Privacy Policy
At Leaders from the Inside Out (LIO), we collect and use only the personal data necessary to make our platform and services work properly. This includes creating and managing accounts, providing personal access to the platform, enabling relevant connections within our community, and ensuring the security and proper functioning of our services. We do not sell, rent or exploit our members’ personal data for unrelated commercial purposes.
As a digital platform, LIO relies on technical service providers to host, support and maintain certain parts of its infrastructure. In the course of providing these services, such providers may process or have access to limited personal data where this is technically necessary for hosting, security, maintenance, communications or other related functions.
ARTICLE 1 – Purpose and scope of the privacy policy
This Privacy Policy is intended to explain, in a clear, transparent and accessible manner, how Leaders from the Inside Out (LIO) collects, uses, stores, protects and, where applicable, shares the personal data necessary for the operation of the services it provides.
It applies to the processing of personal data carried out in particular in connection with the use of the website (the Platform available at the following URL: https://www.leadersfromtheinsideout.com/) and includes personal data processed in connection with the steps taken to join the LIO ecosystem, the creation and management of member accounts, the interactions made possible between members, as well as the use of the digital and collaborative features offered as part of the activities developed by LIO.
This Privacy Policy applies to personal data relating to website visitors, representatives of member or applicant organisations, authorised users of member accounts, persons contacting LIO and, more generally, any person whose personal data is reasonably necessary for the provision, administration or development of the services offered.
LIO undertakes to process personal data in accordance with the principles set out in Regulation (EU) 2016/679 of 27 April 2016 on the protection of personal data (GDPR), the Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data, as well as any other applicable legal and regulatory provisions.
This Privacy Policy should be read in conjunction with the General Terms of Use, the Cookie Policy and any specific terms or additional information applicable to certain services offered by LIO.
ARTICLE 2 – Controller of personal data processing
In connection with the processing of personal data described in this Privacy Policy, Leaders from the Inside Out (LIO) acts as the data controller within the meaning of Regulation (EU) 2016/679 ("GDPR") when it determines the purposes and essential means of the processing necessary for the operation of its website, the management of applications, the administration of member accounts, the organisation of collaborative features, community management, and the security and proper functioning of the Platform.
This responsibility covers, in particular, processing relating to the creation and management of user accounts, the provision of the Member Directory, the management of connection requests between members, the organisation of community programmes, the sending of communications relating to the operation of the services, as well as the technical and security administration of the LIO ecosystem.
LIO may engage technical or organisational service providers acting as data processors in accordance with Article 28 of the GDPR. These providers act only on LIO's instructions and within the limits necessary to perform the services entrusted to them.
The arrangements for contacting LIO regarding any questions relating to the protection of personal data or the exercise of rights granted under the GDPR are set out in Article 13 of this Privacy Policy.
ARTICLE 3 – Our commitments and principles of personal data governance
The protection of personal data is an essential element of the operation and development of the services offered by Leaders from the Inside Out (LIO). The processing activities implemented are designed and carried out in accordance with the principles set out in the GDPR and any other applicable legal and regulatory provisions.
LIO ensures that it processes only personal data that appears necessary and proportionate in view of the purposes pursued. Personal data is collected, used and retained only for the period reasonably necessary to achieve the objectives pursued by the relevant processing activities and in compliance with any applicable legal obligations.
The processing activities implemented within the LIO ecosystem are designed according to a data protection by design approach and, where appropriate, from the configuration stage of the services offered. Technical, organisational and functional developments that may affect the processing of personal data take into account the principles of data minimisation, security, confidentiality and proportionality established by applicable law.
LIO also strives to provide clear and intelligible information regarding the processing activities carried out. When new services, features or digital technologies are integrated into the LIO ecosystem, the information provided to data subjects is adapted to reflect the nature and reasonably foreseeable consequences of the relevant processing activities.
The services offered by LIO are designed to foster relevant professional interactions between participating organisations. Any digital technologies used in this context are intended solely to facilitate access to the services offered, their reasonable personalisation, and the continuous improvement of their operation. They shall not be interpreted as pursuing any purpose incompatible with those described in this Privacy Policy.
Finally, LIO implements appropriate technical, organisational and operational measures designed to ensure the security, confidentiality and responsible governance of personal data processed in connection with the services offered.
