Privacy Policy
This privacy policy (hereinafter referred to as the “Privacy Policy”) defines and informs concerned persons and clients (potential and actual), hereinafter referred to as the “concerned persons”, of the manner in which Sandrine Hellinckx, hereinafter referred to as “Pivotalys”, uses and protects the information transmitted to it, in particular, but not exclusively, when the concerned person uses this website accessible via the following link: https://www.pivotalys.com/, hereinafter referred to as the “Website”, or when the concerned person uses or subscribes to the services offered by Pivotalys.
This Privacy Policy may be amended or supplemented at any time by Pivotalys, notably in order to comply with any legislative, regulatory, case law or technological developments. In such a case, the date of the update will be clearly identified at the beginning of this Privacy Policy. Such amendments shall become binding on the concerned person as from the date they are published online. The concerned person is therefore invited to consult this Privacy Policy regularly, as well as the rules regarding the use of cookies, in order to be aware of any possible changes.
PERSONAL DATA
As a general rule, it is possible to visit the Website without providing any personal information. In any event, the concerned person is under no obligation whatsoever to transmit any information to Pivotalys.
However, in certain cases where such information is not provided, the concerned person may not be able to benefit from the requested services. Indeed, in order to provide the concerned person with the services offered by Pivotalys, the latter may, in certain cases, request that the concerned person provide their surname, first name, postal and email addresses, hereinafter referred to as the “Personal Information”. By transmitting such information, the concerned person expressly agrees that it may be processed by Pivotalys for the purposes specified under section 2 below and for the purposes stated at the time of each request.
In accordance with the General Data Protection Regulation (GDPR) of 14 April 2016, Pivotalys informs you of the following:
Identity of the Data Controller
The data controller is:
Sandrine Hellinckx - Avenue des Coccinelles 45 - 1170 Brussels
BE 1034.637.632
E-mail. sandrine.hellinckx@gmail.com
The data controller ensures the accuracy and relevance of the personal data collected and processed. In addition to the above, the data controller ensures that such data complies with the applicable regulations and with this Privacy Policy.
Data collected
Pivotalys collects the following personal data:
preferred language
surname and first name;
postal address
email address
landline and/or mobile telephone number(s)
employment and job function
training and education
internet browser used and browsing method used (PC or mobile)
billing data, bank account number and VAT number.
Purpose of processing
Pivotalys may process the personal information transmitted for the following purposes:
sending electronic newsletters to the concerned person
providing the information or services requested by the concerned person (on-site, by email, by phone or by post) and tailored to the concerned person, including in particular:
processing and monitoring requests for quotation and/or information submitted to Pivotalys
presenting the services offered and provided by Pivotalys
compiling statistics related to visits to the Pivotalys Website
collecting information enabling Pivotalys to improve the Website and its services (in particular through cookies)
enabling Google Analytics to analyse the Website through cookies, as further described in the disclaimer available on the Pivotalys Website via the following link: https://www.pivotalys.com/disclaimer
enabling the concerned person to access Pivotalys services and infrastructures under the best possible conditions
managing agreements concluded between the concerned person and Pivotalys with regard ro its legal and contractual obligations.
Recipients
Pivotalys is the sole recipient of the personal information communicated.
Such information, whether in individual or anonymised form, will under no circumstances be transferred to third parties, except to subcontractors, external service providers or partners engaged by Pivotalys in connection with its legal or contractual obligations or in the performance of its corporate purpose, in order to ensure a complete and appropriate service to the concerned person.
Neither Pivotalys nor any of its subcontractors, external service providers or partners market the personal data of Website users or Pivotalys concerned persons.
Retention Period
Personal information is only kept by Pivotalys for the period corresponding to the purposes for which it was collected as set out above. In any event, unless a different retention period is required by a legal or contractual obligation, data will not be retained for more than 10 years.
Data storage location
Pivotalys stores data electronically and primarily in the Google Drive cloud environment, whose privacy policies may be consulted via the following link: https://policies.google.com/privacy?hl=fr&gl=US
Pivotalys uses its best efforts to ensure data security by implementing technical and organisational measures in line with the standards applicable to this type of data and business.
Rights of the concerned person
The concerned person has the following rights, in accordance with the above-mentioned European Regulation:
Right of Access and Communication of Data
The concerned person has the right to access and consult their personal data retained by Pivotalys. The concerned person may also obtain information on how Pivotalys obtained such data and to whom it is communicated. The concerned person may also request a copy of their personal data being processed.
Given the obligation of security and confidentiality in the processing of personal data, any request for access and consultation made by the concerned person will be processed subject to proof of identity, notably by means of an electronic or paper copy (accompanied by a signature) of a valid identity card or passport of the concerned person. This request will in any case be free of charge for the concerned person.
Pivotalys may however object to concerned person requests that are manifestly abusive or unfounded (due to their number or repetitive or systematic nature).
Right to rectify data
The European Regulation allows the concerned person to request the rectification, updating or erasure of data concerning them where such data is inaccurate, erroneous, incomplete or outdated.
Right to object
The concerned person has the right to object to the processing of data in the following two situations:
where the exercise of this right is based on legitimate grounds as provided for in Article 6(f) of the GDPR; or
where the exercise of this right aims to prevent the collected data from being used for commercial prospecting purposes.
Right to erasure
The concerned person has the right to request and obtain the erasure of their data held by Pivotalys.
Pivotalys will comply with the request of the concerned person if:
the personal data is no longer necessary for the purposes for which it was collected;
the processing was based exclusively on the consent of the concerned person and the concerned person withdraws such consent;
the concerned person objects to the processing on legitimate grounds.
In any event, the request for erasure may be refused by Pivotalys where the data retention is necessary for the establishment, exercise or defence of legal claims or for compliance with a legal or contractual obligation incumbent upon Pivotalys.
Right to data portability
The concerned person may request that their personal data be transmitted to another data controller. The concerned person may therefore request that Pivotalys provide such data in a structured, commonly used and machine-readable format.
Exercise of Rights
The above-mentioned rights may be exercised by sending a letter to the postal address of Pivotalys or by email to: sandrine.hellinckx@gmail.com.
Response Times
Pivotalys will comply with the concerned person's request by replying with the same means as that used by the concerned person to exercise their right.
Pivotalys undertakes to respond to any request for access, rectification, objection, erasure or any additional request for information within a reasonable period and, in any event, within a maximum period of one month from receipt of the request.
Depending on the complexity of the request, the response period may be extended to three months, in accordance with the applicable European Regulation.
Persons authorised to access personal data
Only members of Pivotalys staff are authorised to consult personal data, subject to the application of section 4 above. Such persons reasonably require access to the data in connection with the tasks and missions entrusted to them or the requirements related to Pivotalys’ activities.
Authorised service providers and transfer outside the European Union
Pivotalys further informs the concerned person that it uses authorised subcontractors to facilitate the collection and processing of the data communicated. These subcontractors are located within the European Union.
Pivotalys has ensured beforehand that its service providers implement adequate safeguards and comply with strict conditions regarding confidentiality, use and data protection.
Complaint to the competent authority
Pivotalys wishes that any difficulty relating to the processing of personal data be resolved through dialogue. However, where this is not possible, the concerned person has the right to lodge a complaint with the Belgian Data Protection Authority (“DPA”).
The DPA is located at Rue de la Presse 35, 1000 Brussels, Belgium, and may be contacted by telephone at +32 2 274 48 00 or by email at contact@apd-gba.be.