Last update: July 2018
Your privacy is critically important to us. Therefore, in light of the new European legislation on the protection of personal data (the ‘General Data Protection Regulation’, mainly known as the ‘GDPR’), we would like to inform the visitors of our website in a transparent manner on his or her rights with respect to the personal data collected via this website.
For any question regarding the collection or processing of your personal data, or for any request to exercise your rights in relation to your personal data, you can contact us in writing at any time on the address mentioned below, via e-mail (email@example.com) or phone (+32 2 534 35 50).
1. Who is responsible for the data processing?
Proxyclick SA, having its registered office at 1150 Brussels, rue Saint-Hubert 17, registered in the Belgian Crossroads Bank of Undertakings under number 0863.261.693 (hereinafter: ‘Proxyclick’, ‘we’, ‘our’, ‘us’), is the data controller for the processing of your personal data via the website (www.proxyclick.com) of Proxyclick.
Be aware that Proxyclick will only be the data controller for the processing of personal data for its own purposes, such as the processing of personal data of our (potential) customers in relation to sales, service delivery, invoicing, customer relationship management and direct marketing.
On the other hand, if you are a user of ‘Visitor Management’ or ‘Service Desk’, or if you are a visitor of one of our customers, our customer will be the ‘data controller’ and Proxyclick will be acting as our customer’s ‘data processor’. In such case, our customer is the one assuming responsibility for the processing of personal data through our services.
2. What is personal data?
Personal data is any information relating to an identified or identifiable natural person. It is sufficient that the data allow us to establish a (direct or indirect) link between one or more data-pieces and a natural person.
Personal data does not include anonymous or non-personal data (i.e., information that cannot be associated with or tracked back to a specific individual). By your use of the website, you in any case consent to the processing and using of anonymous and non-personal data that is no longer identifiable.
3. What (categories of) personal data do we process?
Proxyclick’s website provides information about the Proxyclick services and allows you to contact Proxyclick. You can visit our website without telling us who you are or revealing any information about yourself. In addition, we collect the personal data that you submit to our website, depending on your qualification (visitor of website/user of services/business contact person/visitor registered in our services), such as your name, company name, business/work email address, language preference, geographical location, IP address, operating system, browser type, financial information (solely upon the purchase of a subscription), and any other contact or other information that you choose to provide by:
- using the contact forms (website chat room) on this website;
- registering for the 15-day free trial through Proxyclick’s inquiry form;
- allowing you to make use of any other functionalities offered on our website;
- corresponding with a representative of Proxyclick via e-mail using the hyperlinks created for that purpose;
- subscribing to Proxyclick’s services.
4. Why do we process personal data and on which legal basis?
We are only processing your personal data to the extent necessary for the intended purposes. In essence, Proxyclick processes your personal data for an overarching goal: we want to offer the best-personalized experience when visiting our website and using our applications.
The personal data collected is processed for the following purposes:
- to ensure and improve the proper technical functioning of our website and services;
- to provide you access to the application in a secure, effective and user-related manner;
- to follow up on the sales process (communication of fee quotes and invoices);
- to manage our customer relationships;
- to contact you if you have requested to be contacted by means of the contact form (website chat room);
- to handle any complaints that might arise in relation to our products or services as well as to provide after-sales services;
- to the extent you have given your consent thereto, to send you (personalized) marketing, advertising, and promotional messages and other information that may be of interest to you, in relation to the products, services, and events provided by Proxyclick. You can unsubscribe or opt-out from receiving these communications via the link in the marketing correspondence.
Most of the aforementioned processing activities are either necessary for the performance of a contract to which you are a party or to perform the required pre-contractual measures, or justified on the basis of our legitimate interests, such as building and managing our customer and contractual relationships. Furthermore, we can process your personal data to the extent required by law. However, we will not send you direct marketing without consent where such consent is required.
