Privacy Policy

Who is responsible
Voxdale BV, Bijkhoevelaan 32C, 2110 Wijnegem, Belgium, enterprise number 0749.635.695. For any question about privacy, or a request about your data, write to privacy@voxdale.be.

When this applies to you
Voxdale contacts people at product and engineering companies in Belgium and the Netherlands to offer its own product development services. To do so, we process professional data about you that we did not receive from you. This page applies to you if we called or wrote to you without you contacting us first, and also if you are in our database of potential clients and we have not contacted you yet.

What data

• your name, the address of your LinkedIn profile, and your connection degree with the Voxdale employee whose account ran the search

• your job title and its description, the summary on your LinkedIn profile, your career history, your employer, your location, and how long you have been in your role and with your employer

• the assessment by a language model described below, with its short explanation

• your mobile phone number, which we only look up after a Voxdale employee has approved you as a valid prospect that may well be interested in our services

• a short call briefing about your professional role, written by a language model before a call

• the date and outcome of our calls and messages, and our notes on them

• research notes about your company from public sources, which can mention you in your professional role

We also use data about your employer, such as sector, size and what it makes, to decide whether the company fits what we offer.

Where the data comes from

• LinkedIn: searches in LinkedIn Sales Navigator

• A contact data provider: your mobile phone number, looked up with your name, your employer and the address of your LinkedIn profile.

• Public web sources about your company, for the research notes.

Why, and on what legal basis
We use this data to contact you as a potential client about work that falls within your own role, and to keep track of when we were in touch.

Legal basis: our legitimate interest (Article 6(1)(f) GDPR) in offering our services to the companies and people for whom they are relevant. We weighed that interest against yours. We only approach people in their professional role, about an area they are responsible for, and we only use data about your work. A person makes every call and approves every message, and one request is enough for us to stop. You can ask us for that assessment at privacy@voxdale.be.

Assessment by a language model
Before a person reviews your data, a language model assesses whether your role matches the people our services are meant for. This is profiling within the meaning of Article 4(4) GDPR. The model receives your job title and its description, the summary and career history on your LinkedIn profile, and data about your employer. It does not receive your name or the address of your LinkedIn profile. If the model does not let you through, we do not propose you as a contact, unless a Voxdale employee reviews your profile and decides otherwise. If it does let you through, a Voxdale employee decides whether to add you as a contact. The assessment has no legal effect on you and does not affect you in a similarly significant way; there is no automated decision within the meaning of Article 22 GDPR. You can object to it at any time (see "Your right to object").

Preparing a call
Before a Voxdale employee calls you, a language model writes a short briefing for that call. It receives your name, your role and your employer, the research notes about your company, and a summary of our earlier contacts with your company. It does not receive your phone number or the address of your LinkedIn profile.

A person makes every contact
A Voxdale employee decides whether to add you as a contact, and makes every call and sends every message personally. Nothing is called or sent automatically.

Who receives the data
These categories of service providers process data for us, under our instructions:

• providers that collect professional data from LinkedIn and look up contact information, such as a mobile phone number

• providers of AI language models, for the role assessment, company research and call briefings

• cloud infrastructure and database hosting providers

• the IT contractor that operates this system for us

• our email and calendar provider

Some of these providers are outside the European Economic Area, in the United States and Singapore. For those transfers we rely on an adequacy decision of the European Commission (the EU-US Data Privacy Framework) or on Standard Contractual Clauses approved by the European Commission. You can ask for a copy of those safeguards, and for the names of the providers, at privacy@voxdale.be.

We sell no data, and we do not pass it on to other companies for their own purposes.

Your right to object
You can object at any time, free of charge and without giving a reason, to the use of your data for prospecting and to the assessment by the language model. Tell us during a call, or write to privacy@voxdale.be. Within one month at the latest, we:

• take you off our call list and out of every planned contact

• mark your LinkedIn profile, so our system no longer proposes you as a contact, no longer prepares you for a call and no longer looks up your phone number

Today we take these steps by hand. The mark holds the address of your LinkedIn profile and the reason, is used only to make sure we do not approach you again, and is kept with no end date.

How long we keep data
Today we apply these periods by hand.

• If we never contacted you: 9 months after collection. After that we delete your data, or assess again whether you still fit what we offer. When we delete it, we keep only a scrambled, one-way code made from the address of your LinkedIn profile, so that the same search does not add you again. The code cannot be turned back into the address.

• If we contacted you and nothing followed: 18 months after our last contact.

• After an objection: out of all active use within one month at the latest. The mark described under "Your right to object" is kept with no end date.

• Backups of our database are kept for 7 days, so a deletion reaches the backups after 8 days at the latest.

• One exception: our log of contact moments cannot technically be deleted from. What it holds about a contact with you, such as the date, the channel and a short note, stays there, also after the periods above and after an erasure request.

Your rights
You have the right to access your personal data, including where it came from, to have it corrected or erased, to restrict or object to its processing, and to receive it in a portable format. Write to privacy@voxdale.be and we will answer within one month.

You also have the right to lodge a complaint with the Belgian Data Protection Authority, Drukpersstraat 35, 1000 Brussels, www.dataprotectionauthority.be. If you live or work in the Netherlands, you can also turn to the Dutch Autoriteit Persoonsgegevens, www.autoriteitpersoonsgegevens.nl.

Changes to this policy
When the way Voxdale handles personal data changes, we update this page and the date at the top.