Privacy & Cookie Policy

→ CLERENS PRIVACY POLICY

→ CLERENS COOKIE POLICY

CLERENS PRIVACY POLICY – Q&A

Effective since: 25 May 2018

We make it a matter of pride to respect the privacy of our users and to treat their personal data in the strictest confidentiality and in accordance with the legislation in force.

The privacy policy is intended to inform you, in a transparent manner, about the data we collect, the purpose for collecting it, the way we use it and the rights you have regarding the processing of such data.

We provide you with a simplified version of our privacy policy in the form of questions and answers. We invite you to also read the detailed version of our privacy policy.

We are committed to being transparent about the technologies we use, and we’ve outlined below how we use cookies when you visit our site www.clerens.com.

We draw your attention to the need to read this privacy policy carefully. If you have any other questions, do not hesitate to contact us at the following address: secretariat@clerens.eu

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

CLERENS NV/SA is the controller of your personal data.
Here is our complete contact information:
CLERENS NV/SA
AVENUE ADOLPHE LACOMBLE 59/8, 1030 BRUSSELS, BELGIUM
Belgian business registry (BCE) number: BE0791.153.081

secretariat@clerens.eu

2. WHAT DATA DO WE COLLECT?

We collect your data – personal or otherwise – for various reasons which are defined in the following point (see point 3). It includes the following data:

  • your identifying information (surname, first name, e-mail address, delivery address and country);
  • the type of domain with which you connect to the Internet;
  • the IP address assigned to you;
  • the date and time of your access to our website;
  • the pages you viewed on our website;
  • the type of browser, platform and/or operating system you are using;
  • the search engine and the keywords used to find the website;
  • your browsing preferences.

3. WHY DO WE COLLECT YOUR DATA?

We collect your data mainly to send our newsletter, improve our service and, more generally, to easily communicate with each other. Finally, your data also allows us to improve and facilitate your navigation on our website. We don’t collect your data to share them with anyone.

4. HOW DO WE COLLECT YOUR DATA?

Most of your data is communicated to us by your active intervention. Other data, such as the date and time of your access to our website, the pages you have viewed, or your location data, are collected automatically through servers consulted and “cookies” placed on our website. For more information on what a cookie is, how it is used and the exact data it collects, visit our page concerning our cookie policy.

5. ARE YOUR DATA PROTECTED?

We take pride in respecting the privacy of our users. We maintain a strict privacy policy and take all appropriate measures to ensure that our servers prevent, to the extent possible, any unauthorised leak, destruction, loss, disclosure, use, access or modification of your data.

6. HOW LONG DO WE STORE YOUR DATA?

We keep your data for the time necessary to accomplish the objectives pursued (see point 3). Once this goal is achieved, we either delete or anonymise them.

7. WHAT ARE YOUR RIGHTS AND HOW CAN THEY BE EXERCISED?

You may, at any time, request to verify, access, rectify, delete, transfer and object to the use of your data, as well as request the limitation of such use of your data. To do so, simply send us an email at the following address: secretariat@clerens.eu. We will then make every effort to take the necessary action as soon as possible.

8. WHO HAS ACCESS TO YOUR DATA AND TO WHOM ARE THEY COMMUNICATED?

Our employees have access to it and may use it only to the extent necessary for processing your request and/or for fulfilling the objectives pursued (see point 3). Each of them is subject to a strict obligation of confidentiality.

9. DO WE TRANSFER YOUR DATA ABROAD?

No, we do not transfer your data to anyone. The third party cookies may do so far web-page information (e.g. Google Analytics).

10. WHAT IS OUR POLICY ON DATA CONCERNING MINORS?

Our websites are not targeted at children under the age of 13. If you learn that your minor child has provided us with their personal data without your consent, contact us at the following address: secretariat@clerens.eu

11. WHAT HAPPENS IN THE EVENT OF A CHANGE TO THE PRIVACY POLICY?

If we had to make any changes to this privacy policy, you would be notified through our website or email.

