Privacy policy

Last revision on 16 Sept 2025

1. General

This website (“Website”) is operated by Spacewell International NV and its affiliates (collectively, “Spacewell”, “we” or “us”). Spacewell respects the privacy of visitors to this Website and the importance of protecting the personal information that we collect, receive and use in connection with our Website and the operation of our business (collectively, we refer to this information as “Personal Data”). We are committed to handling your Personal Data in a transparent and responsible manner.

This privacy policy (“Privacy Policy”) explains how and why we process Personal Data in connection with our Website and the operation of our business. Spacewell will only use your Personal Data for the purposes stated in this Privacy Policy and we will not disclose your Personal Data to any natural person, legal person, or entity other than Spacewell (“Third Party” or “Third Parties”), except as described in section 5 of this Privacy Policy.

We will ensure that your Personal Data is handled in accordance with applicable law, including: (i) the EU General Data Protection Regulation (the “GDPR”) and its national implementing legislation; (ii) the Privacy and Electronic Communications Directive 2002/58/EC and its national implementing legislation; and (ii) all similar or related legislation relating to the processing of Personal Data and/or privacy applicable to Spacewell from time to time (together the “Privacy Legislation”).

We may share your Personal Data with our subsidiaries and affiliated companies to fulfill the purposes described in this Privacy Policy. Depending on the service or request, these companies may process your data independently or, in certain cases, jointly with us. Each recipient acts as a separate controller and may provide its own privacy notice explaining how it manages your personal data.

However, when you use a Spacewell product provided by your organization, we may process your Personal Data on behalf of your organization, which acts as the data controller. In those cases, Spacewell acts as a data processor in providing the product and related services in accordance with our agreement with your organization.

If you have questions about how your organisation handles your Personal Data, please consult with them in the first instance as they are the primary data controller responsible for that processing. If you have any questions about Spacewell’s processing of your Personal Data for our legitimate business purposes, please contact us:

• by e-mail at legal@spacewell.com   or
• by mail on the following address: Spacewell International NV, Attn. of the Data Protection Officer, Sneeuwbeslaan 20 bus 3, 2610 Wilrijk, Belgium.

By accessing or using our Website, creating an account, or using any of our products or related services, you acknowledge that you have read and understood this Privacy Policy.

2. Personal data that we collect

We may collect various types of Personal Data and keep it on our servers, including among others:

• First and last name;
• Office or private address;
• Telephone number;
• Email address;
• Company or employer’s name;
• Job title;
• Data on your use of the Website (e.g. browser and IP address); and
• Data of emails (e.g. number of times the email was opened).

If you choose to contact us, request a demo, subscribe to newsletters, or otherwise submit a form, we collect the information you provide through those forms.

In addition, if you apply for a job through our Careers page, we may collect the following additional categories of Personal Data for recruitment purposes:

• Your CV or résumé, cover letter, and employment history
• Contact details such as your name, email address, and phone number
• Links to your professional profiles (e.g. LinkedIn, Indeed)
• Any other Personal Data you voluntarily include in your application materials

We may receive this information directly via the Website or through third-party recruitment platforms, depending on how you submit your application.

3. What are the purposes of data collection and processing?

Your Personal Data may be used for the following purposes (collectively, the “Purpose”):

• Informative purposes related to the use of the Website;
• Commercial purposes related to your possible purchase of our products and/or services;
• To respond to your requests;
• To provide and improve our level of service;
• To improve the content of our communications; and
• For our own administrative and quality assurance purposes.

Furthermore, Spacewell may access, retain and disclose your Personal Data, where necessary and permitted by law including the following cases:

• to comply with applicable laws or regulations;
• if a law enforcement authority or other government agency so requests;
• to enforce or apply our general Terms and Conditions or other contractual rights;
• investigate or prevent actual or suspected fraud, security breaches, or other prohibited or illegal activities; and/or
• to protect the rights, property, safety of Spacewell, our users, or others.

If you submit a job application via our Careers page or through a third-party recruitment platform, we may also process your Personal Data for recruitment purposes, including but not limited to:

Complying with legal obligations related to employment and equal opportunities.Your Personal Data may be used for the following purposes (collectively, the “Purpose”):

Assessing your suitability for a position at Spacewell;

Contacting you regarding your application or future job opportunities;

Managing the recruitment process and making informed hiring decisions;

• Informative purposes related to the use of the Website;
• Commercial purposes related to your possible purchase of our services;
• To respond to your requests;
• To improve our level of service;
• To improve the content of our communications; and
• For our own administrative and quality assurance purposes.

Furthermore, Spacewell International NV has free access to your Personal Data, and may freely save and publish your Personal Data in the following cases:

• to comply with applicable laws or regulations;
• if a law enforcement authority or other government agency so requests;
• to maintain its general Terms and Conditions;
• for investigating suspicious or fraudulent or illegal activities; and/or
• to protect security and/or your rights or Spacewell International NV’ rights.