ARTICLE 4 – The personal data we process
The personal data processed by Leaders from the Inside Out (LIO) depends on how data subjects interact with its website, digital services and features accessible within the ecosystem.
In connection with the assessment of applications, the creation of member accounts and the administration of the services offered, LIO processes, in particular, identification and contact data relating to representatives of the organisations concerned, such as their first name, last name, professional position, professional email address, professional telephone number where provided, as well as information necessary to identify the organisation they represent.
LIO also processes information relating to member or applicant organisations where such information directly or indirectly identifies a natural person. This information may include, in particular, the organisation's profile, activities, areas of expertise, professional interests, projects or any other information voluntarily provided in connection with the services offered.
Use of the Platform also generates certain data relating to user activity, such as information necessary for managing connections, administering accounts, tracking connection requests, ensuring service security, preventing misuse, and maintaining the proper functioning of the IT systems used.
Information relating to organisations and their representatives is processed to the extent necessary for the creation, management and display of organisational profiles and for the operation of member-only features. The information used for these purposes is primarily provided as part of the application, onboarding and relationship management process with the organisation concerned.
Finally, LIO may process information exchanged in connection with requests addressed to its team, communications relating to the services offered, incident management, compliance with its legal obligations, or the protection of its rights and legitimate interests.
LIO does not actively seek to collect special categories of personal data within the meaning of Article 9 of the GDPR and asks users to provide only information that is strictly necessary for the use of the services offered.
ARTICLE 5 – Purposes of processing and applicable legal bases
The personal data processed by Leaders from the Inside Out (LIO) is used exclusively for specific, explicit and legitimate purposes compatible with the activities of the Platform and its ecosystem.
These processing activities include, in particular, reviewing applications submitted to LIO, creating and administering member accounts, managing organisational profiles, facilitating interactions between members, operating the Member Directory, organising community programmes, responding to requests addressed to LIO, communicating with users, ensuring the security of the services offered, and improving and developing the features of the Platform.
Where processing is necessary for the assessment of an application, the provision of the services offered or the management of the relationship established with a member organisation, it is based on the performance of pre-contractual or contractual measures within the meaning of Article 6(1)(b) of the GDPR.
Certain processing activities are carried out to enable LIO to comply with the legal, regulatory, administrative or judicial obligations to which it is subject. Such processing is based on Article 6(1)(c) of the GDPR.
LIO may also process certain personal data on the basis of its legitimate interest where such processing is necessary for the proper functioning of the Platform, the security of the services offered, the prevention of misuse, the protection of its rights, community management, the improvement of the user experience or the reasonable development of its activities. In this context, LIO ensures that a balance is maintained between its legitimate interests and the fundamental rights and freedoms of data subjects.
Where applicable regulations require the prior consent of data subjects, in particular for certain optional communications or technologies requiring prior consent, the relevant processing activities are carried out only after valid consent has been obtained, which may be withdrawn at any time under the conditions provided by applicable regulations.
Personal data is not used for purposes incompatible with those described in this Privacy Policy. Where a substantial change to the processing activities requires additional information or specific formalities, LIO ensures compliance with the requirements of the GDPR and other applicable provisions.
ARTICLE 6 – Personal data accessible within the LIO ecosystem and interactions between members
One of the objectives of the LIO ecosystem is to foster professional interactions between participating organisations. Certain features therefore require some of the information provided by members to be made accessible to other authorised users in accordance with the settings applicable to the Platform.
The information accessible through the Member Directory or as part of connection features mainly consists of professional information that member organisations and their representatives choose to share in order to present their activities, expertise, interests or opportunities for collaboration.
The visibility of this information varies depending on the nature of the services used, the settings available on the Platform, and the relationships established between members. Some information remains accessible exclusively to LIO, while other information may be viewed by members with the necessary permissions or by persons with whom a connection has been voluntarily established.
The professional information displayed in the Member Directory corresponds to the information that the organisation chooses to include in its profile. Administrative, verification, billing or internal management information is not made accessible to other members. The contact details of the primary representative are shared only through the connection mechanisms provided by the Platform or with the consent of the person concerned.
Members who access personal data through the services offered by LIO remain responsible for complying with the legal obligations applicable to them when using this information for their own professional purposes.
