Privacy policy
Last updated: 16 October 2026
1. Who we are
REALWISE BV is responsible for the processing of your personal data as described in this policy ("controller" within the meaning of the GDPR).
| Name | REALWISE BV |
|---|---|
| Company number | BE0736.906.327 |
| Address | Lange Gasthuisstraat 3/202, 2000 Antwerp |
| Privacy contact | zaven@realwise.be |
| Phone | +32 472 81 30 69 |
This policy applies to candidates who apply, our employees, self-employed advisors and occasional referrers who work with us, contact persons at (potential) clients, and visitors to realwise.be and our social media. For consumers we speak to during campaigns, see article 3.
REALWISE has not appointed a data protection officer (DPO), as this is not legally required for our activities. Privacy questions are handled directly by the managing director.
2. What data we process, why and on what basis
We only process data we need for a specific purpose, and every purpose is based on a legal ground from article 6 GDPR.
| Who | What data | What for | Legal basis |
|---|---|---|---|
| Candidates | First and last name, email, phone, place of residence, Instagram or LinkedIn profile (optional), how you found us, CV or profile if you apply through a job site, notes from the introductory meeting, availability, evaluation of any observation day | Getting in touch, scheduling an introduction and any observation day, selection, assessing whether there is a match | Steps at your request prior to an agreement (art. 6.1.b) |
| Candidates who do not (yet) start | The same data, kept after selection | Contacting you again later for a suitable collaboration | Legitimate interest (art. 6.1.f); you can always ask us to delete your data |
| Self-employed advisors | Name, address, contact details, date of birth, company and VAT number, bank account, agreement and annexes, campaign and area planning, results and commissions, self-billing invoices, equipment on loan (campaign clothing, iPad) | Performance of the agreement, invoicing and payment, planning, training and coaching, quality monitoring per campaign, management of campaign equipment | Agreement (art. 6.1.b), accounting and VAT obligations (art. 6.1.c), legitimate interest in quality control and brand safety (art. 6.1.f) |
| Occasional referrers | Name, address, contact details, date of birth, national register number, bank account, number of opportunities referred and fees received | Performance of the agreement, payment, monitoring of the legal ceilings, preparation of the tax form | Agreement (art. 6.1.b), tax obligations (art. 6.1.c); we only use the national register number for the tax form |
| Employees and students | Identity and contact details, national register number, bank account, employment contract, position, work performed and pay, absences and sick notes (only the period of incapacity for work) | Employment, payroll processing, social security declarations | Agreement (art. 6.1.b), social security and tax obligations (art. 6.1.c); sick notes on the basis of art. 9.2.b GDPR (employment law) |
| Advisors and referrers | Photos, videos, first name and role on our website and social media | Recruitment and communication about REALWISE | Consent (art. 6.1.a), can always be withdrawn |
| Contact persons at clients | Name, position, company, business email address and phone, sector, correspondence, quotes, contracts and invoices | Quotes, running campaigns, reporting, invoicing, relationship management | Agreement (art. 6.1.b), legal accounting obligation (art. 6.1.c), legitimate interest in B2B contact (art. 6.1.f) |
| Website visitors | IP address, browser and device data, pages visited, forms submitted | Operation and security of the site, answering your question | Legitimate interest (art. 6.1.f); we only use strictly necessary cookies, see our cookie policy |
| Followers of our social media | Interactions, messages, public profile data | Answering messages, statistics for our pages | Legitimate interest (art. 6.1.f) |
For data on Facebook and Instagram, we are jointly responsible with Meta for the page statistics. For the rest of the processing by those platforms, their own privacy policy applies.
We do not ask for special categories of data (such as health, religion or origin), except sick notes from employees, of which we only use the period of incapacity for work. We do not work with persons under the age of 18. We do not make decisions about you based solely on automated processing.
Where we rely on legitimate interest, we have weighed that interest against your privacy. You can always object to this (see article 7).
Data we need to conclude an agreement or to comply with the law (such as your company number or bank account as an advisor) must be provided to us; without that data we cannot work together. All other data is provided voluntarily.
Selection of candidates. Candidates come to us through our website form, job sites such as Indeed, our social media or a referral by someone who already works with us. We manage their data in a CRM for candidates. Anyone who wishes can join an observation day in the field; we only use that short evaluation to decide together whether to start. No one starts without a signed agreement.