CLERENS PRIVACY POLICY

Effective since: 25 May 2018

We make it a matter of pride to respect the privacy of our users and to treat their personal data in the strictest confidentiality and in accordance with the legislation in force.

The privacy policy is intended to inform you, in a transparent manner, about the data we collect, the purpose for collecting it, the way we use it and the rights you have regarding the processing of such data.

We draw your attention to the need to read this privacy policy carefully. If you have any other questions, do not hesitate to contact us at the following address: secretariat@clerens.eu

1 GENERAL WARNING

1.1 CLERENS NV/SA (from now on will be referred to as CLERENS) respects the privacy of its users (hereinafter, the “Users“).

1.2 CLERENS  processes the personal data transmitted to it in accordance with the legislation in force, and, in particular, Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, applicable from 25 May 2018 (hereinafter the “General Data Protection Regulation“).

1.3 Access to all websites managed by CLERENS (hereinafter, the “Websites”) implies the User’s full and unreserved acceptance of this Privacy Policy (hereinafter the “Policy”), as well as its general terms of service (hereinafter the “Terms”) and the cookie policy (hereinafter, the “Cookie Policy”).

1.4 The User acknowledges having read the information below and authorises CLERENS to process, in accordance with the provisions of the Policy, the personal data that he/she communicates on the Websites.

1.5 The Policy is valid for all pages managed by CLERENS and for the registrations of these Websites. It is not valid for the pages hosted by third parties to which CLERENS may refer and whose privacy policies may differ. CLERENS cannot, therefore, be held responsible for any data processed on these websites or by them.

2 DATA CONTROLLER

2.1 Simply visiting the Websites shall take place without having to provide any personal data, such as first name, surname, postal address, e-mail address, etc.

2.2 As part of the Service, the User may be required to provide certain personal data. In this case, the data controller is:

CLERENS NV/SA
AVENUE ADOLPHE LACOMBLE 59/8
1030 BRUSSELS
BELGIUM
Belgian business registry (BCE) number: BE0791.153.081

2.3 Any questions regarding the processing of this data may be sent to the following address: secretariat@clerens.eu

3 DATA COLLECTED

3.1 By completing an order or registration form on the Websites and using the Service, the User allows, in particular, CLERENS to record and store, for the purposes mentioned in point 4, the following information:

  • identifying data, such as the first name and surname, e-mail address and company delivery address, country;
  • invoicing information;
  • communications between the User and CLERENS;
  • The User also authorises CLERENS to record and store the following data for the purposes mentioned in point 4:
  • information voluntarily provided by the User for a purpose specified in the Policy, the general terms and conditions of sale (hereinafter the “GTC“), the Terms, the Cookie Policy, on the Website or on any other medium of communication used by CLERENS;
  • additional information requested by CLERENS to the User in order to identify him or to prevent him from violating any of the provisions of the Policy;

3.3 In order to facilitate browsing the Websites as well as to optimise technical management, the Websites may use “cookies”. These “cookies” record, in particular:

  • the User’s browsing preferences;
  • the date and time of access to the Websites and other data related to traffic;
  • the pages visited;

All information relating to “cookies” is included in CLERENS’s Cookie Policy.

3.4 When the User accesses the Websites, the servers consulted automatically record certain data, such as:

  • the type of domain with which the User connects to the Internet;
  • the IP address assigned to the User (when connected);
  • the date and time of access to the Websites and other data related to traffic;
  • the pages visited;
  • the type of browser used;
  • the platform and/or operating system used;
  • the search engine as well as the keywords used to find the Websites.

3.5 No nominative data identifying the User is collected through the cookies and servers consulted. This information is kept for statistical purposes only and to improve the Websites.

