Privacy Policy

DConnect

Version 1.0, effective as of 5 September 2026

1. Who are we?

This privacy policy applies to the processing of personal data carried out by DConnect, a private limited liability company (SRL) incorporated under Belgian law, with its registered office at Rue Abel Roger 24, 7070 Le Rœulx, Belgium, registered with the Crossroads Bank for Enterprises under number 1016.266.624 (hereinafter “we” or “us”).

We operate a platform through which the employees of companies that subscribe to our offer may, if they so wish, complete a questionnaire and receive an individual profile of their digital well-being. Their employer, for its part, only receives an aggregated diagnostic of its organisation.

2. What does this policy cover?

We value your privacy and protect your personal data in accordance with applicable law, in particular Regulation (EU) 2016/679 (the “GDPR”) and the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.

This policy explains what data we collect, for what purposes and on what legal basis we process it, how and for how long we keep it, with whom we share it, and what your rights are.

It is addressed to three categories of people whose situations differ: employees who take part in a diagnostic, contact persons within client companies, and visitors to our website. Where a rule concerns only one of these categories, we state this expressly.

We may amend this policy, for example if the law or our activities change. The most recent version is always available at https://dconnect.app/privacy-policy-platform. In the event of a material change, and provided we have your email address, we will actively inform you.

3. Quel est notre rôle dans le traitement de vos données ?

Our role differs depending on the operation concerned.

We act as controller, meaning that we ourselves determine the purposes and means of the processing, for collecting your answers to the questionnaire, calculating your profile, producing the aggregated diagnostic and delivering your individual profile. Your employer gives us no instructions regarding these operations and has no access to your answers.

We act as processor on behalf of your employer, meaning on its behalf and on its instructions, solely for the registration operations: receiving the list of invited employees and sending invitations and reminders. For these operations, your employer is in principle the controller and you may also contact it directly.

Your employer is also responsible for the use it makes, within its organisation, of the aggregated diagnostic we provide to it.

Because your employer is the one inviting you to take part, it has access, as part of these registration operations, to a tracking area showing the progress of the questionnaire for each invited employee. This area contains neither your answers, nor your scores, nor your profile. Section 8 explains what your employer sees and what it does not see.

4. De qui traitons-nous les données ?

This policy concerns anyone whose data we may process in the course of our activities, in particular:

employees of client companies who take part in a diagnostic (hereinafter “Participants”)
directors, representatives, employees and other contact persons of our current and former clients, business partners, advisers and service providers
visitors to our website.

5. How do we collect your data?

Directly from you, when you create your account and complete the questionnaire
Directly from you, when you contact us, send us your business contact details or fill in a form on our website
From your employer, which provides us with the business contact details of the employees it wishes to invite. This takes place within the framework described in section 3
Through cookies placed on our website. Please refer to our cookie policy https://dconnect.app/privacy-policy
Automatically, when you use the platform: connection data, as well as audience measurements collected in pseudonymised form, which never include your answers.

6. What data do we process and for what purposes?

The table below describes our processing activities. The legal basis indicated is the one under the GDPR.

7. Data concerning health and consent

The questionnaire contains a range of questions grouped into seven dimensions: focus & efficiency, cognitive overload, hyperconnectivity, work/life boundary, social interactions, stress & digital exhaustion, sleep & digital recovery. Some of these questions, in particular those relating to sleep, stress and cognitive overload, as well as the resulting profile, may constitute data concerning health, which the GDPR classifies among the special categories of data and protects more strictly.

We only process this data on the basis of your explicit consent, obtained before you start the questionnaire, through a step that is separate from accepting our terms of use.

Your participation is voluntary. You are under no obligation to complete the questionnaire. Declining to take part has no consequences on our side. Please note, however, that your employer, which invites you to take part, knows whether or not you have completed the questionnaire (see section 8).

You may withdraw your consent at any time, without giving any reason, by completing the dedicated form available at https://dconnect.app/withdraw-consent, on which you enter your surname, first name and email address. Withdrawing consent is as easy as giving it. It ends the processing for the future and results in the erasure of your answers and your profile within 72 hours, without affecting the lawfulness of processing carried out before the withdrawal. Data already included in an anonymous aggregated diagnostic cannot, however, be removed from it, since it can no longer be linked to an individual.

Access to this data within our organisation is limited to those whose duties require it. These persons are bound by a duty of confidentiality and a list of them is kept available to the Belgian Data Protection Authority.

8. What your employer receives and what it does not receive

This point is essential and we are contractually committed to it towards your employer.

Your employer never receives your answers to the questionnaire, your individual profile, your scores or the recommendations report intended for you.

However, because your employer is the one inviting you to take part, it has access to a tracking area showing, for each invited employee, their email address, their role and the progress of the questionnaire: not started, in progress or completed. Your employer therefore knows whether you have taken part, but knows nothing about the content of your answers or your result.

It only receives an aggregated diagnostic of its organisation. No result is produced for a group with fewer than 15 respondents or with a participation rate below 60%. The purpose of this threshold is to prevent any result from being linked to an identifiable individual.