4. How do we protect your personal data?

Spacewell shall take reasonable administrative, technical and organizational measures, in accordance with the applicable Privacy Legislation, against unauthorized or illegal processing of Personal Data or unintentional loss, destruction or damage, unauthorized or illegal access, disclosure or use of Personal Data.

5. Who do we share your personal data with?

We will not transfer, transmit or otherwise disclose your Personal Data to Third Parties without your prior express consent except as described below and and always in accordance with applicable Privacy Legislation:

• to trusted Third Party-service providers to process your Personal Data on our behalf, based on our instructions and in compliance with applicable Privacy Legislation;
• To Third Parties (including advisors or counterparties) where necessary to establish, exercise, or defend our legal rights, or to enforce contractual rights;
• to regulatory or law enforcement agencies if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings;
• to Third Parties in connection with an audit, merger, acquisition or reorganization, or salel of all or a portion of our business or assets (including in the context of insolvency or bankruptcy).

Such Third Parties will only have access to the Personal Data strictly necessary for the relevant processing purpose, and are contractually bound to use such data solely for those purposes. The Third Parties to whom the Personal Data is transferred are also subject to an obligation of confidentiality and are required to implement appropriate organizational and technical measures to ensure the security of your Personal Data. We do not allow these Third Parties to use your Personal Data for their own marketing activities.

In the event that the Third Parties listed above are located outside the European Economic Area, the transfer of Personal Data to these recipients will only take place if:

• the European Commission has issued an adequacy decision for the country concerned, guaranteeing that an adequate level of protection of Personal Data is offered in that country;
• you have given explicit consent; or

appropriate safeguards have been implemented, such as the European Commission’s Standard Contractual Clauses or other legally recognized transfer mechanisms.

6. What Is Our Legal Basis for Processing Your Personal Data?

We process your Personal Data only when we have a valid legal basis under the GDPR. Depending on the context, we rely on one or more of the following legal grounds:

1. Performance of a Contract (Art. 6(1)(b) GDPR)

We process your Personal Data when it is necessary to take steps at your request before entering into a contract or to perform a contract with you. This applies when you:

• Request a quote or demo;
  • Sign up for and/or provide our services;
  • Communicate with us in relation to an ongoing business relationship.

1. Legitimate Interests (Art. 6 (1)(f) GDPR)

We may process your Personal Data where it is necessary for our legitimate business interests and does not override your rights and freedoms. This includes:

• Operating, maintaining, and improving our Website and services;
  • Managing and optimizing customer relationships;
  • Tracking website usage and user engagement for analytics purposes;
  • Preventing fraud or misuse of our systems;
  • Sending B2B marketing communications (subject to applicable laws);
  • Assessing job applications and managing recruitment;
  • Undergoing an audit, due diligence or other compliance review.

You can object to processing based on legitimate interest at any time (see section 6 of this Privacy Policy).

1. Legal Obligations (Art. 6(1)(c) GDPR)

We may process your Personal Data where necessary to comply with legal obligations, including:

• Responding to lawful requests from public authorities;
• Complying with tax, employment, or regulatory requirements;
• Retaining certain data for audit or legal compliance purposes.

1. Consent (Art. 6 (1)(a) GDPR)

We will request your consent before:

• Sending you newsletters or direct marketing communications where required by law;
• Using certain non-essential cookies or similar technologies;
• Collecting or processing data on our Careers page in jurisdictions where this is required.

You may withdraw your consent at any time by following the instructions in our communications or contacting us directly.

7. What are my rights as a data subject?

We want to guarantee a safe and lawful processing of Personal Data, and we assure you that your Personal Data will be processed in a straightforward and lawful way. This implies that the Personal Data will only be processed for the aforementioned, explicitly stated and legal Purpose. Spacewell furthermore assures that the Personal Data will always be processed in an adequate, relevant and non-excessive manner.

My right to withdraw my consent

When we process your Personal Data on the basis of your consent, you have the right to revoke your consent to such processing at any time. You will not suffer any detrimental consequences if you do so. This consent withdrawal will not affect the lawfulness of the processing that occurred prior to the revocation of your consent.

My right to object to the processing of my Personal Data

When we process your Personal Data on the basis of our legitimate interests, you have the right to object to such processing activities at any time. If you object to a processing activity, we will no longer process your Personal Data for the purposes for which you do not want us anymore to process your data, unless we have compelling legitimate grounds for such processing or we need it for the establishment, exercise or defense of legal claims.

My right for information

If you have questions or suggestions with regard to the processing of your Personal Data, provided you are able to prove your identity, you have the right to request information concerning the processing. We will then provide you with access to your Personal Data that we process as well as the source of these Personal Data.

