Last updated 27 September 2019
1. Parties and Object
EUROLOGOS GROUP SPRL (hereinafter referred to as "EUROLOGOS" or "the Processing Manager")
Chaussée de Boondael 6 box 5 in 1050 Brussels, Belgium
Crossroads Bank of Enterprises / VAT: BE0438027056
EUROLOGOS has drafted this confidentiality policy, the purpose of which is to clearly notify Users of the website hosted at the following address: www.eurologos.com (hereinafter referred to as "the Site") and persons who send information by email to any address belonging to the eurologos.be domain name of the way in which their personal data will be gathered and processed by EUROLOGOS.
Here the term "User" refers to all users, whether natural or legal persons, who visit the Site, interact with it in any way or send data via email to any address belonging to the eurologos.be domain name.
As such, EUROLOGOS shall determine all technical, legal and organisational means and purposes with regard to the processing of User personal data. To this end, EUROLOGOS shall endeavour to take all measures necessary to process personal data in accordance with the law of 30 July 2018 on the protection of individuals with regard to the processing of personal data (hereinafter referred to as "the Law") and the European Regulation of 26 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data (hereinafter referred to as "the Regulation").
EUROLOGOS is free to choose any natural or legal person to process the personal data of its users at its request and on its behalf (hereinafter referred to as "the Subcontractor"). If necessary, EUROLOGOS shall undertake to select a Subcontractor offering sufficient guarantees with regard to technical and organisational security measures for the processing of personal data, by virtue of the Law and the Regulation.
2. Processing of personal data
Use of the Site or the sending of material by Users via email may lead to the communication of personal data. Any processing of said data by EUROLOGOS in its capacity as Processing Manager or by service providers acting in its name and on its behalf shall comply with the Law and the Regulation.
Personal data shall be processed by EUROLOGOS in accordance with the following objectives as outlined below, via:
- use of the Site (containing cookies);
- sending of contact forms completed on the Site or via email;
- sending requests for information through the forms on the Site or via email;
- sending of requests for services and the issuing of orders via the forms on the Site or via email;
- sending of job applications via email.
3. Purpose of processing of personal data
In accordance with article 13 of the Regulation, the purpose of the processing of personal data shall be communicated to the User and it shall be as follows:
- to ensure that services are provided to the User;
- to answer the User’s questions;
- to improve the quality of the Site and services proposed by the Processing Manager;
- to make it possible to better identify User needs.
4. Personal data likely to be processed
- information provided for contractual purposes and to allow the smooth fulfilment of reciprocal obligations, i.e. surname, first name, postal address, email address, telephone number, IBAN number and banking data and more generally any information voluntarily submitted by the User;
- during visits to the Site, the data gathered automatically are as follows: IP address, type of browser model, time zone, operating system, all data concerning the pages that the User browses on the Site, and in particular the URL and time of visit.
The User has the right to withdraw his or her consent at any time. Withdrawal of consent shall not affect the legality of the processing performed based on the consent previously given.
6. Length of time for which User data may be stored
In accordance with article 13 §2 of the Regulation and of the Law, the Processing Manager shall only keep personal data for such time as is reasonably necessary in order for the data processing purposes to be accomplished.
7. Data recipients and communication to third parties
Personal data may be sent to the agents, employees, subcontractors and suppliers of EUROLOGOS, who provide sufficient guarantees regarding data security and cooperation with EUROLOGOS within the framework of the marketing of products and the provision of services. They act on the direct authority of EUROLOGOS, and are in particular responsible for collecting, processing and outsourcing this data.
In the event that the data is communicated to third parties for the purposes of direct marketing or canvassing, the User shall first be notified so that he or she may indicate consent to the use of said personal data.
