Privacy policy 

treatment of personal data 

This privacy policy defines and informs data subjects and customers (potential and actual), hereinafter referred to as ‘data subjects’, of the manner in which the company, hereinafter referred to as ‘CL4change’ or ‘the company’, uses and protects the information transmitted to it and, more particularly but without being exclusive, when the data subject uses this site accessible via the following link: https://www.cl4change.com/, hereinafter referred to as the ‘site’, or when the data subject calls upon or uses the services and products offered by CL4change. 

This privacy policy may be amended or supplemented at any time by the company, in particular in order to comply with any changes in legislation, regulations, case law or technology. In such a case, the date of the update will be clearly identified at the top of this policy. These modifications are binding on the person concerned as soon as they are put online. The person concerned is therefore invited to consult this privacy policy regularly, as well as the rules governing the use of cookies, in order to take note of any changes. 

PERSONAL DATA 

In general, it is possible to visit the site without providing any personal information. In any event, the person concerned is in no way obliged to transmit this information to the company. 

However, in certain situations where information is not provided, it is possible that the person concerned may not be able to benefit from the services requested. In order for the person concerned to benefit from the services offered by the company, the company may, in certain cases, ask you to provide your surname(s), first name(s) and address(es) (e-mail and postal), hereinafter referred to as ‘personal information’. By transmitting this information, the person concerned expressly agrees to it being processed by the company, for the purposes indicated in point 2 below and for the purposes indicated at the time of each request. 

In accordance with the General Data Protection Regulation (GDPR) of 14 April 2016, the company informs you of the following: 

  1. Identity of the data controller 

The data controller is 

CL4change SRL, Rue Véronèse 57 - 1000 Brussels 

BE : 1015.794.292 

E-mail address. Claude.Lorea@cl4change.com 

The data controller ensures the accuracy and relevance of the personal data collected and processed. In addition to the above, he/she ensures that it complies with the applicable regulations and with this privacy policy. 

2.Data collected 

The company collects the following personal data: 

  • Identification data 

  • Billing data 

  • Training and education 

  • Profession and employment 

  • Image 

  • Navigation  

  • Geolocation 

    3. Purposes of processing 

CL4change may process the personal data you provide for the following purposes: 

  • Sending the electronic newsletter to CL4change visitors; 

  • Providing the information or services requested by the data subject (by presence on the operating sites, by e-mail, by telephone or by post) and tailored to the data subject, and more specifically :  

  • the processing and follow-up of requests for prices and/or information made to CL4change; 

  • presentation of the services offered and provided by CL4change; 

  • statistics on visits to the CL4change website; 

  • To collect information enabling CL4change to improve the site, products and services (in particular by means of cookies); 

  • To Google Analytics, by means of cookies, as set out in the disclaimer which can be consulted on the company's website via the following link: https://www.cl4change.com/ ; 

  • To enable the data subject to access CL4change services and infrastructures under the best possible conditions; 

  • To manage the contracts concluded between the data subject and CL4change with regard to its legal and contractual obligations; 

  • Comply with the procedures and obligations imposed by state or European bodies and/or authorities. 

By signing a contract or any other document referring to these confidentiality policies, the data subject gives his or her consent to the processing of data in the areas in question, insofar as the intended purpose allows. 

The data controller may need to process personal data for purposes other than those mentioned above. In this case, it shall ensure that such processing is compatible with the aforementioned purposes for which the data subject has given his or her consent. 

4.Recipients 

CL4change is the sole recipient of any personal information provided. 

This information, whether in individual or anonymised form, is under no circumstances passed on to a third party, with the exception of sub-contractors, external service providers or partners called upon by the company within the framework of its legal or contractual obligations or within the framework of achieving its corporate purpose, with a view to ensuring a complete and adequate service to the visitor. 

Neither the company nor any of its subcontractors, external service providers or partners market the personal data of visitors to the site or the company. 

The processing of the data subject's personal data by a processor, external service provider or partner is subject to the conclusion of a contract or other legal act under EU law or the law of a Member State, which binds it in relation to the data controller. 

5. Retention period 

Personal data is only kept by the company for the period of time corresponding to the purposes for which it was collected, as set out above. In any event, unless another retention period is imposed by a legal or contractual obligation, data will not be retained for more than 10 years. 

The company stores data on computer media, mainly on the local disk of the various devices and in a cloud whose privacy policies can be consulted via the following links: 

The company makes every effort to guarantee data security by implementing technical and organisational measures that comply with the standards applicable to this type of data and company. 

7. Rights of the data subject 

The data subject has the following rights, in accordance with the aforementioned European Regulation: 

  • - Right of access and communication of data 

The data subject has the right to access and consult the personal data concerning him or her held by the company. The data subject may also find out how the company obtained the data and to whom it has been communicated. The data subject may also request a copy of the personal data being processed. 

In view of the company's obligation of security and confidentiality in the processing of personal data, the data subject's request for access and consultation of data will be processed subject to proof of identity, in particular by producing an electronic or paper copy (accompanied by a signature) of his/her identity card during the period of validity thereof. In all cases, the request is free of charge for the person concerned. 

However, the company may object to requests that are manifestly abusive or unfounded (by their number or their repetitive or systematic nature, for example). 

  • Right to rectify data 

European regulations allow visitors to request the rectification, updating or deletion of data concerning them which may be inaccurate, incorrect, incomplete or obsolete. 

  • - Right to object 

The data subject has the right to object to the processing of data in the following two situations: 

  • When the exercise of this right is based on legitimate grounds or 

  • When the purpose of exercising this right is to prevent the data collected from being used for commercial prospecting purposes. 

  • Right to erasure 

The data subject has the right to request and obtain the erasure of data concerning him or her held by the company. 

The company will comply with the visitor's request if : 

  • The personal data is no longer necessary for the purposes for which it was collected; 

  • The data processing was based exclusively on the visitor's consent and the visitor withdraws his/her consent; 

  • The data subject objects, on well-founded grounds, to the processing. 

In any event, the request for erasure may be refused by the company if the request is necessary for the exercise or defence of legal claims or for compliance with a legal or contractual obligation on the part of the company. 

  • Right to data portability 

Data subjects may request that their personal data be transferred to a data controller identical to the company. The data subject may therefore ask the company to send him or her the data in a structured, commonly used and computer-readable format. 

  • - How to exercise your rights 

The aforementioned rights may be exercised by sending a letter to the company's address or by sending an e-mail to the following address: Claude.Lorea@cl4change.com

8. Response times 

The company will comply with the visitor's request by replying in the same way as the person concerned exercised his/her right. 

The company undertakes to respond to any request for access, rectification or opposition, deletion or any other additional request for information within a reasonable time and in any event within a maximum of 1 month from receipt of your request. 

Depending on the complexity of the request, the response time may be extended to 3 months, in accordance with the applicable European regulation. 

9. Persons authorised to consult personal data 

Only members of the company's staff are authorised to consult personal data, with the exception of the application of point 4 above. These persons have a reasonable need for the data due to the tasks and missions entrusted to them or the requirements linked to the company's activity. 

10.  Authorised service providers and transfer to a country outside the European Union 

The company also informs the person concerned that it uses authorised service providers to facilitate the collection and processing of the data communicated. These service providers are located within the European Union. 

11.  Complaints to the competent authority 

The company hopes that any difficulties arising from the processing of personal data will be resolved through dialogue. However, if this is not possible, the data subject has the right to lodge a complaint with the DPA (Data Protection Authority). 

The DPA is located at Rue de la Presse 35, 1000 Brussels, and can be contacted by telephone on +32 2 274 48 00 or by e-mail at contact@apd-gba.be.