Privacy and personal data policy

1. GENERAL

This Privacy Policy applies to the personal data (hereinafter the “Data”) that we collect from you in order to provide you with the products and services we offer.

We attach particular importance to the protection of your personal data, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and with the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.

2. CONTACT DETAILS OF THE DATA CONTROLLER

CUSTY BELGIUM SPRL (hereinafter “CUSTY”), whose registered office is at Résidence du Midi 4, 6530 THUIN (Belgium), registered with the Crossroads Bank for Enterprises under number (BE) 0457.886.025, is the controller of the personal data that you provide to us directly in the context of our contractual relationship, on the one hand, and via our website CUSTY.COM, on the other.

3. WHAT DATA DO WE COLLECT, FOR WHAT PURPOSE AND ON WHAT LEGAL BASIS?

This is the Data that you provide to us in the context of our contractual relationship, on the one hand, and through the forms available on the CUSTY.COM website, on the other, as well as through cookies placed by us or, more generally, by third-party services.

We will only use the Data for the legitimate purposes we pursue. These processing purposes are as follows:

3.1. In the context of our contractual relationship

3.1.1. Ensuring the security of systems

The purpose of this processing is to ensure the security of systems by maintaining the IT infrastructure (server maintenance, antivirus, backups, security, updates, configuration of the multifunction printer, etc.).

In this respect, we process the following Data:

• Personal identification data: name, first name, address, telephone number;
• Electronic identification data: email address;
• Security-related data: login and password;
• Connection data: IP addresses, connection times, log files.

The legal basis for this processing is our legitimate interest.

3.1.2. Customer relationship management

We collect your Data for the purpose of managing the contractual relationship between us: management of contracts, orders, invoices and payments, after-sales service.

This Data is as follows:

• Personal identification data: name and first name (of a contact person), billing address, telephone number (where applicable, of a contact person);
• Electronic identification data: email address (where applicable, of a contact person);
• Financial identification data: bank account number and VAT number where applicable;
• Transactions / financial situation: billing information, amounts due and paid, balances, payment methods, guarantees, etc.;
• Company number.

The legal basis for this processing is the performance of the contract.

3.1.3. Keeping Data up to date

The purpose of this processing is to keep your Data in the Customer database up to date (additions/deletions/changes).

• This database contains the following Data:
• Personal identification data: name and first name (of a contact person), billing address, telephone number (where applicable, of a contact person);
• Electronic identification data: email address (where applicable, of a contact person);
• Financial identification data: bank account number and VAT number where applicable;
• Transactions / financial situation: billing information, amounts due and paid, balances, payment methods, guarantees, etc.;
• Company number.

The legal basis for this processing is our legitimate interest.

3.1.4. Bookkeeping

The purpose of this processing is to enable us to keep our accounts.

• In the context of this processing, we process the following Data:
• Personal identification data: name, first name, address, telephone number;
• Electronic identification data: email address;
• Financial identification data: bank account number and VAT number where applicable;
• Transactions / financial situation: billing information, amounts due and paid, balances, payment methods, guarantees, etc.;
• Company number.

The legal basis for this processing is compliance with our legal obligations.

3.1.5. Compliance with accounting and tax obligations

The purpose of this processing is to enable us to comply with our accounting and tax obligations.

• In the context of this processing, we process the following Data:
• Personal identification data: name, first name, address, telephone number;
• Electronic identification data: email address;
• Financial identification data: bank account number and VAT number where applicable;
• Transactions / financial situation: billing information, amounts due and paid, balances, payment methods, guarantees, etc.;
• Company number.

The legal basis for this processing is compliance with our legal obligations.

3.2. CUSTY.COM website

3.2.1. Contact form

The purpose of this form is to enable you to send us any request for information about our services and products.

• Through this form, we collect the following Data:
• Personal identification data: name, first name, address;
• Free-text message;
• Connection data: IP addresses, connection times.

The legal basis for this processing is the performance of a pre-contractual measure.

3.2.2. Brochure request form

The purpose of this form is to enable you to ask us to send you a brochure about our services and/or products.