4 PURPOSES OF PROCESSING THE DATA

4.1     The Websites collect, store and use their Users’ data for the following purposes, in particular:

  • to establish, carry out and conduct the contractual relationship with the User;
  • to analyse, adapt and improve the content of the Websites;
  • to provide the Service;
  • to facilitate the availability and use of the Websites;
  • for any marketing activities and promotions proposed by CLERENS or affiliated associations to Users who have given their consent;
  • to inform them about any changes on the Websites and their features;
  • for any other purpose to which the User has expressly consented.

5 RIGHTS OF THE PERSON CONCERNED

5.1 According to the regulations on the processing of personal data, the User has the following rights:

  • Right to be informed about the purposes of the processing (see above) and the identity of the data controller.
  • Right of access and verification of data: the User may, at any time, have access to the data that CLERENS has on him or check if he is included in the database of CLERENS. CLERENS asks the User to make this request by mail in order to be able to identify him with certainty (Please provide CLERENS with your first name, surname, complete address and a copy of your identity card). CLERENS will thus be ensured that only the User accesses his data.
  • Right of objection: the User may, at any time, object to the use of his data by CLERENS and by its active partners by sending his request to CLERENS by mail.
  • Right of cancellation and/or modification: the user may, at any time, notify CLERENS of corrections to the data concerning him and, where appropriate, request the deletion of his personal data.
  • Right of limitation of processing: the User may, in particular, obtain a limitation of processing when he has objected to the processing, when he disputes the accuracy of the data, or when he considers that the processing is illegal.
  • Right of transferability: The User has the right to receive the personal data that he has communicated to CLERENS and may also ask said company to send this data to another data controller.

5.2 The User may, at any time, request access to his personal data, verify them, transfer them, and, in some cases, as aforementioned, limit their processing and rectify them, by writing to CLERENS accompanied by a copy of his identity card or passport to the following email address: secretariat@clerens.eu or to the postal address: CLERENS, AVENUE ADOLPHE LACOMBLE 59/8, 1030 BRUSSELS, BELGIUM.

5.3 The User may also request rectification free of charge and, where applicable, request the deletion of all his personal data from CLERENS’s database – except those which CLERENS has a legal obligation to keep on record – and object to the use and, where appropriate, request the limitation thereof by sending a written request, accompanied by a copy of his identity card or passport, to CLERENS: by e-mail: secretariat@clerens.eu by mail: CLERENS, AVENUE ADOLPHE LACOMBLE 59/8, 1030 BRUSSELS, BELGIUM

5.4 CLERENS will then take the necessary steps to satisfy this request as soon as possible.

6 DURATION OF STORING THE DATA

6.1 CLERENS will keep the personal data of its Users for the duration necessary to achieve the objectives pursued (see point 4).

6.2 CLERENS may also continue to keep personal data concerning the de-registered User, including all correspondence or request for assistance sent to CLERENS in order to be in a position to reply to all questions or complaints that may be sent to it after the order, and in order to comply with all applicable laws, namely with regard to taxes.

7 COMPLAINT WITH THE SUPERVISORY AUTHORITY

The User is informed that he has the right to lodge a complaint with the Commission for the Protection of Privacy.

Rue de la Presse, 35
1000 Bruxelles

commission@privacycommission.be

8 SECURITY

8.1 In order to guarantee optimal payment security, CLERENS uses online payment service INGENICO, which meets high-security standards.

8.2 In addition, CLERENS has taken the appropriate organisational and technical measures to ensure a level of security adapted to the risk and that, to the extent possible, the servers hosting the personal data processed prevent:

  • unauthorised access to or modification of this data;
  • improper use or disclosure of such data;
  • unlawful destruction or accidental loss of such data.

8.3 In this respect, employees of CLERENS who have access to this data are subject to a strict confidentiality obligation. Nevertheless, CLERENS may in no way be held liable in the event that this data is stolen or hijacked by a third party despite the security measures adopted.

