Data Privacy Policy

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MegaCool Technologies bv (“we,” “our,” or “us”) believes that protecting the security and privacy of your personal data is important. This Privacy Policy explains how we collect, store, use, disclose, transfer, and otherwise process your personal data.

1. Definitions and key terms

To explain this Privacy Policy as clearly as possible, the following terms have the meanings set out below:

Company: when this policy mentions "company," "we," "us," or "our," it refers to MegaCool Technologies bv that is responsible for your information under this Privacy Policy.
Customer: refers to any company, organization, or individual that uses or purchases MegaCool Technologies’s products, including hardware, software, or services.
Product: means the hardware, software, services, solutions, and other products provided by MegaCool Technologies to customers, including those that may require the processing of personal data in connection with the commercial relationship between the customer and the company.
Device: refers to any internet-connected device, such as a smartphone, tablet, computer, or any other electronic device that can be used to access MegaCool Technologies’ website, online platforms, digital systems, or services.
Website: MegaCool Technologies’ site, which can be accessed via this URL http://www.megacool-technologies.com
Cookie: small amount of data generated by a website and saved by your web browser. It is used to identify your browser, provide analytics, and remember information about you such as your language preference or login information.
You: refers to any individual or entity that interacts with MegaCool Technologies and whose personal data is processed by us.

2. What is personal data?

The personal data that we collect about you depends on the context of your interactions with us, the product, services and features that you use, your location, and applicable law.

Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information that could be used on its own, or in combination with other pieces of information, to identify a person. Personal data extends beyond a person's name or email address. Some examples include financial information, political opinions, genetic data, biometric data, IP addresses, physical address, sexual orientation, and ethnicity.

The Data Protection Principles include requirements such as:

Personal data collected must be processed in a fair, legal, and transparent way and should only be used in a way that a person would reasonably expect.
Personal data should only be collected to fulfill a specific purpose and it should only be used for that purpose. Organizations must specify why they need the personal data when they collect it.
Personal data should be held no longer than necessary to fulfill its purpose.
People covered by the GDPR have the right to access their own personal data. They can also request a copy of their data, and that their data be updated, deleted, restricted, or moved to another organization.

3. Categories of personal data processed and purposes of processing

When visiting our external and internal websites or using our applications, or services (each a “Product”), we may process the following categories of personal data:

Your contact information, such as full name, address, telephone number, mobile phone number and email address;
Organizational information, including job position and company name;
Your date of birth in case of product requiring verification of your age;
Information submitted as part of a support request, survey or comment or forum post;
Further personal data that you provide by filling in forms in our products;
Information on your interaction with the product, including your device and user identifier, information on your operating system, sites and services accessed during your visit, the date and time of each visitor request; and
Personal data accessed through permissions you grant to our mobile applications, such as your device’s location data (e.g. GPS coordinates for asset tracking), camera input (e.g. bar code scans for inventory), microphone input (e.g. for voice commands), stored files or media (e.g. for uploading diagnostic reports), Bluetooth connectivity (e.g. for interacting with nearby industrial equipment), local network access (e.g., for connecting to on-premise systems), and notification settings (e.g. for receiving service-related alerts), insofar as you choose to use features that require such access. You may grant or deny such permissions at any time via your device settings.

3.1 Purposes of processing

To contact you with information and offers concerning our products and services, to send you further marketing information or to contact you in the context of customer satisfaction surveys;
To provide the product’s services and functions which includes creating and administering your online account, updating, securing, and troubleshooting, providing support, as well as improving and developing our products;
To verify your identity;
To verify your age;
To answer and fulfill your requests or instructions;
To bill your use of the product;
To process your order or to provide you with access to specific information or offers;
As reasonably necessary to enforce the product’s terms, to establish or preserve a legal claim or defense, to prevent fraud or other illegal activities, including attacks on our information technology systems.

3.2 Products provided by your organization

Our products may be provided to you for your use by the organization to which you belong, such as our enterprise customers. If your organization provides you with access to a product, our processing of personal data provided by or collected from you or your organization in connection with the product’s content is performed under the direction of your organization and is subject to a data processing agreement between your organization and us. In such an instance, your organization is responsible for any personal data contained in such content and you should direct any questions about how personal data contained in such content is used to your organization.

4. Processing of Personal Data Related to Human Resources Activities

4.1 Categories of personal data processed and purpose of processing

In connection with our human resources activities, we may process personal data relating to current employees, former employees, job applicants, contractors, interns, and other individuals involved in our workforce activities.

