Privacy Policy

How we handle your data during the Winbooks to Odoo migration process.

Last updated: 09/10/2025

Document version 1.0

1. Introduction

This Privacy Policy outlines how Whatswhat Consulting SRL (“we”, “our”, or “us”) operating as Twinbooks, collects, uses, maintains, and discloses information collected from users (“you”, “your”) of our Winbooks to Odoo migration service (“Service”).

We are committed to protecting your privacy and handling your data in an open and transparent manner. This policy applies to information we collect during the process of importing data from Winbooks and migrating it to Odoo.

2. Data We Collect

During the Winbooks import and migration process, we may collect and process the following types of data:

  • Client Information: Company name, address, VAT number, contact details of company representatives
  • Business Data: Customer and supplier records, financial transactions, accounting entries, analytical accounting data
  • Financial Documents: Invoices, credit notes, payment records, asset registers, and other financial documentation
  • Technical Data: Information about your Winbooks database structure, chart of accounts, and configuration settings
  • Correspondence: Email communications, support requests, and other interactions related to the migration service

3. How We Use Your Data

We use the collected data for the following specific purposes:

  • To provide the Winbooks to Odoo migration service effectively
  • To import and transfer your financial data accurately
  • To preserve historical records including PDF attachments
  • To ensure data integrity and validate the migration process
  • To communicate with you about the migration progress
  • To provide technical support and troubleshooting assistance
  • To respond to your inquiries and service requests
  • To comply with legal and regulatory requirements

We process this data based on the following legal grounds:

  • Contract Performance: Processing is necessary for performing our service contract with you
  • Legal Obligations: Processing is necessary for compliance with legal obligations
  • Legitimate Interests: Processing is necessary for our legitimate business interests, such as improving our services
  • Consent: Where applicable, we process data based on your explicit consent

4. Data Storage and Security

We take the security of your data seriously and implement appropriate technical and organizational measures to protect your data against unauthorized access, alteration, disclosure, or destruction.

Your financial data is:

  • Processed on secure servers located within the European Economic Area (EEA)
  • Protected by encryption during transfer and storage
  • Accessible only to authorized personnel on a need-to-know basis
  • Retained only for the period necessary to complete the migration unless otherwise required by law

After the completion of the migration service, we will:

  • Delete your data within 30 days of service completion
  • Retain only minimal information required for legal and business record-keeping purposes
  • Securely archive any data that must be retained for regulatory compliance

5. Data Sharing

We do not sell, trade, or rent your personal or business data to third parties. We may share your information with:

  • Service Providers: Third parties who help us deliver our services, such as hosting providers and IT service providers
  • Professional Advisors: Accountants, lawyers, and consultants as necessary for our business operations
  • Legal Authorities: When required by law, court order, or governmental regulation

All third parties who process data on our behalf are required to respect the security of your data and treat it in accordance with applicable laws and our data protection standards.

6. Your Rights

Under data protection laws, you have rights regarding your personal data, including:

  • Right to Access: You can request a copy of the personal data we hold about you
  • Right to Rectification: You can ask us to correct inaccurate or incomplete data
  • Right to Erasure: You can ask us to delete your personal data under certain conditions
  • Right to Restriction: You can ask us to restrict processing of your data under certain conditions
  • Right to Data Portability: You can request the transfer of your data to another controller
  • Right to Object: You can object to our processing of your personal data under certain conditions

To exercise any of these rights, please contact us at hello@twinbooks.be. We will respond to your request within one month.

7. Cookies and Tracking

Our website uses cookies and similar tracking technologies to enhance your browsing experience and collect information about how you use our site. These technologies help us analyze website traffic, customize content, and deliver targeted advertisements.

We use the following types of cookies:

  • Essential Cookies: Required for the website to function properly
  • Analytics Cookies: Help us understand how visitors interact with our website
  • Marketing Cookies: Used to track visitors across websites to display relevant advertisements

You can control or delete cookies through your browser settings. However, disabling certain cookies may limit your ability to use some features of our website.

8. International Data Transfers

Your data is primarily processed within the European Economic Area (EEA). However, some of our service providers may be located outside the EEA. When transferring data outside the EEA, we ensure appropriate safeguards are in place, such as:

  • Standard Contractual Clauses approved by the European Commission
  • Adequacy decisions by the European Commission
  • Binding corporate rules for transfers within a corporate group

9. Children's Privacy

Our Service is not intended for children under 16 years of age. We do not knowingly collect personal information from children. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us so that we can take necessary action.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the new Privacy Policy on this page and, where appropriate, sending you an email notification.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

11. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Whatswhat Consulting SRL
Email: hello@twinbooks.be.

If you are not satisfied with our response, you have the right to lodge a complaint with the Belgian Data Protection Authority (GBA/APD).

© 2025 Whatswhat Consulting SRL. All rights reserved.