Declaration of Privacy Protection

 

This Declaration of Privacy Protection describes how DefenseWise may collect information from or about you when you visit our website www.defense-wise.com.

DefenseWise values your privacy and provides this Declaration of Privacy Protection to explain what information we collect and use and how we protect it.

In some countries, your use of the DefenseWise web site may be deemed to constitute your consent to DefenseWise's use of such information. If you do not want DefenseWise to collect or use your information as described in this Declaration of Privacy Protection, please do not use the DefenseWise Web site or provide DefenseWise with your information.

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

What is personal data?

"Personal Data" means personally identifiable information that allows a person to be identified, 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 individuals with regard to the processing of personal data and on the free movement of such data, commonly referred to as "GDPR", as amended from time to time, as well as the Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data.

When does DefenseWise collect personal data?

DefenseWise collects contact information of its customers or future customers when they contact DefenseWise, such as first name, last name, organization, title, position, telephone number, certain third-party integration data when such data is essential to process requests, and e-mail addresses.

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

Finally, as part of its D-Wise Academy program, DefenseWise may collect more detailed information about its customers, such as simulated situations relating to subjects taught by DefenseWise, awareness tests on the various national and international export control regimes, the results of certain qualifying training courses, risk scores, general assessment results, information relating to subscribed training courses and services, and information downloaded from DefenseWise subscription services.

How does DefenseWise collect personal information?

DefenseWise collects this personal data when you visit its website, when you submit information via forms, when you contact DefenseWise to subscribe or inquire about its services, or when you voluntarily send us information or download information about our services.

DefenseWise uses common information collection tools, such as usage data collection tools, cookies and similar technologies to automatically collect information containing personal data from your computer or mobile device when you browse its website, use its services, fill out its forms or interact with DefenseWise by e-mail.

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

The purposes for which DefenseWise collects personal data are to respond to your questions and requests, to send you requested information about its services/events or notifications about the availability of new services/events, to administer the services to which you subscribe or for which you request information, or generally to improve the services DefenseWise offers its customers 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 uses the legal basis of the performance of the contractual relationship (service offer subscribed by you) for the collection and use of your personal data in the following processing operations:

1. for the use of our online tools, subscription services or other services provided to you as part of the service agreement between you or your organization and DefenseWise;
2. for the use of our customer web interface, including any tools or services hosted on it;
3. to collect and manage payment information resulting from transactions with you;
4. for any consulting services we provide; and
5. for webinars and e-learning modules to which you have subscribed.

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

1. to evaluate and improve your experience of the free services and tools made available by DefenseWise (such as analyzing trends or tracking your use of and interactions with our services to improve your overall experience);
2. for security purposes, for example investigating suspicious activity on our website or via our contact e-mail addresses, or
3. for compliance purposes, for example to investigate fraud or abuse of our website.

In addition, DefenseWise may occasionally ask you for specific permission to process some of your personal data (i.e. legal basis for consent), and will only process your personal data in this way if you consent to this. You may withdraw your consent at any time by contacting us at privacy@defense-wise.com.

Finally, DefenseWise uses the legal basis of compliance with a legal obligation for the transfer of personal data when DefenseWise is the recipient of mandatory requests issued in the context of legal proceedings conducted by the competent judicial authorities.

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

The DefenseWise web site and services are not intended for children of any age, and in particular children under the age of 16, and DefenseWise does not knowingly collect information from children to sell or promote its services. No child or person under the age of 16 may or should provide any information to DefenseWise on or through the DefenseWise website, and if DefenseWise learns that information about a child (especially one under the age of 16) has been received, DefenseWise will endeavor to delete such information permanently.

What are cookies 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 cookies to provide 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, DefenseWise may use third-party service providers ("TSPs") to help provide some of its services to you and/or to perform specialized services you have requested that require the processing of personal data, but may also use companies that are or will be affiliated with DefenseWise in the future.

When DefenseWise provides personal data to these TSPs/affiliates, they are not permitted to use this personal data for any purpose other than that for which DefenseWise has engaged/used them. For example:

When DefenseWise uses Google's secure hosting sites for customer data through Odoo's enterprise service provider and/or Odoo's third-party service providers (TSPs), it is necessary for a transmission to take place in order for DefenseWise to provide you with the services to which you subscribe, including from personal data located on these secure hosting sites.

When you register for a webinar, it is likely that such registration will be through these TSPs. In these circumstances, your information will be subject to the Declaration of Privacy Protections of those TSPs and/or in accordance with the DefenseWise Privacy Policy available here. If you do not wish 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 purchaser or assignee in the event of a merger, assignment, restructuring, reorganization, dissolution or other sale or transfer of all or a portion of its assets, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding.

In accordance with applicable laws, we will do what is necessarily reasonable to inform you as soon as possible of any transfer of personal data to an unaffiliated third party, and you may request that your personal data be deleted from our systems.

Finally, DefenseWise reserves the right to disclose your personal data under the following conditions: (1) where permitted or required by law; (2) in an attempt to protect against or prevent actual or potential fraud, unauthorized transactions or other suspected illegal activities; or (3) as part of an investigation into suspected fraud or other suspected illegal activities that have already taken place.

Does DefenseWise sell your personal data?

DefenseWise will never sell your personal data.

What is the role of an administrator or account manager?