8.4 Users undertake not to commit acts that may be contrary to this Policy, the Terms of Service, the Cookie Policy or, in general, the law. Violations of confidentiality, integrity and availability of information systems and data which are stored, processed or transmitted by these systems, or the attempt to commit one of these violations, shall be punishable by imprisonment of between three months and five years and a fine of between twenty-six euros and two hundred thousand euros, or one of these penalties only.

9 COMMUNICATION TO THIRD PARTIES

9.1 CLERENS treats personal data as confidential information. It will not communicate them to third parties under any condition other than those specified in the Policy, such as to achieve the objectives set out and defined in point 4, or under the conditions in which the law requires it to do so.

9.2 CLERENS may communicate its Users’ personal information to third parties to the extent that such information is necessary for the performance of a contract with its Users. In such a case, these third parties will not communicate this information to other third parties, except in one of the two following situations:

  • the communication of this information by such third parties to their suppliers or subcontractors to the extent necessary for the performance of the contract;
  • where such third parties are obliged by the regulations in force to communicate certain information or documents to the competent authorities in the field of combating money laundering, as well as, in general, to any competent public authority.

9.3 The communication of this information to the aforementioned persons shall, in all circumstances, be limited to what is strictly necessary or required by the applicable regulations.

10 TRANSFER TO A NON-EU COUNTRY OR COMPANY

CLERENS does not transfer data to non-EU countries. Third parties (e.g. Google Analytics) may execute transfers.

11 PAYMENT SERVICE

11.1 The payment service integrated into the Websites is provided by INGENICO at www.ingenico.com

11.2 The relationship between the User and INGENICO is governed by the Privacy Policy available at the following address: https://ingenico.be/privacy-policy which also includes provisions relating to the processing of personal data sent to INGENICO as part of its service, and for which INGENICO is the data controller.

11.3 When making a payment through CLERENS, the User declares that he/she has read, understood and accepted the INGENICO privacy policy.

12 DIRECT MARKETING

12.1 The personal data may be used by CLERENS or its affiliates for direct marketing purposes for similar services than those to which the User has already subscribed.

12.2 The User retains the right to object to such use at any time, upon request and free of charge. The User may simply communicate his request by writing to the following address: secretariat@clerens.eu

13 NOTE CONCERNING MINORS

Persons under the age of 13 and persons who do not have full legal capacity are not permitted to use the Website. CLERENS asks them not to provide their personal data.

14 UPDATES AND CHANGES TO THE POLICY

By informing Users through the Website, CLERENS may modify and adapt the Policy, in particular, to comply with any new legislation and/or regulations applicable (such as the General Data Protection Regulation applicable from 25 May 2018), the recommendations of the Belgian Privacy Commission, the guidelines, recommendations and best practices of the European Data Protection Board and the decisions of the courts and tribunals on this issue.

15 VALIDITY OF THE CONTRACTUAL CLAUSES

15.1 Failure by CLERENS to invoke – at any given time – a provision of this Policy, may not be interpreted as a waiver to subsequently make use of its rights under the said provision.

15.2 The invalidity, expiration or the unenforceable nature of all or part of one of the above or below mentioned provisions shall not give rise to the invalidity of all the Policy. Any fully or partially invalid, lapsed or unenforceable provision shall be deemed not to have been written. CLERENS undertakes to substitute this provision with another which, to the extent possible, fulfils the same objective.

16 APPLICABLE LAW AND COMPETENT COURT

16.1 The validity, interpretation and/or implementation of the Policy are subject to Belgian law, to the extent permitted by the provisions of applicable private international law.

16.2 In the event of a dispute relating to the validity, interpretation or implementation of the Policy, the courts and tribunals of Brussels have exclusive jurisdiction, to the extent permitted by the provisions of applicable private international law.

CLERENS COOKIE POLICY

Effective since: 25 May 2018

COOKIE POLICY

CLERENS operates a strict privacy policy. We are committed to being transparent about the technologies we use, and we’ve outlined below how we use cookies when you visit our site www.clerens.com

Insofar as the information collected using cookies constitutes personal data, the provisions of the Privacy Policy shall apply and supplement this Cookie Policy.

