Privacy Policy

We understand that your trust in us is NASCENT's (hereinafter referred to as "NASCENT", "we" or "us") most important asset. As such, your privacy is essential to us.

This privacy policy (hereinafter "Privacy Policy") is applicable to all processing activities of NASCENT (as defined below) as a data controller, including processing (i) on our website https://nascent.live (hereinafter the "Website"), (ii) on the Nascent platform (accessible via the Website) and (iii) any (commercial) relationships between NASCENT and its customers, users, prospects and business partners.

NASCENT hereby wishes to emphasize that it always attempts 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 Belgian Privacy Law of 30 July 2018, (iii) the Dutch General Data Protection Regulation Implementation Act of 16 May 2018, (iv) the ePrivacy Directive 2002/58/EC of 12 July 2002 and/​or (v) other (future) amendments or applicable data protection legislation (hereinafter the ​"Privacy Legislation").

NASCENT AS A DATA CONTROLLER

The data controller of the processing activities is NASCENT BV, a company organized and existing under the laws of Belgium, having its office located at Peter Benoitstraat 54, 3500 Hasselt, Belgium and registered with the Register of Legal Entities of Antwerp, region Hasselt, under number 1022.018.427 and with VAT-number 1022.018.427

For any questions regarding your privacy, you can contact privacy@nascent.live.

NASCENT'S PROCESSING ACTIVITIES

Which Personal Data we collect, store and process and the purpose for which we process this data may differ depending on your relationship with NASCENT.

We process your Personal Data when:

You are browsing on our Website

Contacting NASCENT via the contact form:

  • Purpose: Answering questions / inquiries via the contact form
  • Personal Data: Full name, (work) email address, voluntarily provided message
  • Legal ground: Consent
  • Retention period: Up until one (1) year after your last contact with NASCENT

Downloading a whitepaper:

  • Purpose: Downloading a NASCENT whitepaper via the Website
  • Personal Data: Full name, (work) email address, company name, company function
  • Legal ground: Consent
  • Retention period: Up until one (1) year after your last contact with NASCENT

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.

  • Purpose: Optimizing and personalizing your browsing experience.
  • Personal Data: Electronic identification data: IP address, information collected via cookies
  • Legal ground: Legitimate interest for necessary cookies. Explicit consent for non-essential cookies (consent can be withdrawn at any time).
  • Retention period: Dependent on type of cookie and the cookie consent.

You (wish to) receive direct marketing (such as newsletters) relating to NASCENT's Platform and services

Direct marketing:

  • Purpose: Providing information on NASCENT, (new features on) the Platform or related services or events
  • Personal Data: Full name, (work) email address
  • Legal ground: Consent
  • Retention period: Until you have objected to the processing of your Personal Data for this purpose (cfr. "Right to object"). You will be automatically unsubscribed if we did not contact you for over five (5) years.

You are a prospect and/or seeking a commercial relationship with NASCENT (B2B)

General communication with NASCENT and prospecting by NASCENT:

  • Purpose: Having quality conversations to provide more information about NASCENT, the Platform and its services via mail, telephone, business social media etc.
  • Personal Data: Full name, (work) email address, phone number, company name, country, type of company, social media / business channel, voluntarily provided information
  • Legal ground: Legitimate interest
  • Retention period: Until you have requested to no longer be contacted by NASCENT or until one (1) year following your latest contact with NASCENT, whichever comes first

Quotes / proposals:

  • Purpose: Providing qualitative quotes and proposals for possible cooperations
  • Personal Data: Full name, company name, (work) email address, billing address, VAT-number
  • Legal ground: Legitimate interest
  • Retention period: Until one (1) year following the termination of the commercial relationship between the company and NASCENT

You are an active NASCENT customer (B2B)

General communication and (technical) support via the support chat:

  • Purpose: To enable communication with and to provide support to customers
  • Personal Data: Full name, (work) email address, company information (name, VAT-number), telephone number, billing address
  • Legal ground: Necessary for the performance of the agreement
  • Retention period: Until one (1) year following the termination of the commercial relationship between the company and NASCENT

Invoicing:

  • Purpose: Invoicing for the use of the Platform and the services
  • Personal Data: Full name, company name, (work) email address, billing address, VAT-number
  • Legal ground: Legal ground for bookkeeping reasons
  • Retention period: A period of 7 years for bookkeeping reasons

