Privacy Policy

Last updated: December, 2025

1. Introduction

This Privacy Policy describes how Wisely B.V. (trading as "Incree," "we," "us," or "our"), a company registered in the Netherlands, collects, uses, and shares information when you use our AI-powered sales and customer engagement platform and related services ("Services").

We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

Data Controller Contact

  • Company Name: Wisely B.V.
  • Trade Name: Incree
  • CoC (KvK): 94583226
  • VAT ID: 866826932B01
  • Address: Onderwijsboulevard 694, 5223DV 's-Hertogenbosch
  • Email: info@incree.nl

2. Information We Collect

2.1 Information You Provide

  • Account Information: Name, email address, phone number, company name, billing information.
  • Business Data: Customer lists, conversation histories, product information, pricing data.
  • Communication Data: Messages, voice notes, images, and documents shared through our platform.
  • Payment Information: Processed securely through Stripe (we do not store full card details).

2.2 Automatically Collected Information

  • Usage Data: Features used, conversation metrics, API calls, performance data.
  • Device Information: IP address, browser type, operating system, device identifiers.
  • Log Data: Access times, pages viewed, system activity, error reports.
  • Location Data: Approximate location based on IP address.

2.3 Information from Third Parties

  • Social Media Platforms: When you connect WhatsApp, Instagram, or Facebook Messenger via our platform.
  • OAuth Providers: Profile information when you choose to log in via Google, Microsoft, or Facebook.

3. How We Use Your Information

3.1 Primary Purposes

  • Provide, operate, and maintain our Services.
  • Process AI-powered conversations and sales automation.
  • Handle customer support and respond to inquiries.
  • Process payments and manage subscriptions.
  • Send service updates, security alerts, and important notifications.

3.2 AI Processing

To provide our intelligent features, we utilize AI services from third-party providers, including OpenAI, Anthropic, and Google (Gemini).

Important regarding AI Training:

  • Your data is NOT used to train the third-party AI models utilized by our Services.
  • We have configured our agreements and settings with AI providers to ensure your data remains confidential.

3.3 Legal Basis for Processing (GDPR)

We process your data based on:

  • Contract Performance: To provide the Services you have requested.
  • Legitimate Interests: To improve our platform, prevent fraud, and ensure security.
  • Consent: For marketing communications and tracking cookies.
  • Legal Obligations: To comply with tax laws and other regulatory requirements.

4. Data Sharing and Sub-Processors

To provide our Services, we share data with trusted third-party service providers. We have Data Processing Agreements (DPAs) in place with all sub-processors.

4.1 We share data with:

  • AI Service Providers: OpenAI, Anthropic, Google (Gemini)
  • Communication & Social Platforms: Meta (Direct APIs for WhatsApp, Instagram, Messenger)
  • Infrastructure & Hosting: DigitalOcean (Amsterdam, EU), Stripe (Payments)
  • Analytics & Marketing: Google Analytics, Meta Pixel, LinkedIn Insight Tag

4.2 We do NOT:

  • Sell your personal data.
  • Share data for third-party marketing (except where you have consented to our own remarketing efforts).
  • Transfer data outside the EU without appropriate safeguards.

5. Data Retention

  • Active Account Data: As long as your account is active.
  • Conversation Data: 3 years after the last activity (configurable).
  • Financial Records: 7 years as required by Dutch tax law.
  • Marketing Data: Until you withdraw consent.

Upon account termination, we delete or anonymize your operational data within 30 days, except where retention is required by law.

6. Your Rights Under GDPR

You have the right to Access, Rectification, Erasure, Portability, Restriction, and Objection regarding your data.

To exercise these rights, please contact us at: info@incree.nl

We will respond to your request within 30 days.

7. Cookie Policy

We use Essential Cookies (for functionality), Analytics Cookies (Google Analytics), and Marketing Cookies (Meta/LinkedIn pixels). You can control cookies via your browser settings.

8. Data Security

We implement robust security measures including hosting within the EU (DigitalOcean Amsterdam), encryption in transit (TLS/SSL), and encryption at rest.

9. International Data Transfers

Our primary infrastructure is in the Netherlands (EU). Transfers to US-based providers (like OpenAI/Stripe) are protected by the EU-US Data Privacy Framework or Standard Contractual Clauses (SCCs).

10. White-Label and Agency Services

If you use Incree to provide services to your own clients (End-Users):

  • You (the Agency) are the Data Controller for your End-Users' data.
  • Wisely B.V. (Incree) acts as your Data Processor.
  • A separate Data Processing Agreement (DPA) governs this relationship.

Contact Us

Wisely B.V.
Onderwijsboulevard 694
5223DV 's-Hertogenbosch
The Netherlands
info@incree.nl