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Privacy & Cookie Policy
This Privacy and Cookie Policy is solely intended to provide you with information in relation to the processing of personal data through your use of the website. For our privacy practices in relation to our services, we refer you to the agreement as may be concluded between us.
We”, “us” or “our” means:
We act as controller for the personal data we gather through your use of our website. Your privacy is important to us, so we have developed this Privacy and Cookie Policy that sets out how we collect, disclose, transfer and use (“process”) the personal data that you share with us, and which rights you have. Please take a moment to read through this policy.
If you have any questions, concerns or complaints regarding this Privacy and Cookie Policy or our processing of your personal data or you wish to submit a request to exercise your rights as set out in article 5, you can contact us:
(a) Via-mail: info@theoryx.com, to the attention of our Data Protection Officer
(b) By post:
Oryx IT Services
To the attention of the DPO
Galileilaan 15
2845 Niel – Belgium
We collect and use personal data that can be used to directly or indirectly identify a natural person (such as name, identification number, location data, etc.), that you provide to us directly through our website, when you use or view our website via your browser’s cookies, you register online or voluntarily provide us your contact details.
The personal data we collect, is collected and used for the purposes as listed hereunder:
(a) In the event you use the contact form on our website, we will use your personal data to reply to your query, via e-mail or telephone.
(b) In the event you register for our newsletter, your e-mail address will be used in order to send you our newsletters, which may include invites to events, seminars, etc. organized by us.
(c) We process your personal data for the purpose of supporting the website and enhancing your user experience, which includes ensuring the security, availability, performance, capacity and health of the website.
(d) We process your personal data to enforce or exercise any rights that are available to us based on the applicable law, such as use for the establishment, exercise or defense of legal claims.
(e) We may also use your personal data to fulfill our obligations as set out by the applicable law.
The following categories of personal data can be distinguished:
(i) Contact data: in the event you make use of the contact form, you will be asked to provide the following information: First and last name, function, Company; e-mail address, phone number, and any personal data that you choose to put in the designated blank field (please do not provide us with any sensitive information, such as health information, information pertaining to criminal convictions, or credit card/account numbers). This is information that is provided directly by you.
(iii) Usage data: We collect personal data regarding your activities on our website: IP address, device ID and type, referral source, language settings, browser type, operating system, geographical location, length of visit, page views, or information about the timing, frequency and pattern of your service use. This information may be aggregated and used to help us provide more useful information regarding the use of our website. In the event the usage data is completely anonymized (and can therefore not be traced back to you as an individual), this will not be considered personal data for the purpose of this Privacy Policy. This is personal data that is automatically collected through your use of the website.
(ii) Newsletter: If you register for our newsletter, you will be asked to provide your e-mail address. This is information provided directly by you.
We use the personal data we receive from you via our contact form, as well as the user information we aggregate from the behavior shown on our website, on the basis of the legal ground “legitimate interest”. Thus, we have a legitimate interest to answer the question(s) being asked by you or to react on the remarks you made. The user information is used to make our users’ website experience as comfortable and safe as possible. In any case, we strive towards a balance between the legitimate interest and respecting your privacy.
If you subscribe for our newsletter through our website, and in case you are not yet a client from us, you give us your explicit consent therefore. Your personal data will also be used for direct marketing, provided that you gave an explicit consent. If you are already added to our mailing list to receive electronic marketing material, we can use your data to send marketing regarding our services. In the event the legal basis for the processing of your personal data is consent, you will, at all times, have the right to withdraw your consent. This will, however, not affect the lawfulness of any processing done prior to the withdrawal of consent. And in the event the legal basis for processing is our legitimate interests the public interest, you will have the right to object to such processing, as set out in article 5 of this Privacy Policy.
With regard to our services and to our clients, we use the identification and financial data based on the legal ground “necessary for the execution of the agreement”. Thus, we need these identification data to deliver you our invoices (electronically) or to incorporate them in our accounting, as well as for our client administration and our supplier administration.
Your personal information will not be kept for longer than is necessary for a specific purpose. The retention period can differ depending on the purpose. The contact information we receive from you when using the contact form, and the user information, in the light of using our website, will never be stored for a period longer than 24 months. The identification and financial data we process with regard to our services and with regard to our client administration are being stored for a maximum of 7 years.
In the event you withdraw your consent or you object to our use of your personal data, and such objection is successful, we will remove your personal data from our databases. Please note that we will retain the personal data necessary to ensure your preferences are respected in the future. The foregoing will, however, not prevent us from retaining any personal data if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.
This article lists your principal rights under data protection law. We have tried to summarize them for you in a clear and legible way.
To exercise any of your rights, please send us a written request in accordance with article 1 of this Privacy Policy. We will respond to your request without undue delay, but in any event within one month of the receipt of the request. In the event of an extension of the term to respond or in the event we do not take action on your request, we will notify you.
On the basis of the December 8, 1992 Law and as of the 25th of May 2018 on the basis of the General Data Protection Regulation you have the right to:
The right to access:
You have the right to confirmation as to whether or not we process your personal data and, in the event we do so, you have the right to access such personal data, together with certain additional information that you also find listed in this Privacy Policy. You have the right to receive from us a copy of your personal data we have in our possession, provided that this does not adversely affect the rights and freedoms of others. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies.
The right to rectification:
If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed.
The right to erasure (right to be forgotten)
In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include:
(a) The personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed;
(b) You withdraw your consent, and no other lawful ground exists;
(c) The processing is for direct marketing purposes;
(d) The personal data have been unlawfully processed; or,
(e) Erasure is necessary for compliance with EU law or Belgian law.
