1. Who we are
Revident (“we”, “us”) is the data controller responsible for the personal data described in this policy.
- Registered address: Antoon van Dyckstraat 7
- Email: privacy@revident.eu
If you have any question about this policy or about your data, contact us at the email address above.
2. What we collect
We collect personal data only when you choose to give it to us:
- Our waitlist and newsletter. When you join our waitlist, you give us your name and your email address.
- Pilot interest. After joining the waitlist, you can put your company forward for our pilot. You then also give us your company’s name and, if you choose, your role, your company’s accounting system and its next year end, so that we can reply. If you write to us by email instead, we also receive what you write.
- Expressions of interest in working with us. On our careers page you can leave a link to your LinkedIn and/or GitHub profile and, if you choose, the area you are interested in. We may look at the public profile the link points to. We do not ask for a CV or anything else. If you write to us by email instead, we also receive what you write.
With what you enter in one of these forms, we store the page you sent it from and the date and time. For the waitlist we also store the wording you agreed to, next to the button, as proof that you consented, which the law requires us to be able to demonstrate. We do not store your IP address with any of it.
Visiting our website. Like every website, ours is delivered by a web server. Our host, Hostinger, records the technical details of each request in its server logs: your IP address, the page asked for, the date and time, and your browser’s User-Agent header. When you send one of our forms, it goes to our own form service on Microsoft Azure, which handles your IP address only to deliver the request and does not store it.
Spam protection on our forms. Our forms are protected by Cloudflare Turnstile, a service that distinguishes real people from automated bots. When a form opens, Turnstile processes a small set of technical signals from your browser: your IP address, your TLS fingerprint, your User-Agent header, and an identifier for our site. It does this whether or not you go on to submit the form.
Turnstile does not set tracking cookies, build a profile of you, or follow you across websites. Cloudflare states that it cannot identify individuals from these signals.
Website statistics (analytics cookies), only with your consent. If you accept analytics cookies in our cookie banner, we use Google Analytics to understand how our website is used: which pages are visited and for how long, from what kind of device and browser, and from which country or city. Google Analytics 4 does not log or store IP addresses for visitors in the EU. We use it only for these statistics: not to identify you, and not for advertising. If you do not allow it, Google Analytics does not load at all.
Company recognition (marketing cookies), only with your consent. If you accept marketing cookies in our cookie banner, our website loads Apollo.io’s website tracker. It gives your browser a random identifier, kept in your browser’s local storage, and sends Apollo your IP address, the pages you visit on our website, the website that sent you to us and any campaign tags in the link you followed. Apollo uses your IP address to work out which company the visit comes from, and shows us that company, the pages it viewed and when. We have set Apollo to recognise companies only, not the individual people who visit. If you do not allow it, the tracker does not load at all.
We do not collect your address, phone number, payment details, or any other personal information beyond what is described here. We do not buy email lists or add anyone who has not signed up themselves.
3. Why we use it, and on what legal basis
We process personal data for seven purposes, each with its own legal basis.
To send you our newsletter. We use your name and email address for this, and your company if you gave it to us. Our legal basis is your consent (Article 6(1)(a) GDPR). You gave that consent when you signed up, and you can withdraw it at any time. See section 6.
To reply to your pilot request. We use the details you give us to contact you about a pilot. Our legal basis is taking steps at your request before entering into a contract (Article 6(1)(b) GDPR).
To consider you for a role. We use the profile link you give us, the public profile it points to and the area you chose to decide whether to contact you when we are hiring. Our legal basis is taking steps at your request before entering into a contract (Article 6(1)(b) GDPR).
To stop bots and spam on our forms. We use the Turnstile signals described above for this and nothing else. Our legal basis is our legitimate interest (Article 6(1)(f) GDPR) in protecting our forms from automated abuse and in not filling our mailing list with fake addresses. We consider this proportionate: the signals are minimal, they are not used to identify or track you, and without them the forms would be usable by anyone running a script. You can object to this processing, as described in section 6, although we may not be able to offer you the forms if you do.
To deliver our website and keep it secure. We use our host’s server logs, described in section 2, only to run the website, find faults and protect it against abuse. Our legal basis is our legitimate interest (Article 6(1)(f) GDPR) in a website that works and is safe; a website cannot be delivered without them.