You are a user of the NASCENT Platform

General communication and (technical) support:

  • Purpose: Assisting with possible issues and/or answering any questions
  • Personal Data: Full name, (work) email address, voluntarily provided information, (technical) information about the enquiry
  • Legal ground: Necessary for the performance of the agreement
  • Retention period: Up until two (2) years after your last contact with NASCENT

Creating your account:

  • Purpose: Making use of the Platform and the services
  • Personal Data: Full name, (work) email address, date of birth, education, professional experience, language knowledge, profile picture (optional), company information
  • Legal ground: Necessary for the performance of the agreement
  • Retention period: Until two (2) years following the termination of the commercial relationship between you and NASCENT (i.e. the use of the Platform)

Using the Platform:

  • Purpose: Performing NASCENT's soft skills assessment and using the Platform for its intended services
  • Personal Data: Soft skills analysis, personality analysis, history of assessments, matching scores, profile information, interaction data
  • Legal ground: Necessary for the performance of the agreement
  • Retention period: Until deletion of the self-assessments or account or two (2) years following the termination of the commercial relationship between you and NASCENT

You are part of NASCENT's scientific research efforts

Research purposes:

  • Purpose: Processing of data by NASCENT for research purposes
  • Personal Data: Data collected as part of scientific research such as identification data and survey data
  • Legal ground: Legitimate interest
  • Retention period: Until completion of the research project or anonymization

You are a using the NASCENT Platform via a partner

If you are using this Platform through one of our partners, please note that the partner is considered your data controller (as they chose to use the Platform, determine whether you receive an account and manage other decisions). However, NASCENT may act as your data controller in specific situations, such as when you directly interact with NASCENT for customer support or account creation.

LEGAL GROUNDS

You can find more information on the applicable legal ground for each of the identified processing activities in the section above. In case the legal ground for processing is legitimate interest, NASCENT 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.

RETENTION PERIOD

You can find more information on the applicable retention period for each of the identified processing activities in the section above Unless a longer storage period is required or justified (i) by law or (ii) through compliance with another legal obligation, NASCENT shall only store your Personal Data for the period necessary to achieve and fulfil the purpose in question.

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

NASCENT shall never 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 trusted:

The necessary contracts or legal binding acts are in place to ensure these third parties treat your Personal Data in accordance with the Privacy Legislation (e.g. Article 28 GDPR).

In addition, Nascent might transfer your Personal Data:

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, NASCENT will ensure that one or more of the listed EU-approved safeguards are in place:

SECURITY MEASURES

We use reasonable and appropriate technological and operational security measures to keep your Personal Data protected against (i) any unauthorised access and (ii) loss, abuse or alteration of your Personal Data. Such measures include:

YOUR PRIVACY RIGHTS

Based on the Privacy Legislation, and provided that you meet the requirements set by this legislation, you can contact us to exercise the following rights:

THIRD PARTY APPLICATIONS AND WEBSITES

This Website contains links to other websites operated by third parties, including but not limited to certain social media sites such as Linkedin. This Policy does not apply to any website, other than this one. Third party websites are governed by their own terms and conditions. You should therefore always carefully check the privacy and cookie policies of third party websites before accepting to be redirected to them.

We also display social media buttons on our Website. When you click on any of those buttons, your Personal Data may be transferred to these companies and they may also set cookies or other tracking technologies on your browser. The privacy policies and terms of use of each of those companies govern the collection and use of your Personal Data when you click on their buttons on our Website.

UPDATES

As NASCENT expands and improves its Website and Platform, or as legal requirements change, we may need to update this Privacy Policy. This Privacy Policy may be modified from time to time without prior notice. We encourage you to review this Privacy Policy on a regular basis for any changes. The date of the latest version and the respective version history will be identified at the bottom of the Privacy Policy.

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:

COMPLAINTS

If you are not satisfied with the manner in which we collect, store or otherwise treat or secure your Personal Data, we will take all reasonable measures to rectify the situation upon notification.

You also have the right to lodge a complaint with the supervisory authority in the European member state of your habitual residence, your place of work or the alleged infringement of applicable data protection legislation:

In Belgium, the Supervisory Authority is:

Belgian Data Protection Authority

Rue de la Presse 35 / Drukpersstraat 35

1000 Bruxelles / 1000 Brussel

Tel. +32 2 274 48 00

contact@apd-gba.be

www.dataprotectionauthority.be

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