Commencement date of this Privacy Statement: 1 December 2019
General introduction to the Privacy Statement
This Privacy Statement concerns the processing of your personal data by Ebucon bvba during all interactions with Ebucon bvba, for instance, when you visit our website, use our services as a visitor or partner, subscribe to our newsletters, contact experts, etc.
Ebucon bvba treats your privacy seriously. It processes the personal data obtained in accordance with the principles on the processing of personal data and the obligations imposed by European Directive (EC) 2016/679 of the European Parliament and the Council of 27 April 2016 concerning the protection of natural persons with regard to the processing of personal data and with regard to the free circulation of this data and to the revocation of Directive 95/46/EC, or the “General Data Protection Regulation” (“GDPR).
When processing the personal data obtained, Ebucon bvba takes account of the following principles which all data processing must meet, in particular:
a) The personal data is processed with respect to the data subject in a manner which is legitimate, proper and transparent (“lawful, fair and transparent”);
b) The personal data will only be collected for well-defined, explicitly described and legitimate purposes. Ebucon bvba does not further process this data in any manner that is incompatible with these purposes (“purpose limitation”);
c) The personal data must be adequate, relevant and be limited to what is necessary for the purposes for which it is processed (“data minimization”);
d) The personal data must be correct and updated where necessary; Ebucon bvba takes all reasonable measures to immediately remove or correct personal data that is inaccurate, in view of the purposes for which it is processed (“accuracy”);
e) The personal data must be stored in a form that does not allow the data subjects to be identified for any longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods where the personal data is processed merely with a view to archiving it in the public interest and for scientific or historical research or statistical purposes in accordance with article 89(1), provided that the appropriate technical and organisational measures required under this regulation are taken to protect the rights and freedoms of the data subject (“storage limitation”).
f) By taking appropriate technical or organisational measures, personal data is processed in such a manner that appropriate protection is guaranteed, and that it is protected amongst other things against unauthorised or illegitimate processing and against unintentional loss, destruction or damage (“integrity and confidentiality”).
Who is the controller for the processing of the personal data?
Ebucon bvba, registered in the Crossroads Bank for Enterprises under number 0543.993.816, with its registered office at Dorpsstraat 163/A, 8340 Damme, Belgium, and represented by its business manager, Johan Houbart, +32 473 607 210
What personal data do we process?
We understand personal data to be all information about an identified or identifiable natural (living) person.
We do not in principle process directly identifiable personal data via our website www.ebucon.be unless you have provided this to us voluntarily, for instance, by completing and sending the contact form, sending an email via our website or by subscribing to our newsletter.
· When completing the contact form: your surname, first name, company name, email address and telephone number. Other data that cannot be further specified which you provide in the “message” section. When subscribing to our newsletter: your email address.
· We also process certain non-directly identifiable personal data when you visit our website, such as the type of web browser and the operating system of the computer that you use, your IP address, etc.
During other interactions where information is exchanged (meetings via telephone, email, video conferences, etc.), we solely collection personal data that is either necessary for the performance of the agreement which you enter into with us, or which is necessary to comply with a legal requirement.
For what purposes is your personal data used and under which eligibility grounds is your data processed?
The personal data that we obtain via our website is used for the following purposes:
· Data provided via the contact form:
We solely use this data for entering into contact with you. This is underpinned by the legal ground of “contractual necessity”.
· When subscribing to the newsletter:
We only use your email address to send you email messages via Ebucon bvba. The legal ground for this processing is “consent”.
· The non-directly identifiable personal data obtained via Google Analytics because you visit our website, such as the type of web browser, the operating system of the computer that you use, your IP address, etc.:
We solely use this data to enable us to better organise and improve our website. The legal grounds for this processing are “legitimate interest”, in particular “freedom to conduct business” and “good business operation”.
· Personal data obtained during other interactions (for instance, during meetings or via email):
We solely process this personal data to enable us to correctly provide services or to meet a legal obligation. The legal grounds for this processing are “contractual necessity” and “legal obligation”.
Who receives your personal data?
The personal data that we process is not accessible in principle by third parties and it is merely used internally by Ebucon bvba. Nevertheless, Ebucon bvba uses third parties for certain services or technical services, such as web hosting, organising email campaigns, the use of specific software, cloud computing and ITC support, and third parties do have access to your personal data within this context. Ebucon bvba has entered into separate processor agreements with each of these service providers who process personal data on behalf of Ebucon bvba, in accordance with Article 28 of the GDPR.
We may exchange certain personal data with the following categories of recipients solely within the context of the normal provision of services and depending on the nature of the assignment entrusted to Ebucon bvba:
· Experts (third-party service providers with whom Ebucon has entered into a partnership) which the client wishes to call upon.
Furthermore, Ebucon bvba does not provide your personal data to other third parties unless it is legally required to do so.
Is your data sent to a third country outside of the European Economic Area?
We use specific software provided by an external service provider only for sending our email campaigns. This service provider may process your data outside of the European Economic Area. This processor processes the data in the United States and it is subject to an appropriate level of protection in the form of participation in the EU-US Privacy Shield.
Storage period for your personal data
The personal data that is necessary for the performance of the service between Ebucon bvba and the client is stored for up to ten years after the service provision has ended. The email addresses collected for sending newsletter are stored until the data subject has objected to the processing (unsubscribed).
Your rights as a data subject.
As a natural person whose personal data is processed by Ebucon bvba, you have the following rights:
· The right to inspect your personal data;
· The right to correct your personal data;
· The right to remove your personal data;
· The right to restrict your personal data;
· The right to object to the processing;
· The right to data portability.
To exercise these rights, you can contact Ebucon bvba via firstname.lastname@example.org or send a letter by registered post to Ebucon bvba, Dorpsstraat 163a 8340 Damme
Processing based on consent.
When the processing of personal data is based on consent, you have the right as a data subject to withdraw your consent at any time, without this affecting the legitimacy of the processing based on your consent before it was withdrawn.
Right to submit a complaint.
If you have a complaint about the processing of your personal data by Ebucon bvba, you can contact Ebucon bvba via email@example.com or send a letter by registered post to Ebucon bvba, Dorpstraat 163A, 8340 Damme, Belgium.
As a data subject, you have the right at all times to submit a complaint to the Data Protection Authority (formerly the Privacy Commission), Drukpersstraat 35, 1000 Brussels, Belgium (02/274.48.00 or firstname.lastname@example.org).
Contractual or legal obligation to provide data.
With the exception of data processing within the context of direct marketing (sending mail-outs), Ebucon bvba processes the personal data of users of its website and its clients under the grounds of a legal or contractual obligation. The data subject is not obliged to provide the requested personal data, in which case the provision of the service cannot proceed.
Use of automated individual decision-making.
Ebucon bvba does not process any personal data with a view to automated individual decision-making, including profiling.
Processing of personal data for a purpose other than the purpose for which it was collected.
When Ebucon bvba intends to further process your personal data for a purpose other than the purpose for which the personal data was collected, Ebucon bvba will inform the data subject prior to any further processing about the other purpose and will provide all relevant further information.
You are free to subscribe to our newsletters. Your subscription is based on your consent, in the sense of a free, specific, informed and unambiguous indication of intent where you as a data subject accept by means of a statement or an unambiguous positive action that your personal data will be processed. You always have the option to unsubscribe from our newsletter without providing reasons. The effect of unsubscribing is that your email address will be moved to the “unsubscribers” category and will not be further used.
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