Privacy Policy

Inclusio SA (hereinafter referred to as "us", "we" or "The Company") is committed to protecting and respecting your personal privacy.

This policy provides the basis for how we will process any data we collect about you or that you provide to us. Please read the text below carefully in order to understand our vision and practices regarding your data and how we will use that data. By browsing our website, you accept and agree to the practices described in this Privacy Policy.

Information we collect about you

We will collect and process the following data about you:

Data you provide to us:

This is data about you that you provide to us by filling out forms on our website or by communicating with us by phone, email or other channel. This includes data you provide to us, when you fill out an online contact form or subscribe to the newsletter. The data you provide us includes your name, first name and e-mail address.

Information we collect about you

Each time you visit our website, we automatically collect the following information :
On each of your visits to our website, we will collect the following data by automated means: Technical data including the IP (Internet Protocol) address used to connect your computer to the Internet, browser type and version, time zone, browser plug-in types and versions, operating system and platform.
Data about your visit including the full Uniform Resource Locators (URL), the click sequence to, on and from our website (including date and time), the products/services you viewed or searched for, page response times, download errors, length of visit to certain pages, data about interaction with the page (such as scrolling, clicks and mouse-overs), methods used to leave the page.

Cookies

Our website uses cookies. This helps us to provide you with a good experience when you browse our website, and it also allows us to improve our website. For detailed information about the cookies we use, and the purposes for which we use them, please see our Cookie Policy.

Uses made of your data

We use the information we have about you in the following ways:

Data you provide to us

We will use this data to:

To fulfill our obligations resulting from any agreements we have with you, and to provide you with the data and services you request from us;
Notifying you of changes in our services;
To ensure that the content of our website is presented in the most effective manner for you and your computer/device.

Information we collect about you

We will use this data:

To manage our website for internal operation, including troubleshooting, data analysis, testing, research, statistical purposes and surveys;
To improve our website to ensure that content is presented in the most effective way for you and your computer/device;
To allow you to participate in interactive features of your service, if you choose;
As part of our efforts to keep our website secure and prevent fraud.

Data we get from other sources

We may combine this data with data you give us, and data we collect about you. We may use this data and the combined data for the following purposes:

To improve our website to ensure that content is presented in the most effective way for you and your computer/device.

Legal Basis

Your data is collected and processed on the following legal bases:

When necessary to pursue our legitimate interests, to the extent that your fundamental rights and freedoms do not outweigh those interests, we will use your information to know your preferences, better personalize our product offerings, prevent fraud and secure our website.
As needed to perform our agreement with you; or
If you have agreed to this, e.g. if you have given your prior explicit consent, we may use your e-mail address to send you marketing messages.

Communication of your data

You agree that we have the right to share your data with our selected third parties:

Our branches/other entities within the Group;
Government services (including justice and police services);
Our suppliers of IT-related services, e.g. SAP;
Analytics and search engine service providers that assist us in improving and optimizing our website, e.g. Google.

We will also disclose your information to third parties:

If we sell or buy any business or assets, where we will disclose your information to the potential seller or buyer of such business or assets;
If the Company or substantially all of its assets are acquired by a third party, the Company's customer data may be one of the transferred assets;
If we are required to disclose or share your data in order to comply with a legal obligation or to protect the rights, property or safety of the Company, our customers or others. This includes exchanging data with government agencies (including law enforcement and police departments), for example in the event of a cyber security incident.
If appropriate to accomplish any of the purposes set forth in Section 3 of this Privacy Policy.

Transfer of your data

We may transfer your data to a destination outside the European Economic Area (EEA) if this is appropriate (i) to achieve any of the purposes set out in section 3 and/or (ii) to communicate your data to a third party in accordance with section 5 of this Privacy Policy.

If your data is transferred outside the EEA, we will ensure that your data is protected using the following security mechanisms:

The laws of the country to which your data is transferred guarantee an adequate level of data protection (Article 45 GDPR); or
The transfer is covered by the data protection clauses approved by the European Commission (Article 46.2 AVG) or by the EU-US Privacy Shield;
The transfer is based on binding corporate rules (Article 47 AVG), an approved code of conduct (Article 40 AVG); an approved certification mechanism (Article 42 AVG); an approved data transfer agreement (Article 46.3 AVG); data protection clauses adopted by the Belgian data protection authority (Article 46.2 AVG).