To understand how our website is used. We use the Google Analytics statistics described in section 2 for this. Our legal basis is your consent (Article 6(1)(a) GDPR), which you give, or refuse, in our cookie banner. You can withdraw it at any time with the “Cookie settings” link at the bottom of every page.
To see which companies are interested in us. We use the company recognition described in section 2 to learn which companies visit our website and what they look at, so that we can get in touch with a company that seems interested in Revident. Our legal basis is your consent (Article 6(1)(a) GDPR), which you give, or refuse, by accepting or rejecting marketing cookies in our cookie banner, separately from analytics cookies. You can withdraw it at any time with the same “Cookie settings” link.
We do not profile you or make automated decisions that produce legal effects for you. Turnstile does make an automated judgement about whether you appear to be a bot, but the only consequence is whether the form submits; if you are blocked in error, email us and we will sign you up manually. Company recognition is about the company a visit comes from, not about you as a person, and no decision about you is taken on it without one of us involved.
4. Who else sees it
Microsoft (Microsoft Ireland Operations Limited, Dublin, Ireland) runs the cloud platform, Microsoft Azure, on which our own form service receives our forms and stores what you send us: the waitlist, pilot requests and expressions of interest. Microsoft processes this data on our behalf as our processor, under its Data Protection Addendum, which requires it to keep the data secure and use it only on our instructions. We store it in Microsoft’s Belgium Central region, in Belgium; the service’s technical monitoring runs in the West Europe region and also keeps its data in Belgium. Microsoft keeps customer data stored in the EU within the EU (its EU Data Boundary). Where Microsoft or its sub-processors may still access it from outside the EEA, for example to give support, the transfer is covered by the EU–US Data Privacy Framework, for which Microsoft is certified, and by the European Commission’s Standard Contractual Clauses.
Hostinger (Hostinger International Ltd., Larnaca, Cyprus) hosts our website and keeps the server logs described in section 2, as our processor under its data processing agreement.
Cloudflare, Inc. provides the Turnstile bot protection on our forms and receives the technical signals described in section 2. Cloudflare acts in two different capacities here, and we want to be clear about both:
- When Cloudflare uses those signals to protect our form, it acts as our processor, under our instructions and under a data processing agreement.
- Cloudflare separately uses those signals to improve Turnstile’s bot-detection for all of its customers. For that purpose Cloudflare is a data controller in its own right and relies on its own legitimate interests. That processing is governed by Cloudflare’s Turnstile Privacy Addendum (cloudflare.com/turnstile-privacy-policy) and its main privacy policy, not by this one. You can reach Cloudflare’s Data Protection Officer at dpo@cloudflare.com.
Cloudflare is a US company operating a global network, so these signals may be processed outside the EEA. Cloudflare relies on the European Commission’s Standard Contractual Clauses for such transfers.
Google (Google Ireland Limited, Dublin, Ireland) provides Google Analytics, but only if you accept analytics cookies. Google processes the statistics on our behalf as our processor, under Google’s data processing terms. The data may be transferred to Google LLC in the United States, which is certified under the EU–US Data Privacy Framework; that certification is the legal basis for the transfer.
Apollo.io (ZenLeads Inc., doing business as Apollo.io, San Francisco, United States) provides company recognition, but only if you accept marketing cookies. Apollo processes the visit data on our behalf as our processor, under its data processing agreement with us. Because Apollo is based in the United States, the data is transferred there; the transfer is covered by the European Commission’s Standard Contractual Clauses, which are part of that agreement.
Apart from the above, we do not share, sell, rent, or disclose your data to anyone. The only exception is where we are legally required to disclose it, for example in response to a valid order from a court or public authority.
5. How long we keep it
We keep your waitlist details for as long as you remain subscribed.
If you unsubscribe, we delete your address from our active list immediately. We may retain a minimal record (your email address and the fact that you unsubscribed) so that we do not accidentally contact you again. If you would prefer us to erase that record too, just ask.
We keep the details of a pilot request for as long as we are in contact with you about a pilot. If no pilot follows, we delete them within 12 months of our last contact.
