This website or application (“Website”) is an initiative of Circletex, non-profit association under Belgian law, with company number BE 0764.399.689 and with its registered office at Koningin Astridlaan 59A bus 9, 1780 Wemmel (“Circletex” of “we”). Any user of or visitor to the Website (“User”, “Visitor” of “you ”) shall provide personal data by visiting and/or using the Website as further explained below. Circletex acts as the responsible entity for processing with regard to personal data collected via the Website.

Circletex strives to collect and process your personal data in accordance with the applicable legal framework, such as the Belgian Privacy Act of 8 December 1992 and the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 (hereinafter “GDPR”).

You declare that you have read this Privacy and Cookie Policy (“Policy”), and therefore accept the processing of your personal data as described herein.

This Policy is subject to future adjustments and changes by Circletex. Circletex will clearly communicate such adjustments or changes, after which you expressly accept these changes. It is therefore up to the Visitor or User to consult this Policy on a regular basis.

1. Who processes your personal data?

Circletex acts as the controller for the processing. Circletex also uses a number of processors who process your personal data on behalf of Circletex, and who ensure the proper technical functioning of the Website.

Circletex makes use of the following categories of processor in the context of the Website:

• Processors who are responsible for hosting or creating the Website
• Processors who collect and display statistics from the Website
• Processors who provide email marketing and other communication services

2. Why is your personal data processed?

Circletex collects and processes your personal data in order to offer you a safe, optimal and personal user experience of the Website. Data processing is essential for the proper functioning of the Website and the associated services. The processing is done for the following purposes and other compatible purposes:

• To provide the User with access to his or her user profile with which he or she can perform actions on our Website;
• To offer a general and personalised service;
• Sending communications of a commercial or non-commercial nature;
• Informing about the activities and services of Circletex;
• Checking declarations and paying premiums if applicable;
• Managing customers, suppliers and other business partners;
• Providing support in the event of questions or comments;
• Follow-up of complaints regarding the operation of our Website;
• Performing analyses and drawing up reports;
• Performing audits to verify the relevant figures;
• Announcing and registering for events;
• Promoting our cooperation with you;
• Detection of and protection against fraud, errors, criminal or illegal behaviour and/or any other action that contravenes the terms of our Website.

Circletex processes and stores your personal data for as long as this is necessary for the purposes described above.

3. On what grounds are your personal data processed?

Circletex processes your personal data collected via the Website on the basis of (i) your acceptance of this Policy, and/or (ii) the preparation and execution of the agreement concluded between you and Circletex through the Website (iii) compliance with our legal obligations, and/or (iv) promotion of the legitimate interest of Circletex, such as conducting direct marketing, preventing fraud, managing internal administration or monitoring appropriate network and information security.

4. How is your personal data collected?

Your personal data is obtained on the one hand by you, for example, creating your profile or filling in online forms, on the other hand by various technical means employed by the Website to optimise the User– and Visitor experience and to detect any (technical) errors in the Website, such as cookies (see article 7) and log information.

5. Which categories of personal data are processed?

Circletex collects the following categories of personal data, insofar as applicable to you:

• Identification data: Surname, first name
• Contact details: E-mail address, telephone number
• Professional data: Position, employer, company number
• Personal characteristics: Gender, language
• Payment details: Bank account number
• IP address, time of consultation, probable location of consultation, data relating to the device used.

6. Will my data be transferred to third parties within the EU?

Your personal data can be shared with the categories of processors as defined in Article 1 of this Policy, business partners of Circletex and with authorities or government.

Your personal data will not be sold, passed on or communicated to third parties.

7. Cookies & Scripts

This Website uses only functional scripts to provide the layout of the website. This website does not use any cookies to track or follow you or to collect personal data. Cookies are small text files that are placed on the hard drive of your computer and allow us to recognize the User or Visitor and thus allow them to use the website functions efficiently. This Website only uses cookies that are strictly necessary for the communication or for the provision of a service that you have explicitly requested, such as technical cookies and cookies about the content of the transaction (the choice of language, the content of a form, etc.). Consult your browser settings if you do not want a website to place cookies on your computer or to delete your cookies.

This site uses Fathom Analytics, which is GDPR compliant, for visitor statistics.

8. What are my rights?

You can exercise a number of rights regarding your personal data with regard to Circletex, insofar as you have those rights under applicable law.

You can exercise these rights via email, accompanied by proof of your identity. Circletex will respond to such requests and may or may not comply with such requests in accordance with applicable law and in principle within a period of one month, also in accordance with applicable law.

You can also address or submit a complaint to the Data protection authority (Belgian Privacy Committee).

Right to object

You have the right to object, on grounds relating to your specific situation, to the processing of your personal data that is based on Circletex’s legitimate interest, and to object to the processing of your personal data for direct marketing.

Right of access and inspection

You have the right to inspect your personal data and to obtain a copy of this personal data. You also have the right to certain information regarding the processing of your personal data, including the purposes of this processing, the categories of personal data, the categories of recipients, etc.

Right to improvement

You have the right to have incorrect personal data corrected or to supplement personal data. In the first instance, you can change your data yourself in your profile.

Right of erasure

You have the right to have your personal data deleted if and to the extent:

1. your personal data is no longer necessary for the purposes;
2. (there is no longer a legal basis for processing;
3. you object to processing and there are no overriding legitimate grounds for processing by Circletex;
4. your personal data has been processed unlawfully; or
5. your personal data must be deleted in order to comply with a legal obligation placed on Circletex.

Right to restriction of processing

You have the right to have the processing of your personal data restricted by Circletex if and to the extent:

1. you dispute the accuracy of the personal data, for a period that enables Circletex to verify its accuracy;
2. the processing is unlawful and you oppose the deletion of the personal data and instead request the restriction of its use;
3. Circletex no longer needs the personal data for the purposes, but you need it for a legal claim;
4. you have objected to processing, pending the answer to the question as to whether Circletex’s legitimate grounds outweigh those of the User or Visitor.

You have the right to object, on grounds relating to your specific situation, to the processing of your personal data that is based on Circletex’s legitimate interest, and to object to the processing of your personal data for direct marketing.

In the event of restriction of processing, the data may still be stored by Circletex.

Right to data portability

For the personal data that (i) are processed in the context of the execution of the agreement, (ii) were provided by yourself and (iii) are processed via an automated proces, you have the right to obtain it from Circletex in a structured, commonly used and machine-readable form, as well as to transfer that data to a similar supplier or have it transferred directly, if this is technically possible.