Preamble

This charter reflects the Privacy Policy of Codata Services SA in accordance with the General Regulations on the Protection of Personal Data which took effect on May 25th, 2018.
Codata Services SA is a limited liability company under Belgian law.
Its head office is established in Belgium at Avenue du Bourgmestre Jean Materne 143-145, 5100 Namur-Jambes. It is registered at the Crossroads Bank for Enterprises under number 0505.976.645 and for value added tax purposes with identification number BE0505.976.645
Codata Services SA has no operating office outside Belgian territory but is active in various countries of the European Union. Incidentally, Codata Services is also active outside the European Union, particularly in Switzerland and Great Britain.

Codata Services SA carries out a “B2B” activity which consists in offering data and decision support tools to companies active in the commercial real estate and retail sectors.

For the purpose of this activity, Codata Services SA may be required to process personal data in the sense of the General Regulations on the Protection of Personal Data, in force since May 25th, 2018.

Codata Services SA refrains from any profiling process of a personal nature, the collected data being solely for the purpose of supplying products and services of a strictly professional nature, intended for professional companies in the commercial real estate and retail sectors.

This Privacy Policy applies to all personal data (personal data is any information directly or indirectly identifying a natural person such as name, address, telephone number) processed by Codata Services SA acting as responsible for data processing in the context of the products and services provided to business customers and also as data controller for personal data of persons “related” to business prospects.

The term “related persons” means any natural person related to your business, including manager, legal representative, partner, owner, employee, beneficial owner, in the current or future relationship with Codata Services SA.
The charter specifies which data we are likely to collect about these persons, in which way and for how long we use these data, with whom we are likely to share them and what measures we take to ensure their confidentiality and security, as well as the rights attached to the owners of the personal data.
It covers all the processing of personal data whose responsible is Codata Services SA.
All ”related persons” whose data you transmit to us must be informed, in particular through this Charter, of how we are likely to collect and process their data. These persons must be informed of their rights by your company.
When we use the words ”you” or ”your”, this means you, your company or anyone who may act on behalf of your company.

 

Part 1: We must work together to protect the privacy of related persons

1.1 Codata Services SA protects personal data.

We process personal data in a legal, correct and transparent manner.

Whether you are a customer or a prospect, Codata Services SA takes the same care in data processing.

1.2 Read this information carefully to know your rights.

We advise you to read this information carefully in order to clearly understand for what purpose Codata Services SA uses your data. You will also find more information in this charter about privacy rights and recourses and how they can be exercised.

Codata Services SA has the right to amend this charter. The most recent version will always be available on
www.codata.eu. You will be notified of any changes by Codata Services SA, by email or other communication channels.

1.3 Contact Codata Services SA if you have any questions about data processing.

If you have questions about the protection of privacy or wish to change the privacy settings or exercise your rights, you can contact Codata Services SA in the following ways:

  • By mail to the following address:

    Codata Services SA – Support Service/ Privacy –
    143-145 Avenue du Bourgmestre Jean Materne à 5100 Namur-Jambes – Belgium.
     
  • By e-mail to the following address: privacy@codata.eu

 

Part 2: You have the right to the protection of your privacy.

You have rights in relation to the processing of your personal data.

2.1 You have the right to consult your data.

Through the right of access, you can obtain information about the processing of your personal data as well as a copy of this personal data.

2.2 You can request correction of your data.

If you believe that your personal data is inaccurate or incomplete, you may require that this personal data be modified accordingly.

2.3 You can request the deletion of your data.

If you have any suspicions about inappropriate treatment of certain data by Codata Services SA, you may request that this data be deleted, within the limits of legal or regulatory provisions or for legitimate reasons.

2.4 You can object to a specific use of your data.

If you do not agree on how Codata Services SA processes certain data based on its legitimate interests, you have the right to object. We will accept this opposition unless there is a regulatory reason.

2.5 How to exercise your rights.

Always be specific when you want to exercise your rights. Codata Services SA will then be able to process your request in a fast and efficient manner.

Codata Services SA must verify your identity with the utmost rigor to prevent someone else from exercising your rights instead of you. For this purpose, a proof of identity will be required in the case of such requests.

If you have a complaint about the exercise of your rights, the service in charge of personal data is ready to help you:

  • By mail to the following address:

    Codata Services SA – Support Service/ Privacy –
    143-145 Avenue du Bourgmestre Jean Materne à 5100 Namur-Jambes – Belgium.
     