• Through this form, we collect the following Data:
• Personal identification data: name, first name;
• Electronic identification data: email address;
• Free-text message;
• Brochure requested;
• Connection data: IP addresses, connection times.

The legal basis for this processing is our legitimate interest.

3.3. Cookie management

This website uses cookies.

A cookie is a small file sent with the pages of a website and stored by the browser on the hard drive of your computer, tablet or phone. The information it contains may be sent back to the site’s servers during a subsequent visit, enabling the site’s author to track the user’s activity.

Please note that the term “cookies” also covers any other technical tracking method, such as “scripts” in general. A script is a fragment of programming code used to make a website work interactively. Finally, “web beacons”, “tracking pixels” and “social media cookies” are also cookies.

Cookies make it possible to personalise content and provide features necessary for a website to function properly, such as managing a shopping basket or remembering a language choice. Some cookies may be placed or controlled by third parties (partners or subcontractors) for targeted marketing purposes.

3.3.1. Technical cookies (“Necessary” or “Preference”)

We use certain cookies to remember your settings and preferences, such as the language chosen. These cookies are essential for the site to function properly and cannot be disabled without affecting the proper functioning of the site. This type of cookie and/or similar technology does not allow us to collect Data that could identify you.

3.3.2. Audience measurement cookies

We use them to analyse and improve the performance of the Site. We use tools that collect, for example, your IP address when you connect, the date and time of access to the Site, the pages viewed, the type of browser used, and the platform and/or operating system used.
The legal basis for this processing is your consent.

3.3.3. Marketing cookies

Marketing cookies are used to track visitors across the Site. The aim is to display advertisements that are relevant and engaging for the individual user and therefore more valuable for publishers and third-party advertisers.
The legal basis for this processing is your consent.

3.3.4. Consent

You can change or withdraw your consent at any time by setting your preferences atinfo@custy.com

3.3.5. List of cookies used on this site:

When you consent to all cookies, the following cookies may be placed:

4. HOW LONG DO WE KEEP YOUR DATA?

We will keep your Data for as long as necessary for the operations for which it was collected and in compliance with the legislation in force.

At the end of the retention period, the controller makes every effort to ensure that your Data has been made unavailable.

4.1. In the context of our contractual relationship

4.1.1. Ensuring the security of systems

Your Data is kept for as long as necessary for the purpose of the processing.

4.1.2. Customer relationship management

Your Data is kept for as long as necessary for the performance of the contractual relationship.

4.1.3. Keeping Data up to date

Your Data is kept for as long as necessary for the performance of the contractual relationship.

4.1.4. Bookkeeping

Your Data is kept for 7 years from the end of the performance of the contract.

4.1.5. Compliance with accounting and tax obligations

Your Data is kept for 7 years from the end of the performance of the contract.

4.2. CUSTY.COM website

4.2.1. Contact form

The Data is kept for as long as necessary to respond to your request.

4.2.2. Brochure request form

The Data is kept for as long as necessary to respond to your request.

5. TO WHOM MAY YOUR DATA BE DISCLOSED?

For the above purposes, your Data may be disclosed to the other companies belonging to CUSTY and forming part of the GIE Groupe Burrus Technologies.

In the course of providing our services, we may subcontract some or all of our tasks to technical subcontractors bound to us by contract.

CUSTY requires its subcontractors to comply with data protection legislation and to provide sufficient guarantees regarding the implementation of appropriate technical and organisational measures, so that the processing meets the requirements of the applicable data protection legislation and ensures the protection of your rights.

We do not sell or disclose, in any way whatsoever, the Data we collect about you to third parties.

In certain circumstances, our website and applications will provide you with plugins from various social networks. If you choose to interact with a social networking site such as Facebook or LinkedIn, your activity on our site or via our applications will also be accessible on that social network. Please read the privacy policies of these social networks for detailed information on the collection and transfer of personal information, your rights and how to obtain satisfactory privacy settings.

