- 1- FRAMEWORK
L&E GLOBAL BV CVBA, with registered office at 1050 Brussels, Avenue Louise 221, registered with the Belgian Crossroads Bank for Enterprises under number 0832.474.883 (hereinafter referred to as L&E Global or as “we”/“us”/“our”) attaches great importance to the protection of the Personal Data it processes. In the context of legally responsible dealing L&E Global undertakes to comply with the 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 of the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the “GDPR”).
You are requested to read this Policy carefully, with the understanding that it may be modified from time to time in the light of the feedback or changes to services, conditions or legal or regulatory provisions.
- 2- DEFINITIONS
For the proper understanding of the terminology used in the context of this policy statement, a number of terms are defined below, as the case may be in accordance with the GDPR:
|L&E Global||L&E Global and the international offices and other companies and entities that are associated with it;|
|Personal Data||Any information relating to an identified or identifiable natural person (“Data Subject”) in terms of the GDPR;|
|Website||website of L&E Global (http://leglobal.org);|
|Processing or to Process||any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, adoption, or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;|
|Controller:||the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data, being, as the case may be, L&E Global;|
|Processor||a natural or legal person, public authority, agency or another body, which processes Personal Data on behalf of the Controller, being, as the case may be, L&E Global;|
|Personal Data Breach||a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Processed Personal Data;|
|Data Subject||means a natural person whose Personal Data have been provided explicitly or implicitly to L&E Global by him or by a third party|
This Policy applies to all Data Subjects whose Personal Data are Processed by L&E Global, with the exceptions of persons working at L&E Global.
For example, this Policy applies to:
- clients of L&E Global;
- potential clients (to be) contacted by L&E Global;
- visitors of the Website;
- recipients of newsletters and commercial emails sent by L&E Global;
- all other persons who contact L&E Global or of whom L&E Global processes Personal Data;
This Policy does not apply to partners, employees, secondees, student interns and applicants, it being understood that separate privacy policies are put in place with regard to the Personal Data Processed with regard to the aforementioned categories of Data Subjects.
- 4- THE COLLECTION AND THE NATURE OF THE PERSONAL DATA
L&E Global collects Personal Data through the transfer thereof by you directly, via the Website or via publicly accessible sources (such as professional Social Media platforms). In addition, the server of the Website automatically recognizes the IP address and/or the domain name of the person who visits the Website.
More specifically, we will record your name when you visit our offices. Camera footage is taken outside our offices, at the front desk and at the entrances of meeting rooms. We do this so we know who is in the building in the event of emergencies and to ensure that no unauthorised persons can access our offices. Camera footage will by default be destroyed after 10 days.
Personal Data therefore include among other things, surname and first name, contact details, such as the address, the telephone number, the e-mail address, identification data such as the VAT number and the national register number, data concerning civil status, date and place of birth and data relating to employment or professional activities, browsing behaviour on the Website, whether you open a newsletter or commercial email and what sections you select, type of device you use to access the Website, the operating system and version and your browser type.
We do not Process any sensitive Personal Data or confidential information protected by the professional secrecy of lawyers or civil law notaries for marketing campaigns. We will ask your explicit, informed and prior permission if we want to create a personal, individual customer profile. You can always withdraw this permission at a later time.
- 5- THE PURPOSE OF PROCESSING
We use Personal Data to select relevant newsletters or alerts and invite you to upcoming events. We may also use the data to inform you about other matters that may be of interest to you. However, we will enable you to set your preferences to determine whether you wish to receive such information or not.
We automatically Process Personal Data for technical and functional management of our website and to ensure it is easy to use. We use various technologies to collect and store information when you visit our Website.
Furthermore, when you contact us with questions or requests, we will use Personal Data provided by you to answer your query.
In particularly, we use your Personal Data for the following purposes:
- fulfil legal obligations;
- maintaining contact with our clients (e.g. to send you newsletters, updates, invitations to events and seminars and requested information);
- improving our product and service information and carrying out targeted marketing campaigns;
- carrying out and analysing client satisfaction surveys;
- improving and securing our website;
- preparing user statistics of the Website;
- access control and company security.
All Personal Data will be Processed exclusively for the purpose for which it was collected and to the extent that is necessary to achieve that finality. This restriction applies both to the quantity of Personal Data and to the scope of processing, the retention period and the accessibility.
If Personal Data should be Processed for a different purpose than those for which they were initially collected, L&E Global ensures that the Processing does not take place in a manner that is incompatible with the purpose for which Personal Data has been provided. In case the desired finality is incompatible with the initial finality for which Personal Data has been provided, L&E Global will ask the consent of the relevant Data Subject for the Processing of their respective Personal Data in the light of this new purpose, provided that the consent is given freely.
