1. About at-ica.com and [AT+ICA]
The website at-ica.com is an initiative of [AT+ICA], an European association of trade+investment compliance and controls attorneys.
[AT+ICA] is the controller of your personal data.
[AT+ICA]’s secretariat is located at Bert Gevers offices, c/o Loyens & Loeff, Tervurenlaan 2, B-1040 Brussels, Belgium . It can be reached by phone at +32 2 743 43 43.
2. [AT+ICA]’s Privacy Statement
3. What Information is Collected and How It Is Used
Nature of information collected
In order to receive newsletters or information about at-ica.com, to contact at-ica.com for any questions or comments, or to register for events and trainings on at-ica.com, you may choose to provide some personal information. The categories of personal information that [AT+ICA] may collect for the processing purposes described hereto are: family name, first name, organization, position, activity, main centre of interest, address, postal code, country, phone, website, and email.
[AT+ICA], or third parties on its behalf, may use the personal information that you provide:
- to process and respond to your questions and/or inquiries, and
- to deliver you newsletters, emails, or other communications relating to products and services that you may be interested in;
- to provide you with any services and products on at-ica.com.
[AT+ICA], or third parties on its behalf, may also use certain information you provide in an aggregate and anonymous form for internal business and planning purposes, such as statistics.
Protecting your privacy and your information is a priority at [AT+ICA]. [AT+ICA] has taken reasonable measures to protect your personal information from loss, misuse and alteration. However, please be aware that no data transmission over the internet or storage technology can be guaranteed to be 100% secure. [AT+ICA] can only take steps to help reduce the risks of unauthorized access. Each individual using the internet can take steps to help protect his/ her personal information and further minimize the likelihood that a security incident may occur.
Cookies and session cookies
Subject to your prior explicit consent where such consent is required by the applicable law in your jurisdiction, [AT+ICA] Sites like at-ica.com use “cookies” (i.e., small text files which are downloaded to a user’s device when visiting the [AT+ICA] Sites) in order to make easier for users to navigate around the at-ica.com website and improve the quality. Cookies are essential in order to enable you to move around the at-ica.com webite and use their features, such as accessing secure areas of the at-ica.com website or making pages load properly. You can disable cookies by changing your web browser settings.
General information on cookies
4. Disclosure of Information
[AT+ICA] does not disclose your personal data to third parties, except to [AT+ICA]’s network, business partners and service providers, or except as may be required by any applicable law, regulation, or governmental request or to protect the rights of [AT+ICA]. Access to your information may be granted to such third parties as needed to perform their assistance or services. Yet [AT+ICA] does not authorize third parties to use or to transfer your information for any other purposes.
Transfer of personal data outside the European Union
5. Rights to Unsubscribe of to Access the Information
How to unsubscribe from the at-ica.com newsletter
If you no longer wish to receive any kind of communications from a-ica.com (e.g. newsletters), you may opt out by cancelling your subscription on at-ica.com through the link sent in each email you receive from at-ica.com, or by sending an email to firstname.lastname@example.org.
How to access and update your information
6. Links to Other Sites
7. Social Networks
8. Intellectual Property (IP) / Content
All content displayed on at-ica.com, including but not limited to, text, graphics, logos, buttons, icons, images, sounds, audio clips, digital downloads, data compilations and software, is the property of [AT+ICA] or its content suppliers and is protected by the Belgian and/or foreign applicable laws.
Registered trademarks of [AT+ICA] are marks indicated on at-ica.com and include licensors, in Belgium and other countries. All other trademarks that appear on at-ica.com are the property of their respective owners.
You are prohibited from using, without permission, any of the marks, trademarks, trade names, service names, logos or other propriety graphic appearing throughout at-ica.com. For more information, please ask us.
Effective since: 14 May 2018
1.1 [AT+ICA] respects the privacy of its users (hereinafter, the “Users“).
1.2 [AT+ICA] 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“).
1.4 The User acknowledges having read the information below and authorizes [AT+ICA] to process, in accordance with the provisions of the Policy, the personal data that he/she communicates on the Website.
1.5 The Policy is valid for all pages hosted on the Website and for the registrations of this Website. It is not valid for the pages hosted by third parties to which [AT+ICA] may refer and whose privacy policies may differ. [AT+ICA] cannot therefore be held responsible for any data processed on these websites or by them.