6. WHAT ARE YOUR RIGHTS?

• Right of access: you have the right to obtain confirmation that your Data is being processed, to have access to your Data at any time and free of charge, and to obtain a copy of your Data.
• Right to rectification: you have the right to require that incorrect Data be corrected, that incomplete Data be completed and that inappropriate Data or Data that is no longer needed be deleted. Please note that you are responsible at all times for checking the accuracy of the Data you provide to us.
• Right to erasure: when you no longer wish your Data to be processed and you meet the conditions for requesting erasure, we will delete your Data from our database.
• Right to data portability: where necessary, you will also be entitled to the portability of your Data under the conditions provided for by the applicable data protection legislation.
• Right to object: you have the right to object to any use of your Data where the processing is based on CUSTY’s legitimate interest.
• Right to restriction of processing: finally, you have the right to obtain from CUSTY the restriction of the processing of your Data, in accordance with the applicable data protection legislation.

7. HOW CAN YOU EXERCISE YOUR RIGHTS?

By sending an email to info@custy.com or a letter to the registered office of
CUSTY
Résidence du Midi, 4
6530 THUIN
Belgium

You can also contact our Data Protection Officer (DPO) by email at dpo@custy.com or by letter to
GDPR Agency
Chemin du Cyclotron, 6
1348 Louvain-la-Neuve
Belgium

8. WHAT HAPPENS IN THE EVENT OF A DISPUTE?

If you believe that we are failing to meet any of our legal and/or contractual obligations, please contact us by email at info@custy.com. We will do everything possible to follow up with you as quickly as possible.

Any claim, complaint or grievance should be sent to the address of CUSTY’s registered office.

If you are not satisfied with our response, you have the right to lodge a complaint with the supervisory authority of your country, the list of which is available here:
https://edpb.europa.eu/about-edpb/board/members_en

You can also contact the Belgian supervisory authority responsible for CUSTY (“lead” authority):

DATA PROTECTION AUTHORITY
Rue de la Presse 35
1000 Brussels
Email: CONTACT@APD-GBA.BE

9. INFORMATION CONCERNING CHILDREN

As a general rule, we do not knowingly collect personal information about children under the age of 13. If we discover that we have inadvertently collected information about children under 13, we will take steps to delete the information as soon as possible, unless the law in force requires us to keep it.

Where we know that a child is over 13 but is considered a minor under the law in force, we will obtain parental/guardian consent before using that child’s personal information.

10. LINKS TO OTHER WEBSITES AND SERVICES

Our sites may contain links to third-party sites, and some of our services give you access to third-party services (such as social networks).

We have no control over how third-party sites and services process your personal information. We do not check third-party sites and services, and we are not responsible for these third-party sites and services or their privacy practices. Please read the privacy statements of the third-party sites or services you access from our sites or services.

11. SECURITY

We have developed appropriate technical and organisational security rules to prevent the destruction, loss, falsification, modification, unauthorised access, accidental disclosure to third parties and any other unauthorised processing of Data.

12. LIMITATION OF LIABILITY

CUSTY’s liability shall be limited to direct damage, excluding any indirect damage. CUSTY can never be held liable for damage deemed indirect such as, without this list being exhaustive, loss of Data, financial or commercial loss, loss of profits, increased overheads or disruption of planning.

Furthermore, CUSTY cannot be held liable for any damage resulting from unlawful manipulation of the Data by third parties (Data theft, viruses, phishing or other computer offences).

We would also like to point out that the Website may contain hyperlinks and other references to other sites that we do not manage or control and to which these provisions do not apply. We are not responsible for the content of these websites or for the offers, products and services they provide. We therefore recommend that you carefully read the privacy rules of each site you visit, as these may differ from these rules.

13. GOVERNING LAW AND JURISDICTION

These provisions shall be governed, interpreted and enforced in accordance with Belgian law, which shall be the sole applicable law in the event of a dispute.

Any dispute that cannot be settled amicably within a period not exceeding one month from its occurrence, which period may be extended by mutual agreement, may be brought by the most diligent party before the French-speaking Courts and Tribunals of the judicial district of Hainaut, which shall have exclusive jurisdiction.

14. EFFECTIVE DATE

This policy was created and came into force on 01/08/2022. We reserve the right, at our sole discretion, to change, modify, add or remove parts of this policy at any time.