Privacy policy

Last updated: April 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).

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). 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). Retention: reports and related answers 2 years after publication, then anonymised or deleted.

11. Anonymisation of feedback

Answers from feedback givers are processed completely anonymously in the report. They are only aggregated from five respondents onwards and labelled via a random coding (e.g. Respondent A, B, C). Neither the participant, their employer, nor the Human Matters coach can see who answered what.

We use a cryptographically secure random assignment (Fisher-Yates with crypto.randomInt) to convert respondents into anonymous labels. This assignment:
– is random and bears no relation to the order in which your 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 consistent throughout.

It is therefore not possible to trace from a report which colleague gave which answer. The uniformity of this assignment is monitored by automated tests.

12. Right to be forgotten

You can request via contact@humanmatters.cc to have all your data deleted from our systems. We process the request within 30 days via an audited delete procedure. The audit-log of the deletion is kept without personal data (only the fact that a deletion took place, for compliance reasons).

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