Date of Last Amendment: 27 November 2022
Our contact details
- Name: EPIC Web Agency SPRL
- Address: Rue Wiertz 38 box 12,B-4000 Liège Belgium
- BCE number: 0812.258.994
- Telephone number: +32 78 15 11 45
- Email: email@example.com
Data categories and source
We currently collect and process the following information about you/your company:
- Contact details (i.e. first name, last name, email address) in particular to send you our newsletter;
- Information about your project (budget, deadline and any other information or document that you would share with us);
- Information about you in case you are sending us your application (portfolio, what position you are looking for, your resume and any other information or document that you would share with us);
- Financial personal data in order to prepare our invoice for our services.
Purposes of the processing of personal data
Most of the personal data we process are provided to us directly by you for one of the following reasons:
- To send you our newsletter (based on your consent);
- To thoroughly answer to your request via the forms on our website (for a new project, for an application or any other requests you would send us);
- To monitor that our website is functioning correctly and to improve our services (based on our legitimate interest).
In accordance with the General Data Protection Regulation (GDPR) and the Belgian law of 30 July 2018 on the protection of individuals with regard to the processing of personal data, the legal bases on which we may rely to process this personal data, are as follows:
- We may rely on your (explicit) consent;
- We may have a contractual obligation to process your personal data if we have a contract together;
- We have legal obligations that impose us to process your personal data (such as accounting and tax obligations that requires us to keep your information, for example in the context of invoicing our services to you)
- We have a legitimate interest in collecting your personal data and exchanging with you (including to respond to your requests, prevent abuse and fraud, monitor the regularity of our services, exercise, defend and preserve our rights, for example in case of disputes, as well as to provide evidence of any violation of our rights, manage and improve our relationship with you, continuously improve our website and our products/services, unless these interests are overridden by your interests or your freedoms and fundamental rights requiring the protection of your personal data.)
In any case, we ensure you that we maintain a proportionate balance between our legitimate interest and respect for your privacy.
If the legal basis for our processing is based on your consent, you have the right to withdraw it at any time (for example, you can opt-out at any time from receiving our newsletter).
The information you provide may be shared, in complete confidentiality, with our subcontractors.
We use subcontractors (in particular IT service providers for the secure hosting of your data) who are carefully selected. These subcontractors are subject to an obligation of confidentiality.
In the event of a dispute, the personal data of the users concerned may be transmitted to a third-party responsible for managing disputes (law firm, collection company, etc.), which will also ensure compliance with the applicable legislation regarding this data.
In the event of a transfer (total or partial) of our activities (merger, sale, transfer of assets, judicial reorganisation, etc.), we may also share your personal data as part of this operation.
With your consent, we may also transfer your personal data to partner companies (for example if we subcontract part of the mission or the request you have entrusted to us).
Data supply requirement: regulatory or contractual?
The requirement to provide personal data may be a contractual requirement or a condition for the provision of our services (indeed, we may need your personal information to invoice you or to send you our newsletter).
If you do not want to provide us with your personal data when required, we may not be able to perform our services (e.g. we won’t be able to send you our newsletter if you do not provide us with your email address).
Data retention period
We keep your data for a certain period of time which may vary depending on the circumstances. After this period, we will erase or anonymize your personal data.
We will retain personal data about you for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
To give you concrete examples : we will keep your personal data until your decide to opt-out from our newsletter for this purpose and we will keep your financial personal data until it is not required anymore from a legal perspective (usually 10 years).
We do not make automated decisions on the basis of your personal data.
Rights of the data subject
Under data protection legislation and subject to our own rights and obligations, you have the following rights:
Right of access: You have the right to request access to your personal data from us, free of charge, and to obtain a copy in an accessible format.
Right of rectification: you have the right to ask us to rectify personal data that you consider to be inaccurate. You also have the right to ask us to complete your information.
Right of erasure: You have the right to ask us to delete your personal data in certain circumstances.
Right to processing restriction: you have the right to ask us to restrict the processing of your personal data in certain circumstances.
Right to object to the processing: you have the right to object to the processing of your personal data in certain circumstances.
Right to data portability: you have the right to ask us to return your data to you in an easily transferable format or, if technology permits, to transfer it directly to another service provider.
To exercise these rights, you can simply send us an email to the following address: firstname.lastname@example.org
Please note that we may need to verify your identity before responding to your request.
We will then do everything in our power to do what is necessary as soon as possible (usually within 30 days).
Complaint to the supervisory authority
If you are not satisfied with the way we have responded, you also have the right to file a complaint with the Data Protection Authority, whose contact details are as follows:
Rue de la Presse, 35, 1000 Brussels
Tel: +32 (0)2 274 48 00
Transfer of personal data outside the EEA (European Economic Area)
Unless otherwise indicated, we do not transfer your personal data outside the European Economic Area. If this happens, we would only transfer your data to a non-EU country if that country provides an equivalent level of protection of the European Union (for more information, see the following link).
In such a case, we may also use the standard contractual clauses drafted by the European Commission or specific exemptions under Article 49 of the GDPR (such as your consent or the fact that the transfer is required for the performance of the contract).
Protection of the data subject’s personal data
What is our policy on data concerning minors?
Our website and services are not targeted to minors. If you learn that your minor child has provided us with their personal data without your consent, please contact us at the following address: email@example.com.
We undertake to take the necessary steps to replace the provisions that would be considered as null, invalid or lapsed with valid provisions whose purpose will be as close as possible to that of the provisions to be replaced.
What to do in case of dispute?
Long trials do not benefit anyone. In the event of a dispute between us, we commit to give priority to dialogue and openness in the search for an amicable solution.