PRIVACY POLICY
1. Parties and Purpose
Thomas Dolvelde (hereinafter "Thomart" or the "Data Controller")
ECB / VAT: BE0777.997.606
Mail: info@thomart.be
Telephone: 0475/76.32.10

Thomart has established this Privacy Policy in order to transparently inform Users of the website hosted at the following address: www.Thomart.be, (hereinafter the "Site"), of the manner in which personal data is collected and processed by Thomart.

The term "User" refers to any individual or legal entity who visits or interacts in any way with the Site.

As such, Thomart determines all the technical, legal and organizational means and purposes of processing Users' personal data. To this end, Thomart undertakes to take all necessary measures to guarantee the processing of personal data in compliance with the Law of July 30, 2018, on the protection of individuals with regard to the processing of personal data (hereinafter, "the Law") and the European Regulation of April 26, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter, "the Regulation").

Thomart is free to choose any individual or legal entity that processes users' personal data at its request and on its behalf (hereinafter the "Subprocessor"). Where applicable, Thomart undertakes to select a Sub-processor offering sufficient guarantees as to the technical and organizational security measures for the processing of personal data, with regard to the Law and the Regulation.

2. Processing of personal data
The use of the Site by Users may result in the communication of personal data. The processing of such data by Thomart, in its capacity as Data Controller, or by service providers acting in the name and on behalf of Thomart, will comply with the Law and the Regulation.

Personal data will be processed by Thomart, in accordance with the purposes mentioned below, via: prospecting, contract renewal, appointment setting, Thomart's own advertising communication.

3. Purpose of personal data processing
In accordance with Article 13 of the Regulation, the purposes for which personal data is processed are communicated to the User and are as follows:

Ensure the execution of the services offered and agreed upon with customers or on the site.
Monitor the performance of the services offered.
To carry out marketing and promotional information activities with the prior consent of the User and until such consent is revoked, for example by sending promotional information on the products and services of the Data Controller.
To compile statistics in order to improve the website, the services offered and the internal organization of operations.
To better identify the User's interests.
4. Personal data likely to be processed
When visiting and using the Site, the User consents to Thomart collecting and processing the following personal data in accordance with the terms and principles described in this Privacy Policy:

Information provided by Users for contractual purposes and to enable the proper performance of reciprocal obligations, i.e. surname, first name, address, IBAN or bank number, date of birth, national number, e-mail address, website, fixed and/or mobile telephone number, copy of identity card, VAT number, legal form of company, a copy of contract, customer number existing with different types of suppliers and/or operators, ean code, sim card number; and more generally, any information voluntarily given by the User.
We collect information from Users by filling in forms or by contacting them by telephone, e-mail or other means, such as name, address, e-mail address and telephone number.
With regard to each of the Users' visits to the Site, the information collected is as follows;
a. IP address, browser type and model, time zone, operating system;

b. all information concerning the pages that the User has consulted on the Site, in particular the URL, browsing time, etc.

5. Consent
By accessing and using the Site, the User declares that he/she is aware of and gives his/her free, specific, informed and unequivocal consent to the processing of his/her personal data. This agreement covers the content of the present Privacy Policy.

Consent is given by the positive act by which the User has checked the box proposing the Privacy Policy in hypertext link. This consent is an indispensable condition for carrying out certain operations on the Site or for allowing the User to enter into a contractual relationship with Thomart. Any contract between Thomart and a User concerning the services and goods offered on the Site is subject to the User's acceptance of the Privacy Policy.

The User consents to the processing and collection by the Data Controller, in accordance with the terms and principles set out in this Privacy Policy, of the personal data that the User communicates on the Site or when using the services offered by Thomart, for the purposes indicated above.

The User has the right to withdraw consent at any time. Withdrawal of consent does not compromise the lawfulness of processing based on consent previously given.

6. Retention period for Users' personal data
In accordance with article 13 §2 of the Regulation and the Law, the Data Controller only keeps personal data for as long as is reasonably necessary to achieve the purposes for which it is processed.

In all cases, this period is less than: 3 years

7. Recipients of data and disclosure to third parties
Personal data may be transmitted to Thomart's employees, collaborators, subcontractors or suppliers who offer adequate data security guarantees, and who collaborate with Thomart in the marketing of products or the provision of services. They act under the direct authority of Thomart, and are in particular responsible for collecting, processing or subcontracting such data.

In all cases, the recipients of the data and those to whom the data has been disclosed comply with the contents of this Privacy Policy. Thomart assures that they will only process such data for the intended purpose, in a discreet and secure manner.

In the event that data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed in advance so that he/she may express his/her consent to the use of such personal data.

8. User rights
At any time, the User may exercise his rights by sending a message by e-mail to the following address: info@thomart.be, or a letter by post addressed, enclosing a copy of his identity card to the following address: Rue du Pachy 20, 1315 Incourt

a. Right of access
In accordance with Article 15 of the Regulation, Thomart guarantees the User the right of access to his/her 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 has been or will be communicated, in particular recipients established in third countries or international organizations;
where possible, the length of time for which personal data will be kept or, where this is not possible, the criteria used to determine this length of time;
the existence of automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the Regulation, and, at least in such cases, useful information concerning the underlying logic, as well as the significance and expected consequences of such processing for the data subject
The Data Controller may charge a reasonable fee based on administrative costs for any additional copies requested by the User.

Where the User submits such a request electronically (by e-mail address, for example), the information is provided in a commonly used electronic form, unless the User requests otherwise.

