Privacy Policy

 

This Privacy Policy describes how DefenseWise may collect information from or about you when you visit its website www.defense-wise.com.

DefenseWise values your privacy and provides this Privacy Policy to explain what information we collect, how we use it, and how we protect it.

In some countries, your use of the DefenseWise website may be considered as your consent to DefenseWise’s use of your information as outlined in this Privacy Policy. If you do not want DefenseWise to collect or use your information as described in this Privacy Policy, please refrain from using the DefenseWise website or providing your information to DefenseWise.

Please take a few minutes to read this Privacy Policy. If you have any questions about it, please contact privacy@defense-wise.com.

What is personal data?

"Personal Data" refers to information that can identify an individual, either directly or indirectly, as defined by applicable legislation. The legislation applicable to DefenseWise is Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons concerning the processing of personal data and on the free movement of such data, commonly known as the "GDPR," as amended from time to time, along with the Belgian law of 30 July 2018 on the protection of natural persons concerning the processing of personal data.

When does DefenseWise collect personal data?

DefenseWise collects clients’ or prospective clients’ contact information when they reach out to DefenseWise, such as first name, last name, organization, title, position, phone number, specific third-party integration data when essential for processing requests, and email addresses.

DefenseWise also automatically collects data that may be of a personal nature, such as information gathered through cookies, including the visitor's device IP address, browser name, operating system details, domain name, visit date and time, pages viewed, and other similar information.

Lastly, as part of its D-Wise Academy program, DefenseWise may collect more detailed information about its clients, such as simulated scenarios related to the topics taught by DefenseWise, awareness tests for various national and international export control regimes, results from certain qualifying training sessions, risk scores, general assessment outcomes, information about training and services subscribed to, and data uploaded to DefenseWise subscription services.

How does DefenseWise collect personal information?

DefenseWise collects personal data when you visit its website, submit information through forms, contact DefenseWise to subscribe to or inquire about its services, or voluntarily provide or upload information to its services.

DefenseWise also uses common information-gathering tools, such as usage data collection tools, cookies, and other similar technologies, to automatically collect information, including personal data, from your computer or mobile device when you browse its website, use its services, complete forms, or interact with DefenseWise via email.

For what purposes and uses does DefenseWise collect your personal data?

The purposes for which DefenseWise collects personal data include:
- Responding to your inquiries and requests. 
- Sending you information about its services/events or notifications regarding the availability of new services/events. 
- Managing the services you subscribe to or inquire about. 
- Generally improving the services DefenseWise provides to its clients and visitors.

DefenseWise uses all such personal data in compliance with the legal obligations set forth by the RGPD regarding the collection, use and protection of personal data as well as the exercise of individuals' rights with respect to their personal data transmitted to DefenseWise or collected by DefenseWise, and in strict compliance with DefenseWise's professional ethics. In addition, DefenseWise undertakes to keep personal data only for the minimum period necessary for its effective use, and to delete it as soon as its use is no longer legally justified.

What is the legal basis for the collection of personal data by DefenseWise?

DefenseWise relies on the legal basis of performing the contractual relationship (service offer subscribed by you) to collect and use your personal data in the following processing operations:

1. For the use of its online tools, subscription services, or other services provided under the service agreement concluded between you or your organization and DefenseWise;
2. For the use of its client web interface, including tools or services hosted therein;
3. To collect and manage payment information resulting from transactions made with you;
4. For any consulting service it provides to you; and
5. For webinars and online learning modules to which you have subscribed.

DefenseWise relies on the legal basis of legitimate interest to collect and use your personal data for the following purposes:

1. To evaluate and improve your experience with the free services and tools provided by DefenseWise (such as trend analysis or monitoring your usage and interactions with its services to enhance your overall experience);
2. For security purposes, for example, to investigate suspicious activities on its website or through its contact email addresses; or
3. For compliance purposes, such as investigating fraud or abuse on its website.

Additionally, DefenseWise may occasionally request specific authorization to process certain personal data (i.e., the legal basis of consent) and will only process your personal data in this way if you consent. You can withdraw your consent at any time by contacting DefenseWise at privacy@defense-wise.com.

Finally, DefenseWise relies on the legal basis of complying with a legal obligation for the transfer of personal data when DefenseWise receives mandatory requests issued in judicial proceedings conducted by competent judicial authorities.

What is DefenseWise's position on protecting children's privacy?  

The DefenseWise website and its related services are not intended for children of any age and particularly not for children under the age of 16. DefenseWise does not knowingly collect information from children for the purpose of selling or promoting its services. No child or person under the age of 16 may or should provide information to DefenseWise through or via the DefenseWise website. If DefenseWise becomes aware that information about a child (particularly under the age of 16) has been received, DefenseWise will make every effort to permanently delete such information.

