Privacy Policy

Because of the common concern about privacy on the World Wide Web, SPI has adopted the following Privacy Policy for the Site. This Privacy Policy was developed as an extension of SPI’s commitment to combining the highest-quality products and services with the highest level of integrity in dealing with our customers and partners. The Policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to SPI and to assist you in making informed decisions when using our Site and our services. This statement will be continuously assessed against new technologies, business practices, and SPI’s customers’ needs.

Table of content

1. Who processes your personal data collected through this website?
2. For what purposes does SPI collect your personal data?

1. 2.1 Personal data that you voluntarily provide to SPI through this website
2. 2.2 Technical and not personally-identifiable information (cookies)

3. Who are the data recipients of the personal information we collect about you?

1. 3.1 Categories of recipients
2. 3.2 International transfers

4. For what period will SPI retain your personal data?
5. What rights can you exercise with respect to the processing of your personal data?
6. Who to contact when you have a query regarding the processing of your personal data?
7. What rules apply to the processing of your personal data when clicking on links placed on SPI website directing to SPI partner’s websites or other websites?
8. Changes to the privacy policy

1. Who processes your personal data collected through this website?

Sales Performance International NV whose registered office is located at Elsinore Building Da Vincilaan 9 B-1930 Zaventem Belgium (hereinafter referred to as “SPI”) is responsible for the processing of your personal data (i.e. any information that would allow to identify you, either directly or indirectly) collected through this website.

2. For what purposes does SPI collect your personal data? 

When you visit SPI’s Site you may provide SPI with two types of information: personal information that is collected on an individual basis and Site use information collected as you browse our Site.
1. SPI processes personal data that you voluntarily provide to SPI through this website for the purposes of:

1. a) in connection with the provision of SPI services. For example, if you fill out a “Contact us” Web form, you will be asked for your contact details (name, email address, phone numbers). The Company will use the information provided to contact you about your interest in our services.
2. b) storing and processing that information to better understand your needs and interests and how SPI can improve and enhance your experience on our website; For instance we monitor and analyse trends, usage and activities of website’s visitors (eg. when a visitor downloads a piece of content) in order to adapt our website content to people’s behaviour and interests. Such processing, aimed at having a better understanding of SPI members’ needs and offering you customized functions to enhance your experience of SPI products / services, is based on our “legitimate interest”, with due regard to your interests and data protection rights.
3. c) promotional and marketing activities (subject to your personal consent);
   1. i. to send you email notifications for SPI product developments and news, special promotions / deals;
   2. ii. to contact you in order to participate in customer surveys in order to improve our services;
   3. iii. to participate to promotional contests / sweepstakes organized by SPI.
   4. iv. to display advertising on our Web sites or to manage our advertising on other sites.
4. d) sending administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies. Such processing, aimed at sending administrative information to you, is based on our “legitimate interest”, with due regard to your interests and data protection rights.

2. In some cases, SPI may automatically (i.e., not via registration) collect technical information when you connect to the Site that is not personally-identifiable.

Examples of this type of information include the type of Internet Browser you are using, the type of computer operating system you are using and the domain name of the Web site from which you linked to our Site.
When you view the Site, SPI also may store some information on your computer. This information will be in the form of a “Cookie” or similar file and can help us in many ways. Cookies are pieces of information that some Web sites transfer to the computers browsing that Web site, and are often used for record-keeping purposes. Cookies perform various functions such as saving your passwords, listing potential purchases and saving your personal preferences with respect to particular Web sites. Many consider the use of Cookies to be an industry standard.

Your Internet browser is probably set to accept Cookies. With most Internet Browsers, you can erase Cookies from your computer hard drive, block all Cookies or receive a warning before a Cookie is stored. If you alter the configuration of your browser to refuse Cookies, it is possible that some areas of our site that may use Cookies will not function properly when you view it.

Please refer to your Browser instructions to learn more:

1. If you use Internet Explorer:
   Windows Cookies
2. If you use Safari :
   Apple Cookies
3. If you use Firefox:
   Mozzilla Cookies
4. If you use Chrome:
   Chrome Cookies
5. If you use Opera:
   Opera Cookies

Each cookie falls within one of the four following categories:

1. Analytics — data gathering and usage tracking.
2. Functionality / Preference — storing user preferences, and preferences for navigation, pop-ups, and other site functions.
3. Essential — information that is essential to the optimization and performance of the website(s).
4. Targeting / Advertising — data gathering for advertising, marketing, and targeted ad purposes.

The list of Cookies used on the Websites is attached as Annex 1.
The personal data processed for these purposes are necessary for the performance of the rental agreement concluded with SPI. SPI does not sell and does not intend to sell or rent personal data about you to third parties.

