Cookie Policy


Last update on 4th of March, 2020. This Cookie Policy governs the use of cookies on the website www.ngrave.io (hereinafter: “Website”) of NGRAVE (hereinafter: “NGRAVE”, “we”, “us”, “our”).

A cookie is a small text file that the Website saves on your computer or mobile device when you visit the Website, and which contains certain information and sometimes personal data. It enables the Website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the Website or browse from one page to another.

Social media plugins are small pieces of software developed and provided by Social Media Service providers (e.g. Facebook, LinkedIn, Google, YouTube, Pinterest, Instagram and Twitter), which add social media integration when built into the Website.

NOTE: If you want general information on how we process your personal data other than the processing through cookies, social media plug-ins, including in relation to your communication with us via e-mail, telephone, fax and social media and in relation to your registration on our Website, please refer to our Privacy Policy.

By continuing to use the Website after having been informed of the use of cookies and social media plugins, you acknowledge that you have read this Cookie Policy carefully and that you agree with it without reservation. You may, however, at all times change your cookie preferences through the cookie settings.

1. In General

1.1. Your personal data are processed by NGRAVE, a company registered as Ngrave.IO NV under Belgian company number 0700.252.896, having its registered office at Kloosterstraat 94, 2000 Antwerpen. NGRAVE can be contacted via e-mail at privacy@ngrave.io.

Explanation: This is the entity responsible for the processing of your personal data as covered in this Cookie Policy.

1.2. Any notion starting with a capital shall be defined by explicit reference in this Cookie Policy. Where possible given the context, singular words shall be interpreted as also including the plural and vice versa.

Explanation: To make sure we have the same understanding of what is written here, it is important that certain notions are interpreted in the same way by you and by us.

1.3. Where reference is made to certain laws or regulations, such reference shall also include any change, replacement or annulment of said laws or regulations, including any related executive decisions.

Explanation: Laws tend to change from time to time, and we want to make sure that this Cookie Policy remains in line with any such changes.

1.4. NGRAVE reserves the right to modify, change or amend this Cookie Policy at its own discretion and from time to time. Such modification, change or amendment shall be communicated via the Website. If you do not accept the modifications, changes or amendments, you are to inform us by sending an e-mail to privacy@ngrave.io. If we do not receive such an e-mail from you within three (3) business days after the changes to the Cookie Policy have been announced in a visible manner on our Website, you will be deemed to have unambiguously accepted all such changes.

Explanation: As any company, changes in laws, market circumstances, interests etc. may require us to change our Cookie Policy from time to time to ensure that it remains accurate. If this happens, you are kindly asked to take note of the changes and to agree with them if you find them acceptable.

2. Cookies

2.1. You can control and/ or delete cookies being placed by configuring your browser as such. For more details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work or stop working properly.

To learn how to opt out of behavioral advertising delivered by Network Advertising Initiative member companies, please visit the Network Advertising Initative and Digital Advertising Alliance. You may download the AppChoices app to opt out in mobile apps. If you opt out from interest-based advertising, you may see advertising that is not relevant to you. At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.

Explanation: This provision is self-explanatory.

2.2. When you visit the Website, NGRAVE places a number of cookies. Most data pertaining to these cookies, their placement and use allow to identify you, and NGRAVE uses them to gain insight in how you and other visitors use the Website by gathering statistical and usage data, enabling NGRAVE to provide a better user experience on the Website.

Explanation: With this provision, NGRAVE aims to appropriately inform you of the cookies that are placed on your device when visiting and using the Website.

2.3. Find here the complete list of cookies used on the Website.

Explanation: This provision is self-explanatory.

2.4. You may at all times withdraw your consent with NGRAVE’s use of cookies. To exercise this right, it suffices to delete the cookies, which have been placed on your device. To do so, you are kindly asked to refer to the appropriate instructions of your browser manufacturer, as listed above.

Explanation: This provision is self-explanatory.

3. Purposes for which NGRAVE uses your personal data

3.1. NGRAVE processes your personal data to perform statistical analyses so that we may improve our Website, advertisement, products and services, or to develop new products and services.

Explanation: This provision is self-explanatory.

3.2. NGRAVE processes your personal data to provide you in a personalized and efficient way with the products and services, via the Website.

Explanation: We have to process certain personal data to provide you with our services.

3.3. NGRAVE processes your personal data for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of NGRAVE regarding our products and services.

Explanation: This provision is self-explanatory.

3.4. NGRAVE may process your personal data for informing any third party in the context of a possible merger with, acquisition from/by or demerger by that third party, even if that third party is located outside the EU.

Explanation: This provision is self-explanatory.

3.5. NGRAVE may process your personal data for the preservation of the legitimate interests of NGRAVE, its partners or a third party if and when your registration with, or use of, the Website can be considered (a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Website, (c) a danger to the Website or any of NGRAVE’s or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.

Explanation: Here we reserve the right to process your personal data if you use our Website in any way that may harm NGRAVE or someone else or is illegal.

3.6. Your personal data may be transferred to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by your through your use of the Website.

Explanation: From time to time we may be legally required to transfer your personal data to governmental authorities.

4.1. For processing your personal data under the conditions outlined in this Cookie Policy, but with the exception of functional cookies, NGRAVE as the responsible party asks for your consent.

Explanation: The law requires us to state precisely which legal basis we use to process your personal data, considering the purposes we have listed in the previous article. The main legal basis for the processing covered in this Cookie Policy is your consent. NGRAVE obtains your consent through the cookie banner. By clicking on this banner affirmatively and continuing to use any of the Website you acknowledge that you have read this Cookie Policy carefully and that you agree with it without reservation.