L&E Global states as a principle not to make use of automated decision-making.
If the Data Subject does not wish its Personal Data to be Processed for publicity and marketing purposes or business courtesies, as envisaged by article 5, 2), 3) and 4) of this Policy, the Data Subject can, by means of a simple request to L&E Global as referred to in article 14 of this Policy, or via the means provided for in the relevant communication, withdraw its consent at any time in accordance article 10.1 of this Policy.
- 6- THE LAWFULNESS OF PROCESSING
L&E Global Processes Personal Data 1) to comply with its legal obligations or 2) in light of the legitimate interests of L&E Global (in the latter instance, for example, in order to conduct a policy for provision of information to its members).
If the Processing cannot be justified by one of the aforementioned legal grounds, for instance in the case of Processing for advertising and marketing purposes aimed at conducting a policy of customer binding, L&E Global may request your consent, provided that this consent is freely given.
- 7- THE RECIPIENTS AND (SUB-) PROCESSORS
L&E Global may transfer Personal Data (or may be required to transfer Personal Data) to public authorities and may transfer Personal Data to (sub-)Processors so that they can process these Personal Data on behalf of L&E Global on the condition that (sub-)Processors guarantee an adequate level of protection regarding Personal Data and are contractually obliged to comply with the GDPR. Personal data will not be transferred to countries that do not offer protection that is at least equivalent to this protection within the EEA.
Personal Data can be communicated for internal use to L&E Global staff members, though always insofar as and to the extent that this is necessary for the performance of their duties, such as the administrative follow-up and follow-up of customer relations.
L&E Global may also transfer Personal data (or may be obliged to transfer Personal data) in connection with its use of external (sub-)Processors (such as suppliers of IT services, including services relating to software for administrative processing and follow-up or accounting, the accountant, and other persons involved). More specifically, L&E Global shares Personal Data with its international offices and the various companies and entities that make up L&E Global’s international network, and may also share Personal Data outside L&E Global’s international network, including to:
- Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of Personal Data for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers;
- Third parties relevant to the legal services that we provide. This may include, but is not limited to, counterparties to transactions or litigation, other professional service providers, regulators, authorities, governmental institutions and stock exchanges;
- To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation;
in any of the abovementioned cases provided that they offer sufficient guarantees with respect to the implementation of appropriate technical and organizational measures to ensure that the Processing complies with the requirements of the GDPR and the protection of Personal Data rights and when the transfer is necessary within the applicable legal or regulatory framework taking into account the purposes of the Processing.
To the extent required by the GDPR, L&E Global has entered into a contract with the (sub-)Processors in which the purpose of the Processing is determined, the Processor undertakes, among other things, to respect the confidentiality of Personal data, to limit the Processing to what is in line with L&E Global’s instructions or with what is legally permitted and to cooperate with the exercise of the rights granted to the Data Subject in accordance with the GDPR.
For the avoidance of doubt, when L&E Global transfers Personal Data outside Europe, it will ensure that the Personal Data is protected and transferred in a manner consistent with legal GDPR- requirements. This can be done in a number of different ways, for instance:
- The country to which L&E Global sends the Personal Data may be approved by the European Commission;
- The recipient may have signed a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect the transferred Personal Data;
- In case the recipient is located in the US, it may be a certified member of the EU-US Privacy Shield scheme.
In all cases, however, any transfer of Personal Data will be compliant with applicable data protection regulation.
You can obtain more specific details of the protection given to his/her Personal Data when it is transferred outside Europe (including a sample copy of the model contractual clauses) by contacting us using the details set out below in article 14 of this Policy.
- 8- STORAGE OF PERSONAL DATA
L&E Global can store Personal Data on servers that are outside of Belgium or in a cloud-environment. In such a case, L&E Global ensures that the Personal Data are stored in an EU Member State and/or in a country that is recognized to offer an equivalent level of data protection and/or that compliance with the provisions of the GDPR is contractually guaranteed.
- 9- RECORD OF PROCESSING ACTIVITIES
To the extent required by law, L&E Global shall keep a register of the Processing activities carried out by it or under its responsibility. In that case, the register will contain the information required by GDPR, such as the name and contact details of the (joint) data protection officer, the processing purposes, the description of the categories of Data Subjects, of Personal Data and of recipients, the retention period, etc.
- 10- YOUR RIGHTS
You may exercise the rights set out below by submitting a written notification to the following e-mail address: firstname.lastname@example.org.
L&E Global draws attention to the fact that if the Data Subject objects to the Processing of Personal Data in question or exercises the rights set out below, this may result in L&E Global being unable to further deliver some or all of its services to the respective Data Subject.