My right of rectification

You have the right to have your Personal Data rectified, erased or amended, free of charge, and to correct inaccuracies, in the event these Personal Data is incomplete or incorrect, or is being processed in an unlawful manner.

My right of erasure

You have the right to request the deletion of your Personal Data as collected by us in the following cases:

• your Personal Data is no longer required for the Purposes set forth in this Privacy Policy;
• you revoke your previous consent for the processing of your Personal Data (where your consent was used as legal basis for our processing) and there is no other legal basis on which we can rely for the (further) processing of your Personal Data;
• you object to the processing (or further processing) of your Personal Data and there are no compelling legal grounds for the processing of your Personal Data by us;
• your Personal Data has been processed unlawfully;
• your Personal Data must be deleted in order to comply with a legal obligation incumbent upon us;
• your Personal Data was collected when you were a minor.

In the event of a deletion request, you should be aware that we may need to retain certain Personal Data in order to comply with our legal obligations or for the establishment, exercise or defense of legal claims.

My right of transferability of Personal Data

You have the right to receive a copy of the Personal Data that you have provided to us in a structured, common and machine-readable format (via the email address that you have provided us with) so that you can pass it on to another data controller or so that we can pass it on to another data controller at your request and if technically possible. Requesting a copy is free of charge. If you request additional copies of your Personal Data, we may charge a reasonable fee to cover administrative costs.

My right to restrict the processing

You have the right to request that we restrict the processing of your Personal Data to processing made: (i) for storage purposes, (ii) with your consent or (iii) or for the establishment, exercise or defense of legal claims in the following cases:

• you contest the accuracy of such Personal Data (in this context, the use of your Personal Data shall be restricted during a certain period of time in order for us to verify the accuracy of your Personal Data);
• the processing of your Personal Data is unlawful and instead of its deletion, you request us to limit the processing of your Personal Data and its use;
• we no longer need your Personal Data for the processing Purposes as described above, but you need this Personal Data for the initiation, exercise or substantiation of a legal claim;
• when after exercising your right to object to the processing of your Personal Data and as long as no decision has been made on the exercise of such right, you request us to limit the use of your Personal Data.

Exercising my rights

If you have any questions about this Privacy Policy or wish to exercise your rights under the Privacy Legislation, you may contact us at:

Spacewell International NV,

Attn: Data Protection Officer
Sneeuwbeslaan 20 bus 3,
2610 Antwerp, Belgium.
Email: legal@spacewell.com

If you are unsure which entity is responsible for processing your Personal Data, feel free to contact us at the general Spacewell International NV email address above, and we will direct your request to the appropriate entity.

My right to file a complaint with the data protection authority

If you have a complaint on the processing of your personal data or on the exercise of your rights, please send an email to legal@spacewell.com. We undertake to respond to any request to exercise the aforementioned rights within thirty (30) calendar days.

You have also the right to lodge a complaint with a data protection supervisory authority if you believe that your Personal Data is not being processed in accordance with the Privacy Legislation. Depending on the Spacewell entity responsible for processing your Personal Data, the competent supervisory authority may be one of the following:

If the relevant data controller is Spacewell International NV (Belgium):

Data Protection Authority (GBA)
Rue de la Presse 35, 1000 Brussels, Belgium
Tel: +32 (0)2 274 48 00 / +32 (0)2 274 48 35
Email: contact@apd-gba.be
Website: https://www.dataprotectionauthority.be

If the relevant data controller is Spacewell Spain S.L. (Spain):

Agencia Española de Protección de Datos (AEPD)
C/ Jorge Juan, 6, 28001 Madrid, Spain
Tel: +34 91 266 35 17 / +34 901 100 099
Email: internacional@aepd.es
Website: https://www.aepd.es

If the relevant data controller is Spacewell Netherlands B.V. or MCS NV (Netherlands):

Autoriteit Persoonsgegevens
Bezuidenhoutseweg 30, 2594 AV The Hague, Netherlands
Tel: +31 (0)88 1805 250
Website: https://autoriteitpersoonsgegevens.nl

If the relevant data controller is myMCS AB (Sweden):

Integritetsskyddsmyndigheten (IMY)
Drottninggatan 29, 5th floor, 104 20 Stockholm, Sweden
Tel: +46 (0)8 657 61 00
Email: imy@imy.se
Website: https://www.imy.se

8. Storage and removal of data

We will keep your Personal Data as long as reasonably required to provide you with access to the Website and our services, and for the Purpose as described in this Privacy Policy. Afterwards, your Personal Data will be erased.

9. Updates or changes to our privacy policy

We may modify or amend this Privacy Policy from time to time. To let you know when we make changes to this Privacy Policy, we will amend the revision date at the top of this page and display a specific note on our Website. The new modified or amended privacy policy will apply from that revision date. Therefore, we encourage you to periodically review this statement policy to be informed about how we are processing and protecting Personal Data.