The categories of personal data we may process include:

Identification and contact information, such as full name, address, telephone number, email address, date of birth, nationality, and other identification information;
Employment-related information, including job title, department, employment history, qualifications, education, professional certifications, skills, performance records, and work experience;
Recruitment information, including information provided in applications, CVs/resumes, cover letters, interviews, assessments, references, and background checks where applicable;
Contract and payroll information, including employment contract details, salary information, bank account details, tax-related information, benefits information, and other information necessary for employment administration;
Working time and attendance information, including working hours, leave records, absence information, and related documentation;
Performance and development information, including performance evaluations, training records, career development plans, and professional objectives;
IT and security-related information, including user accounts, access records, device information, and information relating to the use of company systems and equipment;
Information required for legal and regulatory compliance, including information necessary for employment law, tax, social security, health and safety, export control, and other applicable obligations.

Where required by applicable law, we may process special categories of personal data, such as health-related information, only where there is a lawful basis and appropriate safeguards are implemented.

4.2 We process your personal data for the following purposes:

We process personal data related to human resources activities for the following purposes:

Managing recruitment processes, including reviewing applications, conducting interviews, assessing candidates, and communicating with applicants;
Establishing, managing, and terminating employment or contractual relationships;
Managing employee administration, including payroll, benefits, working time, leave, and other employment-related activities;
Providing employees with access to company systems, tools, facilities, and resources necessary to perform their work;
Managing employee performance, training, professional development, and career progression;
Maintaining workplace security, protecting company assets, and ensuring the proper use of company systems and information;
Complying with legal and regulatory obligations, including employment, tax, social security, health and safety, and reporting requirements;
Conducting internal investigations, audits, risk management activities, and resolving disputes;
Establishing, exercising, or defending legal claims.

5. Processing of personal data related to your business relationship with us

5.1 Categories of personal data processed, and purpose of the processing

In the context of the business relationship with us, we may process the following categories of personal data of consumers and contact persons at (prospective) customers, suppliers, vendors and partners (each a “Business Partner”):

Contact information, such as full name, address, telephone number, work mobile phone number and email address;
Organizational information, including job position and company name;
Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
Further information necessarily processed in a project or contractual relationship with us or voluntarily provided by the Business Partner, such as personal data relating to orders placed, payments made, requests, and project milestones;
Personal data collected from publicly available resources (including business and employment oriented social networks and websites), integrity databases and credit agencies;
Information that is legally required for Business Partner compliance screenings or export control checks, such as date of birth, nationality, place of residence, ID numbers, identity cards and information about relevant and significant litigation or other legal proceedings against Business Partners.

5.2 We may process the personal data for the following purposes:

Communicating with Business Partners about our products, services and projects, e.g. by responding to inquiries or requests or providing you with information about purchased product;
Planning, performing and managing the (contractual) relationship with Business Partners; e.g. by performing transactions and orders of products or services, processing payments, performing accounting, auditing, billing and collection activities, arranging shipments and deliveries, facilitating repairs and providing support services;
To create a personal profile containing business-related information on interactions between you and us with the aim of being able to offer you and the company you work for relevant information and suitable offers for our services and products and to improve our personal communication with you;
Administrating and performing market analysis, sweepstakes, contests, or other customer activities or events;
Contacting you with information and offers concerning our products and services, sending you further marketing messages and conducting customer satisfaction surveys
Maintaining and protecting the security of our site location and facilities, products, services and websites, preventing and detecting security threats, fraud or other criminal or malicious activities;
Ensuring compliance with legal obligations (such as record keeping obligations), export control and customs, Business Partner compliance screening obligations (to prevent white-collar or money laundering crimes), and our policies or industry standards; and
Solving disputes, enforcing our contractual agreements and establishing, exercising or defending legal claims.

6. Processing of personal data related to event participation and management

6.1 When you register for or attend one of our in-person events (“Events”), we process:

The personal data described in Section 5 (“Processing of personal data related to your business relationship with us”);
Your name, organization and contact details (“Participant Information”);
Automated attendance data collected by sensors, including session check-ins and movement patterns within Event areas.
Additional information you provide during registration, such as food or accommodation preferences; To the extent that your food or accommodation preferences reveal sensitive personal information (such as dietary requirements indicating religious beliefs or health information), we will process such data only where permitted or required by applicable law, which may include obtaining your consent, fulfilling our legal obligations, or protecting your vital interests.

