information internally or with selected third parties. There might also be a certain statutory or legal obligation that we believe in good faith requires us to disclose your personal information externally. Parties we might share data with include: 

• other Wolters Kluwer affiliates or subsidiaries, e.g. for customer data management or providing underpinning technology to support the Services we are delivering; 
• our service providers, e.g. for managing or hosting services and/or underpinning technology for the Services we are providing; 
• our business partners and advertisers, e.g. if you have purchased or expressed interest in a product or service, or have been delivered or viewed an advertisement, of such a business partner, interacted with them or otherwise authorized the sharing of your personal information with such a business partner;
• subscribing, accrediting or professional organizations, e.g. for providing utilization information to organizations that provide you with access to our Services and/or sharing tracking and redeeming credits for professional accreditation; 
• organizations involved in business transfers, e.g. to a purchaser or successor entity in the event of a sale or any other corporate transaction involving some or all of our business; 
• other parties, e.g. as needed for external audits, compliance, risk management, corporate development and/or corporate governance related matters; or 
• governmental authorities, regulators and other third parties, in response to a legal request, court orders and/or as otherwise necessary to comply with applicable law. 

Whenever we share personal information internally or with third parties in other countries, we have appropriate safeguards in place in accordance with the applicable data protection laws, including as applicable the EU Model clauses or other transfer safeguard specified in the applicable data protection laws such as binding corporate rules, a mutual agreement or derogations. As required under the applicable law, third parties are required to use appropriate safeguards to protect personal information, and they can only access the personal information that is necessary for performing their specific tasks. 

6 How long do we keep your personal information?

Your personal information will be processed to the extent necessary for the performance of our obligations, to comply with legal obligations, and for the time necessary to achieve the purposes for which the information is collected, in accordance with our data retention policies and the applicable data protection laws. When we no longer need your personal information, we will take all reasonable steps to remove it from our systems and records or take steps to properly anonymize it so that you can no longer be identified from it. 

7 Children

Users of Codabox must be at least 18 years old.

8 Automated decision-making and profiling

No automated decisions are made about you as part of the processing described in this statement.

A profile of your behavior when you use our Web site will be created by Wolters Kluwer if you consent to our advertising and tracking cookies being placed on your computer.

9 Your rights

You have the right to ask us for a copy of your personal data, to ask us to correct, delete or restrict (stop active) processing of your personal data, and to provide the personal data you have provided to us in a structured, machine-readable format. In addition, you may object to the processing of your personal data in certain circumstances (in particular, where we do not need to process your personal data to comply with a contractual or other legal requirement).

Where we have requested your consent, you may withdraw it at any time; however, this will not affect processing that has already taken place prior to the withdrawal. You may withdraw your consent associated with our use of cookies by deleting the cookies associated with our domain.

You may exercise the above rights by contacting us as described in the “Contact Us” section below.

These rights may be limited, for example, if complying with your request would reveal personal information about another person, or if you ask us to delete information that we are legally required to retain or have a compelling legitimate interest in retaining.

If you have unresolved issues, you have the right to file a complaint with the Data Protection Authority: https://www.gegevensbeschermingsautoriteit.be/

10 Contact

If you have any questions about this privacy statement or wish to contact us for any reason in connection with the processing of your personal data, please contact us by sending an e-mail to wkbe-gdpr@wolterskluwer.com or by sending a dated and signed request to Wolters Kluwer Belgium NV, Motstraat 30, 2800 Mechelen.