If you would like to receive further details about the transfer of your data and/or the security mechanisms put in place (including how to receive a copy thereof), please contact us using the contact details found below in item 12.

Your rights

You have certain rights regarding the data we hold about you. These rights can be exercised by contacting us as set out below:

You have the right to access the data we hold about you - this is because we want you to be aware of the data we hold about you, and to enable you to check that we are processing your data in accordance with applicable data protection laws and regulations;
You have the right under certain circumstances to block or stop further use of your data. When processing is restricted in this way, we can still store your data, but we can no longer use it;
If your data is incorrect or incomplete, you have the right to request the correction of your data;
You have the right under certain circumstances to request that your data be erased or deleted from our systems;
You have the right to complain to your national data protection authority about the way we treat or process your data;
If our processing of your personal data is specifically based on your consent, you have the right to withdraw that consent at any time. This includes your right to withdraw your consent to the use of your data for direct marketing purposes;
You have the right, under certain circumstances, to obtain your data from us in a structured, common and machine-readable form so that you can reuse it for your own purposes for different services. For example: if you want to work with another service provider, you can easily and securely transfer your data to this new service provider.

You also have the right to object to certain forms of processing, including processing for direct marketing purposes.

Note, however, that we may need to retain certain data, for example, for legal or administrative purposes (e.g., record keeping).

For all requests mentioned above, please send us an e-mail to info@inclusio.be with "data privacy request" in the subject line and attach a copy of your identity card or other proof of your identity (e.g. driver's license). By doing so, you will help us prevent unauthorized access, modification or deletion of your data. We will respond to your request as soon as practically possible. If (after receiving your request) we will take more than one month to respond to your request, we will get back to you and let you know.

Security of data collected

We have implemented a number of security features in our website to prevent unauthorized release of or access to data collected and/or received. While we have made every effort to create a secure and reliable website for you, please note that we cannot guarantee the confidentiality of any communication or material sent by or to us or any other party through our website. We cannot be held responsible or liable for the security of any data sent using these methods.

All information you provide to us is stored on secure servers. If we have given you (or you have chosen) a password that allows you to access certain areas of our website, you are responsible for keeping this password confidential. We ask that you not share this password with anyone else.

Keeping track of your information

The data we hold about you will be kept in a manner consistent with applicable data protection laws. In no case will your data be kept longer than necessary to achieve the purposes stated in this Privacy Policy.

In particular, we will:

Keep your information about your online search only as long as necessary to provide you with the requested information

Unless:

The processing of your data is required in connection with any actual or potential litigation (for example, we need this data to bring or defend legal actions), in which case we will retain your data until the end of such litigation; and/or
Retention is necessary for us to comply with any legal or regulatory obligation (for example, for tax purposes), in which case we will retain your data for as long as required by that obligation.

External websites

Our website may from time to time contain links to and from websites and/or applications of our partner networks, advertisers and affiliates. To the extent that hyperlinks or hyperlinked banner advertisements are used to access third-party websites and/or applications, please be aware that these third-party websites and/or applications are not controlled by us and have their own privacy policies. Therefore, they are not subject to this Privacy Policy and we accept no responsibility or liability for them. Please review these policies before sending any data to these websites and/or applications.

Agreement on the collection and use of your information - changes to our Privacy Policy

By using this website, you acknowledge that you have read the terms of this Privacy Policy and that you consent to the collection and use of your information as set forth above.

We may change this Privacy Policy from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page and, if applicable, notified to you by email. Please check back periodically to see if the Privacy Policy has been updated or changed. Your continued use of this website following the posting of changes to this Privacy Policy constitutes your acceptance of those changes. This Privacy Policy was last updated on 31 08 2020.

Identity of the controller -contact information

The designated Controller under this Privacy Policy is the Company with company number BE 0840.020.295, located at 40 Avenue Herrmann-Debroux, 1160 Brussels

Questions, comments and requests about the Privacy Policy should be addressed to Inclusio - Avenue Herrmann-Debroux 40, 1160 Brussels - info@inclusio.be.

Complaints

If you would like more information, or to file a complaint, please contact the Data Protection Authority:

The Data Protection Authority
Rue de la Presse 35 - 1000 Brussels
Tel: +32 (0) 2 274 48 00
Fax: +32 (0) 2 274 48 35
E-mail: contact@apd-gba.be
URL : www.dataprotectionauthority.be/citizen