6.2 We may process the personal data for the following purposes:

To organize and manage the Event (including registration, access control, and logistical arrangements),
To provide Event access and networking opportunities,
To track session attendance where required, and to improve future Events. In case of automated processing of attendance data:
To automate attendance verification and remove the need for manual check ins; To support logistical planning and management of Event areas;
To analyze attendee flows and participation patterns;
To improve the design and organization of future Events;
To share your Participant Information encoded on your badge with exhibitors or sponsors, if you choose to have your Event badge scanned by such exhibitors or sponsors. Exhibitors and sponsors use the Participant Information for their own follow up and networking purposes under their own Privacy Policies and based on your direct relationship with them.

7. Processing of personal data related to your use of virtual meeting features

7.1 Categories of personal data processed, and purpose of the processing

If you participate in a virtual meeting where - to the extent permitted by applicable law - recording, transcription, or AI-assisted features are activated, we may process the following categories of personal data:

Audio, video, and text content of your contributions during the meeting, including your voice, your image, content shared by you, and messages you send in the chat;
Information about your participation, such as your name, your email address, the times of joining and leaving the meeting, details of your interactions during the meeting, as well as technical connection data (e.g., IP address).

7.2 The purposes for processing your personal data in this context are:

To provide the requested recording, transcription, or AI assistance features for participants;
To create meeting recordings, transcripts, and AI-generated summaries;
As necessary, to establish or defend legal claims, prevent fraud, and comply with applicable law.

8. Cookies

All relevant information on the processing of personal data in connection with cookies may be found in our Cookie Policy.

9. Processing of personal data for customer satisfaction surveys and for direct marketing

Where and as permitted under applicable law, we may process your contact information for direct marketing purposes (e.g. trade show invitations, newsletters with further information and offers concerning our products and services) and to carry out customer satisfactions surveys, in each case also by e-mail. You may object to the processing of your contact data for these purposes at any time by writing to info@megacool-technologies.com or by using the opt-out mechanism provided in the respective communication you received.

10. Processing of personal data related to your job application

When you apply for a job, we process your personal data as set out in the Privacy Policy of the Company Recruiting Portal or of the respective other recruiting platform you may use.

11. Transfer and disclosure of personal data

We only transfer your personal data as below:

Affiliated Companies and sales partners

For the purpose of and to the extent necessary to conduct our business relationship with you, we may share your personal data with affiliates and other third parties (e.g., sales partners and agents).

We, for example, sell certain products and services only via local business relationships and in this case, we may transfer your personal data to our respective local affiliates or other sales partners conducting the business relationship with you.

Service Providers

We employ affiliates and other companies to perform functions on our behalf, such as IT-services or payment processing services. These affiliates and other companies process personal data only for the purpose of such services.

Other third parties

We may transfer personal data to other third parties in connection with complying with legal obligations or establishing, exercising or defending rights or claims (e.g., for court and arbitration proceedings, to regulators, law enforcement and government authorities, to attorneys and consultants).

The recipients of your personal data may be located outside of the country in which you reside. Personal data published by you on products (such as chat rooms or forums) may be globally accessible to other registered users of the respective Product.

12. Retention periods

Unless indicated otherwise at the time of the collection of your personal data (e.g. within a form completed by you), we erase your personal data if the retention of that personal data is no longer necessary for the purposes for which they were collected or otherwise processed, or to comply with legal obligations (such as retention obligations under tax or commercial laws).

13. Your rights

The data protection laws in the jurisdiction in which you reside may entitle you to specific rights in relation to your personal data.

In particular, and subject to the legal requirements, you may be entitled to

Obtain from us confirmation as to whether or not personal data concerning you are being processed, and where that is the case, access to the personal data;
Obtain from us the correction of inaccurate personal data concerning you;
Obtain from us the erasure of your personal data;
Obtain from us restriction of processing regarding your personal data;
Data portability concerning personal data, which you actively provided;
Object, on grounds relating to your particular situation, to further processing of personal data concerning you; and
Withdraw your consent to our processing of your personal data.

14. Security

To protect your personal data against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access, we use adequate physical, technical and organizational security measures.

15. Data privacy contact

Our Data Privacy Organization provides support with any data privacy related questions, comments, concerns or complaints or in case you wish to exercise any of your data privacy related rights. The Data Privacy Organization may be contacted at: dpo@megacool-technologies.com.

