Privacy Policy

1.      Introduction

Masjien CommV is a limited partnership under Belgian law, registered at Justitiestraat 35, box 201, 2018 Antwerp, and listed in the Crossroads Bank for Enterprises under enterprise number 0782.545.619 (hereinafter “Masjien”). Ardor BV (trading under the name “PIVOT law”) is a private limited company under Belgian law with its registered office at Rue Lambert Crickx 16/6, 1070 Brussels (hereinafter “PIVOT law”). Together, they have developed an online platform under the name Josie, which provides access to an AI agent, an information platform with educational videos, and customized services. For the purposes of this privacy policy, both companies are jointly referred to as “Josie.”

Josie attaches great importance to your personal data and strives to process these personal data in accordance with applicable data protection laws, in particular the General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter “GDPR”) and the Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data (together referred to as the “Privacy Legislation”).

For questions or requests, you can reach us at lets@askjosie.ai.

In accordance with your rights, this privacy policy informs you how we collect, store, use, and otherwise process information about individuals in the context of our activities. In this policy, “personal data” refers to any information relating to an identified or identifiable natural person (“data subject”), as defined in Article 4 of the GDPR.

2.      Scope of application

This privacy policy applies exclusively to Josie's website, services, and products. It is applicable when you interact with us through the website, the Josie platform, or otherwise use our services.

This policy does not apply to third-party websites, applications, services, or platforms to which we link via hyperlinks, including the websites of Masjien and PIVOT law. Such external resources are operated independently and are governed by their own privacy policies. Josie assumes no liability for the content, operation, or privacy practices of these third parties.

3.      Personal data we collect

We process the following personal data, exclusively for the purposes listed below:

A. Data provided by the user:

Identification details (name, first name, email, phone number)

Company information (name, company registration number, role)

B. Data collected through use of the website/tool:

IP address, login logs, device information, cookies, session details

C. Third-party data (indirect):

Technical data from analytics, hosting, or email providers

When you use our website or the Josie platform, we may collect data about your device, usage data about your browsing actions and patterns, and contact information. We may collect this information through cookies, server logs, and similar technologies. For more information, see the section on Cookies below.

Where applicable, we may also receive personal data from third parties, including:

·       Analytics providers (like Google Analytics) or email services, when you interact with them through our website or communications;

·       Other third parties you have authorized to share your data with us in the context of our service delivery.

We may use external service providers to develop, deliver, maintain, and optimize our products and services. These include IT providers, hosting companies, email services, database providers, consultants, or marketing agencies. In this context, we may share personal data with them solely to the extent necessary for their services to Josie and only under appropriate processor agreements.

4.      Purposes of the Processing

Josie may process the aforementioned personal data for the following purposes, based on the following legal grounds: performance of a contract (Art. 6.1 (b) GDPR), legal obligations (Art. 6.1 (c) GDPR), and, where applicable, legitimate interest (Art. 6.1 (f) GDPR):

If you are a customer: for the fulfilment of our contractual obligations, based on the necessity to perform the agreement with our customers, and for compliance with our legal obligations

For administrative purposes, based on our legitimate interest in professionally managing our administration, including invoicing and customer relationship maintenance

For legal defense purposes, based on our legitimate interest to defend Josie in legal proceedings if necessary

To contact website visitors who have expressed interest via forms, based on our legitimate interest to engage with potential customers

To develop, improve, and optimize the website and Josie platform, based on our legitimate interest to provide a user-friendly experience

To ensure the security of our website and the Josie platform, based on our legitimate interest to keep them free from illegal content, viruses, malware, and other harmful content.

5.      Cookies

What are cookies?

Cookies are small text files stored on your device when visiting a website. They contain information about your browsing behavior and preferences and can be read on subsequent visits. Some cookies are technically necessary; others enhance your user experience or collect statistics and marketing data.

How do we use cookies?

We only use strictly necessary cookies, which are essential for the functioning of our website or web application (such as session management, security, or access control).

Certain third-party partners may place their own cookies via our website, solely under our control and for the purposes listed above.

Josie does not use non-essential cookies that require your consent.

6.      Retention and deletion

We do not retain personal data longer than necessary. For invoicing and accounting purposes, your data are retained for 5 years, unless a different statutory retention period applies. This is based on our legal obligations regarding fiscal and accounting documentation and to protect our legal position in the event of disputes.

When we no longer need your personal data, we will remove them from our systems and/or take steps to anonymize them.

7.      Sharing with third parties

In accordance with the principles set out in this privacy policy and when necessary, we may disclose certain personal data to third parties. Such disclosure will always be on a need-to-know basis and with appropriate safeguards to ensure the security of the personal data.

This includes:

Service providers acting as our processors or sub-processors, including but not limited to software vendors or IT service providers responsible for security, analytics, hosting, and infrastructure of Josie and/or the Josie platform

Other service providers we engage for specific assignments, such as lawyers, payment processors, administrative processors, and/or external consultants

Third parties in the context of a legal obligation, or in good faith cooperation with ongoing legal investigations, court orders, or lawsuits, or to protect Josie’s interests in legal proceedings

We do not transfer personal data to countries outside the European Economic Area (EEA). However, it is possible that our processors or sub-processors may transfer your data to countries outside the EEA. In that case, we will implement adequate safeguards to protect your data during such transfers.

More information about the specific transfer mechanisms used by us and a list of our sub-processors is available upon request.

8.      Your rights

You have the following rights regarding your personal data:

Right of access and copy: you may request information about the personal data we process about you

Right to rectification or deletion: you may ask us to correct or delete inaccurate or outdated personal data

Right to erasure: you may request that your personal data be deleted, provided no legal obligation requires us to retain them

Right to restriction of processing: you may request that we limit the processing of your data

Right to object: you may object to the processing of your data, for example when based on our legitimate interest

Right to data portability: you may receive your personal data in a structured, commonly used, and machine-readable format and transmit those data to another controller

9.      Technical and organizational measures

Josie will implement appropriate technical and organizational measures to protect the personal data being processed. Josie is not liable for unauthorized access, use, or disclosure of personal data unless such breach results from Josie’s gross negligence in maintaining reasonable security measures in accordance with industry standards.

10.  Modifications

We may amend this policy at any time. If we do, an updated version will be posted on this website.

11.  Contact

To submit a complaint or ask a question about this privacy policy and its application, you can contact Josie at: lets@askjosie.ai.

You may also contact the Belgian Data Protection Authority:
www.gegevensbeschermingsautoriteit.be
Address: Drukpersstraat 35, 1000 Brussels
Email: contact@apd-gba.be