There are certain exclusions to the right to erasure. Those exclusions include where processing is necessary,
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation; or,
(c) for the establishment, exercise or defense of legal claims.
The right to restrict processing;
You have the right to restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes), if:
(a) You contest the accuracy of the personal data (and only for as long as it takes to verify that accuracy);
(b) The processing is unlawful and you request restriction (as opposed to exercising the right to erasure);
(c) We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; or,
(d) You have objected to processing, pending the verification of that objection.
In addition to our right to store your personal data, we may still otherwise process it but only:
(a) with your consent;
(b) for the establishment, exercise or defense of legal claims;
(c) for the protection of the rights of another natural or legal person; or,
(d) for reasons of important public interest.
We will inform you before we lift the restriction of processing.
The right to data portability
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. You also have the right to have your personal data transferred directly to another company, if this is technically possible, and/or to store your personal data for further personal use on a private device.
The right to object to processing
You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
(a) The performance of a task carried out in the public interest or in the exercise of any official authority vested in us;
(b) The purposes of the legitimate interests pursued by us or by a third party.
If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
ask us to get insight in the personal data we process, provided that this has no adverse effect on the rights and freedom of others. You have the right to ask for a copy of your personal data in an understandable format that is free of charge;
add, remove or protect data because of being false or incomplete;
have your data removed in case (i) the personal data are no longer needed, (ii) you withdraw your consent (and there is no other ground for processing, such as a contractual relationship), (iii) your personal data were processed in an unlawful way, or (iv) this needs to be done based on a legal requirement.
use the right on limitation of your personal data, in case (i) the correctness of your personal data is being contested, (ii) the processing is illegal, (iii) your personal data or no longer necessary, but needed for the set-up of a legal claim, or (iv) you object the processing;
use the right on transferability of your personal data in case the processing is based on consent and is being processed through automated procedures;
use the right on objection against the processing of personal data in case the ground for the processing is the legitimate interest or in the light of direct marketing;
use the right to not be subjected to automated individual conclusions;
The right to complain to a supervisory authority
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In Belgium, you can submit a complaint to the Authority for the protection of personal data (Data Protection Authority), Drukpersstraat 35, 1000 Brussel (contact@apd-gba.be; https://www.dataprotectionauthority.be/contact-us).
This Privacy statement is only applicable on us and our website. The website can include links to other websites, which we do not monitor and wherefore this Privacy Statement is not applicable. Other websites do have their own privacy policy. Our website uses social media plugins that make it possible to link you to our social media channels, or that enable you to share content on your social media channels. These social media channels are Facebook, LinkedIn and Twitter. In case you click on such a link, it is possible that the social media partners mentioned here use personal data, such as personal data concerning your profile.
In order to provide you with our website, we work with service provider to process and store your personal information. We use the following categories of service providers:
We may also disclose your personal data in the event such disclosure is required or necessary in order to fulfil a legal obligation. We may also disclose personal data in order to protect your vital interests or the vital interest of another natural person.
As such, we do not disclose your personal data to our social media partners. We do, however, make use of social media plugins to direct you to our social media channels and to allow you to interact with our content. These social media channels are (Facebook, LinkedIn, Twitter, YouTube). In the event you click such link, such social media service provider may collect personal data about you and may link this information to your existing profile on such social media.
We are not responsible for the use of your personal data by such social media service provider. In such case, the social media service provider will act as controller. For your information only, we have included the relevant links (these may be changed from time to time by the relevant service provider):
(a) Facebook: http://facebook.com/about/privacy;
(b) LinkedIn: http://linkedin.com/legal/privacy-policy;
(c) Twitter: http://twitter.com/privacy;
(d) YouTube: https://www.google.com/intl/en/policies/privacy/;
We will not transfer your personal data outside of the European Economic Area. We will ensure that any transfer of personal data to countries outside of the European Economic Area will take place pursuant to the appropriate safeguards.
This website makes use of cookies that trace your online activity, including, but without restriction, your subscription, the offer of information and the request for information.
Cookies are small pieces of data that a website asks your browser to store on your computer or mobile device when you visit the website or certain pages. The cookie allows the website to “remember” your actions or preferences over time. Most browsers support cookies, but users can set their browsers to decline them and can delete them whenever they like.
Cookies will usually contain the name of the website where the cookie has come from, how long the cookie will remain on your device, and a value which is usually a randomly generated unique number.
Some cookies will be deleted as soon as you leave the website (the so-called “session cookies”), other cookies will remain stored on your computer or mobile device and will help us identify you as a visitor of our website (the so-called “permanent cookies”).
Why do we use cookies?
Cookies on our Website are used for a variety of different purposes. We use cookies to improve the user-experience on the Website and to map your surfing behaviour (e.g. the pages you have visited and the time you spent on that page). Cookies make our Website easier to use and allow us to better tailor our Website to your interests and needs. Cookies are also used to help speed up your future activities and experience on the Website. We use cookies, for example, to remember your language preferences.
We also use cookies to compile anonymous, aggregated statistics that allow us to understand how our Website is being used and how we can improve our services.
Which cookies do we use?
We use first party and third-party cookies:
A further distinction can be made between the following types of cookies:
How can you manage or delete cookies?
You can at any time manage or delete cookies using the settings on your internet browser, allowing you to refuse some or all cookies. How to do this on the most commonly used browsers:
We reserve the right to modify this Privacy and Cookie Policy at any time, and without prior notice, by posting an amended Privacy and Cookie Policy on the website. You will always be able to consult the most recent version of the Privacy and Cookie Policy on the website.
This Privacy Policy was revised last on 14/08/2020, version nr. 2020/01.