1. WHO WE ARE

1.1 "We", "us" or "our" means START IT X NV. We shall be considered the data controller with respect to the personal data we collect within the framework of your use of our website.

1.2 This privacy policy only aims at providing you with information regarding the processing of personal data within the framework of our website.

1.3 Our website, startit.be is owned and managed by START IT X NV, with registered office at VAN OVERSTRAETENPLEIN 2, 3000 LEUVEN, BELGIUM with company number BE 0730.852.042. The website is hosted by DIGITAL PULSE NV, NIJVERHEIDSKAAI 3 BUS 0011, 8500 KORTRIJK, BELGIUM with company number BE 0704 609 483. For further information, please refer to article 5 of this Privacy Policy.

1.4 Your privacy is important to us. Therefore, we have developed this privacy policy to provide you with more information regarding the collection, communication, transfer and use ("processing") of the personal data you share with us, as well as to provide you with more information regarding your rights. We therefore ask you to read this privacy policy.

1.5 If you have any questions, comments or complaints regarding this Privacy Policy or the processing of your Personal Data, or you wish to make a request in accordance with Article 4, please contact us in one of the following ways

(a) By e-mail: to info@startit.be, for the attention of the Privacy Officer / Data Protection Officer;

(b) By post: to Start it X NV, Van Overstraetenplein 2, B-3000 Leuven.

1.6 This Privacy Policy was last updated on 17 November 2021.

2. HOW WE USE AND COLLECT YOUR PERSONAL DATA

2.1 Personal data is defined as any information relating to an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.) that can be used to directly or indirectly identify a natural person.

2.2 The personal data that we collect is collected for the following purposes:

(a) If you use a contact form on our website, we will use your personal data to respond to your request, either by e-mail, by post or by telephone. Your email address will also be included in our database for the purpose of sending our newsletter and providing you with information regarding events, seminars, etc.

(b) If you create a profile on our website or provide us with transaction data, we will collect your personal data for the purpose of storing such information, making a payment for the purchase of goods and/or services, offering our services and enabling us to ship your orders or contact you.

(c) If you subscribe to the newsletter, your e-mail address will be used to send you our newsletters. In addition, we may keep you informed of events, seminars, etc. that we organise which may be of interest to you.

(d) We process your personal data for the purpose of supporting the website and improving your user experience. This purpose extends to monitoring the security, availability, (performance), power, and health of our website.

(e) We process your personal data to enforce or comply with the rights granted to us under applicable law (such as defending against legal claims) when necessary. We may also use your personal data to fulfil our obligations under applicable law.

2.3 We collect the following categories of personal data:

(a)Contact details: If you use the contact form, you will be asked to provide the following information: name, address, e-mail address, telephone number, and personal data which you enter yourself in the free box (please do not enter sensitive information such as health information, information relating to criminal convictions, or bank account numbers). This is information provided directly by you.

(b)Newsletter: If you subscribe to our newsletter, you will be asked to provide your email address. This is information provided directly by you.

(c)Usage information: We process personal data relating to your use of our website: IP address, device ID and type, referral source, language settings, browser type, operating system, geographical location, duration of visit, page visited, or information regarding the timing, frequency and pattern of your visit. This information may be aggregated and may help us gather useful information regarding the use of the website. In the event that such usage information is anonymised (and therefore not identifiable to you as a natural person), then such information is not covered by this Privacy Policy. This information is collected automatically through your use of the website.

2.4 The legal basis for the use of your personal data is your consent and/or legitimate interest or public interest.

2.5 If the legal basis for processing your personal data is your consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of the processing that took place before the withdrawal of your consent.

2.6 If the legal basis for the processing is our legitimate interest or public interest, then you have the right to object to the processing as set out in section 4 of this Privacy Policy.

2.7 Your personal data will only be used for the purposes set out in clause 2.2.

3. RETENTION OF YOUR PERSONAL DATA AND DELETION

3.1 Your personal data will be kept for no longer than is necessary to fulfil a specific purpose. However, since it is not possible to specify a period in advance, the period will be decided as follows:

(a) As long as interaction can be shown between you and START IT X (or one of its related entities), the data will be kept.

(b) The moment there is no more interaction, your personal data will be kept for another two years.

3.2 If you withdraw your consent or if you object to the processing of personal data, and such objection is sustained, we will delete your personal data. We will, however, retain that personal data which is necessary to respect your preference in the future.

3.3 We are, however, entitled to retain your personal data if this is necessary to comply with our legal obligations, to bring a legal claim or to defend ourselves against such a claim or for reasons of evidence.

4. YOUR RIGHTS AS AN INDIVIDUAL

4.1 This article contains an overview of your most important rights under applicable data protection law. We have tried to summarise them for you in a clear and readable way.

4.2 If you wish to exercise any of your rights, please send us a written request in accordance with clause 1 of this Privacy Policy. We will endeavour to respond to your request without unreasonable delay and in any event within a period of one month of receipt. If we are unable to respond within the aforementioned one-month period and wish to extend the period, or if we will not comply with your request, we will inform you accordingly.