2.1 Simply visiting the Website 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:
[AT+ICA] – Bert Gevers
c/o Loyens & Loeff
Belgian business registry (BCE) number: (soon)
2.3 Any question regarding the processing of this data may be sent to the following address: email@example.com.
3.1 By completing the order form on the Website and using the Service, the User allows, in particular, [AT+ICA] 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 [AT+ICA];
3.2 The User also authorizes [AT+ICA] to record and store the following data for the purposes mentioned in point 4:
- additional information requested by [AT+ICA] 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 Website as well as to optimize technical management, the Website may use “cookies”. These “cookies” record, in particular:
- the User’s browsing preferences;
- the date and time of access to the Website and other data related to traffic;
- the pages visited;
3.4 When the User accesses the Website, 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 Website 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 Website.
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 Website.
PURPOSES OF PROCESSING THE DATA
4.1 The Website collects, stores and uses its 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 Website;
- to provide the Service;
- to allow the User to receive messages (for example for renewal notifications)
- to facilitate the availability and use of the Website;
- to personalize the User’s experience on the Website;
- for any marketing activities and promotions proposed by [AT+ICA] or partners to Users who have given their consent;
- to inform them about any changes on the Website and its features;
- for any other purpose to which the User has expressly consented.
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 [AT+ICA] has on him/her or check if he/she is included in the database of [AT+ICA]. [AT+ICA] asks the User to make this request by mail in order to be able to identify him with certainty (Please provide [AT+ICA] your first name, surname, complete address and a copy of your identity card). [AT+ICA] 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 [AT+ICA] and by its active partners by sending his request to [AT+ICA] by mail.
- Right of cancellation and/or modification: the user may, at any time, notify [AT+ICA] 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 [AT+ICA] 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[AT+ICA] accompanied by a copy of his identity card or passport to the following email address: firstname.lastname@example.org or to the postal address of the secretariat: [AT+ICA] – Bert Gevers offices, c/o Loyens & Loeff, Woluwe Atrium, Neerveldstraat 101-103, B-1200 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 [AT+ICA]’s database – except those which [AT+ICA] 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 [AT+ICA]:
by e-mail: email@example.com
by mail: [AT+ICA] – Bert Gevers offices, c/o Loyens & Loeff, Tervurenlaan 2, B-1040 Brussels, Belgium.
5.4 [AT+ICA] will then take the necessary steps to satisfy this request as soon as possible.
DURATION OF STORING THE DATA
6.1 [AT+ICA] will keep the personal data of its Users for the duration necessary to achieve the objectives pursued (see point 4).
6.2 [AT+ICA] may also continue to keep personal data concerning the de-registered User, including all correspondence or request for assistance sent to [AT+ICA] 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.
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
8.1 In order to guarantee optimal payment security, [AT+ICA] may use online payment services, which meets high security standards.
8.2 In addition, [AT+ICA] takes the appropriate organizational 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:
- unauthorized 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, individuals related to [AT+ICA] who have access to this data are subject to a strict confidentiality obligation. Nevertheless, [AT+ICA] 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.
COMMUNICATION TO THIRD PARTIES
9.1 [AT+ICA] 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 [AT+ICA] 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 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.
TRANSFER TO A NON-EU COUNTRY OR COMPANY
[AT+ICA] transfers data to a non-EU country only when that country provides an adequate level of protection within the meaning of the legislation in force, and, in particular, the Law of 8 December 1992 on protection of privacy and its executive orders, and 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“), or within the limits permitted by the legislation in force, for example by ensuring the protection of data by appropriate contractual provisions.
11.1 A payment service can be integrated into the Website.
12.1 The personal data may be used by [AT+ICA] or its partners 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: firstname.lastname@example.org.
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. [AT+ICA] asks them not to provide their personal data.
UPDATES AND CHANGES TO THE POLICY
By informing Users through the Website, [AT+ICA] 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.
VALIDITY OF THE CONTRACTUAL CLAUSES
15.1 Failure by [AT+ICA] 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. [AT+ICA] undertakes to substitute this provision with another which, to the extent possible, fulfils the same objective.
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.