This Policy applies to both personal data provided to us either by an individual or by organisations. We may use personal data provided to us for any of the purposes as set out in this Policy, or as otherwise disclosed at the point of collection.
"Affiliate" means any company, corporation or other entity that directly or indirectly controls, or is controlled by, or is under common control with either Alpega or Customer.
"Agreement" means the General Terms and Conditions of Alpega, any order form or contract proposal accepted by the Customer under any form for the subscription to Services and the approval thereof by Alpega, the documentation relating to the Services (including without limitation user manuals, training materials, supporting materials, technical specifications and requirements), and where applicable, any applicable Special Terms and Conditions of Alpega, this Policy, together constituting the entire agreement governing the relationship between Alpega and the Customer.
"Alpega" means Alpega S.A./N.V., a Belgian company with its registered office at Belgicastraat 17, 1930 Zaventem (Belgium), registered under number 0872.586.165 in the Belgian Registry of Companies, as well as its Affiliates.
"Customer" means the (legal or natural) person subscribing to the Services.
"Data Protection Legislation" means the provisions of the EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) and the Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector, as well as any national legislation and/or regulations implementing them, as this legislation may be amended or replaced from time to time.
"Services" means the products and services of Alpega and its Affiliates, as these may change from time to time, to which the Customer has subscribed under the Agreement.
"User" refers in this Policy to the visitors of the Websites and/or to the users of the Services on behalf of the Customer.
“you” and “your” (and other similar terms) to refer to Customers, individuals associated with Customers, Users, contacts, suppliers and job applicants.
“we”, “us”, and “our” (and other similar terms) to refer to Alpega.
"Websites" refers to all internet pages and applications provided and operated by Alpega.
For the purpose of this Policy, other terms such as "personal data", "processing", "data subject", "data controller", "data processor" and "supervisory authority" shall have the meanings set out in the applicable Data Protection Legislation .
2. Who is responsible for your personal data?
Alpega is the data controller responsible for your personal data. Our contact details are provided below.
3. What personal data do we collect and process?
We collect and process the following personal data from you:
If you provide information to us about any person other than yourself (your family, employer, employees, counterparties, advisers, suppliers…), you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it. If we need personal data in respect of individuals associated with Customers in order to provide Services we ask Customers to provide this Policy to such individuals as data subjects.
4. How do we collect your personal data?
In the majority of circumstances we will collect personal data (1) from Customers and Users or (2) if you sign up to attend any of our events and/or to receive our communications. In some circumstances (3) we may collect personal data from third parties. The circumstances in which we can collect personal data about you are the following:
Where we need to collect personal data by law or in order to perform the Agreement and you fail to provide that data when requested, we may not be able to perform the Agreement we have or are trying to enter into with you. In this case, we may have to cancel our Agreement you have with us, but we will notify you if this is the case at the time.
5. How will we use your personal data and on what basis?
We will use your personal data, in such a manner as we believe is reasonably necessary, only for the following purposes and on the following legal basis:
6. Who else may have access to your personal data?
On occasion, we may need to share your personal data with third parties. We will only share personal data where we are legally permitted to do so.
Where you provide us with personal data as a client, we will assume, unless you instruct us otherwise in writing, that we can disclose your personal data in such manner as we believe is reasonably necessary to provide our Services (including as described in this Policy), or as is required under applicable law.
We share your personal data:
7. International transfers of Information
When we transfer your personal data to other countries, including in territories outside of the European Economic Area (“EEA”), we will safeguard that information as described in this Policy.
The legal regimes of some countries outside of the EEA do not always offer the same standard of data protection as those inside the EEA, although we will ensure that your personal data is only ever treated in accordance with this Policy. We only transfer personal data to these countries when it is necessary for the Services we provide you, or it is necessary for the establishment, exercise or defense of legal claims or subject to safeguards that assure the protection of your personal data, such as European Commission approved standard contractual clauses.
