Privacy statement – The workable method

(update 13/10/2025)

FENAVIAN VZW (hereinafter collectively, "we", "us" and "our") understand how important privacy is to you and respect your privacy. 

Please read this privacy statement carefully. We explain in it:

• What data we collect
• How we collect your data
• How we use your data
• To whom we transfer your (personal) data
• How long we keep your data
• How we secure your data
• How to exercise your rights as a data subject
• Changes to this privacy statement
• Cookie policy

1. What data we collect

The categories of personal data we collect may include:

• Identification data and contact information: surname and first name, user name, company address, telephone and/or mobile phone number, e-mail address, company number, etc.
• Data related to the provision of our products and services and the prospection thereof: offers, invoices, payment details, products and services delivered, contracts, etc.
• Data related to jobs and employment: job title, etc.
• Data concerning the use of our website: browser type, language preference, IP address, etc.
• Data related to complaints, requests and their handling.

2. How we collect your data

We collect personal data in various ways, in particular personal data we receive:

• from the data subject himself/herself
• from the data subject's employer, for example when our customer or supplier is a company and the data subject is designated by this company as a contact person, when we conduct a due diligence, or when we need to process personal data as part of our services to the data subject's employer
• from our customers, about their customers, suppliers and other data subjects whose personal data they collect
• from other parties, e.g. government agencies or the data subject's advisers and other consultants, or when our customer provides information about their family members e.g. as part of our tax or legal services
• through the data subject's use of our website, social media and other tools
• publicly available information.

3. How we use your data

The personal data we process always depends on the specific circumstances, e.g. the nature of the service or product we are required to provide, the legal obligations we are subject to, the legitimate interests we have to do so or the specific consent you have given us to do so.

We process your personal and organization’s data in connection with the scenarios below based on the performance of a contract or/and the pursuit of a legitimate interest:

• Supply of products or services to our (potential) customers
• Processing in the context of our own administrative, accounting and corporate law obligations

We process the following data on the basis of your consent:

• Cookie: we use essential cookie data when you navigate the website, and with your consent we use non-essential cookie data for marketing and analytics purposes. You can find more information about our use of cookies in our cookie policy below.

You have the right to withdraw your consent at any time, without prejudice to the lawfulness of processing based on consent before your withdrawal. See section 7 for more information: How to exercise your rights as a data subject.

4. To whom do we disclose your (personal) data?

If there is no European Commission adequacy decision for the destination country, we will use appropriate safeguards, as described in Article 46 of the GDPR, when transferring personal data, and such transfers and technical and organisational security measures will be documented in accordance with Article 30 of the GDPR. For example, we use standard contractual clauses to protect the transfer of personal data to countries outside the European Economic Area (EEA), thus insuring that an equivalent level of data protection applies to your personal data even if EU data protection law is not directly applicable.

5. How long we keep your data

We will retain your personal data for no longer than necessary for the above purposes, unless an extension of the retention period is required or permitted by law. The retention period may vary by application case, product and service. We determine the retention period by considering the following points:

• the time required to retain personal data for business purposes, including the provision of products and services
• maintaining related transaction and business records
• monitoring and improving the performance and quality of products and services
• ensuring the security of systems, products and services
• handling possible queries or complaints from customers or other stakeholders
• the requirements of laws, contracts and other data retention guidelines
• industry standards for retention periods
• etc.

5.1 Anonymisation and deletion of personal data

Anonymisation Process. FENAVIAN will subject personal data and organization specific data collected through the Platform to an anonymisation process whereby all direct and indirect identifiers are permanently and irrevocably removed or altered. This process entails that (i) individual organizations or users cannot be identified from the resulting reports and (ii) personal data are permanently removed or altered in such a way that individuals can no longer be identified, either directly or indirectly, even when combined with other available information. Exception is made for Identification data and contact information of organizations and users data (including administrator user data) of organizations, enabling FENAVIAN to interact with such persons and/or organizations in their capacity of client or client contact person.

Deletion After Anonymisation. Once personal data and organization specific data have been successfully anonymised, the original data will be immediately and permanently deleted from all FENAVIAN systems. No copies or backups of the original data will be retained. Exception is made for Identification data and contact information of organizations and users data (including administrator user data) of organizations, enabling FENAVIAN to interact with such persons and/or organizations in their capacity of client or client contact person.

Purpose of Data Processing. FENAVIAN has an exclusive interest in the anonymised data for statistical analysis, sector research, and improving service delivery. The original data is not necessary for these purposes.

No Recovery Possible. After the anonymisation process and deletion of the original data, it is technically impossible to link the anonymised data back to specific individuals or organizations.

Retention Period. The anonymised data, which no longer qualifies as personal data under the GDPR, may be retained and used indefinitely for the aforementioned purposes.

