Privacy Policy

This version of this Privacy Policy is effective as of October 8, 2021.

This Privacy Policy describes how and when Project Pura collects, uses and shares the Personal Information of Users when they use the Project Pura Platform.

The terms of this Privacy Policy are incorporated by reference in the Terms of Use which are available at projectpura.com/terms and which may also be subject to changes in the future.

1. General Purposes

1.1. By accessing the Project Pura Platform, Users acknowledge and agree that Their Personal Data (as defined below) will be collected and/or processed for the purposes as described in this Privacy Policy.

“Personal Data” relates to any information relating to an identified or identifiable individual, in accordance with applicable privacy laws.

“Them” or “They” or “Their” refer to the Users.

1.2. Project Pura has taken technical and operational measures to ensure that the Personal Data of Users are protected from unauthorized access, deletion or modification. Project Pura will make reasonable efforts to ensure that the privacy interests of Users are protected in accordance with applicable law and best practices.

1.3. The purposes for which Project Pura are processing the Personal Data of Users include the following:

User identification on the Project Pura Platform and for using Project Pura Platform; Posting or modifying information on the Project Pura Platform; Contacting Users in relation to the Project Pura Platform and information posted on the Project Pura Platform; Tracking the pages Users are visiting in order to personalize Their use of the Project Pura Platform;

2. Submitting Personal Data through and Becoming a Registered User of the Project Pura Platform.

Project Pura collects and processes Personal Data of Users as provided by Them during the registration process provided for on the Project Pura Platform, or through the use They are making of the Project Pura Platform. Such data may include Their name, first name, Their physical and e-mail address, and – as the case may be – Their telephone number, Their company and Their function. Project Pura also collects and processes data gathered through Their use of the Project Pura Platform. These data may include the date and hour of Their visit (timestamp), the type of browser They use, Their IP address, and the pages visited, as well as data related to the type of files They download from or upload to the Project Pura Platform.

3. Users’ Rights

3.1. Pursuant to applicable law, Users are entitled to access Their Personal Data, as collected and processed by Project Pura, and to obtain the modification or deletion of the data if the data are incorrect or unnecessary for the purposes for which the data were collected.

3.2. Users may also request Project Pura to permanently delete Their personal information from the Platform. Please note, however, that the information Users have submitted to the Platform will remain available, which implies that Users need to obtain the consent of other users of the Project Pura Platform to enable Them to prevent the further processing and/or deletion of such information.

4. Changes

If Users are registered on the Project Pura Platform, They will be able to correct, update or modify Their personal information provided to Project Pura in connection with Their account and user profile through the Account Settings.

5. Right to be Forgotten

If Users would like Project Pura to delete Their personal information, please contact Project Pura’s Data Protection Officer (see below).

6.1. Project Pura collects information Users provide directly when using the Project Pura Platform. This personal information includes, but is not limited to, Users’ name, e-mail address, city and country and professional category. Project Pura also may collect other Personal Data that has been stored on systems or in relation to third party services that are directly connected to or being used in the context of the Project Pura Platform.

6.2. Users acknowledge and accept that, by using the Project Pura Platform, Project Pura may disclose and/or share Their information at Their direction in connection with Their use of the Project Pura Platform, including if Project Pura notifies Users through the Project Pura Platform that certain information they provide will be shared in a particular manner and They provide this information.

6.3. Project Pura only uses the Personal Information of Users collected through the Project Pura Platform to indicate to other users of the Project Pura Platform that They are users thereof, provide, maintain and improve the Project Pura Platform and, as the case may be, to engage or to allow other Users of the Project Pura Platform to engage in a commercial relationship with Them or the company or organization They are representing. Furthermore, Project Pura may use the Personal Information of Users to send Them information about the Project Pura Platform, such as technical notices and administrative messages about the Project Pura Platform, responses to Their comments or questions, news and information Project Pura think will be of interest to Them, information about events, tests, new functionalities of the Platform and other promotional communications. If Users would no longer be interested in receiving or using certain promotional information, They can either adjust Their account settings accordingly or otherwise following the instructions in those communications. Project Pura may still send Users non-promotional communications, such as messages about Their account.

6.4. Please do not process any other information, in particular not sensitive information (such as, but not limited to, medical information, medical diagnosis, clinical data, etc.) in connection with the Project Pura Platform.