  • By e-mail to the following address: privacy@codata.eu

If you would require more information on this matter or if you do not agree with the view of Codata Services SA, please visit the Data Protection Authority website, https://www.dataprotectionauthority.be

You also have the right to file a claim with the Data Protection Authority by sending:

  • A postal mail to the following address:

    Data Protection Authority - Rue de la presse, 35 – 1000 Brussels
     
  • An e-mail to the following address: contact@apd-gba.be

 

Part 3: Codata Services SA has many reasons to process your personal data.

3.1 Codata Services SA must be able to correctly execute a contract.

As a customer of Codata Services SA, you use a number of services that require Codata Services SA to assume its accounting and administrative responsibilities. Examples of personal data processing for contract fulfilment purposes include account management, payments, service access.

For this purpose, Codata Services SA must sometimes transmit certain personal data to an intermediary, a counterparty or a subcontractor (for example the names and surnames of the services users).

3.2 Codata Services SA must be able to operate as a company.

This is called ”legitimate interest”.
Codata Services SA has, as does any commercial enterprise, a number of legitimate interests which provide the basis for the processing of personal data.
In this regard, Codata Services SA ensures that the impact of this processing on the protection of your privacy is as limited as possible and that, in any case, the balance between the legitimate interests of Codata Services SA and its members, and the possible impact on the protection of your privacy is not disturbed. If you still have objections against this processing, you can exercise your rights of opposition.
Personal data are processed in different situations.
They allow us to:

  • Manage and provide you with our products and services, including our mobile apps and websites
  • Administer your subscription to our services and your use of them
  • Analyse the use of our services to develop new features and services. This analysis of your behaviour will not produce any legal effect towards you and / or have any other significant impact on you. The purpose of establishing a profile is solely to provide you with personalized advice, options and benefits
  • Offer you personalized information, unless you have decided to refuse this solicitation
  • Measure, test and monitor the indicators and effectiveness of our services
  • Develop trade statistics
  • Enrich our products and services by allowing our members / customers to access your business details. This information is limited to your name, surname, company, function, postal and electronic business addresses and business telephone numbers, excluding any other information and any aspect of profiling
  • Improve our products and services
  • Review claims concerning our products and services or our website
  • Conform to legal, regulatory and compliance obligations and requirements
  • Periodically send promotional e-mails about our products and services, special offers or other information which we think you may find of interest
  • Contact you from time to time, by e-mail or telephone, to conduct market research
  • Comply with legal obligations incumbent upon Codata Services SA
  • Serve as evidence in the event of a dispute (archives)
  • Establish, exercise, defend and preserve the rights of Codata Services SA or persons it may represent, for example in the event of litigation
  • Create synergy, increased efficiency or other organizational or procedural benefits
  • Organize, create and manage direct marketing campaigns:
    • For existing customers and subscribers in order to offer:
      • actions, promotions, invitations to events, offers and benefits issued by the service or services to which they subscribed,
      • subscription offers to other similar services
    • For prospective purposes: including promotional communication to prospects by telephone, mail, advertising or other channels

 

Part 4: Codata Services SA uses different kinds of data depending on its purpose.

Codata Services SA processes the personal data of your ”related persons” for different purposes. Read on to find out what kinds of data this may concern and inform concerned related persons accordingly.

4.1 The information you provide to us that allows us to identify the ”related persons”, to contact them and to effectively collaborate with you.

Here are some examples of the purposes for which Codata Services SA may use this data:

4.2 Public data and data collected via third parties

Codata Services SA processes certain public data.

These may include, for example:

  • data that is subject to a publication obligation such as your appointment as director of a corporation;
  • or data that you have made publicly available, such as information available on your website, or which is publicly accessible through social networks, or data about you that Codata Services SA has received from third parties who hold them validly.

It may also concern data that is publicly available, for example because it is published in the press, or information found on specific information websites such as the Crossroads Bank for Enterprises, the Register of Commerce and Companies, etc.

These public data and data received via third parties may be used for the purposes of Codata Services SA set out in point 3.2 of this Privacy Policy, but also to check the accuracy of the data in our files.

4.3 The information that you entrust to an employee of Codata Services SA may be processed.

If you are in contact with an employee of Codata Services SA or ”assimilated”, be it on the premises or by telephone, conversations are generally reported:

  • to get an overview of the contact;
  • to have a (brief) report of the contact;
  • for reminder purposes of tasks that our collaborator still has to perform.

Even if you are not yet a customer, Codata Services SA will record the information you provide. It may use this information later, when you become a customer. Codata Services SA wants to avoid you to communicate the same information several times or repeat your answers to the same questions. It can thereby also improve the continuity of its services.