8. User rights
The User may exercise his or her rights at any time by sending an email to the following address: email@example.com, or by sending a letter to the following postal address, enclosing a copy of proof of identity: Chaussée de Boondael 6 box 5, 1050 Brussels, Belgium
a. Right to access
In accordance with article 15 of the Regulation, EUROLOGOS guarantees the User the right to access his or her personal data. The User has the right to obtain access to the aforementioned personal data and also the following information:
- purposes of data processing;
- the personal data categories concerned;
- the recipients or categories of recipients to whom the personal data has been or will be communicated, and in particular the recipients who are established in third countries and international organisations;
- where possible, the length of time that the personal data is intended to be kept, or if this is not possible the criteria used to determine said length of time;
- the existence of automated decision making, including profiling, as specified in article 22, paragraphs 1 and 4 of the Regulation, and - at least in such cases - useful information on the underlying logic, as well as the importance and intended consequences of said processing for the person concerned.
The Processing Manager may request payment of a reasonable fee based on the administrative costs regarding any additional copies requested by the User.
If the User makes this request electronically (for example, using the email address), the information shall be provided in a standard electronic format, unless the User requests otherwise.
A copy of his or her data will be sent to the User by the month following receipt of the request at the latest.
b. Right of rectification
EUROLOGOS guarantees the right to check and delete user personal data.
In accordance with article 16 of the Regulation, any incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User shall first proceed with the necessary modifications himself or herself from his or her user or other account, unless the modifications cannot be made independently, in which case the request may be made through EUROLOGOS.
In accordance with article 19 of the Regulation, the Processing Manager notifies each recipient to whom the personal data is communicated of any rectification of the personal data, unless such communication proves impossible or requires disproportionate effort. The processing manager supplies information on these recipients if the person concerned so requests.
c. Right to erase
The User has the right to secure the erasure of his or her personal data within the quickest possible time and under the circumstances listed in article 17 of the Regulation.
When the Processing Manager publishes the personal data and is obliged to delete it under the terms of the previous paragraph, in view of the technologies available and implementation costs, the Processing Manager shall take reasonable measures (including technical measures) to notify the other processing managers who are processing said personal data that the person concerned has requested the erasure by the processing managers of any links to said personal data and any copies or reproductions of said data.
The provisions of the two previous paragraphs do not apply to the extent that the processing is needed:
- in order to exercise the right to freedom of speech and information;
- to comply with a legal obligation which necessitates the specified processing by EU law or by the law of the Member State to whom the processing manager is accountable, or to carry out a public interest remit or one involving the exercising of the public authority conferred upon the processing manager;
- in order to recognise, exercise or uphold rights in court.
In accordance with article 19 of the Regulation, the Processing Manager notifies each recipient to whom the personal data is communicated of any erasure of personal data and any limitation of the processing carried out, unless such communication proves impossible or requires disproportionate effort. The processing manager supplies information on these recipients if the person concerned so requests.
d. Right to restrict processing
The User has the right to restrict the processing of his or her personal data in the cases listed in article 19 of the Regulation.
In accordance with article 19 of the Regulation, the Processing Manager notifies each recipient to whom the personal data is communicated of any processing restrictions applied, unless such communication proves impossible or requires disproportionate effort. The processing manager supplies information on these recipients if the person concerned so requests.
e. Right of data portability
In accordance with article 20 of the Regulation, Users shall have the right to receive from EUROLOGOS the personal data concerning them in a structured format, used as standard and able to be read by a machine. Users have the right to send this data to another processing manager without EUROLOGOS being able to do anything to prevent this in the cases specified by the Regulation.
If the User is exercising his or her data portability right in application of the paragraph above, he or she has the right to ensure that the data is sent directly from one processing manager to another provided this is technically possible.
Exercising the data portability right in no way affects the right to erasure. This right does not apply for any processing that is required in order to carry out a public interest remit or that relates to the exercising of authority on the part of the public authority conferred upon the processing manager.
The data portability right does not affect the rights and freedoms of third parties in any way.
f. Right to refuse and taking of individual automated decisions
The User may exercise his or her right to refuse the processing of personal data due to his or her particular situation, including the automation of data performed by EUROLOGOS. In accordance with article 21 of the Regulation, EUROLOGOS will no longer process personal data unless there are legitimate and imperative reasons to do so which prevail over the interests and rights of the User, or in order to contest, exercise or uphold rights in court.
If the personal data is processed for canvassing purposes, the User has the right to refuse the processing of his or her personal data - at any time - for canvassing purposes, including profiling to the extent that this is linked to such canvassing activities.
