Privacy policy.

This is the privacy policy of Move37 BV a Belgian company with registered offices at Drie Eikenstraat 373, 2650 Edegem and registered at the Crossroads Bank for Enterprises under the number 0805.637.854 (hereinafter “Wundo” or “we”).

This privacy policy is intended to inform you about the personal data that Wundo collects and processes via its AI-based leadership assistant platform, its website, contact forms or data suppliers, to explain why we collect this data and how we deal with your data. 

About Wundo

Wundo is an AI-powered assistant designed to support leaders and teams through personalized insights, learning cues, and integration with existing workplace tools. The platform combines user input, training data, and contextual information (for example, from HR systems, learning management systems, or communication platforms such as Microsoft Teams) to deliver tailored leadership development support. 

Wundo operates as both a controller (e.g., for demo purposes) and as a processor (e.g., for enterprise customers that provide employee data). 

By using Wundo, users agree to the processing described in this policy. For enterprise users, consent is generally managed by their employer as data controller.

Article 1. When does this privacy policy apply?

This privacy policy applies to the processing of personal data that Wundo collects via its services, platform, websites, applications, integrations, contact forms, social media, communication channels, data from authorized partners, suppliers and on our jobsite. It does not apply to third-party sites or services not operated by Wundo.

Article 2. Who is responsible for the processing of your personal data?

Wundo acts:

  • as Data Controller – for its own operations, user accounts, demo environments, and communication with prospective or registered users. This means that Wundo acts as a data controller for personal data processed in the context of its own platform management, AI personalization, analytics, and communication activities.

  • as Data Processor – for business customers when processing their employee or participant data as part of a contractual engagement. In these cases, Wundo processes data solely on documented instructions of the customer, who remains the Data Controller. Wundo is then only responsible for the processing of the employees personal data. In such cases, the customer determines the purposes and means of processing, and Wundo acts solely on documented instructions.

Article 3. Which personal data do we process about you?

We collect your personal data in three ways:

1.Information provided by you

In the first place, we receive your information when you share it with us. This is e.g. the case when you fill in a form on our website, use our platform, if you sign up for our newsletter or a certain offer, etc.

In these cases, we usually receive information such as your name, e-mail address, telephone number, address details (street, number, postal code, city, and country), date of birth, mobile number, statistical information of the use of our website, and other personal and/ or contact details.

Through the use of our platform Wundo processes personal data that you provide directly, that is generated through your use of the platform, or that is received from third parties such as learning partners or corporate customers. These may include:

  • Identification and contact details (name, email, company, role, etc.);

  • Interaction and behavioural data (use of the platform, learning progress, coaching questions, chat discussions, communication preferences, action points, etc.);

  • We sometimes request you to provide us with your remarks, suggestions or other information regarding our websites, our platform, our products or services or our company.

2. Automatically obtained information

When you browse our website, we receive data from cookie providers about your activity on our website such as the webpages you visit, the pages or products you are interested in, statistical behavioural information, etc. This information does not enable us to identify you directly. Therefore, we cannot know who you are merely based on the automatically obtained information. We can combine the automatically obtained information with the information provided by you. 

More information on the use of cookies by Wundo can be found in our cookie policy.

3. Information obtained from third parties

Sometimes we also receive your information from third parties such as learning partners or corporate customers:

  • Contextual data from authorised integrations (e.g. limited metadata or message context from workplace tools such as Microsoft Teams, where enabled);

  • Information provided by learning management systems (LMS), HR systems, or training partners.

Article 4. What is the legal ground for processing your personal data?

In general, Wundo processes your personal data for various purposes, which are further explained below. Regarding the processing of your personal data, Wundo always relies on:

  • either, the consent that you expressed. In certain cases (e.g. in case of personalised information) we will request your explicit consent. In other cases, your consent can be expressed e.g. by ticking a box to this effect during your navigation on our site, our platform or via another positive action from which your consent is inferred, e.g. by choosing to contact us via a contact form. In this case, you have the right to withdraw your consent for the future at all times;

  • or, on another legal basis laid down by law: for example, if the collection of data is necessary for the performance of a contract with you or if processing is necessary for the fulfilment of a legal obligation to which Wundo is subject. In some cases, the processing of your data may also be necessary to realise a legitimate interest of Wundo. In this case, we will consider whether your interests or your fundamental rights and freedoms outweigh our legitimate interest.

