Privacy Policy - Subskribo

1. Who We Are

Subskribo BV
Registered Office: Gestelstraat 15, 3560 Lummen, Belgium Company Number: BE 0753953284
Email: info@subskribo.be
Website: www.subskribo.be

2. What Personal Data We Collect

We may collect and process the following types of personal data:

• Identification data (name, email address, phone number)
• Authentication data (e.g., eID, login credentials)
• Communication data (messages or requests you send us)
• Uploaded content (documents, media files, metadata)
• Technical data (IP address, browser type, device data, log data)
• Payment information (when applicable)

3. How We Collect Your Data

Your data may be collected when:

• You create an account on our platform
• You upload documents or digital content
• You communicate with us or our partners
• You access or interact with our services (website or app)
• You are designated as a beneficiary by a Subskribo user

4. Why We Use Your Data

We process your personal data for the following purposes:

• To provide, maintain, and improve our services
• To verify identity and secure access
• To execute conditional release of data as requested by users
• To respond to support requests or inquiries
• To comply with legal obligations
• For internal administration and system security

5. Legal Basis for Processing

We rely on the following legal grounds:

• Contractual necessity - when processing is required to deliver our services
• Legal obligation - to comply with applicable laws and regulations
• Legitimate interest - to improve our platform and ensure security
• Consent - where required (e.g., for marketing or optional features)

6. Who We Share Your Data With

We only share your data with:

• Our service providers and subprocessors (e.g., hosting, encryption, email delivery) under data processing agreements
• Trusted partners or verifiers (e.g., insurance providers, notaries), when needed to verify a condition for release
• Public authorities or legal institutions when required by law

We do not sell or rent your data.

7. International Transfers

Subskribo aims to store and process your data within the EEA. If data is transferred outside the EEA, we ensure appropriate safeguards such as Standard Contractual Clauses (SCCs) are in place.

8. Data Retention

Your personal data will be retained:

• As long as your account remains active
• As long as necessary to fulfill the purpose of processing
• As required by applicable legal obligations

9. Your Rights

You have the following rights under the GDPR:

• Access to your personal data
• Rectification of inaccurate or incomplete data
• Erasure ('right to be forgotten')
• Restriction of processing
• Data portability
• Objection to processing
• Withdrawal of consent (if applicable)

To exercise any of these rights, contact us at info@subskribo.be.
You also have the right to lodge a complaint with the Data Protection Authority (Gegevensbeschermingsautoriteit) via https://www.gegevensbeschermingsautoriteit.be/.

10. Cookies

Our website uses only necessary cookies. For more details, refer to our [Cookie Policy].

11. Updates to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify users of material changes where appropriate.