Koloban SRL (hereinafter “NetsuFLow” or the “Data Controller”) Av. Alphonse Allard 120 – 1420 Braine-l’Alleud BCE / VAT: BE0559906269
Register of legal entities: Nivelles – BELGIUM
NetsuFLow establishes this Privacy Policy, the purpose of which is to inform in complete transparency the Users of the website hosted at the following address: www.netsuflow.com, (hereinafter the “Site”), of the manner in which personal data is collected and processed by NetsuFLow.
The term “User” refers to any user, i.e. any natural or legal person, who visits or interacts in any way with the Site.
As such, NetsuFLow determines all the technical, legal and organizational means and purposes of the processing of Users’ personal data. NetsuFLow undertakes to take all necessary measures to ensure that personal data is processed in accordance with the law of 30 July 2018 on the protection of individuals with regard to the processing of personal data (hereinafter, “the Law”) and the European Regulation of 26 April 2016 on the protection of individuals’ data with regard to the processing of personal data and on the free movement of such data (hereinafter, the “Regulation”).
NetsuFLow is free to choose any natural or legal person who processes users’ personal data at its request and on its behalf (hereinafter, the “Subcontractor”). Where applicable, NetsuFLow undertakes to select a Subcontractor offering sufficient guarantees regarding the technical and organisational security measures for the processing of personal data, with regard to the Law and the Regulation.
The following person is appointed Data Protection Officer or Data Protection Officer (hereinafter “DPO”): Joachim Vandersleyen – email: joachim.vandersleyen@koloban.be
PROCESSING OF PERSONAL DATA
Use of the Site by Users may result in the communication of personal data. The processing of this data by NetsuFLow, in its capacity as Data Controller, or by service providers acting in the name and on behalf of NetsuFLow, will comply with the Law and the Regulation. Personal data will be processed by NetsuFLow, in accordance with the purposes listed below, via the Contact form page.
PURPOSE OF PROCESSING
In accordance with Article 13 of the Regulation, the purposes of processing personal data are communicated to the User and are as follows: contact the User.
PROCESSED PERSONAL DATA
The User consents, when visiting and using the Site, that NetsuFLow collects and processes, according to the methods and principles described in this Privacy Policy, the following personal data: name (first name – last name) , email address and telephone number.
CONSENT OF USER
By accessing and using the Site, the User declares that they have read and given their free, specific, informed and unambiguous consent to the processing of personal data concerning them. This agreement covers the content of this Privacy Policy. Consent is given by the positive act by which the User has checked the box offering the Privacy Policy in hyperlink. This consent is an essential condition for carrying out certain operations on the Site or for allowing the User to enter into a contractual relationship with NetsuFLow. Any contract binding NetsuFLow and a User relating to the information or services provided on the Site is subject to the User’s acceptance of the Privacy Policy.
The User consents to the Data Controller processing and collecting, in accordance with the terms and principles included in this Privacy Policy, his personal data that he communicates on the Site or on the occasion of the services offered by NetsuFLow, for the purposes indicated above.
The User has the right to withdraw his consent at any time. The withdrawal of consent does not compromise the lawfulness of the processing based on the consent previously given.
RETENTION PERIOD OF PERSONAL DATA
In accordance with Article 13 §2 of the Regulation and the Law, the Data Controller only stores personal data for the time reasonably necessary to enable the accomplishment of the purposes for which they are processed.
This duration is in all cases less than: 1 year
RECIPIENTS AND DISCLOSURE TO THIRD-PARTIES
Personal data may be transmitted to NetsuFLow’s agents, collaborators, subcontractors or suppliers who offer adequate data security guarantees, and who collaborate with NetsuFLow in the context of the marketing of products or the provision of services. They act under the direct authority of NetsuFLow, and are in particular responsible for collecting, processing or subcontracting this data.
In all cases, the recipients of the data and those to whom this data has been disclosed comply with the content of this Privacy Policy. NetsuFLow ensures that they will process this data for the sole purposes intended, in a discreet and secure manner.
In the event that the data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed in advance so that he can express his consent to the use of this personal data.
USER RIGHTS
At any time, the User may exercise his rights by sending an e-mail message to the following address: joachim.vandersleyen@koloban.be, or a letter by post addressed, attaching a copy of his identity card to the following address: Av. ALphonse Allard 120 – 1420 Braine-l’Alleud
1) RIGHT TO ACCESS
In accordance with Article 15 of the Regulation, NetsuFLow guarantees the User the right of access to his personal data. The User has the right to obtain access to said personal data as well as the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients established in third countries or international organisations;
where possible, the envisaged period for which the personal data will be stored, or, where not possible, the criteria used to determine that period;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation, and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject
The Controller may charge a reasonable fee based on administrative costs for any additional copies requested by the User.