LIO implements measures designed to ensure consistent management of the visibility settings offered on the Platform but cannot control the subsequent use made of information voluntarily shared with other members as part of freely established professional relationships.
ARTICLE 7 – Digital technologies used in the services offered and their evolution
The services offered by Leaders from the Inside Out (LIO) rely on digital technologies designed to ensure the operation of the Platform, the management of member accounts, the security of the services offered and the continuous improvement of the user experience.
The digital technologies used by LIO are primarily intended to ensure the operation of the Platform, the management of member accounts, the organisation of profiles and connections between organisations, and the security of the services offered.
LIO favours a human-centred design approach aimed at preserving user autonomy. The features offered rely primarily on the criteria, searches and choices expressed by members themselves rather than on automated recommendation mechanisms designed to influence their decisions or interactions.
LIO ensures that the technologies used remain proportionate to the purposes pursued and are deployed in accordance with the principles of personal data protection, security, minimisation and transparency.
The services offered may evolve to take into account members' needs, technological developments, recommendations from competent authorities and applicable legal requirements. Where such developments involve new processing of personal data or substantially modify existing processing activities, data subjects are informed in accordance with the requirements of the GDPR.
ARTICLE 8 – Recipients of personal data
The personal data processed by Leaders from the Inside Out (LIO) is accessible only to persons, services or organisations for whom such access appears necessary in view of the purposes pursued.
In this context, certain data may be accessible to authorised persons acting under LIO's authority where such access is necessary for the administration of the services offered, the management of member accounts, user support, Platform security or compliance with applicable legal obligations.
LIO may engage specialised service providers operating, in particular, in the areas of Platform hosting, cloud services, IT maintenance, security, management of cookie-related consent, technical communications and administration of digital services.
Certain information may also be made accessible to other members of the ecosystem where such visibility results from the normal operation of the services offered or from choices made by the data subjects when using the Platform.
Finally, certain personal data may be disclosed to administrative, judicial or regulatory authorities, or to any other person legally authorised to receive it, where such disclosure is required by law, results from a legally founded request, or appears necessary to protect the rights of LIO, its members or third parties.
LIO ensures that all access granted to personal data remains limited to what is strictly necessary in view of the purposes pursued.
ARTICLE 9 – Retention periods for personal data
Leaders from the Inside Out (LIO) retains personal data for no longer than is necessary to fulfil the purposes for which it was collected and processed, subject to legal obligations or legitimate needs justifying longer retention.
The applicable retention period depends, in particular, on the nature of the data concerned, the services used, applicable legal obligations, and the need to protect the rights of LIO, its members or the data subjects.
Data relating to applications, user accounts and member profiles is generally retained for the duration of the relationship with the organisation concerned. When this relationship ends, such data may be deleted or anonymised, unless its retention remains necessary to comply with a legal, administrative, accounting, contractual or security obligation, or to enable the defence of legal claims.
Data relating to requests addressed to LIO and communications exchanged with its teams is retained for the period necessary to process such requests and for the reasonably necessary follow-up of the exchanges concerned.
Technical data and information relating to the use of the services may be retained for the periods necessary for Platform administration, security, prevention of abuse and compliance with applicable legal obligations. Technical and security logs generated by the technical service providers used by LIO are processed and retained in accordance with the applicable policies of those providers.
When personal data is no longer necessary in view of the purposes pursued, it is deleted, anonymised or subject to measures strictly limiting access where its retention remains required by law or necessary for the defence of legal claims.
LIO periodically reviews the retention periods applied to ensure that they remain appropriate to the processing activities actually carried out and to the requirements of applicable law.
ARTICLE 10 – Potential international transfers of personal data
The processing of personal data carried out by Leaders from the Inside Out (LIO) is organised so as to favour, where possible, the use of service providers and solutions offering a high level of personal data protection and complying with applicable legal requirements.
Certain technical service providers used by LIO may process personal data or access it from countries outside the European Economic Area. In such cases, the transfers concerned are governed by the mechanisms provided for in Chapter V of the GDPR and by the safeguards implemented by the relevant service providers, such as an adequacy decision of the European Commission, Standard Contractual Clauses or any other mechanism recognised by applicable regulations.