6.5. Furthermore, although the Project Pura Platform is being offered by Project Pura, she is also relying on various third party service providers in various countries in view of providing, maintaining and improving the Project Pura Platform and the use that is made thereof. These companies include hosting and telecommunications companies with whom Project Pura may or may not have direct contractual relationships, but who may perform essential technical functions in order for the Project Pura Platform to be rendered. In order to achieve this objective, Users acknowledge and accept that Project Pura may provide Their Private Personal Information to such service providers, who are in any case only entitled to process such information for the operation of the Project Pura Platform.

6.6. Any and all information processed through the Project Pura Platform are processed within the European Union; please note, however, that registered users of Project Pura can access the Project Pura Platform and make use of the Services outside the European Economic Area.

6.7. Project Pura may share the Personal Information in response to a request for information if Project Pura believes disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation, or if Project Pura believes the actions of Users are inconsistent with the spirit or language of the Agreement, or to protect the rights, property and safety of Project Pura or others.

7. Logs

7.1. Users expressly acknowledge and accept that Project Pura may automatically record information created, shared or published by and in accordance with Their use of the Project Pura Platform (“Logs”). By way of such Logs, Project Pura keeps track of personal and non-personal information such as but not limited to Users’ IP addresses, operating systems, other users to or with whom Users have provided or exchanged information, location, mobile carrier(s), device and application IDs, etc.

7.2. Project Pura uses these Logs to provide the Project Pura Platform and to measure, customize, and improve them, as well in order to respond to requests from law enforcement bodies, upon Their request. In this respect, Users expressly agree and accept that, notwithstanding anything to the contrary in this Privacy Policy, Project Pura may preserve or disclose Their information in order to comply with a law, regulation or official request from a government body, such as data protection authorities, law enforcement officials or courts, to protect the integrity of a person, to prevent or react on security or technical issues, fraudulent behavior, or the integrity of the Project Pura Platform.

8. Cookies

8.1. Project Pura may use information about Users to personalize and improve Project Pura and provide content or features that match user profiles or interests and to monitor and analyze trends, usage and activities in connection with the Project Pura Platform. In doing so, Project Pura may use various technologies to collect information, and this may include sending cookies to the computer or device of Users.

Cookies are small data files stored in device memory that help Project Pura to improve the Project Pura Platform and the experience of Users, see which areas and features of the Project Pura Platform are popular and count visits. Project Pura is using both functional cookies and analytics cookies.

8.2. Functional cookies are essential for the use of the website www.projectpura.com, store amongst others user preferences, and are not shared with third parties. Analytics cookies helps Project Pura improve the site by providing Project Pura with information about how Users interact with the websites such as the number of visitors to the website, the pages they visit and the length of time spent on the website. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous.

8.3. Project Pura may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in the Project Pura Platform or e-mails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

8.4. Users may change Their browser settings to delete and block cookies. To find out how visit www.allaboutcookies.org. Please note that if Users choose to block, remove or reject cookies, this could affect the availability and functionality of the Project Pura Platform.

9. Security

9.1. Project Pura takes reasonable measures to help protect information about Users from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, as referred to in the Terms of Use, Users expressly acknowledge and accept that – in general – the transmission of information over the Internet is never completely secure, private or confidential. Therefore, any information that is sent or received from the Project Pura Platform may be intercepted, decrypted, consulted and/or used by third parties, even if technology is being used whereby such information exchanges are encrypted.

10. Project Pura Privacy Department

10.1. If Users have any further questions with respect to how Project Pura is using Personal Data, if Users would like to access, correct, update or delete Their Personal Data, or would like to file a complaint, please contact Project Pura Privacy Department and Data Protection Officer (DPO), Mr. Jesse Gielen.

10.2. Users may obtain access to Their Personal Data by sending a written, dated and signed request, together with a copy of Their identity card to the DPO of Project Pura, Mr. Jesse Gielen.

10.3. For additional information, Users may also consult the public register of automated processing kept by the Belgian Commission for the Protection of Privacy, Porte de Hal/Hallepoort, 5-8, 1060 Brussels.

11. Changes to this Policy

11.1. Project Pura shall be entitled to revise this Privacy Policy from time to time. If Project Pura makes changes, she will notify Users by revising the effective date of this Privacy Policy. In some cases, Project Pura may provide Users with additional notice, such as displaying a message on the Project Pura Platform. Project Pura encourages Users to review the Privacy Policy whenever they access the Project Pura Platform to stay informed about the information practices of Project Pura and the ways she can help protect the privacy of Users.