These rights include:
10.1 Right to withdraw consent
If the Processing is based on its consent, you shall at all times have the right to withdraw your consent, without this withdrawal affecting the legality of the Processing that took place before the withdrawal of the consent.
10.2 Right of access
Upon first contact and/or request to deliver services, L&E Global will provide you with information regarding the Processing of the Personal Data relating you, including the objectives, interests and principles of Processing. You may at any time inspect your Personal Data and any information relating to the Processing of your Personal Data.
10.3 Right to rectification
You will be entitled to have any Personal Data concerning yourself that is incorrect or incomplete, corrected, insofar as this is legally possible.
10.4 Right to erasure
Unless Processing is necessary for the assertion, exercise or substantiation of a legal claim or for compliance with a statutory obligation resting upon L&E Global, you will be entitled to have the Personal Data relating to you erased if (a) Personal Data are no longer necessary for the purposes for which they were Processed, or (b) the consent, insofar as the Processing is based on it, is withdrawn by you or (c) you object to the Processing and there are no compelling justified grounds for L&E Global to continue the Processing or (d) the Personal Data have been unlawfully Processed, or (e) the Personal Data must be erased in order to comply with a statutory obligation.
If the request for erasure forms part of objection to Processing for reasons relating to your specific situation, L&E Global will erase the data, subject to compelling justified grounds for Processing that outweigh your interests and rights or that relate to the assertion, exercise or substantiation of a legal claim.
10.5 Right to restriction of Processing
You have the right to obtain from L&E Global the restriction on Processing if (a) the accuracy of the Personal Data is disputed by you, or (b) the Processing is unlawful and you object to the erasure of the Personal Data or (c) you need the Personal Data for the assertion, exercise or substantiation of a legal claim while L&E Global no longer needs the Personal Data for Processing purposes, or (d) you have objected to the Processing on the basis of the justifiable grounds stated in article 21 GDPR.
10.6 Right to data portability
You are entitled to obtain your Personal Data in a structured, customary and legible form and to transfer that Personal Data to another Processing Officer if (a) the Processing is based on your consent or (b) the Processing is based on a contract pursuant to article 6 (1), point (b) of the GDPR.
10.7 Right to object
You are entitled to submit a complaint to the Data Protection Authority (Drukpersstraat 35, 1000 Brussels (www.privacycommission.be) ) in case you believe that the Processing is unlawful.
- 11- THE OBLIGATION OF L&E GLOBAL
L&E Global has taken appropriate measures to protect Personal Data in order to ensure that Personal Data is used in accordance with the aforementioned purposes and that their correctness and updating, as the case may be, are assured.
- 12- THE SECURITY OF YOUR PERSONAL DATA
L&E Global ensures that the Personal Data are protected and secured to the maximum extent possible in order to ensure their confidentiality and to prevent them from being distorted, damaged, destroyed or disclosed to an unauthorized third party.
More specifically, L&E Global secures your Personal Data through various technical and organisational measures, such as firewalls, secured servers and data processing agreements with third parties eg. IT suppliers hosting our website.
In the event of an infringement and the associated violation of the availability, integrity or confidentiality of Personal Data, L&E Global shall report the infringement in connection with Personal Data to the Data Protection Authority within 72 hours of it becoming aware of it, unless it is unlikely that the infringement poses any risk to the rights and freedoms of the Data Subjects concerned.
L&E Global will also report the Personal Data breach to you if it is likely that the breach will entail an increased risk for your rights and freedoms.
- 13- RETENTION PERIOD OF PERSONAL DATA
Personal Data will not be saved longer than necessary for the purposes described in the present Policy. The retention period will vary and will depend principally on:
- the purpose for which L&E Global uses your Personal Data, it being understood that L&E Global will keep the information for as long as necessary – though not longer – in light of the relevant purpose, and
- legal obligations, laws or regulation may set a minimum period for which L&E Global has to keep your Personal Data in its possession.
L&E Global will ensure that the Personal Data is erased or anonymized after this period.
- 14- CONTACT
For all additional information in connection with this Policy or for any request for correction, access or restriction of Processing, please contact L&E Global at email@example.com. You will receive confirmation of your request free of charge within thirty (30) days, it being understood that this period may be extended by an additional period of thirty (30) days, provided that L&E Global considers the request in question to be a complex one.
- 15- DISPUTES AND APPLICABLE LAW
This Policy is governed by and construed in accordance with Belgian law. All disputes relating to this Policy, including its interpretation, as well as disputes relating to the protection of Personal Data, fall under the exclusive jurisdiction of the courts of the district of Brussels, without prejudice to mandatory legal provisions to the contrary. Before bringing a legal claim to court, all parties concerned shall take all possible measures to resolve their dispute amicably.
