Privacy policy
Last updated: September 2026
1. Who are we?
Human Matters BV is based at Begoniastraat 30, 2627 Schelle. VAT: BE0476 294 942. For questions, reach us at contact@humanmatters.cc.
2. What data do we collect?
We collect: contact details (name, email, phone, organisation), messages you send through the contact form or email, and anonymised usage data via Plausible Analytics (cookieless) and Mautic (only after explicit consent). If you complete a self-scan on our site, we store the answers anonymously, without linking them to your email address. If you request the report by email, we use your address for that purpose only; subscribing to the newsletter is a separate choice that you tick and confirm separately.
3. What do we use it for?
To answer your questions, keep you informed about trainings and content you asked about, deliver our services, issue invoices and improve the website.
4. Legal basis
We process data based on your consent (newsletter, marketing analytics), performance of a contract (training, book, coaching) or a legal obligation (accounting).
5. Who do we share data with?
Only with processors. In the EU: Brevo (transactional email), Mautic on our own EU server (marketing automation), Mollie (payments) and Cal.com on our own EU server (bookings). To write 360° reports, our coach also uses Anthropic, outside the EU (see section 10). We never sell or rent your data.
6. Retention
Contact form data: maximum 3 years after last contact. Customer data: 7 years after last invoice (legal retention). Newsletter subscription: until you unsubscribe via the link in every email.
7. Your rights
You have the right to access, rectification, erasure, restriction, portability and withdrawal of consent. Send requests to contact@humanmatters.cc. You can also file a complaint with the Belgian Data Protection Authority (dataprotectionauthority.be).
8. Security
All our servers are in the EU. Access to personal data is limited to staff who need it. Connections use HTTPS.
9. Changes
We may update this policy. The current version lives on this page with the last-updated date at the top.
10. 360° feedback programme
For our 360° feedback tool we process: first name, last name, email and language preference of the participant; the same for the feedback givers the participant invites; the answers to the statements (1–5) and open questions; and (if applicable) the report written by the coach. Sub-processors for this tool: Mollie (payments), Brevo (transactional email), Mautic on our own EU server (mail automation), Cal.com on our own EU server (coaching appointments). To write a first draft of the report, the coach also uses Claude by Anthropic, through the Human Matters account and under Anthropic's business terms, with the setting that lets conversations be used for training switched off. The coach only passes on pseudonymised data: without the name of the participant or the organisation, and with the feedback givers' answers already under a letter. The coach reads the text and rewrites it where needed before the report is published. Anthropic is based in the United States; this transfer outside the EU relies on the European Commission's standard contractual clauses. Retention: reports and related answers 2 years after publication, then deleted. The same goes for the self-assessment and for the feedback givers' names and email addresses. Programmes that close without a report are deleted in the same way 2 years after they close. What remains is the programme itself without its content (organisation, participant, dates, status), for invoicing. In our internal log of actions (the audit log), we erase email addresses and names after 2 years. We also delete programmes where nothing has happened for 2 years and accounts that have not been used for 2 years. Invoices and orders stay, because the law requires us to keep them for seven years.
11. Feedback without names
In the report, answers from feedback givers appear without names. Each feedback giver gets a letter per programme (e.g. Respondent A, B, C). Under that letter the participant sees, for each statement, that person's score and comment, and their open answers, word for word. A report is only made from five completed questionnaires onwards.
Who sees what:
– the participant sees the answers under a letter, never with a name. During the feedback period they see by first name whether someone has already answered, not what;
– the Human Matters coach sees the same letters, never names next to the answers. The coach also sees who filled in the questionnaire, not who answered what;
– the employer or organisation that bought the programme sees no answers, only the status of the programme;
– our database does record who answered what, because otherwise we could not send reminders. We show that link to no one.
The letters are assigned in a cryptographically secure random order (Fisher-Yates with crypto.randomInt). This assignment:
– is random and bears no relation to the order in which colleagues were invited;
– bears no relation to the order in which answers came in;
– bears no relation to names, email addresses or other identifying data;
– is generated once per programme and stays the same throughout.
Because a letter stays the same across the whole report, the participant sees the pattern in each person's answers. That is a deliberate choice: it helps to understand the feedback. It also means that someone who knows a feedback giver's words or writing style well may sometimes recognise that person. We therefore advise feedback givers to write about what they saw happen more than once rather than about a single moment only they and the participant know. The uniformity of this assignment is monitored by automated tests.
12. Right to be forgotten
You can ask us via contact@humanmatters.cc to erase your data. We do so within 30 days. We then erase your account, your login links and your login codes, your 360° programme with the answers, the self-assessment and the report, the emails we kept for you, your newsletter subscription and your contact in our mailing list, your appointments in our calendar, and your name and email address in our internal log (the audit log). If you gave feedback in someone else's 360° programme, we erase your name and email address and your link stops working. The answers you already sent stay in that report under their letter, so the report stays accurate for the others who gave feedback, but no one can link them to you any more. What remains: invoices and orders, which the law requires us to keep for seven years, and of a 360° programme only the fact that it existed, without your name or answers, for the accounts of the organisation that paid for it. Of the erasure itself, the audit log only notes that it happened, without personal data. In our encrypted backups, data is kept for up to six months; after that it disappears by itself.