Criminal record extract. For some campaigns, the client asks that advisors present an extract from their criminal record. In that case we only view the extract. We do not make a copy and only note that it was presented and on what date.
3. Consumers we speak to during campaigns
When our advisors take a sign-up at the door, at an event or in a shop, or when a referrer passes on your interest, we do so on behalf of the brand for which the campaign is running. That brand (the client) is the controller; REALWISE is the processor and acts only on the client's written instructions.
- What data: the data needed for your sign-up with the client, such as name, address, contact details and the chosen offer. The client determines exactly which fields.
- Where it ends up: our advisors and referrers enter your data directly on a device and in the client's system. REALWISE itself does not keep a copy of your sign-up. For the monthly settlement with the client, we do work with an overview of new customers (name, address, place of residence and customer number). We only use it to prepare and check the settlement and to calculate fees for advisors and referrers. How long your data is kept is determined by the client.
- Agreements: our advisors may not note down, photograph or store customer data outside the client's system, and may never forward it via messaging apps.
- Your rights: for access, correction or deletion of a sign-up, it is best to contact the brand you signed up with. If you contact us, we will forward your request without undue delay.
With every client we make written agreements about this processing, as required by article 28 GDPR.
During campaigns, advisors visibly wear the campaign clothing, so you always know on whose behalf you are being approached.
4. How long we keep data
We do not keep data longer than necessary for the purpose or than required by law; after that, we delete or anonymise it.
| Data | Retention period |
|---|---|
| Candidates who do not (yet) start | 2 years after the last contact, or earlier if you ask |
| Agreements, invoices, settlements with clients and other accounting documents | 10 years, as required by accounting law |
| Referrer data for the tax form | 10 years after the year of payment |
| Personnel file and social documents of employees and students | 5 years after the end of employment |
| Photos and videos on website and social media | Until you withdraw your consent; we then remove them within 30 days where we can do so ourselves |
| Contact persons at clients | Duration of the relationship + 3 years |
| Website logs and form messages | 12 months |
If there is a dispute or investigation, we may keep data longer for as long as necessary to defend our rights.
5. Who we share data with
We never sell your data. We only share it with parties who need it for a purpose in this policy.
- Clients: name and email address of advisors working on their campaign, so they can check who represents their brand, and campaign results per advisor or team.
- Service providers working for us (processors): Microsoft 365 for email and files, a CRM for candidates, Odoo and spreadsheets (Excel or Google Sheets) for planning, results and commissions, our website host, our social secretariat Acerta, a payroll agency for the students we exceptionally deploy, and our accountant. What you send through our forms ends up in our CRM and our mailbox. If you apply through a job site such as Indeed, that site's own privacy policy also applies. We have the agreements required by the GDPR with each of our service providers.
- WhatsApp: we only use WhatsApp for planning and practical communication with advisors, never to share customer or prospect data.
- Authorities and advisers: the FPS Finance, the NSSO and other bodies where required by law, and our lawyer or accountant when necessary.
Some service providers (such as Microsoft, Google and Meta, owner of WhatsApp) may process data outside the European Economic Area. In that case we only do so with appropriate safeguards: an adequacy decision of the European Commission (such as the EU-US Data Privacy Framework) or the Commission's standard contractual clauses.
6. Security
We protect data with technical and organisational measures: access only for those who need it, two-step verification on our accounts, encrypted devices, and clear agreements with advisors on handling customer data. If a data breach does occur that poses a risk to you, we report it within 72 hours to the Data Protection Authority and, in the event of a high risk, to you as well.
7. Your rights
You have the right to:
- access your data and obtain a copy;
- have incorrect data corrected;
- have your data erased, unless we are legally required to keep it;
- have the processing restricted;
- receive your data in a common format or have it transferred (portability);
- object to processing based on legitimate interest, and always to direct marketing;
- withdraw consent at any time, without this making the earlier processing unlawful.
Send your request to zaven@realwise.be. We reply within one month and may ask you to confirm your identity.
8. Complaints
If you are not satisfied with how we handle your data, please let us know first. You can also always lodge a complaint with the Data Protection Authority (Gegevensbeschermingsautoriteit), Drukpersstraat 35, 1000 Brussels, www.dataprotectionauthority.be.
9. Changes
We update this policy when our operations or the law change. The date at the top shows the latest version; in the event of important changes, we actively inform those concerned.