Privacy Policy

1. General provisions

The following Privacy Policy applies to the processing of data by NEVEO, a public limited liability

company incorporated under the laws of Belgium, with registered offices at 1050 Brussels, Rue Van

processed and disclosed to third parties. The Privacy Policy further sets out the various measures

NEVEO has implemented to safeguard the security and confidentiality of the personal data it collects.

NEVEO cares about the privacy of visitors to its Platform and all those whose personal data may be

collected (hereafter “Users”) and will only collect and process personal data in accordance with the

provisions of this Privacy Policy.

NEVEO is to be considered as data controller for the processing of personal data and will act in

accordance with the provisions of the Belgian Act of 8 December 1992 on the protection of privacy in

relation to the processing of personal data (hereinafter the “Law on the protection of privacy”) as

NEVEO reserves the right to modify this Privacy Policy at any time and, to the extent permitted by law,

without prior notice, in order to comply with (new) legal obligations and / or improve its services to

you. Therefore, we advise you to consult the Platform regularly.

Please note that the Platform may contain links to other digital platforms or internet resources which

may also collect personal data voluntarily, through cookies or other technologies. NEVEO has no

responsibility, liability for, or control over those other websites or internet resources or their

collection, use and disclosure of your personal data. NEVEO recommends that you review the privacy

policies of these other websites and internet resources to understand how they collect and use

personal data.

The categories of personal data that can be collected during a visit to the Platform or by contacting

NEVEO are as follows:

(a) The first name, email address and password provided by completing the online form upon

registration and which is required to create a user account;

(b) Payment data (banking details and detail and history of transactions) provided in order to

subscribe to NEVEO services;

(c) The name, language, profile picture, telephone number and gender, to ensure optimal after-

sales follow-up and to improve the aesthetics of the journal;

(d) The nickname as well as the birthday of the recipient of the journal, in order to personalize the

services;

(e) The name, first name and postal address of the recipient, in order to carry out the delivery of

version, duration and date of the visit, the network connection type and provider, the network

performance of the device, the type of browser, data from the sensors of mobile terminals

(accelerometer or gyroscope), the selected language, the information activating digital rights

management, … whose processing is necessary to provide certain functionalities of the

Platform and to use certain cookies, it being understood that the use of cookies and internet

beacons by NEVEO is specified in the Cookie Policy, which the User is invited to consult;

(i) Photographs and text messages sent to the Platform in order to enable NEVEO to produce and

print the journals.

The required provision of the data A, B, E, F, G, H, I is a prerequisite for the conclusion of the contract,

that such person has consented to it in accordance with this Privacy Policy. The User who took out the

subscription for a beneficiary, or invited a third party to join the Platform by inserting her/his email

address and/or her/his telephone number, declares having obtained the authorization of the latter to

communicate her/his personal information.

NEVEO will not collect sensitive data. This includes data such as race, ethnicity, religious beliefs,

criminal records, physical or mental health, or sexual orientation of the User. NEVEO will, if necessary,

obtain the explicit consent of the User to collect such data.

The User undertakes to communicate accurate personal data to NEVEO. The User may at any time

NEVEO may disclose personal data with any company with which NEVEO may merge or be acquired by

as part of a reorganization. NEVEO nevertheless undertakes to inform you if necessary.

3. The User’s rights

Each User has the right to access, modify, correct and delete their data free of charge. He/she also has

a right to data portability, which implies that NEVEO can supply (at their request) their data to them

and / or to a third party in a structured and machine-readable form. He/she can also, free of charge,

oppose certain data processing by simple request. In the event that the legal basis for the processing

is consent, he/she may at any time withdraw her/his consent for the processing of the data.

entrusted to it by the Users, as well as to guarantee the confidentiality of the personal data transmitted

by the User.

However, each User recognizes that the disclosure of personal data via the internet is not without risk.

The User therefore acknowledges that NEVEO cannot be held responsible or liable for any direct or

indirect damage she/he may suffer as a consequence of illegal or illegitimate use of her/his personal

data by third parties who do not have the authorization to use the data.

However, NEVEO reminds you that it is your responsibility to take all appropriate measures to ensure

the security of your equipment, data or software, especially against computer viruses circulating on

SMARTELIA SPRL (for the purpose of providing after-sales services) as well as Amazon web services (for

storage purposes).

NEVEO will not communicate any data to third parties for purposes secondary or unrelated from those

mentioned above, unless otherwise stated when collecting these data. Thereto, NEVEO takes all

necessary precautions in order to preserve its confidentiality and declares to be connected with

trusted hosting providers and technology providers, renowned for the reliability of their services and

the high degree of protection they grant to the confidentiality of personal data.

The personal data may however be communicated by NEVEO to the judicial authorities, the

administrative authorities or other bodies, or to third parties if required or desirable to meet the legal

or regulatory requirements or for the purposes mentioned above.

6. Duration of data retention

NEVEO will not transfer personal data to countries that do not have data protection legislation

equivalent to that in force in the European Economic Area.

8. Statistical processing

The User acknowledges that NEVEO has the right to use its data for statistical purposes, and as soon

as it has been made anonymous, and to transfer or assign the corresponding statistical results to any

third party.

9. Registration with the supervisory authority

If you have any questions regarding this Privacy Policy, or if you feel that your interests are

privacy@neveo.io.

Cookie Policy

3. Which information is being collected?

If you have any questions regarding this Cookie Policy, or if you feel that your interests are

unrepresented or inadequately represented, please direct your questions to NEVEO at

privacy@neveo.io.