​DefenseWise will use your personal data to communicate with you for support purposes or to respond to 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 appoint an account administrator who manages access to DefenseWise services and provides them to your organization's registered users. When you or your account administrator upload information (such as your organization's e-mail addresses) to DefenseWise forms or services, 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 regarding the processing of personal data and may only process your organization's personal data to the extent permitted by our service agreements, at the direction of the controller, or by you in the exercise of your rights. If you have any detailed questions regarding these aspects, please contact your account administrator or DefenseWise directly at privacy@defense-wise.com.

Subject to legal and/or contractual requirements applicable to your situation, you may refuse the collection of your data or withdraw your consent to further 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 may contact your organization's account administrator to opt-out of the services provided. In addition, you may contact your account administrator to make changes to your personal data. DefenseWise has no control over how your organization uses your personal data and for what purposes. As a last resort, you may contact us to have DefenseWise contact your organization on your behalf, by sending an e-mail to privacy@defense-wise.com.

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

DefenseWise does not transfer your personal data outside the European Union with the exception of a backup transfer (specific reduced format) to Canada via the Odoo enterprise service provider. In any event, DefenseWise implements, directly or indirectly, appropriate protections with all its TSPs/affiliates to ensure that they meet their data protection obligations, including vis-à-vis personal data in accordance with the RGPD. These appropriate protections may take the form of an adequacy decision, binding corporate rules, standard data protection clauses adopted by the European Commission, standard data protection clauses issued by a supervisory authority or contractual clauses specially authorized by a supervisory authority. Since December 20, 2001, Canada has been deemed compliant with the GDPR by virtue of the adequacy decision issued by the European Commission concerning 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 held securely in accordance with DefenseWise's commitment to its Declaration of Security. Only authorized DefenseWise employees, agents and TSPs (who have agreed to maintain the security and confidentiality of the information) have access to this information. Where DefenseWise provides data to such TSPs under the terms of subcontracts with such TSP(s), the TSP(s) are not authorized to use such data outside the scope for which DefenseWise and such TSP(s) have entered into such contractual relationship.

DefenseWise and all its TSPs use a range of security measures in line with the latest industry standards to prevent unauthorized access, use or disclosure of personal data, in particular physical security and end-to-end resident and dynamic encryption. No method of transmission or electronic storage over the Internet is 100% secure. Therefore, while DefenseWise strives to use industry-standard means to protect personal data, DefenseWise 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 law.

DefenseWise also takes all reasonable steps to ensure that your personal data is accurate, minimal but complete, kept 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 purposes set out above and for which it was collected. If your personal data has been transmitted to a TSP for the performance or support of DefenseWise services and you become aware that it is incorrect, DefenseWise will undertake all reasonable efforts to contact your account administrator and will work with the relevant TSP to request 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 those websites, the content displayed thereon, or the persons or entities associated therewith. By visiting a linked website from the DefenseWise website, you acknowledge that DefenseWise is providing these links to you only as a convenience, and you agree that DefenseWise is not responsible for the content of any such linked website. External sites are governed by their own terms and policies and are not governed by the DefenseWise Declaration of Privacy Protection, Security Statement, Terms of Use, or other terms and policies.

What are your rights regarding personal data collected by DefenseWise?

Subject to local data protection laws, you have all the rights that the GDPR recognizes in terms of personal data protection.

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

1. access to your personal data held by DefenseWise and the possibility of receiving it in a structured format and transferring it to a third party of your choice;
2. correction of your personal data if it proves to be inaccurate;
3. modification and/or deletion of your personal data if it is contrary to the principle of minimization, if it has become obsolete or if its retention period has expired.

DefenseWise also points out:

1. your right to object to any processing of your personal data carried out on the basis of its legitimate interests (right to object); as well as
2. your right not to be subject to a decision based exclusively on automated processing, including profiling, which produces legal effects ("automated decision-making"); and
3. your right to withdraw your consent in cases where the collection, processing and sharing of your personal data are based on the performance of a contractual relationship to which you have consented, without however affecting the lawfulness of the processing based on your consent carried out by DefenseWise prior to such withdrawal.

Finally, you may ask 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 concerning this chapter or concerning the confidentiality of our services or the protection of your personal data, please contact us in writing at the following address privacy@defense-wise.com, specifying the reason for your request as well as the minimum information necessary for DefenseWise to usefully verify its validity, and subject to subsequent review where appropriate, to access it.

Please limit the sharing of personal data in this type of communication to the strict minimum.

You can also send a notice to DefenseWise by simple postal mail to the address below, remembering to indicate a way to contact you:

DefenseWise, SRL

21 Rue Delvaux

4340 Othée, Belgique

For the attention of Fabio Ferretti

DefenseWise is committed to working with you to obtain a fair resolution of any complaint or concern regarding your personal data.

If, however, you feel that DefenseWise has not been able to adequately address your complaint or concern, you have the right to lodge a complaint with the relevant national supervisory authority whose contact details for Belgium are:

Data protection authority

Drukpersstraat 35, 1000 Brussel

Tel: +32 (0)2 274 48 00

Fax: +32 (0)2 274 48 35

E-mail: contact@apd-gba.be

Can DefenseWise modify its Declaration of Privacy Protection?

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

As DefenseWise adds new features and functionality to its website or as DefenseWise policies or applicable laws change, DefenseWise may need to update or revise this Declaration of Privacy Protection. DefenseWise reserves the right to do so, at any time and without notice, by posting a revised version on its web site. Such changes will be effective as of the date DefenseWise posts a revised version on its web site.

If DefenseWise makes any changes to this Declaration of Privacy Protection that materially alter the way DefenseWise handles your personal data, DefenseWise will make a reasonable effort to promptly notify you by reasonable means.

This Declaration of Privacy Protection was last updated on October 24, 2024.