5. Who has access to your personal data and where is it accessible?
We, at Proxyclick, consider mutual confidence very important. That’s why we would like to ensure you that we process your personal data only for internal use: only our employees, agents, administrators or managers will have access to your personal data, to the extent necessary for realizing the intended purposes, mentioned above. We neither rent nor sell your personal data or of those of your visitors in a form that allows for the identification of individuals to anyone for use for their own purposes. We may share statistical reporting on the use of our website and services with third parties, however, such reporting will not contain information that allows the identification of an individual.
Please note that Proxyclick uses a number of data processors that collect, store and process your data. These data processors are natural persons or legal entities that process personal data on behalf of Proxyclick. We have carefully selected our processors. The selected processors offer all the appropriate guarantees with regard to technical and organizational security measures regarding the processing of your personal data.
We may transfer your personal data to our trusted and reputable third party processors for the following purposes:
- hosting of our customer relationship management system;
- enabling payments;
- enabling user support functionalities, such as website chat rooms;
- enabling visit- and usage analytics.
We have carefully selected these external service providers and review them regularly to ensure that your privacy is preserved. All such third party processors are contractually bound by us to keep your information confidential. All information provided to third party processors is used by them only to carry out the service they are providing for us.
We will not transfer your data to any other third parties without your prior permission unless we would be legally obliged to do so or on the basis of a judicial or administrative order or instruction from a competent authority or institution.
6. How long do we retain your personal data?
Except as otherwise permitted or required by applicable law or regulatory requirements, we will retain personal data only for as long as it believes is necessary to fulfill the purposes for which the personal data was collected (including, for the purpose of providing services to you, meeting any legal, accounting or other reporting requirements or obligations). Please note that if we are acting as a data processor, we have to act upon our customer’s instructions regarding data retention.
In any event and unless otherwise required by law, any personal data obtained and processed for commercial or marketing purposes will be deleted 5 years after the last contact with you.
7. Do we use automated decision-making?
Article 22 of the GDPR provides that individuals have the right not to be subject to a decision based exclusively on automated processing which produces legal effects concerning them or otherwise significantly affects them.
Proxyclick does not use such automated decision-making.
8. What are your rights in relation to your personal data?
Pursuant to the GDPR, each individual, in your capacity of the data subject, shall have the following rights:
- the right to access your personal data;
- the right to rectify and correct your personal data;
- the right to erase your personal data (the so-called “right to be forgotten”);
- the right to restrict the processing of your personal data;
- the right to object to any processing of your personal data;
- the right to data portability;
- the right to lodge a complaint with the competent supervisory authority.
The performance of these rights may be subject to certain conditions and exceptions as provided by the GDPR. In any case, you always have the absolute right to object the further use of your personal data for direct marketing purposes.
Any request to exercise these rights should be provided to us in writing, addressed to Proxyclick SA, at 1150 Brussels, rue Saint-Hubert 17 or via e-mail at firstname.lastname@example.org. Within the shortest reasonable time, we will provide you with the necessary information and/or the measures taken in response of your demand. In any case, we strive to respond to your request within one month as of receipt thereof, which can be extended to two months in case of very complex or a high number of demands.
To the extent we rely on your consent as the legal basis for our processing activities, you shall always have the right to withdraw your consent at any point in time and without prejudice to the lawfulness of the processing based on the consent given prior to its withdrawal.
10. How is your personal data secured?
Proxyclick endeavors to maintain physical, technical and procedural safeguards that are necessary to protect the personal data in question. These safeguards are designed to protect your personal data from loss and unauthorized access, copying, use, modification or disclosure. At current, Proxyclick offers -among others – the use of a secure server and all supplied information is transmitted via Secure Socket Layer (SSL) technology, to be only accessed by those authorized with special access rights.
Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while this website strives to protect your personal data, we cannot warrant the security of any information you transmit to us, and you do so at your own risk. Once this website receives your transmission, we make commercially reasonable efforts to ensure its security on our systems.