Privacy policy
This privacy policy (“Privacy Policy”) is applicable to all processing activities of Henchman (as defined below) as a data controller.
Please read this Privacy Policy together with our Cookie Policy. This is the first and only Privacy Policy we have. Henchman may update this Privacy Policy in the future: the latest version can always be found on our Website. You will be able to find our archived Privacy Policies in pdf format here once changes are made.
1. ABOUT THIS PRIVACY POLICY
Due to, for example, your commercial relationship or recent contact with Henchman or due to a visit to or action on our “Website” (i.e. https://www.henchman.io/ including related sub-domains) we may collect, store and otherwise process personal data relating to you or, if you are a company, your employees/representatives (“your personal data”).
This Privacy Policy describes (i) how we collect, treat and store your personal data; (ii) the rights you can exercise in relation to your personal data; and (iii) the measures we take to protect it and to secure your personal data.
Henchman respects your privacy and we always strive 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 ePrivacy Directive 2002/58/EC of 12 July 2002, including future amendments and revisions thereof; and/or (iv) (future) national legislation regarding the implementation of the GDPR (together: “Privacy Legislation”).
2. HENCHMAN IS THE DATA CONTROLLER
We are Henchman BV, a limited liability company with registered office at D’Haenestraat (HEU) 22, 9070 Destelbergen, Belgium, registered with the Crossroads Database for Enterprises under number 0748.395.184 (“Henchman” or “we / us”)
Henchman is the developer and provider of the Henchman solution as described and represented on the Website (the “Solution”), the corresponding service of Henchman (“Service”) and is the owner of the Website.
In light of the Privacy Legislation, Henchman will act as the DATA CONTROLLER of your personal data for the purposes described in this Privacy Policy. This means we are in control of (and thus, responsible for) your personal data.
3. HENCHMAN’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 relation with Henchman.
In particular, we identify five different scenarios:
You are browsing on our Website;
You (wish to) receive direct marketing (such as updates and newsletters) relating to Henchman’s services and products (inc. the Solution);
You are a prospect and/or seeking a commercial relationship with Henchman;
Your company is an active Henchman customer and/or seeking a commercial relationship with Henchman; or,
You are | your company is a partner or a supplier of Henchman.
3.1 You are browsing on our Website
Contacting Henchman via the contact form / Hench-bot on the Website
Purpose:
To answer any questions you may have and/or to initiate a conversation
Personal data:
❑ First name
❑ Voluntarily provided information
❑ Last name
❑ (Work) email address
❑ Nature of inquiry
Legal ground:
Consent
Retention period:
Up until one (1) year after your last contact with Henchman
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.
3.2 You (wish to) receive direct marketing (such as updates and newsletters) relating to Henchman services and products
Direct marketing
Purpose:
Providing more information on (new features of) the Henchman Solution, our Service or related products/services
Personal data:
❑ First name
❑ (Work) email address
❑ Last name
Legal ground:
Consent
Retention period:
Until you have objected to the processing of your personal data for this purpose (cfr. Section 8- “Right to object”). You will be automatically unsubscribed if we did not contact you for over a year.
3.3 You are a prospect and/or seeking a commercial relationship with Henchman
Requesting a personal demo
Purpose:
To schedule your personal demo of the Henchman Platform
Personal data:
❑ First name
❑ (Work) email address
❑ Last name
Legal ground:
Consent
Retention period:
Until you have requested to no longer be contacted by Henchman or until one (1) year following your latest contact with Henchman, whichever comes first ( + verification period of six months)
General communication with Henchman & prospecting by Henchman
Purpose:
To have quality conversations (via mail, telephone or business social media channels) in which Henchman provides more information on its Service and the Henchman Platform
Personal data:
❑ First name
❑ (Work) email address
❑ Last name
❑ Phone number
❑ Company name
❑ Country
❑ Type of industry
❑ Preferred Language
❑ Social media / business channel
❑ Voluntarily provided information
Legal ground:
Legitimate interest
Retention period:
Until you have requested to no longer be contacted by Henchman or until one (1) year following your latest contact with Henchman, whichever comes first ( + verification period of six months)
Registering for | attending a Henchman (network) event
Purpose:
To have an overview of the participants to the event (e.g. drafterwork, webinar, seminar; contest) as well as to have a follow-up communication after the event
Personal data:
❑ First name
❑ (Work) e‑mail address
❑ Last name
❑ Company
Legal ground:
Consent
Retention period:
Until you have requested to no longer be contacted by Henchman or until one (1) year following your latest contact with Henchman, whichever comes first ( verification period of six months)
3.4 Your company is an active Henchman customer
If you read this Policy as an employee of a company relying on Henchman, please note that your employer is to be considered your data controller (as your employer decided to rely on the Solution, choses if you get an account, etc.). To set up the Solution, your employer might have provided us with some of your personal information (e.g. your name, your email-address, etc.). In this context, Henchman has adopted a Data Processing Policy. For more information regarding the Solution, you can always directly contact your employer.
