Personal data protection policy

This personal data protection policy applies to the services provided by BISLINK LTD. as well as the services provided on www.PayAdvisor.eu (hereinafter the "Website") and its mobile applications. (hereinafter, the "Application"), (hereinafter jointly referred to as "PayAdvisor") developed by LTD BISLINK (hereinafter, the "Services").

The Services is an innovative method of tracking and managing invoices to encourage its Customer Debtors to pay the invoices by assigning a positive or negative reputation rating based on their level of execution. The Services are rendered by BISLINK LTD., whose head office is at 523 Avenue Louise, 1050 Brussels, registered with the ECB under number 0683.773.784 (hereinafter "BISLINK").

PayAdvisor allows its users (hereinafter, the "Users") to register, access / connect to the Services. PayAdvisor is made available by BISLINK.

The Services are made available by BISLINK with the intervention of several third parties ("PayAdvisor" Members):

- Service or Product Providers or any other third party with whom you use PayAdvisor to register with them, or connect to their website / application;
- SIM controllers: your telecommunication operator;
- Identity checker: entities that can control your identity.

BISLINK acts as a "data controller" in accordance with the Belgian privacy laws and, as such, BISLINK is responsible for the collection and use of your personal data: "pa . admin @ PayAdvisor . eu" [please do remove spaces around the dots].

This statement explains the different elements of the personal data that will be collected, the purposes of the collection (or sharing of this data with third parties), your rights as a person concerned and the measures put in place to protect your personal data. Please note that the Services necessarily imply that we collect and store personal data about you and that we will disclose certain elements of your personal data to third parties as described below.

This Data Protection Policy only describes how personal data is processed by us or on our behalf in the framework of the Services - Service Providers and Identity Controllers also process your personal data as data controllers as part as their own services or activities: for these processing activities, please consult their personal data protection policies.

Article 1. DEFINITIONS

The legal provisions on the protection of personal data (Law of 08/12/1992 Law on the protection of privacy with regard to the processing of personal data and Regulation (EU) 2016/679 on data protection) define "processing" and "personal data" as follows:

"Processing”: means any transaction or set of operations performed or not using automated processes and applied to data or sets of personal data, such as collection, registration, organization, structuring, preservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form provision, reconciliation or interconnection, limitation, erasure or destruction;

"Personal data": any information relating to an identified or identifiable natural person (hereinafter referred to as a "data subject"); is deemed to be an "identifiable natural person" a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements, proper to his/her physical, physiological, genetic, psychic, economic, cultural or social identity. As the law states, we do not deal with sensitive data, that is, information about racial or ethnic origin, political opinion, sexual orientation, and health.

Article 2. THE PERSONAL DATA WE COLLECT AND HOW

2.1. The Personal Data we process

In order to offer the Services and to exploit PayAdvisor as set out in this Data Protection Policy, we treat different categories of personal data:

- Data regarding our Customer third-party Debtors, which allows us to contact them and send invoices reminders from our Customers (listed in PayAdvisor) as directed by PayAdvisor Customers:
•• Identity and contact details of the contact person (s) within the Debtor (name, surname, address, e-mail address, etc.)

- Identity data, which allows us to identify you. This category covers different kinds of data:
•• basic identity data, including your full name, gender, preferred language, legal address, nationality, date and place of birth, national identification number, etc.
•• contact information (e-mail address and mobile number);
•• different users and preferential settings, your function, etc.

- Registration data, which are specific to the registration process and cover information such as your consent to our Terms of Use for the Website and the Application and our Data Protection Policy, your bank or payment details.

All the data mentioned above are compulsory in order to benefit from the Services and the functions of the Application and the Website. We may process other data on a voluntary basis, but in this case we will notify you and ask for your prior consent.