More in particular, Wundo processes personal data under the following legal grounds:

  • Contract performance – to provide the Wundo services and fulfil contractual obligations to customers and users;

  • Legitimate interest – to improve the quality and security of our platform, to develop our services, and to maintain business relationships. Wundo performs a balancing test to ensure such interests do not override users’ fundamental rights and freedoms;

  • Consent – for marketing communications, cookies, and personalised learning recommendations where required;

  • Legal obligation – where necessary to comply with applicable laws or regulatory requirements. 

Wundo ensures that the collected data has the least possible impact on a user’s or visitor’s privacy and takes all necessary measures to protect the data.

If Wundo wishes to process your personal data for purposes which are incompatible with the purposes as set out below, Wundo will provide you with further information to this end.

Article 5. For which purposes do we process your personal data?

1.In order to provide you with personalised information and promotions based upon your profile if you have expressed your consent on our website

We process your personal data based on your consent to manage your participation in our surveys, activities or other promotional offers or to send you personalised information or advertisements. 

For this purpose, we can process data such as your name, your address, your e-mail address, your telephone number, your preferred language, your company, and/or your credit card or other payment details. 

In case of consent, we develop a profile based upon your behaviour. In this profile, we take your preferences and interests into account, e.g. with respect to the products you have purchased and other products which might interest you. Based upon the information collected in the profile, we can send you general information and advertisements, information and advertisements concerning products that fit your profile or that might interest you. In each e-mail, you have the opportunity to unsubscribe. Furthermore, you are able to contact us regarding this topic at any given moment (see point 10 of this privacy policy with regard to your right to object).

Depending on the individual case, these data are processed based on your unambiguous consent, based on the performance of a contract to which you are a party, or based on your request to take steps prior to entering into a contract.

2. In order to answer your ordering request or to answer your questions or requests

We process your personal data in order to answer your questions or requests (e.g. to make an appointment with one of our sales people). If you request an order, we will process your personal data in order to supply you with the products.

For this purpose, we can process data such as your name, your company name, your e-mail address, your telephone number, your address, your correspondence with Wundo and all other personal data that you provide to us that can be relevant for answering your question.

Depending on the individual case, these data are processed on the basis of your request to take steps prior to entering a contract, on the basis of the performance of a contract to which you are a party, or on the basis of Wundo’s legitimate interest in informing you about its activities.

3. In order to send direct marketing of Wundo 

We process your personal data in order to keep you informed of new information, campaigns, promotions regarding our brand via e-mail, text message or mail (direct marketing). Moreover, we process your personal data to provide information regarding the features, the platform, services and products of  Wundo. These data are processed based upon Wundo’s legitimate interest.

For this purpose, we can process personal data such as your name, your e-mail address, your telephone number and your address.

We aim to keep you informed of our products if you request to receive information or a trial account, if you request to make an appointment with us or if you purchase our products. You prefer not to receive such information any longer? In each e-mail, you have the opportunity to unsubscribe. Furthermore, you are able to contact us regarding this topic at any given moment (see point 10 of this privacy policy with regard to your right to object). 

4. For the technical and functional management of our websites

We process personal data for the technical and functional management of our websites, in order to personalise the websites and to ensure that the websites are easy to use. 

For this purpose, we can process data such as your IP address, the pages you visit, the browser you use, the websites you visited earlier, geographical data such as your location, your preferred language and the time and duration of your visit. We do this e.g. by using cookies. 

Depending on the individual case, these data are processed based on your unambiguous consent or based on Wundo’s legitimate interest in improving its websites and protecting it against cyber-attacks.

5. For the technical and functional management of our platform

Wundo processes personal data of the user of our platform for the following purposes:

  • To provide and improve the AI-based learning and leadership assistant functionality;

  • To personalize user experience and provide learning recommendations or insights;

  • To manage customer contract obligations, user accounts, commercial information and customer relationships;

  • To provide customer support, notifications, confirmations, chat communications, feedback, user status information, and to respond to user requests;

  • To send product information when you have opted in or where legitimate interest applies (you can unsubscribe at any time);

  • To ensure platform security, monitor usage, and prevent misuse.

6.  For the automated processing and user profiling in our platform

Wundo uses automated systems and AI models to deliver personalised insights and learning cues. These processes may include profiling to tailor the experience to each user’s context and preferences. Such automated processing does not produce legal or similarly significant effects on users, and human oversight is maintained at all times. 