4.4 All written correspondence with Codata Services SA is recorded.

If, in order to contact Codata Services SA, you use your e-mail address or other means of communication, Codata Services SA may send you its administrative and legally binding communication by the same means.
Correspondence with employees, in their capacity as employees of Codata Services SA, is presumed to be professional and may therefore be examined within the framework of:

  • their mission,
  • the production of evidence,
  • control at the workplace,
  • security,
  • optimization and / or continuity of service delivery.

4.5 Assignment or transfer of contracts

When a contract is assigned, transferred or assigned individually or globally, we may be required to disclose the ”related persons” data to the future beneficiary.
 

Part 5: About security and privacy

5.1 At Codata Services SA, not everyone has access to your data.

Only authorized persons have access to your personal data and only if this data is relevant to the performance of their mission. Within Codata Services SA, your personal data is normally processed and accessed only by the departments:

  • whom you have, have had or wish to have a contractual relationship;
  • whose intervention is required for the delivery or monitoring of services, products and contracts;
  • fulfilling the requirements that derive from the principles of sound management;

People who have access to your data are also bound by a strict duty of confidentiality and are required to comply with all technical requirements to ensure confidentiality of your personal data and security of the systems that contain them.

5.2 Your data is processed in a limited number of locations.

For the processing of personal data, Codata Services SA seldom makes use of subcontractors.

These are companies that process data on behalf of Codata Services SA such as:

  • consultants, lawyers, bailiffs, attorneys, collecting companies, etc.
  • IT security service providers.

5.3 Data transfer outside the European Economic Area.

Codata Services SA ensures that strict rules are followed in this regard. We may transfer your personal data to third-party suppliers or customers located in countries outside the European Economic Area (EEA), for example in the United States. This transfer of data outside the EEA is legitimate if the recipient of the data is located in a country which ensures an adequate level of protection confirmed by a decision of adequacy of the European Commission. Some of these countries may not have equivalent legislation protecting the use of your personal data. In this case, we assessed the possibility of applying protection measures equivalent to that of the EU, for example by signing standard contractual clauses. In special cases, we will ask for your preliminary consent before transferring your data outside the EEA.

5.4 Codata Services SA takes concrete steps to secure your data.

Codata Services SA ensures that strict rules are followed and that the subcontractors involved:

  • only have access to the data they need to carry out their tasks;
  • are committed to Codata Services SA, on the one hand, to treat these data in a safe and confidential manner, and on the other hand, to use them only for the conduct of their missions.

Codata Services SA takes in-house technical and organizational measures to prevent personal data from falling into the hands of unauthorized persons or being modified or destroyed inadvertently. Premises, servers, networks, transfers and data are adequately protected.

With regard to the links to websites contained in documentation and information available on the Codata Services SA website, Codata Services SA recalls that it does not control these websites. The providers of these websites and of the information contained therein may apply their own privacy policies. We therefore recommend you to read these policies, since Codata Services SA can by no means be held responsible for the content of these websites, for the use of their content or for their privacy policy.

5.5 Codata Services SA does not keep your data indefinitely.

Codata Services SA only uses your personal data if it has a specific reason to do so. Of course, we will keep your data as long as you use our services and platforms including our websites.

With regard to customers, the majority of information is kept for the duration of the contractual relationship and for a maximum of 10 years after the end of the contractual relationship, unless specific deadlines have been set.

We may retain the data even if you decide to stop using our services, notably to defend our interests or assert our rights. Therefore, certain data may be retained for an additional period of time, particularly when concerning the management of claims and / or litigation as well as to meet our legal and regulatory obligations.

Regarding prospects, the information is kept for 3 years counting from the date of collection, or from the date of our last contact.

After the deadlines mentioned above and when we will not need these data anymore, we will destroy them safely according to our internal policy.

5.6 Codata Services SA only responds to certain third parties.

Since Codata Services SA must respect its confidentiality obligations and privacy legislation, it can only answer questions from third parties:

  • which are based on a legal provision or a legitimate interest;
  • which are necessary for the performance of the contract;
  • or with consent of the person concerned.

5.7 You can contribute to securing your data.

Codata Services SA alone does not have any influence on certain aspects of the (technical) data processing and therefore cannot offer a guarantee of total security. We think for example of the Internet or mobile communication (such as smartphones).

Your vigilance is therefore of particularly necessity.

In particular, it is your responsibility to keep the access codes to the services provided by Codata Services SA confidential.

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