Privacy & Cookie Policy

1. General - what is the purpose of this Privacy Policy?

1.1. The website available at the address www.sofindev.com (hereafter: the ‘Website’) is operated by and is the property of Sofindev Management nv, with business number 0884.934.760 and with registered office at Lambroekstraat 5D, 1831 Diegem, Belgium (hereafter: ‘Controller’, ‘we’ or ‘our).

1.2. This Privacy Policy is intended to provide information about the processing of your personal details on or via the Website. This Privacy Policy is intended to safeguard the proper and transparent processing of your personal data.

We highly recommend that you carefully read this Privacy Policy.

1.3. This Privacy Policy is only applicable to the processing of your personal data on or via the Website by the Controller and/or by controllers (e.g. external service providers or subcontractors) which process your personal data on our behalf and which have concluded a controller contract with us in this regard.

This Privacy Policy does not in any way whatsoever cover the privacy policies of other websites or applications to which the Website refers via (permitted) hyperlinks or of companies or entities that advertise our services.

1.4. We are responsible for processing your personal data. As the Controller, we take all appropriate technical and organisational measures so that the processing is in compliance with Regulation (EU) 2016/679 of 27 April 2016 (hereafter: ‘GDPR’). Our appointees or employees who have access to your personal data are also required to comply with the obligations of the GDPR.

1.5. This Privacy Policy can be made available to you electronically and can be viewed at any time under ‘Privacy Policy’ on the Website. If you have any requests or additional comments, please send an email to info@sofindev.com. We shall reply to you with the steps that have been taken in this regard within one month after receipt of your request or question.

1.6. The Controller maintains the right to change this Privacy Policy at all times. This Privacy Policy was last updated on 6 May 2020.

1.7. We must inform you that you must always have express permission from the relevant people before uploading to or placing information on the Website about these people.

2. Who are we and how can you contact us?

Legal form: Limited Liability Company

Company name: Sofindev Management nv

Trade name: Sofindev

Registered office: Lambroekstraat 5D, 1831 Diegem, Belgium

VAT number: BE0884 934 76

Telephone number: +32 (0)2 720 70 07

E-mail: info@sofindev.com

Hyperlink(s) Website: www.sofindev.com

3. For which purposes do we process your personal data?

We process your personal data that you provide on or via the Website, as part of the given consent, to communicate about Sofindev Manangement nv via the newsletter and we store your personal and business-related data in the context of our business relationship.

4. What are the legal grounds for processing your personal data?

4.1. We only process your personal and business-related data in accordance with the legal requirements. We record this data and process it only in the context of the fulfilment of our business obligations to you or to send communication around Sofindev Management nv via the newsletter. Unless you provide us with this information, we are unable to start a business relationship with you or send newsletters. We use your personal and business-related data only in situations and to the extent that you have provided your specific consent.

4.2. In all cases, from the moment that you approve our Privacy Policy, by clicking on the button prior to using the Website and/or the processing of personal details on or via the Website, you provide us with free, specific, informed and unambiguous permission to process your personal data and you explicitly consent to the ways in which this is processed, as set forth in this Privacy Policy.

5. Which personal data do we process?

5.1. On or via the Website, we only process the following personal data if and insofar you have provided your consent:

Amongst the personal and business information we process about you is all the personal or business information we receive from you. This may include your full name, title, gender, mailing address, your telephone number(s), fax number, your email address and/or company name.

5.2. Among other things, we process the following data: device data, log file data such as the IP address, browser, and operating system, the external website that brought you to our Website, and the pages that you visit on the Website (and the date and time you visited these pages). This data is only automatically (without any sort of registration) processed for statistical purposes and with a view to further improve the Website.

6. Who receives and/or processes your personal data, in addition to the Controller?

Your personal data is also processed on our behalf by, among others, our IT supplier SKINN. This processing is arranged in a controller contract that we have concluded with them.