WHAT IS A COOKIE?

A cookie is a small snippet of text that a website asks your browser to store. All cookies have expiration dates in them that determine how long they stay in your browser. Cookies can be removed in two ways: automatically, when they expire, or when you manually delete them. We’ve included more details below to help you understand what kinds of cookies we use.

DOES CLERENS USE COOKIES?

Yes, with the primary purpose to make our website work more effectively and to memorise various information in order to facilitate your navigation on a website/a mobile application, to ensure the smooth functioning of these or to make them more effective, for example by memorising your language preferences.

WHAT KINDS OF COOKIES DOES CLERENS USE AND WHY?

We use different kinds of cookies for various reasons:

  • Essential cookies (strictly necessary) – These cookies are essential for browsing our Website or strictly necessary for the provision of a service specifically requested by a user. The removal of this type of cookies can lead to navigation difficulties and is therefore strongly discouraged.
  • Session cookies – These are temporary cookies that expire (and are automatically erased) whenever you close your browser. We use session cookies to grant access to content and things you have to log in to do.
  • Persistent cookies – these usually have an expiration date of several months and thus stay in your browser until they expire, or until you manually delete them. We use persistent cookies for functionalities like remembering login details, which makes it possible for registered users to return to the site without having to log in. We also use persistent cookies to better understand usage patterns so we can improve the site for our customers. This information is anonymised – when we look at the data, in other words, we look at patterns, but we do not see individuals’ personally identified information (PII).
  • Analytics cookies (statistics) – These cookies are used to gather information about your use of the Website, in order to improve the content of the Website, make it more suitable to your needs and increase its usability. For example, these cookies show us the most visited pages of the Website or help to identify difficulties that may be encountered during navigation.
  • Preference cookies (performance) – These cookies collect information about your choices and preferences and make your navigation more pleasant and personalised. These cookies make it possible to memorise the language chosen during your first visit to our Website in order to personalise it accordingly.

WHAT OTHER COOKIES MIGHT YOU ENCOUNTER ON CLERENS?

There are also limited third-party cookies on the site. These cookies could be session or persistent and are set by entities other than CLERENS. To ensure compliance with our policies, we restrict the use of third-party cookies to trusted partners of CLERENS. For example, we currently allow cookies from sites like Google Maps.

  • Social sharing – This allows you to share our content through various social sharing networks like Facebook, Twitter or LinkedIn. Social networks providing such a sharing button are likely to identify you with this button, even if you did not use this button when visiting our Website. We invite you to consult the privacy policy of these social networks, by visiting their respective websites, to learn the purpose of using the information collected through these sharing buttons.
  • Audience measurement and validation – We use services such as Google Analytics to understand how many people come and what is popular which helps us improve the website. No personally identifiable information (PII) is stored and site usage is always looked at on an aggregate (and anonymous) level. The same is done by our web hosting company.

The collection and use of information by these companies are governed by the relevant third party’s privacy policy and is not covered by our privacy policy.

HOW CAN I CONFIGURE, DELETE OR DISABLE COOKIES?

You can easily delete, disable or accept cookies from our Website at any time by configuring your browser settings.

Each browser (Internet Explorer, Safari, Firefox, Google Chrome, etc.) has its own cookie configuration mode. To learn about the procedure to follow concerning your navigator, visit the site: http://www.allaboutcookies.org/manage-cookies/.

OTHER QUESTIONS?

If you have other questions, contact us:

by sending an email to the following address: secretariat@clerens.eu

by writing to the following postal address:

CLERENS
CLERENS NV/SA
AVENUE ADOLPHE LACOMBLE 59/8
1030 BRUSSELS, BELGIUM

Belgian business registry (BCE) number: BE 0446.408.747