Privacy Policy

1. General

This Website Privacy Policy (the "Privacy Policy") sets out how we (as defined below) collect, share, and use any information that, alone or in combination with other information, relates to you ("Personal Data") ("User", "you" or "your") when you use our Bsit Application (the "App") or our website bsit.com (the "Website"), in relation to the services offered by Bsit through this App. The App and the Website are owned and maintained by Bsit Technologies Public Limited Company, known under the commercial denomination of "Bsit", with registered office at Avenue Louise, 251, 1050 Brussels and registered with the Crossroads Bank of Enterprises (RPM Brussels) under number 0632.842.351, and with VAT BE0632842351 ("Bsit", "us", "we", or "our").

If you have any requests concerning your Personal Data or any queries with regard to these practices please us contact at legal@bsit.com.

In this Privacy Policy, the term "Personal Data" refers to any information, used alone or in combination with other information, allowing to identify you either directly, such as your name and your email address, or indirectly such as information collected from your mobile device. Please carefully read the present Privacy Policy in order to understand how we use your Personal Data after it has been collected by us. Please read through this Privacy Policy before submitting any of your Personal Data to us.

You do not need to submit any of your Personal Data when browsing our Website. If you do not want us to process your Personal Data, please do not submit any of your Personal Data on this Website. Please note, however, that without your Personal Data, you may not be able to use some of the services offered by the Website. In order to use our App, you will need to submit some Personal Data, as set out hereunder.

This Privacy Policy may be updated from time to time in response to the evolution of legal, technical or commercial developments. The date of the most recent revisions will appear on top of this page. When we update our Privacy Policy, we will take appropriate measures to inform you, taking into account the importance of the changes we make. We will obtain your consent for each important change made to this Privacy Policy if this is required by the applicable data protection law.

2. When do we collect Personal Data?

Through our Website, we collect Personal Data from you through the use of online forms and every time you email us your details.

Through our App, we collect Personal Data from you when you create a user profile and every time you use our App.

3. What Personal Data do we collect form you and why?

The types of Personal Data that we may collect about you, and the reasons why we process it, are the following:

Why we collect it (purpose)	Channel	Types of Personal Data	Data subjects	Legal basis
Website access, administration and security	Website	IP address; device identifiers; technical data; log files	Website visitors	Legitimate interest (Art. 6(1)(f) GDPR): ensuring the security and proper functioning of the Website
Handling contact requests and communications	Website	Identification data; contact details; content of communications	Website visitors	Legitimate interest (Art. 6(1)(f) GDPR) : responding to inquiries and communications initiated by users
Sending informational communications following user contact	Website	Identification data; contact details	Website visitors	Legitimate interest (Art. 6(1)(f) GDPR) : following up on user-initiated contact and providing requested information
Sending promotional communications about the App	Website	Identification data; contact details	Website visitors	Consent (Art. 6(1)(a) GDPR)
Statistical analysis and improvement of the Website	Website	Technical data; usage data (aggregated)	Website visitors	Legitimate interest (Art. 6(1)(f) GDPR): analyzing and improving the performance and use of the Website
User registration and account management	App	Identification data (name, first name, email address, phone number); log data	Parents; Sitters	Performance of a contract (Art. 6(1)(b) GDPR)
Provision and operation of the App (matching Parents and Sitters)	App	Identification data; profile data (picture, language); number and age of children; skills, experience and approvals; usage data (sittings history, favourites, ratings)	Parents; Sitters	Performance of a contract (Art. 6(1)(b) GDPR)
Payment processing and financial administration	App	Credit card details (Parents); bank account number (Sitters – optional)	Parents; Sitters	Performance of a contract (Art. 6(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR)
App security, fraud prevention and trust & safety	App	Identification data; usage data; log files; device data	Parents; Sitters	Legitimate interest (Art. 6(1)(f) GDPR): ensuring the security of the App and maintaining trust and safety among users
Statistical analysis and improvement of the App	App	Usage data; technical data; interaction data	Parents; Sitters	Legitimate interest (Art. 6(1)(f) GDPR): analysing usage and improving the App and related services
Marketing measurement and attribution	App	Device identifiers (e.g. IDFA); limited app usage data (e.g. app install, registration completed)	Parents; Sitters	Consent (Art. 6(1)(a) GDPR)
Optional geolocation functionality	App	Geolocation data	Parents; Sitters	Consent (Art. 6(1)(a) GDPR)
Optional access to phone contacts	App	Phone contacts (pseudonymised through encryption)	Parents; Sitters	Consent (Art. 6(1)(a) GDPR)
Social media / Facebook account integration	App	Facebook account data	Parents; Sitters	Consent (Art. 6(1)(a) GDPR)
Referral and invitation features (inviting other users to reserve a Sitting)	App	Identification data; contact details	Parents; Sitters; invited persons	Legitimate interest (Art. 6(1)(f) GDPR): facilitating the organisation and use of the Bsit services
Sharing data with business partners for gifts or advantages	App	Limited identification and contact data	Parents; Sitters	Consent (Art. 6(1)(a) GDPR)
Display of limited user data to promote Bsit services	Website / App	Photo; first name; first letter of surname; postal code; comments	Sitters	Legitimate interest (Art. 6(1)(f) GDPR): promoting the service and ensuring transparency and trust among users
Compliance with legal obligations and requests from authorities	Website / App	Identification data; transaction data; any data required by law	Website visitors; Parents; Sitters	Legal obligation (Art. 6(1)(c) GDPR)
Corporate transactions (audit, merger, acquisition)	Website / App	Identification data; account and usage data	Parents; Sitters	Legitimate interest (Art. 6(1)(f) GDPR): enabling due diligence and corporate transactions

If we ask you to provide any other Personal Data not described above, then the Personal Data we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect that Personal Data.

At the time of collection of your Personal Data, we will indicate to you whether you are obliged to provide certain Personal Data in order to use our services and / or the App. Please note that if you do not wish to provide us with such mandatory Personal Data (contractually obliged or by law), you will not be able to use the App or our services. Other Personal Data that is not mandatory may be provided by you voluntarily and is optional. If you do not wish to share this optional Personal Data, this will not affect your ability to use our services or the App.

From time to time, we may receive Personal Data about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Data to us.

The types of Personal Data we collect from third parties may include contact details and other information provided by suppliers or partners. We use this information solely to the extent necessary to provide and secure our services, and to handle related operational or legal matters.

In general, we will use the Personal Data we collect from you only for the purposes described in this Notice or for purposes that we explain to you at the time we collect your Personal Data. However, we may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

Marketing Measurement and Attribution: To help us reach more families and grow the Bsit community, we use third-party partners to measure the performance of our advertising campaigns. We may share technical identifiers (such as your device's IDFA) and limited app usage data (such as "App Install" or "Registration Completed") with our mobile measurement partners and third-party advertising networks.

Why we do this: Attribution: To understand which ads directed you to our app. Optimization: To ensure our ads are shown to parents who are most likely to benefit from our service.

We only share your unique device identifier (IDFA) for these purposes if you explicitly grant us permission via the iOS App Tracking Transparency (ATT) prompt. You can revoke this permission at any time in your device settings.

4. Who do we pass your Personal Data to?

We may transmit your Personal Data to other Users to enable them to contact you via the App.

We may transfer your Personal Data to our business partners in the context of promotional campaigns in accordance with what is stated here above. However, we do not share your Personal Data with other third parties outside our company without your prior consent. We may share certain technical identifiers with our advertising and measurement partners strictly for the purpose of measuring ad performance and attribution, provided you have given your consent.

