Privacy Policy – Ingenious Sales Solutions

28 sep 2026 · @Jochen Roef

1. Who we are

This Privacy Policy explains how Ingenious Sales Solutions processes your personal data, why we do so and what rights you have.

Version: 1.0 · Effective date: 28 sep 2026

Ingenious Sales Solutions is the trading name of Roef - De Feyter BV, a Belgian private limited company that acts as the controller of your personal data.

In this policy, "we", "us" and "our" refer to Roef - De Feyter BV, trading as Ingenious Sales Solutions. "You" refers to anyone whose personal data we process: website visitors, prospects, clients, participants and subscribers.

2. Scope and our role

This policy covers all personal data we process through our website, our communication channels and our services, in line with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable Belgian law.

Our services are intended exclusively for businesses and professionals. Even so, we process personal data of the natural persons behind those businesses, such as founders, managers, contact persons and participants. This policy applies to them in full.

For the processing described in this policy, we act as the controller. We do not act as a processor on behalf of our clients by default. Where a specific assignment requires us to process personal data on a client's behalf, we agree this in advance in a separate data processing agreement.

This policy does not cover third-party websites or platforms that we link to. Their own privacy policies apply.

3. What we process, why, and for how long

We only process personal data for a specific purpose, on a valid legal basis, and for no longer than that purpose requires. The table below sets this out per activity.

We do not use your personal data for automated decision-making that produces legal effects for you or similarly significantly affects you.

We do not sell your personal data, and we do not share it with third parties for their own marketing purposes.

Where we rely on legitimate interest, we have weighed our interest against your rights. You can object at any time (see section 9). You may request an earlier deletion of your data at any time, unless a legal obligation requires us to keep it.

4. Cookies, analytics and marketing technologies

We only place non-essential cookies and similar technologies after you have given your consent.

We use three categories:

  • Strictly necessary — required for the website to work, for example to remember your cookie choices, secure forms or keep you logged in to the member area. These do not require consent.

  • Analytics — help us understand how visitors use the website so we can improve it. We use them only with your consent.

  • Marketing — help us measure the effect of our campaigns and show relevant content on other platforms. We use them only with your consent.

We manage these technologies through Google Tag Manager, which loads analytics and marketing tags only once you have given the relevant consent.

The current list of cookies and tools, their providers and their duration is available in our Cookie Settings. There you can give, refuse or withdraw your consent at any time, as easily as you gave it. Refusing does not limit your access to the website.

Some pages may contain embedded content from third parties, such as videos or social media posts. Those providers may place cookies once you interact with that content. Where this is the case, we request your consent first.

5. How we use artificial intelligence

We use AI tools to work faster and better for you, never to make decisions about you.

We use Claude (Anthropic) and ChatGPT (OpenAI) under business subscriptions, for example to summarise meetings, structure analyses and prepare deliverables. Under these subscriptions:

  • the providers act as our processors under a data processing agreement;

  • your data is not used to train their AI models;

  • we only enter the personal data a task requires, and anonymise or pseudonymise it where possible.

A person always reviews AI-generated output before we use or share it. AI is a tool in our work, not a substitute for professional judgement.

We record or transcribe a session only after informing you in advance. You may object at any time, in which case we work from written notes only.

If you would like to know which AI tools are used in your assignment, just ask us.

6. Who receives your data

We share personal data only with parties that need it to deliver our services, under contractual safeguards.

Marketing and analytics providers that we use with your consent are listed in our Cookie Settings.

If you invite us to a meeting on your own platform, such as your organisation's Microsoft Teams, your organisation is responsible for that processing.

We may also share personal data with our accountant and legal advisers, who are bound by professional confidentiality, and with public authorities where the law requires us to.

7. International transfers

Wherever possible, we choose providers that process data within the European Union, such as Combell, Billit and WebinarGeek.

Some providers, including Squarespace, Google, Microsoft, Calendly, Stripe, Attio, Anthropic and OpenAI, may process personal data outside the European Economic Area, in particular in the United States. We only allow such transfers with appropriate safeguards, namely:

  • the provider's certification under the EU-US Data Privacy Framework; or

  • the European Commission's Standard Contractual Clauses, supplemented where needed by additional measures.

You may request further information about these safeguards via the contact details in section 10.

8. Security

We take appropriate technical and organisational measures to protect your personal data against loss, misuse and unauthorised access.

These include encrypted connections to our website, access to data limited to what is needed, secure authentication for our accounts, and contractual security obligations for our processors. We periodically delete data that has reached the end of its retention period.

No system is completely secure. If a data breach occurs that is likely to pose a risk to your rights and freedoms, we will notify the Belgian Data Protection Authority and, where required, inform you without undue delay.

9. Your rights

You can exercise the following rights free of charge by emailing info@ingenioussales.solutions:

  • Access — obtain a copy of the personal data we hold about you.

  • Rectification — have inaccurate or incomplete data corrected.

  • Erasure — have your data deleted, unless a legal obligation requires us to keep it.

  • Restriction — have the processing of your data temporarily limited.

  • Objection — object to processing based on our legitimate interest. You can always object to direct marketing, without giving a reason.

  • Data portability — receive the data you provided to us in a structured, commonly used format, or have it transferred to another party.

  • Withdrawal of consent — withdraw your consent at any time, for example via the unsubscribe link in each newsletter or via our Cookie Settings. This does not affect processing carried out before the withdrawal.

We respond within one month of receiving your request. For complex requests, this period may be extended by two further months; we will inform you if so. We may ask you to verify your identity before we act on your request.

If you are not satisfied with how we handle your personal data, please contact us first. You also have the right to lodge a complaint with the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données), Drukpersstraat 35, 1000 Brussels, contact@apd-gba.be, www.dataprotectionauthority.be.

10. Children, changes and contact

Our services are aimed at businesses and professionals. We do not knowingly collect personal data of persons under 16.

We may update this policy when our services, tools or legal obligations change. The version number and effective date at the top show which version applies. We will inform clients and subscribers of significant changes by email.

For any question about this policy or your personal data, contact us at:

Ingenious Sales Solutions (Roef - De Feyter BV) Vossenstraat 45, 9070 Heusden, Belgium info@ingenioussales.solutions · +32 496 16 04 14

This policy is available in English and Dutch. Both versions have the same content.