Depending on the circumstances, these safeguards may include an adequacy decision adopted by the European Commission, Standard Contractual Clauses approved by the European Commission, or any other mechanism recognised by applicable law as providing an appropriate level of protection.
In accordance with the case law of the Court of Justice of the European Union and relevant recommendations of the European Data Protection Board, LIO ensures, where necessary, that it assesses the level of protection available in the country concerned and implements appropriate supplementary measures intended to preserve a level of protection substantially equivalent to that guaranteed within the European Economic Area.
Additional information concerning the safeguards applicable to certain transfers may be obtained in accordance with the contact arrangements provided for in this Privacy Policy.
LIO periodically reviews the transfer mechanisms used in order to take account of developments in applicable regulations, relevant case law and recommendations from competent authorities.
ARTICLE 11 – Security and confidentiality of personal data
Leaders from the Inside Out (LIO) implements appropriate technical, organisational and operational measures designed to ensure the security, integrity, availability and confidentiality of personal data processed in connection with the services offered.
These measures are determined taking into account, in particular, the nature of the processing activities carried out, the risks likely to affect the rights and freedoms of data subjects, the state of available technical knowledge, implementation costs, and applicable legal and regulatory requirements.
Depending on the needs of the processing concerned, these measures may include access controls, authentication mechanisms, authorisation management, activity logging, backups, system monitoring, protection against unauthorised access and, where appropriate, encryption or pseudonymisation measures.
Access to personal data is strictly limited to persons who need it in connection with their duties or responsibilities and only to the extent necessary to achieve the purposes pursued.
LIO also ensures that security and personal data protection requirements are integrated from the design stage, during the development and evolution of the services offered, in accordance with the principles of data protection by design and by default established by the GDPR.
Where a personal data breach is likely to result in a risk to the rights and freedoms of data subjects, LIO applies the procedures provided for by the GDPR, including the assessment and documentation of the incident, any notification to the competent supervisory authority and, where required, notification to the data subjects concerned.
Despite the measures implemented, no IT system or method of electronic transmission can guarantee absolute security. Users are therefore also encouraged to contribute to the security of the services offered by keeping their login credentials confidential and promptly reporting any incident or unauthorised use of which they become aware.
ARTICLE 12 – Your rights regarding the protection of personal data
In accordance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of personal data and any other applicable provisions, every data subject has the rights granted to them in relation to the protection of personal data.
Subject to the conditions, limitations and exceptions provided for by applicable regulations, data subjects may, in particular, obtain confirmation as to whether or not personal data concerning them is being processed, access such data, request its rectification where it appears inaccurate or incomplete, request its erasure in the cases provided for by law, or obtain restriction of certain processing activities.
Data subjects may also object, on grounds relating to their particular situation, to processing based on LIO's legitimate interest where the conditions set out in the GDPR are met.
Where the legal conditions are met, they also have the right to data portability in relation to the personal data they have provided, as well as the right to withdraw consent previously given at any time, without affecting the lawfulness of processing carried out before such withdrawal.
Where the conditions set out in Article 22 of the GDPR are met, data subjects also have the right not to be subject to a decision based solely on automated processing that produces legal effects concerning them or similarly significantly affects them.
The exercise of these rights is subject to LIO's applicable legal obligations and the rights and freedoms of other persons who may be concerned.
LIO endeavours to facilitate the effective exercise of these rights in a transparent, accessible manner and in compliance with the requirements of the GDPR.
ARTICLE 13 – Exercise of your rights and contact details
Any request relating to the exercise of rights recognised by this Privacy Policy or by applicable personal data protection regulations may be addressed to Leaders from the Inside Out (LIO) at the following address: leadersfromtheinsideout@gmail.com, or through any other contact details made available on its website.
In order to protect personal data and prevent unauthorised disclosure, LIO may, where circumstances warrant and in compliance with the principle of data minimisation, request information strictly necessary to verify the identity of the person making the request. No additional information will be requested where the identity of the data subject can reasonably be verified by other means.
Requests are processed as promptly as possible and in accordance with the requirements of the GDPR. Unless specific circumstances justify an extension in accordance with applicable regulations, a response is provided within one month of receipt of the request or, where necessary, of the information required to confirm the identity of the data subject.
