Nudge privacy statement

1. Who are we?

Nudge is currently a project in development, founded by Jente Van Langenaeken. Nudge tests a concept in which starting and experienced entrepreneurs are put in touch for a conversation based on their concrete question, experience and needs.

Jente Van Langenaeken is responsible (the controller) for the processing of your personal data.

For questions about this privacy statement or about the processing of your personal data, you can contact us at:

help.nudge@gmail.com

2. What data do we process?

Depending on how you come into contact with Nudge, we may process the following personal data:

• Your name and contact details, such as your email address and mobile number.
• Your LinkedIn profile or website.
• Information about your business, idea or activity.
• Information about your experience and expertise.
• Information about your question, challenge or the topic you'd like to talk through.
• Your preference for how we contact you.
• Information about your availability.
• Information about proposed matches, conversations and any follow-up contact.
• Feedback about conversations and your experience with Nudge.
• Other information you voluntarily share with us.

When you show interest in Nudge through our website, we initially ask for your name and email address, possibly supplemented with your LinkedIn profile, mobile number and contact preference.

When you are invited to take part in the test phase through a direct message or email, we may ask you to fill in an intake form. In it, we may collect additional information about your business, question, experience, expectations and availability.

Please do not share passwords, trade secrets, confidential documents or other sensitive information that Nudge does not need. You don't have to mention names of people or companies in your answers.

Additionally for experts

• Supplementing with public information: if your profile contains too little information for a good match, we may exceptionally supplement it with publicly available professional information, such as your LinkedIn profile, or with what we know about your experience ourselves. This addition is short, in our own words and without names of people or organisations.
• Notes based on feedback: after a conversation, we may note in your profile what you turned out to be strong at, for example "strong in positioning". This is done without names of starters and without scores.

You can always request these additions and notes and have them changed or deleted.

3. What do we use your data for?

We use your personal data to:

• Register and manage your interest in Nudge.
• Contact you about Nudge and its further development or test phase.
• Understand what you're working on, what experience you have and what you're looking for help with.
• Understand the interest of starting and experienced entrepreneurs in Nudge.
• Test, evaluate and improve the concept.
• When matching takes place, assess which experience fits a concrete question and propose possible matches.
• Supplement expert profiles when they contain too little information for a good match.
• When a match is made, put the participants involved in touch and share relevant information to prepare the conversation.
• Collect feedback and support any follow-up contact.
• Note, based on feedback from starters and without their names, what an expert is strong at, so that future matches improve.
• Comply with legal obligations where necessary.

We do not use your data for purposes that are incompatible with these purposes.

4. On what legal basis do we process your data?

The General Data Protection Regulation (GDPR) requires personal data to be processed on a valid legal basis. We rely on the following legal bases:

• Steps at your request: when you sign up or fill in a form, you ask to take part in Nudge yourself. To carry out that request, we process your data to register your sign-up, understand your question or experience, propose possible matches, put you in touch with your match and help plan the conversation.
• Legitimate interest: we have a legitimate interest in managing, testing, evaluating and improving Nudge. On that basis, we contact you about Nudge and the test phase, collect feedback, support follow-up contact, exceptionally supplement an expert profile with public professional information, note based on feedback what an expert is strong at, and use tools such as AI when proposing matches. We only do so insofar as our interests outweigh your interests and rights. You can always object to this processing.
• Legal obligation: when we have to process certain data to comply with a legal obligation.
• Consent: only for processing for which we ask your consent separately, for example certain updates about Nudge. You can withdraw that consent at any time. This does not affect the lawfulness of processing carried out before the withdrawal.

When you tick the box in our forms confirming that you have read and agree to this privacy statement, you confirm that you know how we use your data. The processing above relies on the legal bases described in this section.

5. Who do we share your data with?

With the person you are matched with. When a match is made, the expert, once they agree, receives a briefing with the starter's name and their answers from the intake form. The starter receives a short summary of the expert's experience. We only share contact details once both agree to have a conversation.

With an AI service. To propose possible matches, we send the content of starters' answers and experts' profiles to an AI service from Anthropic. We do not send names, email addresses, phone numbers or company names. You can read more about this in section 6.

With the tools we work with (processors): Airtable (forms and storage), Make (automation, with a temporary history of the automations), Google Docs and Google Drive (briefings), Gmail (email), Slack (internal notifications, with only a name) and GitHub Pages (website). They only process your data on our behalf.

Direct contact. We contact you personally through the channel you choose, such as email, LinkedIn or WhatsApp.

Some of these services are based outside the European Union. You can read how we handle this in section 8.

We do not sell your data and do not use it for advertising.

6. AI and matching

To propose possible matches, we use an AI service from Anthropic. It compares a starter's answers with the experts' profiles and proposes a short list of suitable experts, with an explanation.

For this, we only pass on content-related information, such as the starter's question, sector and stage, and the experts' experience and expertise. We do not send names, email addresses, phone numbers, LinkedIn profiles, websites or company names. Experts are referred to by a number only. If you mention identifiable information yourself in an open answer, such as a name or a brand name, it may be processed as well.

A proposed match is never imposed as a final decision by an automated system alone. The AI does not decide. Nudge reviews the proposal and chooses which expert to contact. The expert then decides for themselves whether to take up the question.

If the way AI is used within Nudge changes substantially, we will update this privacy statement.

7. How long do we keep your data?

We do not keep personal data longer than necessary for the purposes for which it was collected.

As a general rule, we keep personal data for a maximum of 12 months after the last active contact, unless a longer retention period is necessary to comply with a legal obligation or to exercise a right. This also applies to briefings, proposed matches, additions to expert profiles and notes based on feedback.

If you ask us to delete your data earlier and there is no legal reason to keep it, we will handle your request in accordance with the applicable privacy rules.

8. Where is your data processed?

For certain services we use, personal data may be processed outside the European Economic Area (EEA).

Where this is the case, we ensure that the processing complies with the applicable GDPR rules and that, where necessary, appropriate safeguards are used for international transfers of personal data.

9. What are your rights?

Under the conditions of the GDPR, you have, among other things, the right to:

• Access your personal data.
• Request a copy of your personal data.
• Have inaccurate personal data corrected.
• Have your personal data erased where there is a legal basis for this.
• Have the processing of your personal data restricted.
• Object to certain processing.
• Withdraw your consent where the processing is based on it.
• Transfer your personal data where the right to data portability applies.

If you're an expert, you can also always ask which additions or notes are in your profile, and have them changed or deleted.

You can contact us for this at:

help.nudge@gmail.com

We generally respond to your request within one month. In certain cases, this period may be extended in accordance with the GDPR.

10. Filing a complaint

Do you have questions or complaints about how we handle your personal data? Please contact us first at the email address above.

You also have the right to file a complaint with the Belgian Data Protection Authority.

11. How do we protect your data?

We take appropriate technical and organisational measures to protect personal data against loss, unauthorised access, alteration or disclosure.

Access to personal data is limited to people and service providers who need this information for the management, testing and further development of Nudge.

12. Changes

This privacy statement may be updated as Nudge develops further or when the way we process personal data changes.

The most recent version of this privacy statement is always available on our website.