All our subsidiary undertakings and/or Affiliates throughout the world ensure a level of data protection at least as protective as that required in the European Economic Area.
For further information, including obtaining a copy of the documents used to protect your information, please contact us using the contact details provided below.
8. Security of your personal data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We put in place strict confidentiality agreements (including data protection obligations) with our third party service providers.
We have also put in place procedures to deal with any personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Your rights
You have various rights with respect to our use of your personal data:
• Access: The right of access gives you the right to obtain a copy of your personal data. It helps you to understand how and why we are using your data, and check we are doing it lawfully. There are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information.
• Rectification: You have the right to have inaccurate personal data rectified and to have incomplete personal data completed. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or has changed, so that we can keep your personal data up-to-date. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
• Erasure: You have the right to have your personal data erased. This right is not absolute and only applies in certain circumstances (for example if your personal data is no longer necessary for the purposes for which it was collected, or when your personal data have been unlawfully processed).
• Restriction: You have the right to restrict the processing of your personal data in certain circumstances. This means that you can limit the way that we use your personal data where you have a particular reason for wanting the restriction. This may be because you have issues with the content of the information we hold or how we have processed your data.
• Portability: You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. This right to data portability only applies when our lawful basis for processing this information is consent or for the performance of a contract and we are carrying out the processing by automated means (i.e. excluding paper files).
• Objecting: You have the absolute right to object to the processing of your personal data if it is for direct marketing purposes. In others specific circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data.
• Automated individual decision-making: You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. The right is not absolute and only applies in certain circumstances. You will be specifically informed if we make such automated individual decision.
• Complaints: We are committed to working with you to obtain a fair resolution of any complaint or concerns about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint with a supervisory authority, in the Member State of your habitual residence, of your place of work or of an alleged infringement of the data protection laws (for Belgium see www.dataprotectionauthority.be and for other countries click here ). You also have the right to seek a remedy through the courts.
You may, at any time, exercise any of the above rights, by contacting us using the contact details provided below. If we have doubt about your identity, we may request you to provide us with a proof of your identity, i.e. a copy of your ID card, or passport, or any other valid identifying document.
10. Withdrawal of consent
When personal data is processed on the basis of your consent, you may withdraw consent at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.
In the event that you no longer want to receive any marketing communications from us, please use the unsubscribe option (which is in all of our marketing emails to you), or contact us using the contact details provided below. Withdrawal of consent to receive marketing communications will not affect the processing of personal data for the provision of our Services.
11. How long do we keep your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for us to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled.
Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.
What is a cookie ?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.
Certain cookies contain personal information – for example, if you click to “remember me” when logging in, a cookie will store your username. Most cookies will not collect information that identifies you, and will instead collect more general information such as how Users arrive at and use websites, or a user’s general location.
There are mainly four kinds of cookies:
The majority of browsers support them (Internet Explorer, Mozilla Firefox, Netscape, Safari, etc.). However, users can set their browsers to decline cookies, or they can delete their cookies at will.
What cookies does Alpega use?
Generally, Alpega cookies perform different functions:
How to control and delete cookies through the browser?
The ability to enable, disable or delete cookies can also be completed at browser level. In order to do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” facility). You can find more information on how to do this and about cookies at: www.allaboutcookies.org.
Please remember that if you do choose to disable cookies, you may find that certain sections of the Website do not work properly and be prevented from making use of all of the Services.
13. Links to other websites
Our Websites and social media pages may contain tools, widgets or content that link to other, unaffiliated third party websites and/or social media pages. Please note that we are not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third party websites. You must always carefully review the privacy and confidentiality policy of any third party websites that you may visit in order to understand how the operators of that websites may collect, store and use your personal data.
We reserve the right to update and change this Policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by email.
This Policy was last updated in June 2018. Please check back regularly to keep informed of updates to this Policy.
15. Contact Details
Questions, comments and requests regarding this Policy are welcomed and should be addressed to privacy team at:
Data Privacy Officer: Marc Van Nieuwenhove