SolvaClear privacy statement

1. Who processes your data

The controller is Flex Business Attorneys bv, Drukkerijstraat 11 E, 9240 Zele, Belgium, enterprise number 1003.724.128. SolvaClear is a service of this firm.

If you have questions about the processing of your personal data, you can always reach us: by post at the address above marked “Privacy”, by e-mail at info@flexbusinesslaw.be, or by telephone on +32 52 48 11 34.

2. What we process

Through this app we process:

• your contact details: the name, company, e-mail address and telephone number you enter in the final step;
• the invoices you upload and everything printed on them: your own details, the identity and contact details of your debtor (name, enterprise number, address and, where stated, e-mail address and telephone number), the amounts, the dates and the description of what was invoiced;
• what you add or correct yourself: partial payments received and corrections to the automatically extracted details;
• your declarations: the confirmation that the details are correct and your acceptance of the disclaimer, with the moment you ticked them;
• the payment: the amount, the payment method, the reference and the time. Your card or account number never reaches us — it stays with our payment provider;
• one technical item: your language choice is stored in your own browser. We use no tracking cookies and keep no visitor statistics.

3. Why we process it, and on what basis

• To handle your request and to produce and deliver the solvency report. Legal basis: performance of the contract you enter into with us (art. 6(1)(b) GDPR).
• To assess the solvency of your debtor. We receive the debtor’s data from you and from public or private sources such as the Belgian Crossroads Bank for Enterprises, the filed annual accounts and the Central Register of Notices. Legal basis: the legitimate interest of our client in assessing and recovering their claim (art. 6(1)(f) GDPR).
• To invoice you and to meet our accounting and tax obligations, and to comply with anti-money-laundering legislation. Legal basis: a legal obligation (art. 6(1)(c) GDPR).

As stated in the firm’s general privacy statement, client data may — unless the data subject objects — be used for direct marketing purposes. You may object at any time, free of charge.

We take no decisions based solely on automated processing. The details are read from your invoice automatically, with the help of artificial intelligence, but you check and correct them yourself in the app, and the report is written by our lawyers.

4. Who we share it with

Your file is handled by the lawyers and staff of the firm, who are bound by professional privilege. For this app we also rely on:

• Anthropic PBC (United States) — reads the details from the invoice you upload, through its Claude API. The document is sent to that service for that purpose and is not used to train models.
• Resend (United States) — sends the e-mail that brings your request and your invoices to the firm.
• Mollie B.V. (the Netherlands) — processes your payment and sees the payment details we ourselves never receive.
• BaseNet bvba, Schaliënhoevedreef 20T, 2800 Mechelen, Belgium — the firm’s case management software.
• the party hosting this application.

A data processing agreement is in place with each of them. Where data leaves the European Economic Area — with Anthropic and Resend, both in the United States — this takes place on the basis of the European Commission’s standard contractual clauses, so that your data enjoys an equivalent level of protection there.

Beyond that we do not pass your data to third parties, except where this is necessary to carry out the instruction — for instance to a bailiff or a court if you later proceed to recovery — or where the law obliges us to.

5. How long we keep it

• On the server of this app: the uploaded invoices and the details of your request are deleted as soon as your request has reached the firm by e-mail. All that remains afterwards is the payment record — the reference, the amount, the time and the e-mail address we reply to — which we need for our accounts.
• In our file: electronic data is kept for the duration of the instruction and is thereafter kept for at least 5 years, after which it is archived under the closed files. Paper files may be destroyed 5 years after the file has been closed.
• With our processors: they keep the data only for as long as they need it to provide their service, under the data processing agreement concluded with them. Payment data is kept by our payment provider for as long as financial legislation requires.

6. Security

We have implemented appropriate technical and organisational measures to safeguard the confidentiality of your personal data and to protect it against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. All traffic with this app runs over an encrypted connection, and everything you send us is additionally covered by the professional privilege of the lawyer.

7. Your rights

You can contact us at any time to exercise the following rights:

• a request for access to or rectification of your personal data;
• a request for erasure of your personal data;
• a request for restriction of processing;
• an objection to the processing;
• the withdrawal of your consent;
• an objection to fully automated individual decision-making without human intervention that significantly affects you;
• a complaint if you believe we are not acting in accordance with data protection legislation. You may also lodge one with the Belgian Data Protection Authority, Drukpersstraat 35, 1000 Brussels, contact@apd-gba.be.

In the context of our legal services we process personal data on the basis of the legitimate interest of our client. We will therefore not be able to act on the objections above where we need that data to carry out our instruction in the interest of our client, or where professional privilege stands in the way.

8. Are you the company a screening was requested about?

Then we process your data without having received it from you. It came to us from our client — usually from an unpaid invoice — and we supplemented it with data from public sources such as the Crossroads Bank for Enterprises, the annual accounts filed with the National Bank, and the Central Register of Notices.

The rights set out above apply to you as well. Please bear in mind that the professional privilege of the lawyer and the legitimate interest of our client may prevent us from acting on a request, and that for the same reason we cannot always inform you of the processing in advance (art. 14(5) GDPR).

9. Changes

This statement may be amended from time to time, within the limits of data protection legislation. The most recent version is always available on this page.