We keep an expression of interest for as long as we may be hiring for the roles it concerns, and no longer than 12 months after you sent it. You can ask us to delete it sooner at any time.
Google Analytics keeps the statistics for no longer than 14 months. Its cookies expire after two years, or as soon as you withdraw your consent, when we delete them.
We keep what company recognition tells us in Apollo for no longer than 12 months after the visit. The identifier in your browser stays until you withdraw your consent, when we delete it, or until you clear your browser’s storage.
Our host keeps its server logs only for a limited period, set by its own policies, and we use them for nothing but running and securing the website.
We never receive or store the Turnstile signals ourselves. We only receive a pass/fail result. Cloudflare’s retention of those signals is governed by its own policies.
6. Your rights
Under the GDPR you have the right to:
- Withdraw your consent at any time. Every email we send has an unsubscribe link at the bottom, and one click is enough. For analytics and marketing cookies, use the “Cookie settings” link at the bottom of every page. You can also email us. Withdrawing consent does not affect the lawfulness of what we did before you withdrew it.
- Access the data we hold about you, and receive a copy of it.
- Correct it if it is wrong.
- Erase it (“right to be forgotten”).
- Restrict how we use it, or object to our use of it. The right to object applies in particular to our use of Turnstile, which rests on legitimate interests rather than consent.
- Portability: receive your data in a structured, commonly used, machine-readable format.
To exercise any of these, email us at privacy@revident.eu. We will respond within one month. We will not charge you, and we will not ask you to justify your request.
7. Complaints
If you think we have handled your data improperly, we would like the chance to put it right, so please contact us first. You also have the right to complain directly to the Belgian data protection authority:
Gegevensbeschermingsautoriteit / Autorité de protection des donnéesDrukpersstraat 35, 1000 Brussels
+32 (0)2 274 48 00
contact@apd-gba.be
www.dataprotectionauthority.be
If you live in another EU country, you may complain to your local supervisory authority instead.
8. Security
We keep what you send us in Microsoft Azure, in Belgium. It is encrypted in transit and at rest. Only our founders’ own Microsoft accounts and our form service itself can reach it: there are no shared passwords or access keys, as every access signs in with its own identity. Microsoft Azure is certified to ISO 27001.
No system is perfectly secure, but if a breach ever occurred that posed a risk to you, we would notify the data protection authority within 72 hours and inform you directly where required.
9. Cookies
Necessary cookies, without your consent. Our forms load Cloudflare Turnstile, which reads and writes a small amount of information on your device in order to run its bot check. This is strictly necessary to provide the form you asked for, so we do not ask for your consent to it. This is the exemption in Article 5(3) of the ePrivacy Directive. Turnstile does not use cookies to track you or to build an advertising profile. We also keep two notes in your browser’s local storage: your cookie choice, so that we do not ask again on every page, and that you have seen our opening animation, so that it does not play on every visit. Neither note is sent to us or to anyone else.
Analytics cookies, only with your consent. If you accept analytics cookies in our cookie banner, Google Analytics sets two cookies: _ga, which tells visits from different browsers apart, and _ga_ followed by an identifier for our site, which keeps the state of a visit. Both expire after two years. If you do not allow it, or make no choice, Google Analytics does not load and sets no cookies. You can change your choice at any time with the “Cookie settings” link at the bottom of every page; if you withdraw your consent, we delete these cookies.
Marketing cookies, only with your consent. If you accept marketing cookies, Apollo.io’s tracker keeps a random identifier (apolloAnonId) in your browser’s local storage, so that your visits can be told apart, together with the page visits it has not yet sent and a note of its settings (named after our Apollo account). It uses local storage rather than cookies, but we treat it as a marketing cookie and ask for your consent in the same way. If you do not accept, or make no choice, the tracker does not load and stores nothing. If you withdraw your consent with “Cookie settings”, we delete what it stored.
Apart from the above, our website does not use cookies or any similar tracking technology.
10. Children
Our newsletter is not aimed at children. We do not knowingly collect data from anyone under 13. If you believe a child has signed up, contact us and we will delete the address.
11. Changes to this policy
If we change this policy, we will post the updated version here and change the date at the top. If the change is significant, for example if we start using your email address for something new, we will email you first and ask for your consent.