Where the User makes such a request by electronic means (e.g. via the e-mail address), the information shall be provided in a commonly used electronic form, unless the User requests otherwise.
The copy of his data will be communicated to the User at the latest within one month after receipt of the request.
2) RIGHT TO RECTIFY
NetsuFLow guarantees the right of rectification and erasure of personal data to the User.
In accordance with Article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or erased at any time. The User first makes the necessary changes himself from his user account/other, unless these cannot be done autonomously, in which case the request can be made to NetsuFLow.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data has been communicated of any rectification of personal data, unless such communication proves impossible or requires disproportionate effort. The Data Controller shall provide the data subject with information on these recipients if the latter requests it.
3) RESTRICTION RIGHT OF PROCESSING
The User has the right to obtain restriction of processing of his/her personal data in the cases listed in Article 19 of the Regulation.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data have been disclosed of any restriction on the processing carried out, unless such communication proves impossible or requires disproportionate effort. The Controller shall provide the data subject with information about these recipients upon request.
4) DATA PORTABILITY
In accordance with Article 20 of the Regulation, Users have the right to receive from NetsuFLow the personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transmit this data to another controller without NetsuFLow hindering this in the cases provided for by the Regulation.
When the User exercises his or her right to data portability pursuant to the previous paragraph, he or she has the right to obtain that the personal data be transmitted directly from one controller to another, where technically feasible.
The exercise of the right to data portability is without prejudice to the right to erasure. This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
The right to data portability does not affect the rights and freedoms of third parties.
5) RIGHT TO OBJECT
The User has the right to object at any time to the processing of their personal data based on their particular situation, including the automation of data carried out by NetsuFLow. In accordance with Article 21 of the Regulation, NetsuFLow will no longer process the personal data, unless there are compelling legitimate grounds for the processing that override the interests, rights and freedoms of the User, or for the establishment, exercise or defense of legal claims.
Where personal data are processed for direct marketing purposes, the User has the right to object at any time to the processing of personal data concerning him or her for such direct marketing purposes, including profiling to the extent that it is related to such direct marketing.
Where the data subject objects to processing for direct marketing purposes, the personal data are no longer processed for these purposes.
6) RIGHT TO COMPLAIN
The User has the right to lodge a complaint regarding the processing of his or her personal data by NetsuFLow with the Data Protection Authority, which is competent for the Belgian territory. More information can be found on the website: https://www.autoriteprotectiondonnees.be.
Complaints can be lodged at the following addresses:
Data Protection AuthorityRue de la Presse 35, 1000 Brussels Tel. + 32 2 274 48 00Fax. + 32 2 274 48 35 E-mail: contact@apd-gba.be
7) RIGHT TO DELETE
The User has the right to obtain the deletion of his/her personal data without undue delay in the cases listed in Article 17 of the Regulation.
Where the Data Controller has made the personal data public and is required to erase them pursuant to the preceding paragraph, the Data Controller, taking into account available technology and the costs of implementation, shall take reasonable steps, including technical measures, to inform other data controllers processing the personal data that the data subject has requested the erasure by such data controllers of any links to, or any copy or reproduction of, the personal data.
The two preceding paragraphs shall not apply to the extent that such processing is necessary:
a. Exercise the right to freedom of expression and information;
to comply with a legal obligation which requires processing by Union or Member State law to which the controller is subject, or to carry out a task carried out in the public interest or in the exercise of official authority vested in the controller;
b. For the establishment, exercise or defence of legal claims.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data have been disclosed of any erasure of personal data or restriction of processing, unless such communication proves impossible or involves disproportionate effort. The Controller shall provide the data subject with information about these recipients if requested.
COOKIES
The Site uses cookies to distinguish Users of the Site. This allows to provide Users with a better browsing experience and an improvement of the Site and its content. The objectives and modalities of cookies are contained in this present article. A “Cookie” is a file temporarily or permanently deposited on the User’s hard drive when consulting the Website, with a view to a later connection. Thanks to cookies, the server recognizes the User’s computer. Some of the cookies used by NetsuFLow are necessary for the proper functioning of the Site, others improve the User’s experience. The User can customize or disable cookies by configuring their browser.
Cookies can also be installed by third parties with whom NetsuFLow collaborates.
By using the Website, the User expressly agrees to the management of cookies as described in this article. Both technical and statistical cookies can be used and necessary for the operation of the website.