3. Who are the data recipients of the personal information we collect about you?
3.1 Categories of recipients

Your personal data will be disclosed to:

1. a) the authorised personnel of SPI and of other entities of the same group for the purposes described in this privacy policy;
2. b) authorised third party:
   1. i. Third party ad networks like Linkedin, Facebook and Google Adwords to display advertising on their websites.
   2. ii. Other third parties like Salesforce or Pardot to contact you in order to share news concerning our products or special promotions.
   3. iii. Business partners: SPI may partner with other companies to jointly offer products, services, or programs (such as webinars or downloadable content). If you specifically express interest in, or register for a jointly–offered product, service, or program through SPI’s website, SPI may share data collected in connection with interest with our partner(s).

SPI can also disclose your personal data to the extent required by law and/or by competent authorities.

3.2 International transfers
As necessary to provide you with SPI services, SPI will transfer your personal data to other entities of the SPI group in the EU or outside the EU for the purposes set forth herein.
Depending on the case, certain recipients may be located in countries which have been recognized by the European Commission as ensuring an adequate level of data protection or in countries which has not been recognized as ensuring such a level of protection. In any case, SPI has put in place appropriate safeguards to protect your personal data, in compliance with the EU regulation no.2016/679.
SPI uses sales and marketing products (Salesforce and Pardot) whose data may be stored in the United States. These products have a data protection policy which is compliant with GDPR and you can check here : https://www.salesforce.com/eu/campaign/gdpr/

4. For what period will SPI retain your personal data?

1. 1. a) Personal data processed:
      1. • in connection with the provision of SPI services
      2. • to improve and customize the visitor’s experience on our website
      3. • for marketing activities
      4. • to share administrative information

We retain personal data that you provide us as long as we consider it potentially useful in contacting you about the services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements and for any proportionate and reasonable period necessary to achieve the purposes listed above. We will delete this information from the servers at an earlier date if you so request.

1. b) Personal data processed to assess the effectiveness of site content and traffic through the use of cookies : please see the list of cookies below, which indicates the expiration of each cookie.

5. What rights can you exercise with respect to the processing of your personal data?

As per EU regulation no.2016/679, you can benefit from the following rights:

1. 1. a) right of access: right to obtain confirmation as to whether or not your personal data are being processed by SPI, and, where that is the case, to access to these personal data and to obtain further information on the characteristics of their processing ;
   2. b) right to rectification: right to obtain the rectification of inaccurate personal data or, taking into account the purposes of the processing, the right to have incomplete personal data completed, including by means of providing a supplementary statement;
   3. c) right to erasure (or the so-called “right to be forgotten”): right to obtain the erasure of your personal data in certain circumstances ; right to object and right to withdraw your consent:

At any time, right to object to the processing of your personal data to prevent SPI from continuing to carry out such processing:

1. 1. i. where your data are processed for direct marketing purposes;
   2. ii. where your personal data are processed to improve SPI services, or on the basis of SPI’s legitimate interest more generally. In that case, your request will be satisfied only if you provide SPI with a description of the particular situation legitimating your request and save if SPI can demonstrate overriding legitimate grounds in light of your particular situation.
2. f) right to withdraw your consent: where the processing of your personal data is based on your consent, you benefit from the right to withdraw your consent to the processing of your personal data at any time and to prevent SPI from continuing to carry out such processing;
3. g) right to data portability: where the processing of your personal data is based on your consent and by automated means, the right to receive the personal data you provided to SPI, in a structured, commonly used and machine-readable format and to transmit those data to a third party.

If you wish to exercise any of these rights, please contact us as set out below in section 6. In addition, in SPI promotional and marketing emails and other communications, SPI will also include instructions on how to unsubscribe.
To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections
As per article 77 of the EU regulation no. 2016/679, you can lodge a complaint about the processing of your personal data with the body regulating data protection in your country if you consider that the processing of your personal data infringes the said EU regulation no. 2016/679.

6. Who to contact when you have a query regarding the processing of your personal data?

For general query regarding the processing of personal data carried out by SPI or to exercise your rights (access, rectification, erasure, etc.), or for legal notifications: please send us an email to privacy@spisales.com or contact us at Sales Performance International NV, Elsinore Building Da Vincilaan 9 B-1930 Zaventem, Belgium.

7. What rules apply to the processing of your personal data when clicking on links placed on SPI website directing to SPI partner’s websites or other websites? 
SPI is not responsible for the practices employed by Web sites linked to or from SPI’s Site nor the information or content contained therein.
Please remember that when you use a link to go from SPI’s Site to another Web site, this Privacy Policy is no longer in effect. Your browsing and interaction on any other Web site, including Web sites that have a link on SPI’s Site, are subject to that Website’s own rules and policies. Please read over those rules and policies before proceeding.

8. Changes to the privacy policy
This privacy policy was published on May 15, 2018. In the case of changes to this privacy policy by SPI, such changes will be submitted to you and you will be asked to accept the new conditions.