Privacy Policy
(LAST UPDATED: 13-06-2019)
1. Purposes of this policy
1.1 Information
This policy informs You (in your capacity of data subject) about our processing of your data, in our capacity of Controller in the running of the www.clicpublic.be platform, in compliance with all applicable personal data protection and privacy laws and regulations, including the “GDPR” - General Data Protection Regulation (EU) 2016/679 (hereunder referred to as the “Data Protection Law”), and, more particularly, pursuant to article 13 and 14 of the GDPR.
The purpose of this policy is also to inform you about your rights as regards the processing of your personal data. 1.2 Informed consent In some cases (specified below), the legal basis of our processing is your informed consent. In such cases, this policy’s other purpose is to provide you with the necessary information to get a valid consent from you. Where our personal data processing is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal. To withdraw your consent, you are invited to use the easy opt out mechanisms that are provided in our communication tools or to send us an email (at the address indicated below).
Where our personal data processing is based on your consent, it is our duty to be able to demonstrate that you consented to the processing of your personal data. Therefore, we keep data as regards pertaining to your consent as long as we have the obligation to demonstrate our full compliance with Data Protection Laws. If you are less than 13 years old, it is our duty make reasonable efforts to verify in such cases that consent is given or authorized by the holder of parental responsibility over the child, taking into consideration available technology. This explains why we may ask further information on such holder of parental responsibility.
2. Information on the data controller
Controller’s Identity: Clicpublic SPRL, incorporated under Belgian law, with registered address at rue du Bosquet 21, 1400 Nivelles, Belgium, registered with the Belgian Commercial Register (BCE) under n° 0501.706.962, and with email address info@clicpublic.be (hereafter referred to as “Clicpublic” or “we”).
Contact details of the Controller’s Data Protection Officer: Lorenzo Ceccarini
3. Information on the different personal data processing activities
In this section 3, for any processing activities, we provide information on:
- the purposes of the processing for which the personal data are intended (why do we process your data);
- the legal basis for the processing (and, if applicable, the legitimate interest pursued by us or by a third party);
- the categories of personal data concerned;
- the sources of your personal data;
- the recipients or categories of recipients of the personal data, which are third parties as regards Clicpublic, and to whom we transmit the personal data, if any;
- the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
- where applicable, the personal data transfers to recipients in countries outside EU or to international organisations, and the safeguards provided by the controller in such case;
In order to be as transparent and clear as possible, this information is presented below per processing activity.
Please note that in any cases:
- "Personal identifying data" includes: first name, last name, telephone number, mobile number, email address, physical address, date of birth as well as the official data of the company you are working for (if applicable).
- "Connection data" includes: IP addresses, logs, terminal identifiers, connection identifiers, time stamp information.
- "Internet data" includes: cookies, tracers, navigation data and audience measurement (please also consult our cookie policy) on this regard.
- The data shall at least be made accessible to Clicpublic staff and subcontractors (access rules shall be established on a “need to know” basis).
3.1 Provision of the services offered by www.clicpublic.be and customer management
Purpose:
- Offering, delivering and invoicing the services of www.clicpublic.be, as per our General Conditions
- Performing and delivering all the functionalities of the Clicpublic platform, according to its specifications and your interactions with the platform
- Performing our legal obligations
Legal basis:
- GDPR, art.6, §1 b) (performance of contractual or pre-contractual measures)
- GDPR, art.6, §1 c) (performance of legal and regulatory obligations)
Categories of personal data: All your account data, which include
- your Personal identifying data
- all the data generated by your transactions on the platform (which includes your bidding, buying, selling, offers and payment information)
- all the data generated by your other interactions with the platform (such as consulting and following auctions, adding items to your basket, adding items to your lists)
- Connection data and Internet data
- all the data pertaining to your exchanges with our staff
Sources: We collect directly the data from you or from interactions on the Clicpublic platform. Recipients: We do not share the data with third parties outside the Clicpublic platform unless we are obliged to do so to comply with our legal requirements or as authorized by law or by you (by using the functionalities of the platform, for instance, online payment facilities).
Within the Clicpublic platform, we share your data with other users to deliver the services of www.clicplublic.be, which includes the organization and management of interactions between sellers, bidders and buyers. Retention period: all your personal data are kept as long as you are a registered user of the Clicpublic services. Upon your deregistration, all the data is archived and kept 10 years for evidentiary purposes, and longer if it is necessary to comply with our legal requirements.