What are cookies used for?

DefenseWise uses cookies and other tracking technologies when users interact with its services. Cookies are small text files placed on your computer by a website. Each cookie contains an identification number, an IP address, and the time and date of the last access. DefenseWise does not use these cookies to deliver targeted advertising to users.

For further information on the use of cookies, please refer to our Security Statement, available here.

With whom does DefenseWise share the personal data it collects?

DefenseWise does not share the personal data it collects. However, it may engage third-party service providers (“TSPs”) to help deliver certain services or perform specialized tasks requested by you that require the processing of personal data. DefenseWise may also collaborate with companies affiliated with it, now or in the future.

When DefenseWise provides personal data to these TSPs or affiliated companies, they are not authorized to use the data for purposes other than those for which DefenseWise has engaged them. For example:

When DefenseWise utilizes Google’s secure hosting sites for client data via the enterprise service provider Odoo and/or Odoo’s third-party service providers, data transmission is required to deliver subscribed services, including those involving personal data stored on these secure hosting sites.

When you register for a webinar, this registration may be processed via TSPs. In such cases, your information will be subject to the privacy statements of those TSPs and/or in accordance with DefenseWise’s privacy policy available here. If you do not wish for your information to be shared, you may choose not to participate in the event or webinar in question.

DefenseWise may also disclose your information to a buyer or assignee in the event of a merger, transfer, restructuring, reorganization, dissolution, or another sale or transfer of all or part of its assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings.

In compliance with applicable laws, DefenseWise will take all reasonably necessary steps to inform you promptly of any transfer of personal data to an unaffiliated third party, and you may request the deletion of your personal data from our systems.

Finally, DefenseWise reserves the right to disclose your personal data in the following circumstances: 
- When permitted or required by law, 
- To prevent or mitigate actual or potential fraud, unauthorized transactions, or other suspected unlawful activities, 
- As part of an investigation into suspected fraud or other illegal activities that have already occurred.

Does DefenseWise sell your personal data?

DefenseWise will never sell your personal data.

What is the role of an administrator or account administrator?

​DefenseWise will use your personal data to communicate with you for assistance or to follow up on requests made by you or another user of the subscription services, as well as to enable you to properly use its services. For this purpose, your organization may designate an account administrator who manages access to DefenseWise services and provides them to the registered users of your organization. When you or your account administrator upload information (such as your organization’s email addresses) into the forms or services of DefenseWise, this is done at the discretion of the organization to which you or your account administrator belong. The organization using the account administrator is the “controller” of the personal data, and DefenseWise acts as the “processor” of the personal data. DefenseWise is legally bound by the applicable European requirements between DefenseWise and your organization concerning the processing of personal data and may only process your organization’s personal data to the extent permitted by our service agreements, upon instruction from the controller, or by you in exercising your rights. If you have detailed questions about these aspects, please contact your account administrator or DefenseWise directly at privacy@defense-wise.com.

Subject to the applicable legal and/or contractual requirements in your situation, you may refuse the collection of your data or withdraw your consent for future collection. Your personal data will never be used outside the scope of the transaction between DefenseWise and your organization.

Can you refuse to participate in the collection of your personal data by DefenseWise or your organization?  

When DefenseWise services are provided at the request of your organization, you can contact your organization’s account administrator to opt out of the services provided. Additionally, you can contact your account administrator to make changes to your personal data. DefenseWise has no control over how your organization uses your personal data or for what purposes. As a last resort, you can contact us, and DefenseWise will reach out to your organization on your behalf by sending an email to privacy@defense-wise.com.

Is personal data collected by DefenseWise transferred outside of the European Union?

DefenseWise does not transfer your personal data outside the European Union, except for a backup transfer (in a specific reduced format) to Canada via the enterprise service provider Odoo. In any case, DefenseWise implements, directly or indirectly, the appropriate protections with all its third-party service providers (FST) and affiliated companies to ensure they fulfill their data protection obligations, including for personal data in accordance with the GDPR. These appropriate protections may take the form of an adequacy decision, binding corporate rules, standard contractual clauses adopted by the European Commission, standard contractual clauses published by a supervisory authority, or contractual clauses specially authorized by a supervisory authority. Since December 20, 2001, Canada is deemed to comply with the GDPR under the adequacy decision issued by the European Commission regarding its Personal Information Protection and Electronic Documents Act (PIPEDA).  

How is your data, and in particular your personal data, secured and stored? 

