Updated on March 15th 2021
1. Parties and Purpose
Christophe Dessy (hereinafter “SIMPLIC-IT-Y” or the “Controller”)
Rue Charles Martel, 8
1000 – Brussels
BCE / VAT : BE0551-702-247
E-mail : dpo@simplic-it-y.com
Phone : +32 492 52 93 61
SIMPLIC-IT-Y establishes this Privacy Policy with the purpose of informing users of the website hosted at the following address: https://www.simplic-it-y.com/en (hereinafter the “Site”), in a transparent manner, of the way in which personal data is collected and processed by SIMPLIC-IT-Y.
The term “user” refers to any user, i.e. any natural or legal person, who visits or interacts in any way with the Site.
In this respect, SIMPLIC-IT-Y determines all the technical, legal and organisational means and purposes of processing users’ personal data. To this end, SIMPLIC-IT-Y undertakes to take all necessary measures to ensure that the processing of personal data complies with the Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data (hereinafter, “the Law”) and the European Regulation of 26 April 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”).
SIMPLIC-IT-Y is free to choose any natural or legal person who processes users’ personal data at its request and on its behalf (hereinafter the “Processor”). Where applicable, SIMPLIC-IT-Y undertakes to select a Subcontractor offering sufficient guarantees as to the technical and organisational security measures for the processing of personal data, in accordance with 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 SIMPLIC-IT-Y, in its capacity as Data Controller, or by service providers acting in the name and on behalf of SIMPLIC-IT-Y, shall be in accordance with the Law and the Regulation.
Personal data will be processed by SIMPLIC-IT-Y, in accordance with the purposes mentioned below, via :
– A feedback questionnaire
– The use of analytical cookies
– The contact form
3. Purpose of the processing of personal data
In accordance with Article 13 of the Regulation, the purposes of the processing of personal data are communicated to the user and are as follows :
– To ensure the execution of the services offered and agreed upon on the site.
4. Personal data that may be processed
The user consents, when visiting and using the Site, that SIMPLIC-IT-Y collects and processes, in accordance with the terms and principles described in this Privacy Policy, the following personal data :
Via the contact form :
– Last name
– First name
– Phone number
– e-mail
Through analytical cookies :
– The IP address used by the user
5. Consent
By accessing and using the Site, the user declares that he/she is aware of and agrees to the processing of his/her personal data in a free, specific, informed and unequivocal manner. This agreement relates to the content of this Privacy Policy.
Consent is given by the positive act by which the user has checked the box offering the Privacy Policy as a hyperlink. This consent is a necessary condition for carrying out certain operations on the Site or for allowing the user to enter into a contractual relationship with SIMPLIC-IT-Y. Any contract between SIMPLIC-IT-Y 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 Manager processing and collecting, in accordance with the terms and principles included in this Privacy Policy, his/her personal data that he/she communicates on the Website or on the occasion of the services offered by SIMPLIC-IT-Y, for the purposes indicated above.
The user has the right to withdraw consent at any time. Withdrawal of consent shall not affect the lawfulness of processing based on the consent previously given.
6. Duration of retention of users’ personal data
In accordance with Article 13 ยง2 of the Regulation and of the Law, the Controller shall keep personal data only for as long as is reasonably necessary for the purposes for which they are processed.
This duration is in all cases less than : 12 months
7. Recipients of data and disclosure to third parties
Personal data may be passed on to SIMPLIC-IT-Y’s employees, collaborators, subcontractors or suppliers who offer adequate data security guarantees and who collaborate with SIMPLIC-IT-Y in the marketing of products or the provision of services. They act under the direct authority of SIMPLIC-IT-Y and are responsible for collecting, processing or subcontracting this data.
In all cases, the recipients of the data and those to whom the data has been disclosed shall comply with the contents of this Privacy Policy. SIMPLIC-IT-Y assures that they will process this data only for the intended purposes, in a discreet and secure manner.
In the event that the data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed in advance so that he/she can express his/her consent to the use of this personal data.
8. Data Protection Officer (DPO)
The following person is appointed Data Protection Officer (hereinafter “DPO”): Christophe Dessy
The role of the DPO is to ensure the proper implementation of national and supranational provisions regarding the collection and processing of personal data.