Wundo’s use of AI is subject to Article 22 GDPR and is transparent, limited in scope, and continuously monitored for fairness and accuracy.

 

Article 6. Who has access to your personal data?

Wundo is selective in the parties to whom it discloses your personal data and chooses them carefully. In all cases, we will ensure that sufficient safeguards for the protection and confidentiality of your data are in place.

In the following cases, we may share your personal data with third parties:

  • Service providers supporting hosting, AI model processing, LMS-systems, implementations, analytics, or communication tools;

  • Vendors, partners and distributors of Wundo’s products e.g. to make sure that they are able to contact you to make an appointment.

  • Certain processors who act on our behalf, such as e.g. marketing and communication companies.

  • Affiliated companies, including our investors and other affiliated companies of Wundo only when functionally or contractually required, anonymized and subject to confidentiality obligations.

  • Business partners such as third parties with whom we carry out joint promotions or programs.

  • IT service providers that provide technical support.

  • Payment service providers. 

  • Attorneys and external advisors: In certain cases, Wundo may transfer your personal data to attorneys and external advisors if this is necessary to give us advice or to defend our rights.

  • Supervisory authorities: in certain cases, Wundo may transfer your personal data to police, judicial or other authorities if we believe that we are required to do so based upon the applicable legislation or regulation or based upon another lawful request or order.

  • Possible acquirers of the company in the event that (a part of) our activities would be taken over by a third party.

Wundo does not sell personal data to any third party. Data is shared only when functionally necessary and subject to appropriate safeguards.

Article 7. Does Wundo process your data outside the european economic area (“EEA”)?

In this respect, Wundo is committed to always ensuring an adequate and sufficient level of protection for your data, in particular by making sure that we can rely on an adequacy decision under article 45 GDPR, by concluding standard contractual clauses under article 46.2 GDPR or via any other appropriate safeguard.

Data may be processed by cloud infrastructure and AI technology providers (such as AWS, OpenAI, Microsoft, etc.) located in third countries, always under equivalent data protection commitments (e.g. the EU standard contractual clauses (SCC’s) as referred to in the applicable data protection agreement with such providers). For optional communication channels such as WhatsApp, Wundo applies strict data minimization and uses Standard Contractual Clauses and the EU–US Data Privacy Framework for data transfers.

If you have any questions or would like more information about the transfer of your personal data outside the EEA, you can send a dated and signed request to privacy@wundo.ai .

Article 8. How are your personal data protected?

Wundo strives to protect your personal data as well as possible by means of administrative, technical and organisational measures. To this end, Wundo has developed several procedures which are implemented by our employees. These include encryption in transit and at rest, role-based access control, pseudonymisation, continuous monitoring, and staff confidentiality commitments.

Wundo maintains a comprehensive data protection and security framework designed to preserve the confidentiality, integrity, and availability of personal data. Appropriate technical and organisational measures are implemented in accordance with Article 32 GDPR and industry best practices.

These measures include additionally but not limited to:

  • Segregation of environments and use of pseudonymised or synthetic data for testing and model training;

  • Immutable audit logging of administrative actions and automated access reviews;

  • Incident response and breach notification procedures, including a 48-hour notification commitment where required by law;

  • Vendor and sub-processor due diligence, ensuring equivalent security and data protection standards; and

  • Employee confidentiality and regular (e.g. yearly) awareness training covering data protection, AI ethics, and security hygiene.

Where artificial intelligence or automated processing components are involved, Wundo applies additional controls to prevent misuse, bias, and unintended disclosure of information. These controls include input filtering, anonymization of prompts and interaction logs, and independent fairness and performance reviews of AI models.

Wundo furthermore has committed to ensure that the service providers that process personal data on behalf of Wundo also implement sufficient technical and organisational measures.

Article 9. How long do we keep your personal data? 

Wundo will retain your personal data for the period necessary to fulfil the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.

Upon termination of a contractual relationship, user data will be removed (e.g. due to contract termination) or anonymized (e.g. for analytical purposes) within six (6) months unless a longer retention period is required for compliance or legitimate business purposes.

Backup data is encrypted and automatically deleted according to a rolling retention schedule of thirty (30) to sixty (60) days.