Your personal data is stored securely in accordance with DefenseWise's commitment outlined in its Security Statement. Only authorized employees, agents, and third-party service providers (FST) of DefenseWise (who have agreed to maintain the security and confidentiality of the information) have access to this data. When DefenseWise provides data to these FSTs under the terms of subcontracting agreements, the FSTs are not allowed to use this data beyond the scope for which DefenseWise and the FST have entered into such contractual relations.

DefenseWise and all its FSTs use a series of security measures that comply with the latest industry standards to prevent unauthorized access, use, or disclosure of personal data, particularly physical security and end-to-end encryption, both static and dynamic. No electronic transmission or storage method over the Internet is 100% secure. Therefore, although DefenseWise strives to use industry-standard means to protect personal data, it cannot guarantee its absolute security.

DefenseWise will retain your personal data for as long as necessary for the purposes described in this section or until you request its deletion by exercising your rights, unless a longer retention period is required by applicable data privacy laws.

DefenseWise also takes all reasonable steps to ensure that your personal data is accurate, minimal yet complete, up to date, and reliable for the purposes for which it is intended. DefenseWise will never process personal data in a way that is incompatible with the objectives outlined above for which it was collected. If your personal data has been transmitted to an FST for the execution or support of DefenseWise's services and you find that it is incorrect, DefenseWise will make all reasonable efforts to contact your account administrator and work with the relevant FST to request a correction as soon as possible.

What about external links?

The DefenseWise website may contain links to other websites on the Internet that are not controlled or maintained by DefenseWise. These links do not constitute an endorsement by DefenseWise of these websites, their content, or the people or entities associated with them. By visiting a linked website from the DefenseWise website, you acknowledge that DefenseWise provides these links solely for convenience, and you agree that DefenseWise is not responsible for the content of these websites. External sites are governed by their own terms and policies and are not covered by DefenseWise's Privacy Policy, Security Statement, Terms of Use, or other conditions and policies.

What are your rights regarding personal data collected by DefenseWise?

Subject to local data protection laws, you have all the rights granted by the GDPR regarding the protection of personal data.

Depending on the applicable laws, particularly if you are located in the EEA, these rights may include:

1. Access to your personal data held by DefenseWise and the ability to receive it in a structured format and transfer it to a third party of your choice;
2. The correction of your personal data if it is inaccurate;
3. The modification and/or deletion of your personal data if it violates the principle of minimization, has become outdated, or if its retention period has expired.

DefenseWise also highlights:

1. Your right to object to any processing of your personal data based on legitimate interest (right to object); as well as
2. Your right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects ("automated decision-making"); and
3. Your right to withdraw your consent where the collection, processing, and sharing of your personal data is based on the execution of a contractual relationship to which you have consented, without affecting the legality of processing based on your consent performed by DefenseWise prior to this withdrawal.

Finally, you can request DefenseWise to limit any further use or disclosure of your personal data.

How can you exercise your rights with DefenseWise?

To exercise your rights, if you have any questions about this section or regarding the privacy of our services or the protection of your personal data, please contact us in writing at the following address: privacy@defense-wise.com. Please specify the reason for your request and provide the minimum necessary information so that DefenseWise can effectively verify its validity. After review, if applicable, we will process your request.

Please limit the sharing of personal data to the minimum necessary when communicating with us.

You can also send a notice to DefenseWise by regular mail at the address below, making sure to include a way for us to contact you:

DefenseWise, SRL

21 Rue Delvaux

4340 Othée, Belgium

Attn: Fabio Ferretti

DefenseWise is committed to working with you to achieve a fair resolution of any complaints or concerns regarding your personal data.

However, if you believe that DefenseWise has not adequately addressed your complaint or concern, you have the right to lodge a complaint with the competent national supervisory authority. For Belgium, the contact details are:

Data protection authority

Drukpersstraat 35, 1000 Brussels

Phone: +32 (0)2 274 48 00

Fax: +32 (0)2 274 48 35

E-mail: contact@apd-gba.be

Can DefenseWise modify its Privacy Policy ?

DefenseWise reserves the right to modify this Privacy Policy and related business practices at any time by posting the updated text on this site along with the updated effective date.  

As DefenseWise adds new features and functionalities to its website or as policies or applicable laws evolve, DefenseWise may need to update or revise this Privacy Policy. DefenseWise reserves the right to do so at any time and without prior notice by posting a revised version on its website. These changes will be effective as of the date DefenseWise publishes the revised version on its website.

If DefenseWise makes changes to this Privacy Policy that significantly alter the way DefenseWise processes your personal data, DefenseWise will make reasonable efforts to promptly notify you through reasonable means.

This Privacy Policy was last updated on October 24, 2024.