On the other hand, cookies and similar technologies do not allow us to systematically collect data which may potentially identify the users of our Website. Cookies help us to enhance the functionalities of our Website, to serve our users interests better and to measure the effectiveness of our Website’s content.
We are legally obliged to ask for your consent for using or saving cookies and similar technologies on your computers and/or mobile devices. The present cookies policy (hereinafter referred to as the “Cookies Policy”) together with our privacy statement, informs you in a clear and complete way of the cookies we use and their purpose.
Any further information can be obtained by submitting a written notification to the following e-mail address: firstname.lastname@example.org.
What is a cookie?
Rejecting and deleting cookies
You can set up your browser in such a way that (i) no Cookies are stored, (ii) you can accept or reject each Cookie or (iii) that all Cookies are deleted when you close your browser. Useful information for managing Cookies can also be found on the informative All About Cookies website.
Cookies are stored on every Computer you use to visit websites. If you don’t want to receive any Cookies at all, you should change the settings on all the Computers you use.
How long will the cookies remain on my Computer?
A Cookie has a certain validity period starting on the moment it is stored on a Computer. After the validity period has lapsed, the Cookie will be automatically deleted by your browser. For some Cookies, the validity period is the duration of the browser session. Other Cookies remain valid for a longer period (with a maximum of 12 months) so they can be recognized on the occasion of a subsequent visit to our Website.
Please be aware that Cookies cannot link an individual to a surname or first name. In so far as we collect Personal Data (as defined in our privacy statement) using Cookies, we process these Personal Data in accordance with our privacy statement.
What Cookies will the Website use and for what purposes?
The Website uses a number of different Cookies for analytical purposes and to enhance the functionality and user-friendliness of our Website.
- Single session cookies. These enable the Website to keep track of your movement from page to page in order to ensure that you will not be asked for the same information you have previously given during your visit to the Webs Cookies allow you to proceed through the Website quickly and easily without having to authenticate or reprocess each new area you visit. We may use the Cookies to analyse user behaviour, such as which pages have been visited during the session, in order to improve your overall experience, for example by determining and displaying more user-relevant content.
- Remember me Cookies. These Cookies enable the Website to remember your personal preferences such as log in details in order to improve the user experience, for example by avoiding you having to re-enter these details on each visit to the Webs
- Remember my language Cookies. These enable the Website to retain your language preference for future visits in order to improve the user experience. In addition, this Cookie will determine the language in which the non-content aspects of emails received from the Website will be displayed in.
- Persistent Cookies. These Cookies enable us to collect information such as number of visitors to the Website and pages visited in order to analyse user behaviour. This information is collected in an anonymous form and will be collated with similar information received from other users to enable us to compile reports in order to develop and improve user experience, for instance by displaying more tailored and relevant content. These Cookies record how visitors use our Website. This information may be used to analyse the use of our Website and generate statistics and enables us to better understand our Website visitors and improve the Website using that knowledge.
L&E Global does not share the Personal Data thus collected with third parties unless it has an obligation to do so.
Third party Cookies
The single session and persistent cookies are provided on our behalf by a trusted third party service provider to aid in the reporting of user behaviour on the Website. This behaviour is analysed to provide an improved user experience. The information collected is not linked to Personal Data.
L&E Global’s Website may provide referrals – including hyperlinks – to websites offered by other companies/persons or by social media. L&E Global is not responsible or liable for any processing of your Personal Data via these websites. This Cookies Policy does not apply to the use of such websites.
If you share content from L&E Global’s website via social media, your Personal Data will be visible to the visitors of your personal pages on these social media websites. We are not responsible or liable for any processing of your Personal Data via such media.
As opposed to the relevant social media provider, we do not store or read the Cookies related to social media. We have limited knowledge of and no control over these Cookies. Consequently, we accept no responsibility or liability for these social medial Cookies or for how the relevant social media providers use the collected information.
With your permission, we place Cookies on your Computer, which can be retrieved as soon as you visit our Website. When using our Website, we collect (part) of your IP address, type of browser, operating system and application version, language settings, the page through which you visited our Website and the pages of our Website you visited. If you visit our Website via a mobile device, we’ll also collect information about your mobile device brand and other specific features of the device. The profile thus created is not linked to your name, address, email address and the like, but only serves to match content to your user profile so that they are as relevant to you as possible.
Access, correction and deletion
In accordance with our privacy statement, you have the right to access, correct and delete your Personal Data processed by L&E Global at any time and without any cost, as well as the right to object to the processing of your Personal Data for direct marketing purposes. Please be aware that this may imply that certain functionalities of our Website are disabled and that an optimal user experience of our Website cannot be guaranteed.
If you wish to access your Personal Data processed by L&E Global or have your data updated, corrected or deleted, please send your request to email@example.com.