The User will be sent a copy of his or her data no later than one month after receipt of the request.

b. Right of rectification
Thomart guarantees the user the right to rectify and delete personal data.

In accordance with Article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User shall first make the necessary changes himself/herself from his/her user/other account, unless such changes cannot be made autonomously, in which case a request may be made to Thomart.

In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom personal data has been communicated of any rectification of personal data, unless such communication proves impossible or would require disproportionate effort. The Data Controller shall provide the data subject with information about such recipients if the data subject so requests.

c. Right to erasure
The User has the right to obtain the deletion of his personal data as soon as possible in the cases listed in Article 17 of the Regulation.

Where the Controller has made the personal data public and is required to erase it pursuant to the preceding paragraph, the Controller shall, taking into account available technology and implementation costs, take reasonable steps, including technical steps, to inform other controllers who process such personal data that the data subject has requested the erasure by such controllers of any links to, or copies or reproductions of, such personal data.

The two preceding paragraphs do not apply insofar as such processing is necessary:

the exercise of the right to freedom of expression and information;
to comply with a legal obligation to process that is laid down by Union law or by the law of the Member State to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
the establishment, exercise or defense of legal claims.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom personal data has been communicated of any erasure of personal data or restriction of processing carried out, unless such communication proves impossible or requires disproportionate efforts. The data controller shall provide the data subject with information on these recipients upon request.

d. Right to limit processing
The User has the right to obtain the limitation of the 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 Data Controller shall notify each recipient to whom personal data has been communicated of any restriction on the processing carried out, unless such communication proves impossible or requires disproportionate efforts. The Data Controller shall provide the data subject with information about such recipients if the data subject so requests.

e. Right to data portability
In accordance with Article 20 of the Regulation, Users have the right to receive from Thomart personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transfer this data to another data controller without Thomart being able to prevent this in the cases provided for by the Regulation.

Where the User exercises her right to data portability pursuant to the preceding paragraph, she has the right to obtain that personal data be transmitted directly from one data controller to another, where technically possible.

The exercise of the right to data portability is without prejudice to the right to erasure. This right does not apply to processing that is 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.

f. Right to object and automated individual decision-making
The User has the right at any time to object to the processing of his/her personal data due to his/her particular situation, including the automation of data carried out by Thomart. In accordance with Article 21 of the Regulation, Thomart will no longer process personal data, unless there are compelling legitimate grounds for the processing that override the interests and rights and freedoms of the User, or for the establishment, exercise or defense of legal claims.

Where personal data is processed for canvassing purposes, the User has the right to object at any time to the processing of his/her personal data for such canvassing purposes, including profiling insofar as it is linked to such canvassing.

If the data subject objects to the processing for canvassing purposes, the personal data will no longer be processed for these purposes.

g. Right to complain
The User has the right to lodge a complaint concerning the processing of his/her personal data by Thomart with the Data Protection Authority competent for Belgian territory. Further information can be found on the website: https://www.autoriteprotectiondonnees.be.

Complaints can be submitted to the following addresses:

Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Tel. + 32 2 274 48 00
Fax: + 32 2 274 48 35
E-mail: contact@apd-gba.be

The User may also lodge a complaint with the court of first instance in his place of residence.

9. Cookies
Thomart attaches great importance to protecting the privacy of its visitors. We would like to inform you clearly about the use of your data when you visit our site. No collection of personal data Our website does not collect any personal data. No information concerning your identity, contact details or preferences is recorded during your browsing. Use of cookies Our site does not use tracking, analysis or advertising cookies. We therefore do not place any files on your device to collect browsing information. This means that you can browse in complete peace of mind, without any tracking or analysis of your activity on our site. If you have any questions or require further information, please do not hesitate to contact us..

a. General principles
A "Cookie" is a file deposited temporarily or permanently on the User's hard disk when consulting the Website, with a view to subsequent connection. Cookies enable the server to recognize the User's computer.

 

10. Limitation of the data controller's liability
The website may contain links to other websites owned by third parties not related to Thomart. Thomart is not responsible for the content of these sites or their compliance with the Law and Regulations.

The holder of parental authority must give his or her express consent for a minor under the age of 16 to disclose information or personal data on the website. Thomart strongly advises persons exercising parental authority over minors to promote responsible and secure use of the Internet. The Data Controller cannot be held responsible for collecting and processing information and personal data from minors under the age of 16 whose consent is not effectively covered by that of their legal parents, or for incorrect data - in particular concerning age - entered by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he/she is under 16 years of age.

Thomart is not responsible for the loss, corruption or theft of personal data caused by viruses or computer attacks.

11. Security
The Data Controller implements organizational and technical measures to guarantee a level of security appropriate to the processing and collection of data. These security measures depend on the cost of implementation in relation to the nature, context and purposes of the personal data processing.

The Data Controller uses industry-standard encryption technologies when transferring or collecting data on the Site.

12. Modification of the Privacy Policy
Thomart reserves the right to modify this Privacy Policy in order to comply with legal requirements. The user is therefore invited to consult the Privacy Policy on a regular basis in order to take note of any modifications and adaptations. Any such modification will be posted on the Site or sent by e-mail for enforceability purposes.

13. Applicable law and jurisdiction
This Privacy Policy is governed exclusively by Belgian law. Any dispute shall be brought before the courts of the judicial district of Thomart's registered office.

14. Contact
For any questions or complaints relating to this Privacy Policy, the User may contact the Data Controller at the following address: info@thomart.be

Updated on December 17, 2021