The Data Privacy Organization will always use reasonable efforts to address and settle any requests or complaints you bring to its attention. Besides contacting the Data Privacy Organization, you always have the right to approach the competent data protection authority with your request or complaint.

16. Processing under the EU’s General Data Protection Regulation

This section applies and provides you with further information if your personal data is processed by one of our companies located in the European Economic Area.

Data Controller

The company that provides you with this Privacy Policy, or that is identified as the operator of the relevant website, application, or service, is the controller responsible for processing your personal data under the General Data Protection Regulation.

Business Partner personal data in Customer Relationship Management Systems

In the course of our business relationship with you, we may share Business Partner contact information with affiliated companies and partners where necessary for business purposes. Each entity is responsible for processing personal data in accordance with applicable data protection laws.

The legal basis of the processing

The legal basis for our processing data about you is that such processing is necessary for the purposes of

Exercising our rights and performing our obligations under any contract we make with you (Article 6 (1) (b) General Data Protection Regulation) (“Contract Performance”);
Compliance with our legal obligations (Article 6 (1) (c) General Data Protection Regulation) (“Compliance with Legal Obligations”); and/or
Legitimate interests pursued by us (Article 6 (1) (f) General Data Protection Regulation) (“Legitimate Interest”). Generally, the legitimate interest pursued by us in relation to our use of your personal data is the efficient performance or management of your use of the product, our business relationship with you and in particular, the achievement of the purposes described in the table below. Where the below table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interest is not overridden by your interests and rights or freedoms, given (i) the regular reviews and related documentation of the processing activities described herein, (ii) the protection of your personal data by our data privacy processes, including our Binding Corporate Rules on the Protection of Personal Data, (iii) the transparency we provide on the processing activity; (iv) the rights you have in relation to the processing activity. Where our mobile applications access device data through permissions (such as location or contacts), we provide you with configuration options to manage and revoke such access at any time. This possibility to control the use of permissions is taken into account when assessing whether your legitimate interests are duly respected. If you wish to obtain further information on this balancing test approach, please contact us at: dpo@megacool-technologies.com.

In some cases, we may ask if you consent to the relevant use of your personal data. In such cases, the legal basis for us processing that data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation) (“Consent”).

17. International data transfers

We may transfer your personal data to affiliated companies located outside the European Economic Area where necessary for our business purposes. Such transfers are carried out in accordance with applicable data protection laws and subject to appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission or other lawful transfer mechanisms.

You may request further information about the safeguards implemented in relation to specific transfers by contacting dpo@megacool-technologies.com.

Your competent data protection authority

In case of data privacy related concerns and requests, we encourage you to contact our Data Privacy Organization at dpo@megacool-technologies.com.

Besides contacting the Data Privacy Organization, you always have the right to approach the competent data protection authority with your request or complaint.

18. Further information for US residents

If you are a U.S. resident, then please take note of the following:

Do Not Track

At this time our products do not recognize or respond to “Do Not Track” browser signals. For more information on “Do Not Track”, please visit your browser’s support page.

Usage by Children

Our Products are not directed to children under the age of thirteen. We will not knowingly collect personal data from children under the age of thirteen without insisting that they seek prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent, pursuant to local law and regulations or to protect a child.

State Rights

Depending on the US state in which you reside, you may have special rights with respect to your personal data.

19. Changes To Our Privacy Policy

If we decide to change our privacy policy, we will post those changes on this page, and/or update the Privacy Policy modification date.

20. Applicable Laws and Data Protection Framework

MegaCool Technologies bv is a company incorporated and established in Belgium. We are committed to protecting the privacy and personal data of our customers, partners, website visitors, and other individuals who interact with our products, services, and digital platforms.

This Privacy Policy is prepared in accordance with applicable data protection laws, including the Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR) and applicable Belgian data protection legislation.

MegaCool Technologies bv acts as the data controller for personal data collected and processed through our website, products, services, business interactions, and other activities described in this Privacy Policy. We process personal data only for legitimate business purposes and in accordance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality.

Where applicable, individuals have rights under the GDPR, including the right to access, correct, delete, restrict, or object to the processing of their personal data, as well as the right to withdraw consent and lodge a complaint with the competent data protection authority.

This Privacy Policy shall be interpreted and applied in accordance with the laws of Belgium and the applicable laws of the European Union. Any disputes relating to this Privacy Policy shall be subject to the jurisdiction of the competent courts of Belgium, unless otherwise required by mandatory applicable law.