Transparency. Data subjects are informed about this anonymisation process and the subsequent deletion of their personal data through this privacy policy.

6. How we secure your data

We do everything we can to protect your data in the best possible way. We have a framework of policies, procedures and trainings in place to guarantee professional confidentiality, data protection, confidentiality and security. We use various security technologies and measures to ensure your privacy. In addition, we repeatedly review and evaluate these technologies and measures to keep your data safe.

7. How to exercise your rights as a data subject

Depending on the processing and the legal basis, as a data subject you have a number of possibilities to keep control over your personal data:

• right to access your data
• right to amend your data
• right to object to the processing of your personal data
• right to restrict data processing
• right to have your data erased
• right to withdraw your previously given consent
• right to transfer your data
• right to lodge complaints with the competent data protection authority.

We should point out to you that these rights are not always absolute, that in certain circumstances we are entitled or even required by law to further process your personal data and that we may therefore not always be able to comply (fully) with your request. In such cases, we will inform you accordingly.

You may exercise these rights free of charge, except in cases of abuse and in which case we are entitled to charge an administration fee to comply with your request.

If in our relationship with our customer, from whom we received your data as a data subject, we act only as a processor, we will inform you accordingly and you should address your request to exercise your rights to our customer.

For all questions relating to the exercise of your rights, please contact: support@workable-method.eu

8. Changes to this privacy statement

In connection with the further development of our website, products and services, as well as changes in applicable legislation, we may update this privacy statement. We therefore recommend that you read this privacy statement again from time to time. You can find the most recent version of this privacy statement on our website at any time.

9. Cookie policy

Our website uses cookies and similar technologies. For the readability of this Cookie Policy, we only use the term "cookies" below. All information relating to these cookies can be found in this Cookie Policy.

When you visit our website for the first time or if it has been a while, you have the choice between accepting all cookies or personalising your preferences (see also article 3 below). To make your choice, click the relevant button.

9.1 What are cookies?

Cookies are small data or text files that are stored on your device when you visit websites. They basically contain information linked to the specific website. Cookies are stored on your device and provided with a unique ID and duration. If, for example, you return to a particular website, the cookies are sent to the website again so that the website can recognise you as a returning visitor and remember certain preferences you have previously indicated (such as your language preference).

9.2 Which cookies do we use and why?

We distinguish between cookies that are necessary for the operation of our website and all other cookies that are not necessary.

You cannot refuse cookies that are necessary for the operation of our website because the website would not function without them.

For all other cookies, you can choose whether or not to accept the corresponding cookie category. You do so by clicking the corresponding button in the preferences menu. You can withdraw your consent or change your cookie preferences at any time.

For an overview of the cookies we use, please refer to the preferences menu. We use different cookie categories. All cookies with a similar purpose are assigned to the same cookie category. You can then view the individual cookies by clicking on a particular cookie category and displaying the supplier details. For each individual cookie, you can consult the following:

• Name: this is the name used to identify the cookie in your internet browser.
• Host: this is where the cookie comes from.
• Duration: this is the duration of storage of the cookie.
• Type: this indicates whether the cookie is direct (placed by us) or indirect (placed by a third party).
• Category: this is the category to which the cookie belongs.
• Description: this is a more detailed explanation about the purpose of the cookie.

Name	Host	Duration	Type	Category	Description
_oauth2_proxy	workable-method.eu	Session	Direct	Technical	Used to keep track of the logged-in user's session
PHPSESSID	workable-method.eu	Session	Direct	Technical	Keeps a session for the user in the application
vsme-affinity	workable-method.eu	Session	Direct	Technical	Used to keep track of the server that the user is connected to for load balancing reasons

9.3 How can I manage or delete my cookies?

Changing your cookie preferences in the preferences menu does not, in principle, cause already placed cookies to be deleted. How to delete cookies that have already been placed is explained below.

You can also change your internet browser's cookie settings to block cookies or to alert you when cookies are sent to your device.

The way you can delete cookies or adjust cookie settings depends on the internet browser you are using and sometimes on the version you have installed of it. If you visit our website via different devices (e.g. your computer, smartphone, tablet, etc.), you should ensure that each internet browser on each device is adapted to your cookie preferences.

Below is more information on the most commonly used internet browsers:

Google Chrome	Browser settings
Mozilla Firefox	Browser settings
Microsoft Internet Explorer	Browser settings
Microsoft Edge	Browser settings
Apple Safari (iOS)	Browser settings
Apple Safari (MacOS)	Browser settings

If you disable the cookies we use, this may affect your experience when you visit our website. You may then not be able to use certain functionalities (anymore), or your visit may not be personalised (for example: you have to set your language preference every time).