The aggregated diagnostic is provided to the person designated by your employer to oversee the project, normally a senior executive or the head of human resources. Team managers do not have access to it.

9. Profiling and automated decision-making

Establishing your profile constitutes profiling within the meaning of the GDPR: your answers are processed automatically in order to evaluate certain personal aspects relating to you.

This processing is based on a fixed scoring scale: your answers are weighted according to predetermined rules, without the use of any machine learning system. We can provide you with the principles of this calculation on request.

This profile is intended for you. It is not used to take any decision concerning you that produces legal effects or similarly significantly affects you, and it is not disclosed to your employer or to any third party. It is transmitted to our email service provider solely for the purposes described in section 10. It is not a medical diagnosis and does not replace the advice of a healthcare professional.

10. Learning pathway and communications

If your employer has subscribed to the follow-up programme, we send you, over twelve months, content designed to help you improve your digital well-being.

This content is selected according to the profile assigned to you, and not according to your individual answers. None of your results are disclosed in this context.

For these mailings, we use Brevo, an email service provider acting as processor, whose servers are located in the European Union. We share with it your name, your email address and the profile assigned to you.

You may unsubscribe at any time, using the link at the bottom of each message or by writing to us at privacy@dconnect.app. Unsubscribing ends these mailings without affecting access to your profile.

11. Statistics and improvement of our services

We wish to produce statistics on digital well-being, in particular to allow our clients to benchmark themselves against their business sector, and to improve our methodology and services.

We only carry out this work on data that has been anonymised beforehand, meaning data from which we have irreversibly removed any element that could identify or re-identify you, directly or indirectly.

We do not use your answers and your profile in identifiable form for statistical, development or commercial purposes.

12. How long do we keep your data?

We do not keep your personal data for longer than is necessary for the purposes for which it is processed, unless the law requires a longer period or its retention is necessary to defend our interests in legal proceedings.

13. How do we protect your data?

We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, and to protect your data against destruction, loss, alteration, unauthorised disclosure or unauthorised access.

These measures include encryption in transit (HTTPS and TLS), encryption at rest provided by our hosting providers, password hashing, strict separation of access rights between the employee area and the employer area, segregation of data by client company at database level, and daily backups stored in the European Union.

We strive to keep data accurate and up to date. Please let us know of any change to your data.

14. Who do we share your data with?

We may disclose your data to the following categories of recipients:

our technical service providers acting as processors, with whom we enter into a contract in accordance with Article 28 of the GDPR: our development, maintenance and support provider, our hosting provider, our database provider, our email service provider, our audience measurement tool (which only receives a pseudonymised identifier and never your answers), our internal reporting and dashboard tool (business intelligence), as well as Brevo for the learning pathways
our advisers, auditors and legal representatives, in connection with the services they provide to us and subject to confidentiality
public, administrative or judicial authorities, where required by law or where necessary to establish, exercise or defend our rights
a potential acquirer and its advisers, in the context of a transaction involving all or part of our business, subject to confidentiality
any other person, with your prior consent.

Your employer is not among the recipients of your answers, your scores or your profile. Section 8 sets out the information available to it.

15. Is your data transferred outside the European Economic Area?

No. Your data is hosted and processed within the European Economic Area.

Some of the providers used by our own service providers belong to groups established outside the European Economic Area, while hosting your data within it. Should occasional access from a third country take place for technical support purposes, it would be governed by the standard contractual clauses adopted by the European Commission.

Should we in future use a provider established outside this area, we would only carry out such a transfer to a country benefiting from an adequacy decision of the European Commission or on the basis of appropriate safeguards, in particular the standard contractual clauses adopted by the Commission, supplemented where necessary by additional measures. We would then update this policy.

16. What are your rights and how can you exercise them?

Subject to the conditions and limitations set out in Articles 12 to 22 of the GDPR, you have the following rights:

You can exercise these rights by writing to us using the contact details in section 18. Exercising these rights is in principle free of charge. We may only charge a reasonable fee for manifestly unfounded or excessive requests. We may ask you to prove your identity where necessary.

We will respond to your request within one month. This period may be extended by two months depending on the complexity and number of requests, in which case we will inform you.

For the registration operations only, for which we act as processor on behalf of your employer (section 3), your requests should be addressed to your employer. If you send them to us, we will forward them to it.

17. Complaints

You have the right to lodge a complaint with the Belgian Data Protection Authority (https://www.dataprotectionauthority.be/citizen), Rue de la Presse 35, 1000 Brussels, contact@apd-gba.be, and to seek a judicial remedy. The list of supervisory authorities in other Member States is available on the website of the European Data Protection Board.

18. Contact us

For any question, request or complaint regarding this policy or the processing of your data, you can write to us at privacy@dconnect.app or at Rue Abel Roger 24, 7070 Le Rœulx (Belgium).

DConnect SRL – BE 1016.266.624

info@dconnect.app

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