The DPO can be contacted as follows:
– dpo@simplic-it-y.com
– +32 492 52 93 61
9. User rights
At any time, the user can exercise his rights by sending a message by e-mail to the following address: dpo@simplic-it-y.com, or a letter by post addressed, enclosing a copy of his identity card to the following address Rue Charles Martel, 8, 1000 Brussels.
a. Right of access
In accordance with Article 15 of the Regulation, SIMPLIC-IT-Y guarantees the user’s 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 operation;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients established in third countries or
international organisations;
where possible, the envisaged period of storage of personal data or
, where this is not possible, the criteria used to determine this period;
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, relevant information concerning the underlying logic and 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 this request electronically (e.g. via the e-mail address), the information is provided in a commonly used electronic form, unless the user requests otherwise.
The user will be provided with a copy of his or her data no later than one month after receipt of the request.
b. Right of rectification
SIMPLIC-IT-Y guarantees the user the right to rectify and delete personal data.
In accordance with article 16 of the Regulation, incorrect, inaccurate or irrelevant data can be corrected or deleted at any time. The user will first make the necessary changes himself from his user/other account, unless they cannot be made independently, in which case the request can be made to SIMPLIC-ITY.
In accordance with Article 19 of the Regulation, the controller shall notify each recipient to whom personal data have been disclosed of any rectification of the personal data, unless such disclosure proves impossible or would require disproportionate effort. The controller shall provide the data subject with information about such recipients on request.
c. Right to erasure
The user has the right to obtain the deletion of his/her 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 them pursuant to the preceding paragraph, the Controller shall, taking into account the available technology and the costs of implementation, take reasonable steps, including technical steps, to inform other controllers processing such personal data that the data subject has requested the erasure by such controllers of any link to, or any copy or reproduction of, such personal data.
The two preceding paragraphs do not apply to the extent that such processing is necessary :
the exercise of the right to freedom of expression and information;
to comply with a legal obligation to process laid down by Union law or by the law of the Member State to which the controller is subject, or to carry out a task carried out in the public interest or in the exercise of official authority vested in the controller;
for the establishment, exercise or defence of legal claims.
In accordance with Article 19 of the Regulation, the controller shall notify each recipient to whom personal data have been disclosed of any erasure of personal data or restriction of processing carried out, unless such disclosure proves impossible or would require disproportionate effort. The controller shall provide the data subject with information about such recipients on request.
d. Right to restrict 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 controller shall notify each recipient to whom personal data have been disclosed of any restriction on the processing carried out, unless such disclosure proves impossible or would require disproportionate effort. The controller shall provide the data subject with information about such recipients on request.
e. Right to data portability
In accordance with Article 20 of the Regulation, users have the right to receive from SIMPLIC-IT-Y personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transmit such data to another controller without SIMPLIC-IT-Y being prevented from doing so in the cases provided for in the Regulation.
When the user exercises her/his right to data portability pursuant to the previous paragraph, she/he has the right to have the personal data transmitted directly from one controller to another, where technically possible.
The exercise of the right to data portability shall be without prejudice to the right to erasure. This right shall not apply to processing 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 to object to the processing of his personal data at any time due to his particular situation, including the automation of the data by SIMPLIC-ITY.
In accordance with Article 21 of the Regulation, SIMPLIC-IT-Y will no longer process personal data, unless there are legitimate and compelling reasons for the processing that prevail over the interests and rights and freedoms of the user, or for the establishment, exercise or defence of legal claims.
Where personal data are processed for the purpose of canvassing, the user has the right to object at any time to the processing of personal data concerning him or her for such canvassing purposes, including profiling insofar as it is linked to such canvassing.
Where the data subject objects to the processing for canvassing purposes, the personal data shall no longer be processed for such purposes.
g. Right of complaint
The user has the right to lodge a complaint regarding the processing of his personal data by SIMPLIC-IT-Y with the Data Protection Authority, which is competent for the Belgian territory. More information can be found on the website :
https://www.dataprotectionauthority.be/citizen
Complaints can be submitted to the following addresses :
Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Phone + 32 2 274 48 00
Fax + 32 2 274 48 35
E-mail : contact@apd-gba.be
The user may also file a complaint with the court of first instance at his place of residence.