Right of inspection

4.3 In the event that we process your personal data, you have the right to access your personal data as well as certain additional information as described in this Privacy Policy.

4.4 You have the right to receive from us a copy of your personal data held by us, provided that it does not adversely affect the rights and freedoms of others. The first copy will be provided to you free of charge, but we reserve the right to charge a reasonable fee if you request multiple copies.

Right to rectification

4.5 If the personal data we hold about you is incorrect or incomplete, you have the right to ask us to correct it, or - taking into account the purposes of the processing - to complete it.

Right to data erasure/erasure

4.6 If one of the following applies, you have the right to obtain - without unreasonable delay - the erasure of your personal data:

(a) The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;

(b) You withdraw your consent on which the processing is based and there is no other legal basis for processing your personal data;

(c) Your personal data has been unlawfully processed;

(d) Erasure of your personal data is necessary in order to comply with EU law or Belgian law;

4.7 There are certain exclusions to the right to data erasure. These exclusions include where processing is necessary

(a) For the exercise of the right to freedom of expression and information;

(b) For reasons of public interest in the area of public health;

(c) For archiving in the public interest, or statistical purposes;

(d) For compliance with a legal obligation; or,

(e) For the establishment, exercise or maintenance of legal claims.

Right to restriction of processing

4.8 You have the right to obtain the restriction of the processing of your personal data (which means that the personal data may only be stored by us and only used for limited purposes), if one of the following applies:

(a) You dispute the accuracy of the personal data, during a period of time that allows us to verify the accuracy of the personal data;

(b) The processing is unlawful and you oppose the erasure of the personal data and instead request the restriction of their use;

(c) We no longer need your personal data for the processing purposes, but you require it for the establishment, exercise or substantiation of legal claims; or,

(d) You have objected to the processing, pending the answer to the question whether our legitimate grounds outweigh yours.

4.9 In addition to our right to store your personal data, we may still process it, but only:

(a) With your consent;

(b) For the establishment, exercise or defence of legal claims;

(c) To protect the rights of another natural or legal person; or,

(d) For reasons of public interest.

4.10 You will be informed before we lift the restriction on the processing of your personal data.

Right to transferability of your personal data / data portability

4.11 If the processing of your personal data is based on your consent, and the processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used and machine-readable form. However, this right does not apply insofar as it would infringe the rights and freedoms of others.

4.12 You also have the right to have us transfer your personal data directly to another company, if this is technically possible.

Right to object

4.13 You have the right to object at any time - on grounds relating to your particular situation - to the processing of your personal data, but only to the extent that the legal basis for the processing is that the processing is necessary for:

(a) The performance of a task carried out in the public interest or in the exercise of official authority vested in us;

(b) The protection of our legitimate interests or those of a third party.

4.14 If you object to the processing of your personal data, we will no longer process the personal data unless we can demonstrate legitimate interests for the processing which outweigh the interests or fundamental rights and freedoms of you.

4.15 If your personal data are processed for the purposes of direct marketing, whether this is initial or further processing, you have the right to object at any time and free of charge to such processing, including in the case of profiling as it relates to direct marketing. If you raise such an objection, we will stop processing your personal data for this purpose.

Right to lodge a complaint with a supervisory authority

4.16 If you believe that the processing of your personal data carried out by us is in breach of data protection legislation, you have the right to lodge a complaint with a supervisory authority responsible for data protection. You can do this in the EU Member State of your habitual residence, of the place where you work or of the place where the alleged breach took place. In Belgium, you can lodge a complaint with the Privacy Commission, rue du Peinture 35, 1000 Brussels (commission@privacycommission.be),https://www.privacycommission.be/nl/contact.

5. PROVISION OF YOUR PERSONAL DATA TO THIRD PARTIES

5.1 In order to provide our website, we work with service providers to process and store your personal data. We use the following service providers:

(a) Hosted Power BVBA (hosting provider);

(b) Digital Pulse NV

(c) Pixel & Tonic (Craft CMS);

5.2 If you are a customer of ours, we may pass on your personal data to suppliers with whom we have contracted to offer you services. If you are a supplier to us we may pass your personal data on to our customers for the purpose of contacting you.

5.3 We may need to provide access to your data for legal purposes. In such case we will be obliged to comply with them. We may also provide your personal data if this is necessary to protect the vital interests of another natural person.

5.4 We do not provide personal data to third parties. However, our website uses social media plugins that enable you to link to our social media channels or that enable you to share content on your social media channels. These social media channels are (Facebook, Instagram, LinkedIn, Twitter, and YouTube). If you click on such a link, the aforementioned social media partners may collect personal data, such as personal data relating to your profile.

5.5 We are not responsible for how these social media partners use your personal data. In such case, they will act as data controller. For your information, we list the relevant links below (although these may change from time to time):

6. TRANSFER OF PERSONAL DATA

6.1 No transfer of personal data takes place outside the European Economic Area.

7. COOKIES

7.1 Our website uses cookies. For further information, please refer to our cookie policy.

8. ADJUSTMENTS TO THE PRIVACY POLICY

8.1 We may make changes to this privacy policy from time to time. The most recent version of the privacy policy can always be consulted on the website.