Nevertheless, in some exceptional cases, Henchman will act as your data controller. More specific, Henchman will act as your data controller the following purposes:
General communication and (technical) support
Purpose:
To enable communication with & to provide support to customers
Personal data:
❑ First name
❑ (Work) e‑mail address
❑ Last name
❑ Preferred language
❑ Job function
❑ Voluntarily provided information
❑ Phone number
Legal ground:
In relation with the Customer: necessary for the performance of the agreement
In relation with the End-Users: legitimate interest
Retention period:
Until one (1) year following the termination of the commercial relationship between your company and Henchman
Billing
Purpose:
To prepare invoices for the Service | use of the Henchman Platform
Personal data:
❑ First name
❑ Company
❑ Last name
❑ (Work) e‑mail address
❑ Address
❑ VAT-number
❑ Job function
Legal ground:
Necessary for the performance of the agreement
Retention period:
Until one (1) following the termination of the commercial relationship between your company and Henchman
Quotes | proposals
Purpose:
To draw up (additional) quotes | proposals
Personal data:
❑ First name
❑ Company
❑ Last name
❑ (Work) e‑mail address
❑ Address
❑ VAT-number
Legal ground:
Legitimate interest
Retention period:
Until one (1) year following the termination of the commercial relationship between your company and Henchman
3.5 You are | your company is a partner or supplier of Henchman
General communication and provision of services
Purpose:
To communicate with you in the scope of our commercial relationship
Personal data:
❑ First name
❑ Email address
❑ Last name
❑ Phone number
❑ Company
❑ Preferred Language
❑ Job function
❑ Voluntarily provided information
Legal ground:
In relation with the Customer: necessary for the performance of the agreement
In relation with the End-Users: legitimate interest
Retention period:
For the duration of your commercial relationship with Henchman and in any event accordance with any (data processing) agreements concluded with Henchman
Billing
Purpose:
To pay your invoices for the services provided (incl. corresponding communication)
Personal data:
❑ First name
❑ Company
❑ Last name
❑ (Work) e‑mail address
❑ Address
❑ Financial data (e.g. bank account number)
❑ Job title
❑ VAT-number
Legal ground:
Necessary for the performance of the agreement
Retention period:
For the duration of your commercial relationship with Henchman and in any event accordance with any (data processing) agreements concluded with Henchman
4. LEGAL GROUNDS
You can find more information on the applicable ground for each of the identified processing activities in Section 3 above.
In case the legal ground for processing happens to be legitimate interest, Henchman 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.
5. RETENTION PERIODS
Unless a longer storage period is required or justified (i) by law or (ii) through compliance with another legal obligation, Henchman shall only store your personal data for the period necessary to achieve and fulfil the purpose in question.
6. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
Henchman shall not 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:
Software and cloud providers
Marketing agencies
Freelancers or other service providers
Of course we have made sure that the necessary contracts or similar legal binding acts are in place to ensure that these third parties treat your personal data in accordance with the Privacy Legislation (e.g. Article 28 GDPR).
In addition, we might transfer your personal data:
To competent authorities: for instance, because (i) we are obliged to provide your personal data under law or in the scope of (future) legal proceedings, or (ii) this is necessary to safeguard our rights; or,
In M&A context: meaning, if Henchman or the majority of its assets, is taken over by a third party, in which case your personal data – which Henchman has collected – may be one of the transferred assets.
7. 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, Henchman will ensure that one or more of the listed EU-approved safeguards are in place:
European Commission adequacy decision;
Data transfer agreement (cfr. the Standard Contractual Clauses as provided in the European Commission Implementing Decision (EU) 2021⁄914 of 4 June 2021, including the performance of a transfer impact assessment);
Binding corporate rules; or,
Certification mechanisms.
8. YOUR PRIVACY RIGHTS
The Privacy Legislation (e.g. GDPR) gives you certain rights over your personal data vis-à-vis Henchman. You can exercise these rights by contacting us, as specified in Section 11, and by using the Data Subject’s Rights Form.
Access:
you can ask for confirmation of whether or not personal data that relates to you is being processed. If so, you can ask us to give you copies of your personal data. We may charge you a small fee for this service;
Rectification:
you can ask us to correct | complete any information you believe is inaccurate | incomplete;
Erasure:
you can ask us to erase your personal data, under certain conditions. Please be aware that in this context certain services will no longer be accessible and/or can no longer be provided.
Objection:
You can object to us processing your personal data, under certain conditions.
Restriction of processing:
you can ask us to restrict the processing of your personal data, unless we have legitimate interests for the processing of your personal data that prevail over your interests
Data portability:
you can ask us to transfer your personal data to another organization, or directly to you in a commonly used structured format readable by automatic device, under certain conditions.
9. SECURITY
Henchman undertakes to take reasonable, physical, technological and organizational precautions in order to avoid (i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data.
10. UPDATES
We are entitled to update this Privacy Policy by posting a new version on the Website whereby we will indicate the revision date at the top of this Privacy Policy. As such, it is strongly recommended to regularly consult the Website and the page displaying the Privacy Policy, to make sure that you are aware of any changes.
11. 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 our DPO, via dpo@henchman.io.
12. COMPLAINTS?
You are not satisfied with the manner in which we collect, store or otherwise treat or secure your personal data? We are sorry to hear that and are prepared to take all measures to remedy this situation. Please do contact us!
You also have the right to lodge a complaint with the authorized supervisory authority (i.e. the Belgian Data Protection Authority or the data protection authority of (i) your residence or (ii) your workplace) should you consider that the processing of your personal data infringes the Privacy Legislation. You can send an email to the Belgian Data Protection Authority at contact@apd-gba.be or any other email address provided by the Belgian Data Protection Authority (https://www.dataprotectionauthority.be/contact-us).
Our Data Subject Rights Form