Transfers outside EU: no data is voluntarily transferred by us to a recipient located outside EU.
However, given that the Clicpublic is a web-based service, some transfers may occur depending on your location and the location of other users accessing to your data (this implies transfers outside the European Union, without the protection of your data being formally guaranteed, but which are necessary to provide the services).
3.2 Security and improvement of www.clicpublic.be
Purpose:
- Fixing problems and improving our Services by reviewing information associated with your interactions with the platform
- Monitoring and securing our platform
Legal basis:
- GDPR, art.6, §1, f) (legitimate interest of Clicpublic to secure and improve its services)
Categories of personal data:
- Your Personal identifying data
- all the data generated by your transactions on the platform (which includes your bidding, buying, selling, offers and payment information)
- all the data generated by your other interactions with the platform (such as consulting and following auctions, adding items to your basket, adding items to your lists)
- your Connection data and Internet data
- all the data pertaining to your exchanges with our staff
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Sources: We collect directly the data from you or from interactions on the Clicpublic platform. Recipients: We do not share the data with third parties outside the Clicpublic platform unless we are obliged to do so to comply with our legal requirements.
Retention period: the period that is necessary to run the test, analysis, monitoring or securing procedure. Transfers outside EU: no data is voluntarily transferred by us to a recipient located outside EU.3.3 Newsletter, Advertising and marketing
(Note: as regards the processing of your Internet Data in such context, please refer to our cookie policy) Purpose:
- Advertising and marketing the www.clicpublic.be platform
- Informing users and prospects about our activities and auctions
Legal basis:
- GDPR, art.6, §1 a) (consent)
- GDPR, art.6, §1, f) (legitimate interest: "soft opt-in" for persons who are already registered users or for persons already identified as professional prospects)
Categories of personal data: your Personal identifying data.
Sources: We collect directly the data from you and from professional public associations and organizations Recipients: We do not share the data with third parties outside the Clicpublic platform unless we are obliged to do so to comply with our legal requirements.
Retention period: until you decide to withdraw your consent.
Transfers outside EU: no data is voluntarily transferred by us to a recipient located outside EU.4. Your rights as a data subject
The applicable Data Protection Law grants you some rights, on certain grounds, and subject to certain conditions, including the rights to access, correct, object to the use of, or request the deletion or portability of Personal Data, as well as to ask a restriction of processing.
You can see, review and modify your Personal identifying data by signing in to your account. Please, update such data immediately if it changes or is inaccurate. Keep in mind, however, that once performing some actions (such as a bid), you may not be able to change or remove them.
Please contact us as set out in the “Who to Contact About Your Personal Data” section below with any requests to exercise your rights or if you have any questions or concerns about how we process Personal Data.
You can, in principle, exercise these rights free of charge. Please note, however, that the processing of external requests, which are found to be unfounded or excessive, may sometimes be subject to reasonable administrative fees. Please note that some Personal Data may be exempt from access, correction, objection, deletion, restriction and/or portability rights in accordance with the applicable Data Protection Law or other laws.5. Security
Clicpublic will take appropriate technical, physical, legal and organizational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Data you might have with us has been compromised), please immediately notify us. See the “Who to Contact About Your Personal Data” section below.
When Clicpublic provides Personal Data to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Data.6. Complaints
If you are not happy with our processing of your Personal Data and if you feel that contacting us could not solve the issue, the applicable Data Protection Law provides you with a right to lodge a complaint with the competent supervisory authority (more information is available on its website : https://www.autoriteprotectiondonnees.be/). Autorité de Protection des Données
Rue de la Presse, 35
1000 Bruxelles (Belgique)
Tel. : +32 (0)2 274 48 00
Fax : +32 (0)2 274 48 35
Email : contact(at)apd-gba.be
7. Who to contact about your Personal Data
If you have any questions about our use of your Personal Data you can send us an e-mail at this address: info@clicpublic.be, or write to us using the address provided under article 2.
8. Changes to This Privacy Policy
We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements.
To inform you of the changes, we will place updates on our website.
Please take a look at the “LAST UPDATED” date at the top of this Privacy Policy to see when it was last revised.