2.2. How are personal data collected?

The different categories of personal data described are directly collected from you or by a FoxPAID Member:

- The third-party receivables Data of our PayAdvisor Customers are collected indirectly through PayAdvisor Customers (the creditors), who send us, on the website www.PayAdvisor.eu, a certain amount of identification information Debtors who have not yet paid the invoices registered by the PayAdvisor Customer: contact details for sending reminders to Debtors who have not yet executed. When you have accepted the terms and conditions of PayAdvisor you have consented to the transfer of such data to the PayAdvisor platform and guarantee that you may enjoy the rights or permissions related to such transfer.
- -The Identity Data are collected directly from you and validated (for official information) with the Identity Controller, European Data Validation Agency or any other form of collection.
- Registration Data is created when you register for a PayAdvisor account. Registration data is obtained either directly from you, when you register with PayAdvisor, or through the Identity Controller or PayAdvisor business partners, such as payment providers.

Article 3. WHAT PURPOSES ARE YOUR PERSONAL DATA USED FOR?

The personal data we collect is used to provide you with the Services, on the understanding that this includes:

- make available to you a PayAdvisor invoice tracking manager and grant e-reputation notes to companies that are performing well or failing to meet their payment obligations for invoices you have entered in PayAdvisor;
- process or facilitate the payment of the Services offered by BisLINK;
- carry out the operations that you request to carry out with PayAdvisor and more generally, the operation of PayAdvisor;
- the operation, evaluation and improvement of the Services offered by BISLINK, such as: (i) the management of our communications with you, (ii) the monitoring of the use of the Application and the Website following an advertising or marketing campaign, (iii) the analysis of the products, services and websites of "PayAdvisor", (iv) the facilitation of the functionalities of the Application / Website and (v) the performance of accounting activities , audit, invoiceing, reconciliation and collection.
•• Fraud and risk management;
•• Any processing required to comply with applicable legal requirements and industry standards and policies applicable to PayAdvisor.

The different categories of personal data are processed for the purposes and in the manner described below.

3.1. When are the Third-Party Receivables Data of our Customers processed and how?

- Creation of a Debtot: The data relating to the third Debtors of our PayAdvisor Customers are collected from the creation, modification or correction of a debit card in the Customer PayAdvisor account. You have expressly consented to this by accepting the terms and conditions.
- Archiving: once the performance of the Services is complete, the collected data will be archived for a period of 24 months and will be anonymised for statistical purposes.

3.2. When and how we process the Identity data ?

- Registration for Services: We collect your identity data when you sign the PayAdvisor service provision agreement. You have expressly consented to it by signing the said contract.
- Registration for Services through the Website or the Application : We collect your identity data the first time you register for PayAdvisor identification services (either through an Identity Controller or directly from you) after having consented.
- Registration with a Service Provider : Whenever you register for the first time with a Service Provider through the PayAdvisor Application / Website, your consent is requested. This is because in this case we need to transfer elements of your identity data. You will be asked to consent to each data transfer and any request for additional data if this occurs.
- Archiving: Once you have completed the use of the Services or after a period of two years of inactivity, the data will be archived for evidentiary purposes for a period of two years, following to which they will be destroyed.
All elements of your Identity Data that are communicated to Service Providers will be processed by Service Providers acting as Data Controllers in accordance with their own privacy policy.

3.3. When will the Registration Data be processed and how?

- At registration: Registration Data will be generated and collected at the time of your registration with the Services;
- Proof and Archiving: Registration Data is stored in the database either by the Identity Monitor (acting as a subcontractor for BISLINK), or directly by BISLINK for evidentiary purposes. When you have completed your use of the Services or after a period of inactivity of one year, the data will be archived for a period of two years. After this period, registration Data will be destroyed.

Article 4. THE PERSONAL DATA AND THEIR SHARING

We do not sell or otherwise disclose to third parties the personal data we collect, except as provided in this Data Protection Policy (this document). We only share personal data to enable the performance of any Services to which you have subscribed. In this regard, we may share your personal data with our members, including Service Providers, as described above, we may for example provide information to such third parties to facilitate and process payment for the Services.

We transfer data to third parties who are pursuing data processing activities related to the Services on our behalf (subcontractors). These actors are not allowed to use the data or disclose it in any way except as described above or in order to meet legal requirements. We contractually require these third parties and our Members to appropriately protect the confidentiality and security of the personal data they process on our behalf.

We may also disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials in accordance with their legitimate abilities, or (iii) when we are satisfied that disclosure is necessary or appropriate to prevent physical harm, or (iv) an investigation of suspected or existing fraud or illegal activity.