We will only disclose Personal Data to government bodies and law enforcement agencies, if (i) required by law or (ii) to comply with judicial requests or (iii) to protect your vital interests or those of any other person. We may also share Personal Data with external service providers which we use to help us offer the data processing services or who process the Personal Data for purposes described in this Policy, or which are notified to you when collecting your Personal Data. This concerns communications with third-party providers as well as other service providers we use as part of the services they provide to us, including support in areas such as the development of the App, the payment, hosting or bill processing.

Some of the service providers we use may be based in countries outside the European Economic Area ("EEA"). In such circumstance, we shall comply with all applicable laws and take steps to ensure that your Personal Data receive the same level of protection as within the EEA, that is to say, they are stored and used according to our instructions and this Policy and for the purposes we told you at the time of collection of your Personal Data.

In addition, we may transfer your Personal Data to (i) our auditors, advisors, legal representatives and similar agents in the course of providing consulting services to us for legitimate business purposes and pursuant to a contractual prohibition to use the Personal Data for other purposes or (ii) a potential buyer (and its agents and advisors), in connection with a proposed purchase, merger or acquisition of a part of our business, provided that we inform the buyer that he / she must use your Personal Data only for the purposes described in this Policy.

5. How we protect your privacy

We will protect Personal Data in accordance with this Notice, as follows:

1. Fairness: We will process Personal Data fairly. This means that we are transparent about how we process Personal Data and that we will process it in accordance with applicable law.

2. Purpose limitation: We will process Personal Data for specified and lawful purposes, and will not process it in a manner that is incompatible with those purposes.

   We will not retain your Personal Data longer than is necessary for the proposed purpose of processing of your Personal Data as stated in this Policy. When we do not have a legitimate business need to process your Personal Data, we will delete them or make them anonymous, or if this is not possible (for example, your Personal Data has been stored in backup archives), we store them safely and isolate them from further processing until removal is possible.

3. Proportionality: We will process Personal Data in a way that is proportionate to the purposes which the processing is intended to achieve.

4. Data accuracy: We take appropriate measures to ensure that the Personal Data that we hold is accurate, complete and, where necessary, kept up to date. However, it is also your responsibility to ensure that your Personal Data is kept as accurate, complete and current as possible by informing Bsit of any changes or errors. You should notify your local Bsit contact of any changes to the Personal Data that we hold about you (e.g. a change of address).

5. Data security: We use appropriate technical and organizational measures to protect the Personal Data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data.

6. Data processors: We may engage third parties to process Personal Data for and on behalf of Bsit. We require such data processors to process Personal Data and act strictly on our instructions and to take appropriate steps to ensure that Personal Data remains protected.

7. Data retention: We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

8. International transfers: Since the Internet is a global environment, using the Internet to collect and process Personal Data necessarily involves the transmission of data across international boundaries. Therefore, by browsing the Website or the App and by providing us Personal Data, you acknowledge our processing of your Personal Data on this basis.

   This means that your Personal Data may be transferred and processed in countries other than the country where you reside. These countries may have data protection laws that are different from the laws of your own country (and, in some cases, may not be as protective). More specifically, our servers are located in the EEA and our service providers and partners operate across the globe. This means that when we collect your Personal Data, we can process it in all those countries. However, we have taken appropriate safeguards to require that your Personal Data remain protected in accordance with this Policy. This includes implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Data between our group companies, which require all group companies to protect Personal Data they process from the EEA in accordance with European Union data protection law. Our Standard Contractual Clauses can be provided on request.

6. Bsit Care

If you would use the App as part of the Bsit Care program entered into by your employer, we would like to inform you of the following:

• Your employer cannot be held liable for the processing of your Personal Data by us through the App or Website.
• Your employer may be granted access, once a year and for reasons dependent on the possible departures of its employees, to the following Personal Data: your private telephone number and your corporate e-mail address. However, your employer is not granted access to any other Personal Data, including but not limited to your user history of the Service.