Where the complexity or number of requests received justifies it, this period may be extended in accordance with applicable provisions. In such circumstances, the data subject is informed of the extension and the reasons for it within the time limits provided by applicable regulations.
The exercise of rights by data subjects is generally free of charge. However, where a request is manifestly unfounded, excessive or repetitive within the meaning of the GDPR, LIO reserves the right to refuse to act on it or to charge reasonable administrative fees within the limits permitted by applicable law.
Where LIO considers that it cannot fully or partially comply with a request relating to the exercise of a right recognised by applicable regulations, the data subject is informed of the reasons for that decision and of the remedies available to them under applicable law.
ARTICLE 14 – Complaints and remedies
Data subjects are invited, where they wish, to contact Leaders from the Inside Out (LIO) with any questions relating to the processing of personal data carried out in connection with the services offered or to the exercise of their rights under applicable regulations. LIO endeavours to respond to requests addressed to it in a transparent and accessible manner and in compliance with applicable legal requirements.
Without prejudice to any other administrative or judicial remedy, any data subject who considers that the processing of personal data concerning them infringes applicable personal data protection provisions has the right to lodge a complaint with a competent supervisory authority.
Where the processing concerned falls within the competence of the Belgian Data Protection Authority, data subjects may lodge a complaint with that authority in accordance with the procedures published on its official website.
Data subjects also have the remedies provided for under Articles 77 to 82 of Regulation (EU) 2016/679 and applicable national provisions, in particular the right to an effective judicial remedy against a supervisory authority, a controller or a processor where the conditions provided for by applicable regulations are met.
The exercise of a right, the lodging of a complaint or the exercise of a remedy shall not result in any discriminatory measure against the data subject on account of the legitimate exercise of their rights under applicable regulations.
ARTICLE 15 – Amendments to this privacy policy
This Privacy Policy may be amended to take into account, in particular, changes to the services offered by Leaders from the Inside Out (LIO), the integration of new features, changes to the processing of personal data carried out, recommendations from competent authorities, and applicable legal, regulatory or case-law developments.
Purely editorial, organisational or technical amendments that do not substantially affect the rights of data subjects or the essential characteristics of the processing activities carried out may be incorporated directly into this Privacy Policy.
Where amendments are likely to significantly affect the categories of personal data processed, the purposes pursued, the applicable legal bases, the arrangements for sharing data or the rights of data subjects, LIO ensures that appropriate information is provided to the users concerned before such amendments take effect, in accordance with applicable legal requirements.
Where applicable regulations require specific formalities, the updating of information provided to data subjects or the prior obtaining of consent, such requirements shall be complied with before the relevant processing activities are implemented.
The most recent version of this Privacy Policy remains accessible within the Platform or by any other reasonably appropriate means enabling data subjects to consult it.
The date of the most recent update to this Privacy Policy is indicated in the document so that data subjects can identify the applicable version.
ARTICLE 16 – Final provisions and interpretation of this privacy policy
This Privacy Policy is intended to enable data subjects to understand, in a clear, transparent and accessible manner, how Leaders from the Inside Out (LIO) processes the personal data necessary for the operation of its services and the safeguards implemented to protect such data.
The provisions of this Privacy Policy shall be interpreted in accordance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of personal data, the Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data, and any other applicable legal and regulatory provisions.
This Privacy Policy should be read in conjunction with the General Terms of Use, the Cookie Policy and any additional information that may be provided in connection with certain services, community programmes, events, digital features or specific processing activities implemented by LIO.
No provision of this Privacy Policy shall be interpreted as limiting the rights granted to data subjects under applicable regulations or as authorising any processing of personal data incompatible with the principles of lawfulness, fairness, transparency, data minimisation, accuracy, storage limitation, integrity and confidentiality established by the GDPR.
If any provision of this Privacy Policy is declared invalid, unenforceable or contrary to a mandatory provision of applicable law, this shall not affect the validity of the remaining provisions, which shall continue to have effect to the fullest extent permitted by applicable regulations.
LIO endeavours to maintain responsible, proportionate and evolving governance of the processing of personal data carried out in connection with its activities and to adapt this Privacy Policy where necessary to ensure a level of protection consistent with applicable legal, regulatory and technological requirements.