7. Do we pass your personal data on to companies or entities in non-EU countries?

Your data is stored at the CRM company's data center with which we have an agreement. The data center is located in Canada. When your personal data is passed on outside the EEA, we will provide appropriate safeguards to ensure that this transfer is carried out in accordance with applicable data protection rules. You can request additional information regarding this.

8. Where, how and for how long do we retain your personal data?

We shall not store your personal data for any longer than required to achieve the purposes specified in Article 4. In this context, we could therefore store your personal data for some time. We will store your personal data for a maximum of 10 years after the end of our business relationship.

9. What are your rights?

9.1. You have the right to request:

- a review of your personal data;

- improvement (rectification) or removal (deletion) of your personal data;

- a restriction of the processing that relates to you.

9.2. You have the right to appeal against the processing of your personal data. You can object to the processing of your personal data for direct marketing, including the newsletter, at all times and at no cost.

9.3. You have the right to have your personal data transferred to another controller.

9.4. If the processing of your personal data is based on your permission, you have the right to revoke this permission at all times. However, the revocation of your permission is not retroactive and the lawfulness of the processing based on your permission before the revocation thereof shall remain intact.

9.5. You have the right to submit a complaint to the Privacy Commission/Data Protection Authority.

9.6. The exercise of the aforementioned rights is dependent upon the requirements and conditions as stipulated in the GDPR.

9.7. In order to exercise these rights, you can send a simple request to info@sofindev.com, providing adequate proof of your identity.

10. What are our obligations?

10.1. We take all the appropriate measures to guarantee the security level that is aligned with the risks for and during the protection of your personal data.

10.2. We maintain a processing register in which the (category of) processing of your personal data is described.

10.3. We cooperate with the authorised privacy authorities (at their request).

10.4. Where necessary and/or required, we shall immediately inform the Privacy Commission/National Data Protection Authority within 72 hours after detection of any security incidents or data leaks (including illegal processing, loss, unavailability, destruction, damage, or unauthorised distribution of your personal data).

We will also inform you under the terms and conditions specified in the GDPR if such a violation appears to entail a high risk for your rights.

If you become aware of a violation in relation to your personal data or that of others, you may contact us on the email address info@sofindev.com.

10.5. If we use new technologies or applications in order to process your personal data, which could correspond to high risks in relation to your data protection, we will conduct a so-called ‘Data Protection Impact Assessment’ (DPIA) under the conditions of GDPR and, if necessary, consult the Privacy Commission/Data Protection Authority in advance.

11. Cookie Policy

The Website uses ‘cookies’ with a view to improving the user experience and for the collection of Website visitor statistics. Cookies are small data files that are saved by the browser on your computer when you visit a website and which facilitate the interaction between the visitor and the Website. Cookies do not contain any personal data.

This cookie policy informs you about the use and purpose of cookies on our website. This policy is made available to you electronically and can be consulted at any time under the heading 'Cookie Policy' on our website. We reserve the right to change this cookie policy at any time. Changes will be announced on the website.

11.1. What are cookies and what are they for?

11.1.1. Cookies are small data files that are stored by the browser on the hard drive of your computer or device when you visit and/or consult a website or use a (mobile) application that stores certain user information. Cookie files contain unique codes that, for example, allow your browser to recognise you when you visit the website and thus improve your user experience. Cookies facilitate interaction between the visitor and a website and are used to improve the user experience and to collect statistics among website visitors. Cookies also ensure that your personal settings and preferences are stored or that audio and video material can be played back. Certain cookies may be placed by a third party, e.g. Google Analytics, to measure the use of a website.

11.1.2. Cookies can, among other things, help us to improve your experience with our website and to ensure that it performs optimally as you expect. For example, we may improve your experience of using a website, for example by tracking your use of our website, so that it can be improved to meet your needs.

11.2. Enabling and disabling - managing cookies

11.2.1. You can change your preferences via your browser at any time by following the instructions at the links below, depending on your browser: Internet Explorer, Firefox , Chrome, Safari, iOS.