If no legal retention period applies, Wundo will process your data at least as long as it has a contractual relationship with you.

Article 10. What are your rights and how can you exercise them?

Under the GDPR, you have a number of rights with regard to your personal data. Some of these rights have a very specific scope or are subject to special conditions or exceptions.

1.Right of access

This means e.g. that you can ask us whether or not we process your personal data and for what purposes we do this. For more information, please consult article 15 GDPR.

2. Right to rectification

You also have a right to obtain the rectification of inaccurate personal data. For more information, please consult article 16 GDPR.

3. Right to erasure

In some cases, you can request us to erase your personal data e.g. when personal data is no longer required for the purposes for which we have collected it, when the personal data is processed based upon your consent and you withdraw your consent, etc.

In some exceptional cases, Wundo is not obliged to grant your request to erase your personal data. For more information, please consult article 17 GDPR.

4. Right to restriction of processing

You may request a restriction of your personal data e.g. if you dispute the accuracy of your personal data, if the processing activity is unlawful, etc. A restriction of the processing means that we may only store your data temporarily, except in case you nevertheless consent to the processing of your data, in the context of legal proceedings or in the public interest. A restriction can be terminated afterwards. For more information, please consult article 18 GDPR.

5. Right to data portability

If we process your personal data based upon your consent or based upon the performance of a contract, you can ask us to transfer your data to yourself or to another controller (if this is technically possible). In exceptional cases, Wundo is not obliged to follow up on your request. For more information, please consult article 20 GDPR.

6. Right to object 

You can inform us of the particular reasons why you wish to object to the particular processing activity based upon Wundo’s legitimate interest or in the context of the public interest. If these particular reasons outweigh our legitimate interests, we will terminate the processing activity. Wundo cannot follow up on your request when we process your personal data for the purposes of a legal claim. For more information, please consult article 21 GDPR.

7. Right to object to the processing of your personal data for direct marketing purposes

If we process your personal data for direct marketing purposes, you can always request us to stop processing your personal data without you having to give up a special reason. For more information, please consult article 21 GDPR.

8. Right not to be subject to profiling

Wundo will not process your personal data for profiling purposes unless you have given us your explicit consent (see points 4 and 5 of this privacy policy). For this reason, you have the liberty to choose whether or not you wish to receive personalised information and advertisements. In these cases, Wundo will ensure that you have the right to obtain human intervention or to express your point of view. For more information, please consult article 22 GDPR.

9. Right to withdraw your consent at any time

If the processing of your data is based on your consent, you also have the right to withdraw your consent at any time, without this affecting the legitimacy of the processing done prior to the withdrawal of your consent.

10. Exercising the aforementioned rights

Exercising the abovementioned rights can easily be done in different ways, such as by e-mail, by mail, by filling in the contact form on our website or by contacting our customer service department. Support is available during business hours (9:00–17:00 CET) via email. For privacy and safety reasons, we may request proof of your identity.

11. Competent supervisory authority

In accordance with article 77 of the General Data Protection Regulation (GDPR), you have the right to lodge a complaint with the supervisory authority of your habitual residence, your place of work or the place of an alleged infringement of the GDPR. The Belgian Data Protection Authority is the supervisory authority for Belgium and can be contacted by post (Drukpersstraat 35, 1000 Brussel) or by email contact@apd-gba.be .

Article 11. What about links to other websites and social media?

The websites and platform of Wundo can contain references (e.g. via hyperlinks) to other websites, which are offered by other companies or by social media. Wundo is not responsible for the processing of personal data via these websites. Nor does this privacy policy apply to these websites. Wundo advises you to check the privacy policies of these social media. 

If you share content from Wundo websites via social media, your personal data will be visible for the visitors of these social media. Wundo is not responsible for the processing of personal data via these social media. Nor does this privacy policy apply to these social media.

Article 12. How are you informed of changes to this privacy policy?

We strive to provide you with the best service. Therefore, this privacy policy can be modified. We thus advise you to check this privacy policy regularly on our websites. Any major changes will be announced via other communication channels. The date of modification can be found at the bottom of the privacy policy. 

Article 13. Who can you contact in order to exercise your rights?

If you have any further questions or complaints about the processing of your personal data, about  Wundo’s websites or about this privacy policy you can always contact us by e-mail at privacy@wundo.ai .


Version October 16, 2025.