If the person concerned refuses to process for canvassing purposes, the personal data shall no longer be processed for said purposes.
g. Right to complain
The User has the right to file a complaint with the Data Protection Authority, which has jurisdiction for Belgium, regarding the processing of his or her personal data by EUROLOGOS. More information is available on the following website: https://www.autoriteprotectiondonnees.be.
Complaints may be addressed to the following addresses:
Autorité de Protection des Données
Rue de la Presse 35, 1000 Brussels
Tel. + 32 2 274 48 00
Fax. + 32 2 274 48 35
The User may also file a complaint with the court of first instance in the legal district of his residence.
a. Guiding principles
A "cookie" is a file temporarily or permanently placed on the User’s hard drive during a visit to the Website with a view to subsequent connections. Thanks to cookies, the server is able to recognise the User’s computer.
Cookies may also be installed by the third party partners of EUROLOGOS.
Some cookies used by EUROLOGOS are necessary for the proper functioning of the Site, while others make it possible to improve the User’s experience.
The User may personalise or deactivate cookies by changing his or her browser settings.
By using the Website, the User indicates that he or she expressly agrees that cookies may be managed as described in this article.
b. Type of cookies and purposes served
A number of different types of cookie are used by EUROLOGOS on the Site:
- Technical cookies: they are required for the operation of the Website, allow communication of the data entered and are intended to facilitate browsing by the User.
- Cookies to measure statistics and audience: these cookies make it possible to recognise the User and are used to count the number of Users on the Website over a given period of time. As they also give some indication of browsing behaviour, they are an effective way to improve browsing by the User, as they are able to display product and service offerings that may be of interest. They also allow EUROLOGOS to uncover any possible bugs on the Website and to correct them.
- Functional cookies: these cookies facilitate use of the Website by retaining some of the selections made (e.g. Username and language)
c. Length of time cookies are stored for
Cookies are stored for the time required in order to serve the intended purpose. Cookies that are likely to be stored on the User’s hard drive are as follows, with details on their storage time:
Validity: 2 years
Third-party cookie: Google Analytics.
Explanation provided by Google: Used to identify users.
Validity: 24 hrs
Third-party cookie: Google Analytics.
Explanation provided by Google: Used to identify users.
Validity: 1 minute
Third-party cookie: Google Analytics.
Explanation provided by Google:
Used to regulate rate of demand. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.
Validity: 1 year
Validity: End of browsing session
This type of cookie allows session management. The connection time of your session is saved.
d. Cookies management
If the User deactivates some cookies, he or she acknowledges that the Website may no longer function optimally. Some sections of the Website may therefore become totally or partially unusable.
If the User wants therefore to manage and/or remove some of the cookies, he or she can do this using the following link(s):
For Users with the following browsers:
- Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
- Microsoft Edge: http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq
- Chrome: https://support.google.com/accounts/answer/61416?hl=fr
- Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
- Safari: https://support.apple.com/kb/ph21411?locale=fr_CA
10. Limitation of liability for the Processing Manager
The Website may contain links to other websites owned by third parties not affiliated with EUROLOGOS. EUROLOGOS is not in any way responsible for the content of these sites and their compliance with the Law and the Regulation.
Express parental consent must be given in order for any children aged under 16 to divulge information or personal data on the Website. EUROLOGOS strongly recommends that those with parental authority do all they can to encourage the responsible and secure use of the Internet. The Processing Manager may not be held liable for having gathered and processed information and personal data from persons aged under 16 years whose consent is not actually covered by those of their legal parents or guardians, nor may he be held liable for any incorrect data - in particular concerning the age entered by the person aged below 16. Under no circumstances may personal data be processed by the Processing Manager if the User specifies that he or she is aged under 16 years.
EUROLOGOS may not be held liable for any loss, corruption or theft of personal data, in particular that caused by the presence of viruses or following hacking attacks.
The Processing Manager shall implement all organisational and technical measures possible to ensure an appropriate level of security for the processing and gathering of data. These security measures shall vary according to the implementation costs with regard to the nature, context and purposes of the personal data processing.
The Processing Manager shall use standard encrypting technology within the IT sector for the transfer or gathering of data on the Site.
13. Applicable law and jurisdiction