4.2. The processing of your personal data for the purposes outlined in clause 3.6 is necessary to allow NGRAVE to comply with its legal obligations.

Explanation: Sometimes the law obliges us to process your personal data.

4.3. The processing of your personal data for the purposes outlined in this Cookie Policy is also necessary for the purpose of the legitimate interests of NGRAVE, which are:

  • continuous improvements to NGRAVE’s Website, Social Media Channels, products and services to ensure that you have the best experience possible;
  • keeping our Website, Social Media Channels, products and services safe from misuse and illegal activity;
  • marketing and promotion of our products, services, brands an overall successful commercialization of our products and services.

Explanation: We may also process your personal data for our own legitimate interests, which are mainly concerned with successfully conducting our business as any other company would do.

5. Recipients and transfers

5.1. NGRAVE may share personal data with third party business partners when this is necessary to provide our services to you. Other than this, we do not send your personal data in a directly identifiable manner to any third party without your explicit permission to do so.

You understand, however, that our use of analytical and statistical as well as social media cookies may imply that the third-party providers of those cookies may obtain certain information about you, including about your surfing behavior. You can find more information in the respective policies of those providers.

Explanation: We do not share your personal data with third parties in a way that those parties can identify you directly unless you consent to it or unless we have anonymized your personal data.

You understand however that when you use Facebook for instance to communicate, Facebook also processes your personal data.

5.2. NGRAVE relies on third-party processors to provide you the Website as well as to process your personal data on our behalf. These third-party processors are only allowed to process your personal data on behalf of NGRAVE upon explicit written instruction of us. NGRAVE warrants that all third-party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.

Explanation: Our Website may be developed, maintained or hosted by third parties. Similarly, we rely on the services of third parties such as cloud providers to process your personal data internally.

5.3. Your use of our Website implies that your personal data are transferred outside the EEA. Each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data. Such safeguards will be the consequence of:

  • The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
  • A contractual arrangement between NGRAVE and that entity.

Explanation: Our Website may be developed, maintained or hosted by third parties. Similarly, we rely on the services of third parties such as cloud providers to process your personal data internally.

6. Quality assurance

6.1. NGRAVE does its utmost to process only those personal data which are necessary to achieve the purposes listed under the purpose for processing.

Explanation: We will not process more personal data about you than we really need for the purposes we have communicated to you.

6.2. Your personal data are only processed for as long as needed to achieve the purposes which are described above or up until such time where you withdraw your consent for processing them. Note that withdrawal of consent may imply that you can no longer use the whole or part of the Website and/or services. NGRAVE will de-identify your personal data when they are no longer necessary for the purposes outlined in the purpose for processing, unless there is:

  • an overriding interest of NGRAVE or any other third party in keeping your personal data identifiable; or
  • a legal or regulatory obligation or a judicial or administrative order that prevents NGRAVE from de-identifying them.

Explanation: Here we explain how long we will keep your personal data in a way that allows us to identify you.

6.3. NGRAVE will take the appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access by personnel of NGRAVE or its third-party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only, which can never be guaranteed.

Explanation: We are committed to keeping your personal data safe.

7. Your rights

7.1. You have the right to request access to all personal data processed by NGRAVE pertaining to you. NGRAVE reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to NGRAVE.

Explanation: In this article we explain which rights you have vis-à-vis the processing of your personal data. The rights themselves are self-explanatory.

7.2. You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.

Explanation: In this article we explain which rights you have vis-à-vis the processing of your personal data. The rights themselves are self-explanatory.

7.3. You have the right to withdraw your earlier given consent under clause 4.5 for processing your personal data.

Explanation: In this article we explain which rights you have vis-à-vis the processing of your personal data. The rights themselves are self-explanatory.

7.4. You have the right to request that personal data pertaining to you will be deleted if they are no longer required in light of the purposes which are outlined above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by NGRAVE against:

  • overriding interests of NGRAVE or any other third party;
  • legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

Instead of deletion you can also ask that NGRAVE limits the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes which are outlined above, but you need them to defend yourself in judicial proceedings.

Explanation: In this article we explain which rights you have vis-à-vis the processing of your personal data. The rights themselves are self-explanatory.

7.5. You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with his particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.

Explanation: In this article we explain which rights you have vis-à-vis the processing of your personal data. The rights themselves are self-explanatory.

7.6. You have the right to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.

Explanation: In this article we explain which rights you have vis-à-vis the processing of your personal data. The rights themselves are self-explanatory.

7.7. If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to privacy@ngrave.io for all data subject rights matters. An e-mail requesting to exercise a right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state and specify which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed and accompanied by a digitally scanned copy of your valid identity card proving your identity. NGRAVE will promptly inform you of having received this request. If the request proves valid, NGRAVE shall notify it as soon as reasonably possible and at the latest thirty (30) days after having received the request. If you have any complaint regarding the processing of your personal data by NGRAVE, you may always contact NGRAVE via the e-mail address mentioned in the first paragraph of this clause. If you remain unsatisfied with NGRAVE's response, you are free to file a complaint with the competent data protection authority. For a list of national data protection authorities, visit https://edpb.europa.eu/about-edpb/board/members_en.

Explanation: In this article we explain which rights you have vis-à-vis the processing of your personal data. The rights themselves are self-explanatory.