We also reserve the right to transfer any personal data we have about you in the event that we sell or transfer all or part of our business or assets affecting the Services. Should such a sale or transfer occur, we will ensure that any personal information you provide to us remains treated in a manner that is consistent with this Data Protection Policy.

Article 5. YOUR RIGHTS AND CHOICES

5.1. Access, rectification and data portability

You may at any time exercise your right to access and rectify your personal data that we may retain in connection with the Services, in accordance with applicable data protection laws, by sending a request by registered mail with a copy of the front of your ID card, passport or other proof of identity to the following address: 523 Avenue Louise, 1050 Brussels, for the attention of the Data Protection Officer (DPO),

Please note that some elements of your personal data may be accessed through the interface of the Application or Website www.PayAdvisor.eu and as a User, you have the right to rectify and modify this data at any time. However, since the security of the Services depends on the integrity of the basic identity data, any change whatsoever will require you to go through the registration steps; either through an identity controller or through the Website.
Finally, as soon as this is applicable, you will also have the right to the data portability in accordance with applicable data protection laws.

5.2. Erasure

You may at any time exercise your right to the erasure of your data in accordance with applicable data protection laws by sending a request by registered mail with a copy of the front of your identity card, passport or other proof at the following address: 523 Avenue Louise, 1050 Brussels, "to the attention of the Data Protection Officer (DPO). BISLINK will refrain from using any personal data on this application and will only keep the personal past data for evidentiary purposes for a period of 2 years, after which it will be erased. Once your data has been deleted, you will no longer be able to use the Services or Mobile Services.

5.3. Opposition

When using the Application, Website or Services more generally, you will be asked to consent to certain data processing activities. You will have the right to withdraw your consent for such activities at any time by sending a request with a copy of the front of your identity card, passport or other proof of identity to the following address: 523 Avenue Louise, 1050 Brussels, for the attention of the Data Protection Officer (DPO). This withdrawal will not affect the legality of past data processing. Please note that opting out of a certain treatment may however affect your use of the Services as BISLINK cannot provide the Services without processing the necessary elements of your personal data.

At any time, if you consider that your rights have not been respected, you can also file a complaint with the Belgian Commission for the Protection of Privacy, 35 rue de la Presse, 1000-Brussels.

Article 6. HOW DO WE PROTECT YOUR PERSONAL DATA?

6.1. How do we guarantee the integrity of the stored data

We maintain appropriate technical and physical safeguards to protect personal data against accidental or unlawful destruction, accidental loss, unauthorized modification, disclosure or unauthorized access, misuse and any other illegal form of treatment personal data that is in our possession.

The security measures we adopt depend on the different types of collected and stored information.

- Data retention
All your personal data, whether used actively or archived, is stored in the servers of "OVH" (Oles Van Herman) and not in the Application or the Website themselves. BISLINK uses secure servers, provided by an internationally certified ISO 27001 provider, which are located in France / Belgium to store data. No personal data will be kept outside the territory of the European Union.

- Limited access
Internal access to personal data will be limited on a strict "need to know" basis. Only authorized staff, whose activity will be monitored to prevent misuse, will be able to access the data.

6.2. Measures to prevent misuse

Your unique login is linked to a password chosen by you. This password is automatically encrypted and will only be known to you to the exclusion of any third party, including BISLINK employees or subcontractors.

Article 7. DATA TRANSER

We do not transfer any of your personal data outside the European Economic Area, or in any other way than is not specified above.

Article 8. UPDATING THE PRIVACY POLICY

This Data Protection Policy may be periodically updated to reflect changes in our personal data practices. We will post a notice on our Site and / or through the Application to inform you of any material changes to our Data Protection Policy and will state at the top of the notice when it has been updated. We will ask you to renew your consent to this Data Protection Policy if needed.

Article 9. HOW TO CONTACT US

If you have any questions or comments regarding this Data Protection Policy, if you wish to exercise your rights or update your information about us or your preferences, please contact us at the following address: 523 Avenue Louise, 1050 Brussels, for the attention of the Data Protection Officer (DPO)

BISLINK Ltd

Tel :

Email : "pa . admin @ PayAdvisor . eu" [please do remove spaces around the dots]