7. Cookies

A cookie is a file containing small amounts of information which a website or app can send to your browser, which may then be stored on your computer or mobile device when you use a website or an app. We use cookies to make it easier for you to visit the Website or use the App and to allow us to understand what areas of the Website or the App are of interest to you. For more information about cookies, please read our Cookie Policy available here.

8. Linking to other websites

The Website or the App may contain hyperlinks to websites or apps owned and operated by third parties. These websites or apps have their own privacy policies and we urge you to review them. They will govern the use of Personal Data you submit whilst visiting these websites or apps. We do not accept any liability for the privacy practices of such third party websites or apps and your use of such websites or apps is at your own risk.

We accept no responsibility for the privacy practices of such third party websites or apps and your use of such websites or apps is at your own risk.

9. Security

We maintain appropriate security measures to protect the Personal Data you provide to us through our Website or our App against unauthorized disclosure, use, alteration, or destruction of the Personal Data. Please note, however, that perfect security does not exist on the Internet. Therefore, while we endeavour to protect your Personal Data, as soon as Personal Data are transferred over the Internet they may potentially be accessed and used by unauthorized parties.

10. Your data protection rights

10.1

Under current data protection laws, you have the following rights:

• You may access the Personal Data that Bsit holds about you and, in accordance with the applicable data protection legislation, oppose the processing of your Personal Data for reasons relating to your particular situation and ask us to limit the processing of your your Personal Data;
• In addition, in certain circumstances, you have the right to request the portability, correction or deletion of your Personal Data. Please note that regarding the right to portability, it is strictly limited to Personal Data justified by the contractual necessity arising from the relationship between Bsit and the User and the Personal Data processed by Bsit with your consent. It is important that the Personal Data we hold about you is accurate and up-to-date. It is also your responsibility to ensure that your Personal Data is as accurate, complete and up-to-date as possible. Please keep us informed if your Personal Data changes during your relationship with Bsit;
• If we have collected and processed your Personal Data with your consent, you may withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of any processing we have performed prior to such withdrawal and will not affect the processing of your personal data on the basis of lawful grounds other than consent;
• You have the right to refuse Bsit communications that we send you at any time. You can exercise this right by clicking on the link "unsubscribe" or "waiver" in the advertising emails we send you;
• If you have a complaint or concern about how we handle your Personal Data, we will endeavor to address those concerns. If you believe that we have not sufficiently taken into account your complaint or concern, you have the right to complain to a data protection authority about the collection and use we make of your Personal Data. For more information, please contact your local data protection authority. (The contact details of the data protection authorities of the European Economic Area, Switzerland and certain non-European countries (including the United States and Canada) are available here.)

10.2

In order to create a certain level of trust and to maintain a minimum security among Users, as well as to detect possible fraud or illegal behavior (for example: inappropriate conduct, harassment, theft, etc.), Bsit reserves the right to retain certain relevant Personal Data (such as last name, first name, phone number, e-mail and notes and comments) despite your request to delete your Personal Data in the following cases: When you have obtained an average rating lower than or equal to 3.5 stars awarded by Parents or Sitters or when the Bsit support team, based on serious, objective and concordant information, has reported you in the event of a complaint, negative comment or legitimate suspicion of misconduct.

10.3

You can access and delete your Personal Data on the App at any time.

To do this, you must follow the following steps: You must (1) login to your private Bsit account, (2) access your account settings, (3) go to the "Help & Info" section and (4) click on "My Data".

10.4

Please send your request to exercise your data protection rights as explained above, to legal@bsit.com by attaching a copy of your identity card (only verso). Please note that requests are free of charge and that we will respond in accordance with the applicable data protection law within 1 month of receipt of the request. However, in the case of a complex request, this period may be extended by 3 months (we will notify you of this extension of time by email after receipt of your request).

11. Any questions?

If you have any questions about this Privacy Policy, please contact: legal@bsit.com or this mailing address: Bsit Technologies Public Limited Company, Avenue Louise 251, 1050 Brussels Belgium.