Privacy policy
1. Why This Privacy Policy?
Anyone visiting and/or using our various websites related to Tipaw services (hereinafter referred to as the "Site") or using our Tipaw services (hereinafter referred to as "User" or "You") discloses a number of personal data. Personal data is information that allows us to identify you directly or indirectly as a physical person.
We collect and process your personal data in accordance with the Belgian Law of July 30, 2018, on the protection of privacy with regard to the processing of personal data ("Privacy Law") and the European Regulation of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("Regulation" or "GDPR").
By using the Site or our services, the User declares to have read this Privacy Policy and expressly accepts the collection and processing of your personal data as described in this document.
We reserve the right to make changes to our Privacy Policy at any time.
2. Who Processes Your Personal Data?
2.1. The Data Controller
Flipaw is the data controller and determines the personal data that are collected, the purposes, and the means of the processing.
2.2. The Processor(s)
Flipaw is free to use processors. The processor is the natural or legal person who processes your personal data at the request and on behalf of the data controller. The processor is required to ensure the security and confidentiality of your data and always acts on instructions from the data controller.
Flipaw uses the following categories of processors: Hosting companies, CRM, social networks (Facebook for advertising), Amazon Web Services, Google Calendar, IT maintenance, password management software.
3. On What Basis Are My Data Processed?
In accordance with the Privacy Law and the GDPR, we process your personal data on the following legal bases:
- Based on the performance of the contract to which you are a party or pre-contractual measures taken at your request for the use of our Site and the provision of our services.
- Based on our legal obligations for everything concerning the management of the contractual relationship, notably invoicing.
- Based on our legitimate interest for sending information and newsletters to our customers.
- Based on your explicit consent for sending promotional offers (direct marketing).
4. What Personal Data Are Collected?
The processing of your personal data is limited to what is strictly necessary to achieve the purposes pursued by Flipaw. Below are the categories of data involved in the processing:
- Personal identification data (name, first name, address, identifiers, VAT number, breeders' approval numbers, veterinarians' CVs, photos)
- Contact data (telephone number and email address)
- Financial identification data (bank details)
- Electronic identification data (IP address, location, cookies)
- Personal details (gender, age, date and place of birth, marital status, nationality)
Flipaw may obtain personal data through various means:
- When you register and use our Site and/or our services;
- By filling in questionnaires (for example, when you provide feedback or use our support function);
- When you communicate with a breeder;
- Through social networks (for example, when you contact us on Facebook);
- When connecting third-party devices or services to Flipaw (only when you have given your explicit and prior consent), for example: Google Calendar when making appointments via the Tipaw site;
- By placing cookies (see our Cookie Policy)
- While buying products on our e-shop.
Furthermore, we use cookies to recognize the User and offer a personalized user experience, to remember your choices, and to detect and correct any errors present on the Site. For more information on our use of cookies, please consult our Cookie Policy.
5. What Are the Purposes?
Flipaw collects your personal data to provide you with an optimal, personalized, and secure user experience. The processing of your personal data is therefore essential for the proper functioning of the Site and the provision of our services. If data are missing, incorrect, or incomplete, Flipaw reserves the right to suspend or cancel certain operations.
Flipaw commits to processing your personal data exclusively for the following purposes:
- Verify the professional qualities of breeders and veterinarians;
- Customer management: customer administration, appointment management, invoicing, solvency tracking, support provision, complaint tracking, and sending newsletters;
- Allow you to make appointments with one of our partner providers via Google Calendar;
- Dispute management;
- Protection against fraud and offenses;
- Personalized marketing and advertising if you have expressly consented. In this case, you are free to withdraw your consent at any time.
By visiting our Site, certain data are collected for statistical purposes. These data allow us to optimize your user experience. By visiting the Site, you expressly agree to the collection of these data for statistical purposes.
6. Who Receives Your Personal Data?
Your personal data are intended to be used for internal purposes. However, Flipaw reserves the right to sell, transmit, or communicate your personal data to third parties. By using our Site or our services, you expressly consent to this possible data transfer.
The data is stored on Flipaw's servers in Frankfurt, Germany, with Amazon Web Services. They can only be read by Flipaw and/or its employees who have the correct key.
Some of your data (name, first name, email address, telephone number) are also sent to Google, via the Google Calendar service. We use this service to allow you to quickly make appointments with our partner providers.
Furthermore, Flipaw transfers the contact details of adopters (name, first name, email address, telephone number) to its partners.
Tipaw does not transfer your data outside the European Union.