11.2.2. The use of cookies may be disabled. Your browser allows you to delete cookies automatically or manually and allows you to specify whether or not certain cookies may be placed. You can also set your browser to notify you when a cookie is placed.

If you disable cookies, however, it may happen that the website will no longer function properly or that certain (graphic) elements or applications on the website will function less well or cease to function.

11.3. Consent

11.3.1. Your consent is required for the placement and consultation of cookies via the website on your terminal equipment, unless it concerns the technical storage of information or the provision of a service expressly requested by you when the placement of a cookie is strictly necessary for this purpose.

Therefore, your consent is not required for functional or essential cookies.

However, your consent is required for non-functional or non-essential cookies. Your consent must be:

• obtained before the cookies are placed. If your consent is not given, no cookies may be placed;
• informed, which is why we inform you about the different cookies in this policy;
• express and active. Your permission will therefore be obtained by ticking the boxes in the cookie banner on our website;
• specific and therefore obtained per cookie or per category of cookies.

11.3.2. Functional or essential cookies are necessary for the optimal functioning of our website, to display certain graphical elements, etc. These cookies are technically necessary for the proper functioning and security of the website. These cookies are therefore placed without your consent as they are in the legitimate interest of Sofindev.

On the other hand, non-functional or non-essential cookies are placed for statistical purposes and are not connected with the technical support of our website. They are, for example, the following cookies:

Analytical cookies: these cookies are used to compile statistics on the number of visitors to the website, the most popular web pages, etc. (e.g. Google Analytics - see below). These cookies show how the website is used. For example, Sofindev knows how many times a particular page is read, how much time someone spends on our website, etc. Statistical analyses are made of the information we receive in this way. Thanks to these statistical results, we can improve the structure, navigation and content of our website and related services. The consent of each visitor is required for the placement of these cookies.

11.3.3. If you have given your consent to the use of non-functional cookies on our website, you can change this setting at any time and withdraw your consent. Any cookies already installed will then be deleted. You can do this here.

You can withdraw your consent to our cookies at any time, even if you have previously given your consent. However, please remember that if you do not consent to some of our cookies, the user experience may suffer.

11.4. Third party cookies

11.4.1. Our website uses its own cookies (first party cookies) which are placed directly by our website, as well as cookies from third parties whose services are or may be used on the website (third party cookies) and which are placed by a domain that is different from the domain of our website. This is also indicated in the second column of the table under article 11.6. below.

11.4.2. First party cookies do not presuppose a transfer of personal data to third parties, but may use a third party processor, e.g. to compile statistics. Your consent is also required for the placement of e.g. first party analytical cookies.

11.4.3. Third party cookies make it possible for personal data to be sent to third parties either directly (e.g. by an active component linked to a banner or a spy pixel) or indirectly by placing cookies that are accessible to websites other than that of the advertiser.

For example, we use Google Analytics to collect information about how you use our website. We use the information to compile reports and to help us improve the website.

• Among other things, Google Analytics stores information about:
  the pages you visit;
• the time you spend on each page;
• how you got to the site;
• what you click on while visiting the site.

These securely stored cookies do not collect information that identifies a visitor. All information collected by these cookies is completely anonymous. We only use such information to improve our website. If you do not want Google Analytics to keep track of all websites, please visit: tools.google.com/dlpage/gaoptout.

11.5. The cookies on our website

11.5.1. The table below shows which cookies we use on our website, why we use them and where they come from. We also indicate whether a cookie is a 'permanent' or 'session' cookie. The difference is as follows:

Permanent cookies remain on your device between browser sessions. They are activated each time you visit the website that created this particular cookie. For example, if a 'permanent cookie' is used on a website to remember your preferred language, you don't have to choose that language each time you visit that website.

Session cookies allow us to link a user's actions during a browser session. A browser session starts when you open the browser window and ends when you close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

11.6. The following cookies are or may be used on our website:

Questions? Feel free to contact us via: info@sofindev.com