This policy explains what personal data we process through the Neo Whistle website, why, who receives it, and what you can do about it. It applies to visitors of the website, to people who contact us, and to customers who order Neo Whistle and manage their order through their customer account. We process personal data in line with the GDPR and Belgian data protection law.
This policy does not cover the Neo Whistle reporting channel itself, where reports are submitted and handled. That tool is separate from this website and has its own privacy notice.
Neo Whistle is provided by Belfort Advisory BV, Steinen 32, 9850 Deinze, Belgium, enterprise number BE 1026.995.022 (Belfort Advisory, we). For any privacy question about Neo Whistle, write to neo@belfort-advisory.com. We have not appointed a data protection officer, as we are not required to.
1. Who Is Responsible
Belfort Advisory BV is the controller for all personal data processed through this website.
2. What We Process and Why
| Activity | Data | Legal basis |
|---|---|---|
| Answering contact form enquiries | Name, email address, message; phone number and company if you choose to add them | Steps at your request before a contract (Art. 6(1)(b) GDPR) or our legitimate interest in answering you (Art. 6(1)(f)) |
| Processing orders | Company name, address and VAT number; name, email address, phone number and role of the contact person; billing details; the options and customisation you choose | Steps at your request before a contract and performance of the contract (Art. 6(1)(b)) |
| Customer account | Login details, your order and the customisation settings of your channel | Performance of the contract (Art. 6(1)(b)) |
| Invoicing and accounting | Billing and payment data | Legal obligation (Art. 6(1)(c)) |
| Hosting and security | IP address, request details and timestamps in server logs | Legitimate interest in keeping the website available and secure (Art. 6(1)(f)) |
To set up your reporting channel, we use the order details needed for that purpose in the Neo Whistle tool. From then on, the tool's own privacy notice and our terms and conditions apply.
3. How Long We Keep Data
| Data | Retention |
|---|---|
| Contact form enquiries | 12 months after our last exchange, unless an order follows |
| Orders and customer account | For the duration of the agreement, then up to 5 years for possible claims |
| Invoicing and accounting data | 7 years after the end of the financial year, as required by Belgian accounting law |
| Server logs | Short-term, in line with our hosting provider's log retention |
4. Who Receives Your Data
We do not sell personal data or share it for advertising. Data submitted through the website's forms is received only by Belfort Advisory.
The following provider processes data on our behalf under a data processing agreement:
| Provider | Purpose | Location and safeguard |
|---|---|---|
| Microsoft Ireland Operations Ltd (Azure) | Website hosting | Hosted in the West Europe region (Netherlands). Any remaining transfers under the EU-US Data Privacy Framework and Standard Contractual Clauses |
We also share data with our accountants and auditors, who are bound by confidentiality, and with courts, regulators or authorities where the law requires it.
Payments via Stripe. If you choose to pay through Stripe, you are redirected to Stripe's payment page. Stripe processes your payment details as an independent controller, under its own privacy policy. We only send Stripe the order number and the amount due, and we do not receive your card details.
5. Security
The website is served over HTTPS only. Forms are protected against cross-site request forgery. Access to order and customer data is limited to the people at Belfort Advisory who need it. Keep your customer account login details safe and do not share them.
6. Your Rights
You can ask to:
- access the personal data held about you and receive a copy;
- correct data that is inaccurate or incomplete;
- erase your data, unless it must be kept by law or is needed for legal claims;
- restrict processing while a question about accuracy or lawfulness is resolved;
- receive data you provided, based on contract or consent, in a portable format;
- object to processing based on legitimate interest (Art. 21 GDPR);
- withdraw consent where it was asked, without affecting earlier processing.
Send requests to neo@belfort-advisory.com. We may ask you to confirm your identity. We answer within one month; for complex or numerous requests we can extend that by two further months, and we will tell you why within the first month.
Questions about a report submitted through a reporting channel should be addressed to the organisation that operates that channel.
If you think your data is handled unlawfully, you can lodge a complaint with the Belgian Data Protection Authority (dataprotectionauthority.be), or with the authority in your own country.
7. Cookies and Session Storage
Neo Whistle only uses cookies that are strictly necessary for the website to work. We do not use analytics, advertising, or tracking cookies. We do not use third-party cookies. For this reason we do not ask for your consent and do not show a cookie banner.
| Cookie | Purpose | Duration |
|---|---|---|
PHPSESSID | Keeps you signed in and keeps the state of forms you are filling in. It is only set when needed. | Until you close your browser |
csrf-token_* | Protects forms against cross-site request forgery. | Removed after the form is submitted |
REMEMBERME | Keeps you signed in on this device. It is only set if you tick “Remember me” when signing in. | 30 days |
We also use your browser’s session storage to stop automatic page refreshes from running forever. This data is never sent to us, and it is deleted when you close the tab.
You can block or delete cookies in your browser settings. If you do, signing in and submitting forms will no longer work.
If we ever add cookies that are not strictly necessary, we will update this policy and ask for your consent first.
8. Changes to This Policy
When we change how we process personal data, we update this page and the date at the top. Customers are informed of material changes in advance.
9. Contact
Belfort Advisory BV, Steinen 32, 9850 Deinze, Belgium
Privacy questions and requests: neo@belfort-advisory.com
Security vulnerabilities can be reported to the same address under our responsible disclosure policy.
For how Belfort Advisory processes personal data outside Neo Whistle, see our general privacy policy.