7. How Long Are Your Data Stored?
Your data are stored as long as necessary to achieve the pursued purposes. They will be deleted from our database as soon as they are no longer necessary for the pursued purpose or if you have validly exercised your right to erasure.
8. What Are Your Rights?
8.1. Guarantee of Fair and Lawful Processing
Your personal data are always processed for the legitimate purposes explained in point 5. They are collected and processed in an adequate, relevant, and not excessive manner, and are not kept longer than necessary to achieve the pursued purposes.
8.2. Right of Access
If you can prove your identity, you have the right to obtain information about the processing of your data. Thus, you have the right to know the purposes of the processing, the categories of data concerned, the categories of recipients to whom the data are transmitted, the criteria used to determine the duration of data retention, and the rights that you can exercise over your data.
8.3. Right to Rectification
Inaccurate or incomplete personal data can be corrected. Either directly by the User on their user profile or by sending us a written request to store@tipaw.com.
8.4. Right to Erasure (or "Right to be Forgotten")
You have the right to obtain the erasure of your personal data in the following cases:
- Your personal data are no longer necessary in relation to the purposes;
- You withdraw your consent to the processing and there is no other legal ground for the processing;
- You have validly exercised your right to object;
- Your data have been unlawfully processed;
- Your data must be erased to comply with a legal obligation.
8.5. Right to Restriction of Processing
In certain cases, you have the right to request the restriction of the processing of your personal data, in particular in the event of a dispute regarding the accuracy of the data, if the data are necessary in the context of legal proceedings or the time necessary for Flipaw to verify that you can validly exercise your right to erasure.
8.6. Right to Object
You have the right to object at any time to the processing of your personal data for direct marketing purposes, profiling, or for the purposes of the legitimate interest of the data controller. Flipaw will stop processing your personal data unless it can demonstrate compelling legitimate grounds for the processing which override your right to object.
8.7. Right to Data Portability
You have the right to obtain all the personal data you have provided to us in a structured, commonly used, and machine-readable format. At your request, these data can be transferred to another provider, unless it is technically impossible.
8.8. Right to Withdraw Your Consent
You may withdraw your consent to the processing of your personal data at any time, for example for direct marketing purposes.
9. Security Measures
Under the Privacy Law and the GDPR, Flipaw commits to implementing technical and organizational measures (hereinafter, "security measures") intended to protect personal data against destruction, whether accidental or unlawful, against loss, fraud, dissemination or unauthorized access, or against any other form of unlawful processing or use.
These security measures guarantee a level of security appropriate to the risk involved in the processing. To determine adequate security measures, Flipaw takes into account the state of the art, the implementation costs, and the nature, scope, context, and purposes of the processing as well as the risks to the rights and freedoms of the individuals concerned.
Flipaw strives to provide all reasonable efforts to ensure that their processing systems and services meet the requirements of confidentiality, integrity, availability, and constant resilience, taking into account the state of the art and implementation costs.
10. Notification of a Data Breach
Under the Privacy Law and the GDPR, Flipaw notifies the User of any personal data breach as soon as possible, and no later than 24 hours after having become aware of it. This notification is accompanied by all useful documentation to enable the User, if necessary, to notify this breach to the data protection authority and/or the persons concerned. Flipaw must communicate to the User the following information: the nature of the personal data breach, the categories and approximate number of individuals concerned, the categories and approximate number of personal data records concerned, the likely consequences of the personal data breach, and the measures taken to address the personal data breach or to mitigate its possible adverse effects.
Flipaw notifies the data breach on behalf of and for the account of the User to the supervisory authority as soon as possible and, if feasible, no later than 72 hours after having become aware of it, unless the breach in question is unlikely to result in a risk to the rights and freedoms of natural persons.
Flipaw notifies the data breach on behalf of and for the account of the User to the data subjects as soon as possible, when such a breach is likely to result in a high risk to the rights and freedoms of natural persons.
The decision to inform or not the data protection authority and/or the data subjects of a data breach is up to Flipaw.
11. How to Exercise Your Rights?
To exercise your rights, you must send us a written request and proof of identity, by registered mail to FLIPAW S.A., Avenue de la sapinière 51B -1180 Uccle, or by email to store@tipaw.com. We will respond as soon as possible, and no later than one (1) month after receiving the request.
12. Possibility to Lodge a Complaint
If you are not satisfied with the processing of your personal data by Flipaw, you have the right to lodge a complaint with the Data Protection Authority (https://www.autoriteprotectiondonnees.be/).