10. Cookies
The Site uses cookies to distinguish users of the Site. This allows us to provide users with a better browsing experience and to improve the Site and its content. The purposes and terms of cookies are contained in this section.
a. General principles
A “cookie” is a file that is temporarily or permanently stored on the user’s hard drive when the user visits the Website, with a view to a subsequent connection. Thanks to cookies, the server recognises the user’s computer.
Cookies may also be set by third parties with whom SIMPLIC-IT-Y collaborates.
Some of the cookies used by SIMPLIC-IT-Y are necessary for the proper functioning of the Site, while others are used to improve the user’s experience.
The user can personalise or deactivate cookies by setting their browser parameters.
By using the Website, the user expressly agrees to the management of cookies as described in this article.
b. Type of cookies and purpose
Different types of cookies are used by SIMPLIC-IT-Y on the Site:
Technical cookies: these are necessary for the operation of the Website, allow the communication of the data entered and are intended to facilitate the user’s browsing;
Statistical and audience measurement cookies: these cookies allow the user to be recognised and are used to count the number of users of the Website over a certain period. Since they also indicate browsing behaviour, they are an effective means of improving the User’s browsing experience by displaying proposals and offers likely to interest him/her. They also allow SIMPLIC-IT-Y to identify possible bugs on the Website and to correct them.
Functional cookies: these cookies facilitate the use of the Website by retaining certain choices entered (for example, the user name or language);
Tracking cookies: SIMPLIC-IT-Y uses tracking cookies via Google Analytics, to measure the interaction of users with the content of the Website and to produce anonymous statistics. These statistics enable SIMPLIC-IT-Y to improve the Website.
Google supports the explanation of these cookies at the following address :
https://policies.google.com/privacy?hl=en&gl=en
c. Retention period for cookies
Cookies are kept for the time necessary to achieve the purpose for which they are intended. The cookies likely to be stored on the user’s hard disk and their retention period are as follows :
“_fbp”: 3 months
“_ga”: 24 months
“_gat_gtag_UA_*_1”: 1 minute
“_gid”: 1 day
d. Cookie management
If the user does not want the Website to place cookies on their hard drive, they can easily manage or delete them by changing their browser settings. Browser programming also allows the user to receive a notice or notification when a Website is using cookies and to decide whether to accept or reject them.
If the user deactivates certain cookies, the user accepts that the Website may not function optimally. Some parts of the Website may not be usable, or may be partially usable.
If the user wishes to manage and/or delete certain cookies, he/she can do so by using the following link(s):
For users with :
Chrome: https://support.google.com/accounts/answer/61416?hl=en
Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
Microsoft Edge: https://support.microsoft.com/en-us/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd
Safari: https://support.apple.com/et-ee/guide/safari/sfri11471/mac
Opera: https://help.opera.com/en/latest/web-preferences/#cookies
Brave: https://support.brave.com/hc/en-us/articles/360050634931-How-Do-I-Manage-Cookies-In-Brave-
Vivaldi: https://help.vivaldi.com/desktop/privacy/cookies/
Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
If the user does not want Google Analytics cookies to be used, he/she is invited to set his/her browser to that effect at the following website :
http://tools.google.com/dlpage/gaoptout
11. Limitation of liability of the data controller
The website may contain links to other websites owned by third parties not related to SIMPLIC-IT-Y. SIMPLIC-IT-Y is not responsible for the content of these websites 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 personal information or data on the website. SIMPLIC-IT-Y 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 – especially regarding 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.
SIMPLIC-IT-Y is not responsible for the loss, corruption or theft of personal data caused by viruses or computer attacks.
12. Security
The Data Controller implements organisational and technical measures to guarantee an appropriate level of security for the processing and collection of data. These security measures depend on the costs of implementation with regard to the nature, context and purposes of the processing of personal data.
The Data Controller uses industry standard encryption technologies when transferring or collecting data on the Site.
13. Changes to the Privacy Policy
SIMPLIC-IT-Y 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 regularly in order to be aware of any changes and adaptations. Any such changes will be posted on the Site or sent by email for enforceability.
14. Applicable law and juridiction
This Privacy Policy is governed exclusively by Belgian law. Any dispute shall be brought before the courts of the judicial district of the registered office of SIMPLIC-IT-Y.
15. Contact
For any questions or complaints relating to this Privacy Policy, the user may contact the Data Controller via the following address: dpo@simplic-it-y.com