1. This privacy policy ("Privacy Policy") governs the processing of your personal data as part of your use of our Website (the "Website") and the services related thereto (collectively referred to as the "Services"). This processing is carried out by PHPro NV as the data controller, with registered office at Veldkant 33A, 2550 Kontich ("we", "us"), registered in the KBO under number 0694.507.231, in accordance with the applicable legislation on the protection of personal data.

2. By using our Website and/or our Services, you acknowledge that you have read this Privacy Policy carefully and that you agree to it without reservation. We reserve the right to change the Privacy Policy regularly in our sole discretion. Such changes will be communicated via the Website.

3. Please note that we may use so-called 'cookies' or similar technology as part of the Website and/or the Services. Cookies are small text files that are placed on the hard disk of a device and contain certain information, including sometimes personal data. For more information regarding our use of cookies, please read our cookie policy.

4. This Privacy Policy was last updated on 08/10/2018.

What and why we process data

5. When you use the Website and/or Services, we process personal data relating to you. Such personal information includes:

• When to use Services, us? Use of Services, contacting us, requesting a quote, use of Website
• Which one? Identification data
• Why (purpose)? Processing of application
• Legal basis? Justifiable interest

• When to subscribe to the newsletter? Subscribe to newsletter, download white papers, request folders or information
• Which one? Identification data
• Why (purpose)? Refocusing on related information and additions
• Legal basis? Consent

• When to use live chat on website? Use of live chat on website
• Which one? Identification data
• Why (purpose)? Refocusing on related information and additions
• Legal basis? Consent

6. In principle, we obtain the above-mentioned personal data directly from you. In addition to the above-mentioned purposes, we may also process your personal data.

7. a. To provide you in a personalized and efficient manner with the information about products and services you request, whether via the Website, e-mail, telephone or social media channels.

8. b. To process your personal data so that we can provide the Services.

9. c. For direct marketing purposes, i.e. to provide you with targeted communications, promotions, offers and other advertisements from us or our selected partners. For this we will ask for your prior consent.

10. d. To carry out statistical analyses to improve our Website and/or Services, or to develop new products or services.

11. e. To provide to a financial institution or payment service provider, to enable your financial institution and the payment service provider to comply with their legal obligations.

12. f. To transfer to the police or judicial authorities as evidence of possible crimes or if there are reasonable suspicions of a tort or crime committed by you through your registration with or use of the Website or the Services.

13. g. In the context of a possible merger with, acquisition of/by or division by a third party, even if that third party is located outside the EEA.

14. If and when your registration on the Website or use of the Website or Services may be considered (a) a violation of the terms or intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Services, (c) any danger to the Website or Services or systems of us or of our subcontractors due to viruses, Trojan horses, spyware, malware, or any other form of malicious code, or (d) in any way is illegal or unlawful, discriminatory or offensive, we may process your data in the interest of ourselves, our partners or third parties.

With whom we share data

15. We will not send your personal data to third parties in an identifiable manner if this is not required to provide the Services without your express consent.

16. We may use third party processors to provide you with the Website and/or Services. We ensure that third party processors may process your personal data only on our behalf and on our written instruction. We guarantee that all external processors are selected with the necessary care so that we can count on the security and integrity of your personal data.

17. We may transfer anonymised and/or aggregated data to other organisations that may use this data to improve products and services and to organise the marketing, presentation and sale of customised products and services.

Where we process data

18. We ourselves and our external processors will only process your identifiable personal data in the EEA.

19. We may transfer your anonymised and/or aggregated data to organisations outside the EEA. If such transfer takes place, we will ensure that there are adequate safeguards to ensure the security and integrity of your personal data, and that any rights in respect of personal data that you may have under applicable mandatory law are guaranteed.

20. If a transfer of your personal data and/or anonymised and/or aggregated data takes place, the following legal protection mechanism will be put in place:

• Which HubSpot? HubSpot
• Country outside EEA? USA
• Legal transmission mechanism? US - EU Privacy Shield

• Which one? MAILCHIMP
• Country outside EEA? USA
• Legal transmission mechanism? US - EU Privacy Shield

• Which one? WHOISVISITING
• Country outside EEA? USA
• Legal transmission mechanism? US - EU Privacy Shield

How we process data

21. We will do our utmost to process only the personal data necessary to achieve the purposes stated in this Privacy Policy. We will process your personal data in a legal, fair and transparent manner. We will do our utmost to keep the personal data accurate and up to date.

22. Your personal data will only be processed as long as necessary to achieve the purposes stated in this Privacy Policy or until you withdraw your consent to its processing. Please note that withdrawal of consent may imply that you are no longer able to use all or part of the Website and/or Services. If you have registered with our Website, we will delete your personal data if you delete your profile, unless a legal or regulatory obligation or a court or administrative order would prevent us from doing so.

23. We will take appropriate technical and organisational measures to keep your personal data safe from unauthorised access or theft and from accidental loss, manipulation or destruction. Access by our staff or staff of our external processors is only possible on a need-to-know basis and is subject to strict confidentiality obligations. However, you understand that safety and security concerns are only to the best of your ability and can never be guaranteed.

Your rights

24. You have the right to request access to any personal data we process about you. However, requests for access that appear to be made with a view to causing nuisance or damage to us will not be dealt with.

25. You have the right to request that any personal information about you that is inaccurate or inaccurate be corrected free of charge. If you have registered on our Website, you can correct much of this information yourself through your profile. If such a request is made, you should also enclose with your request proof that the personal data for which correction is requested is inaccurate.

26. You have the right to withdraw your previously given consent for the processing of your personal data. You may withdraw your consent at any time by sending an e-mail to info@phpro.be, or by deleting your profile (if applicable).

27. You have the right to request that personal data relating to you be deleted if it is no longer necessary in the light of the purposes set out in this Privacy Policy or if you withdraw your consent to its processing. However, you should be aware that any request for deletion will be assessed by us in the light of legal or regulatory obligations or administrative or judicial orders that may prevent us from deleting the personal data concerned.

28. Instead of deletion, you may also request that we restrict the processing of your personal data if (a) you contest the accuracy of such data, (b) the processing is unlawful or (c) the data are no longer necessary for the purposes stated, but you need them to defend yourself in legal proceedings.

29. You have the right to object to the processing of personal data if you can demonstrate that there are serious and legitimate reasons relating to special circumstances and justifying such objection. However, if the envisaged processing is considered as direct marketing, you have the right to object to such processing free of charge and without justification.

30. If your personal data are processed on the basis of consent or on the basis of a contract and the processing is automated, you have the right to receive the personal data you provide to us in a structured, commonly used and machine-readable format and, if technically possible, you have the right to transfer these data directly to another service provider. The technical feasibility of this will be assessed exclusively by us.

31. If you wish to request the exercise of one or more of the above rights, please send an e-mail to info@phpro.be. This request must clearly state what right you wish to exercise and why. It must also be dated, signed and accompanied by a digitally scanned copy of your valid identity card showing your identity. We will inform you immediately of the receipt of such a request. If the application proves to be well-founded, we will grant it as soon as reasonably possible and no later than thirty (30) days after receipt of the application.

32. If you have a complaint about the processing of your personal data by us, you can always contact us at the e-mail address info@phpro.be. If you remain dissatisfied with our response, you are free to submit a complaint to the competent data protection authority, the Belgian Privacy Commission. For more information, visit http://www.privacycommission.be.