Data Processing Policy

During the course of every product development trajectory, our team may need access to the personal data of the end users of the product. The following document outlines the default positioning of Panenco as Processor with regard to data processing. These terms will stand unless other signed agreements are in effect.

(Last updated at 07/09/2021)

Panenco BV, with registered office at 3001 LEUVEN, Kapeldreef 60 and with company number 0650.747.066 will act as Processor and will hereinafter be referred to as 'Processor'.


The Client, acting on behalf of a legal entity with registered office, will act as Controller and will hereinafter be referred to as 'Controller'.

Has been set out

The Controller has entered into a service agreement with The Processor. Unless specific contractual arrangements are in place, the services will be delivered under the default Terms & Conditions of Panenco BV.
During the performance of the Service Agreement, The Processor may process personal data under the General Data Protection Regulation ("GDPR");
The Processing shall apply to the type of personal data and categories of data subjects which are required for the delivery of the services (the "Personal Data"; the "Data Subjects");
The Parties wish to organise the Processing in correspondence with the relevant and applicable legislation, including the GDPR;
In this processor agreement (the "Agreement"), Controller and Processor wish to determine their respective rights and obligations as to the Processing.

Has been agreed upon
1. Subject
2. Term & termination
3. Personal Data and categories of Data Subjects
4. Subject-matter, nature, purpose and term of the Processing
5. Relevant and applicable legislation
6. Other Processors
7. Written authorisation
8. Confidentiality
9. Security of the Processing
10. Compliance with obligations of the Controller as to rights of Data Subjects' requests
11. Compliance with obligations of the Controller as to Personal Data security
12. Compliance with the obligations of the Controller as Data breach
13. Deletion and return of Personal Data
14. Information
15. Processing on behalf of the Processor
16. Liability
17. Confidentiality
18. Miscellaneous

In order to take action on the basis of your feedback or to clarify changes made in our processing activities, this document may be amended from time to time. Therefore, we invite you to consult the latest version of this policy on our website as the single source of truth.

Do you have any further questions?

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