Privacy Policy

Version applicable as of December 01, 2020

Your personal data is protected in accordance with :

  • European Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 (which came into force on May 25, 2018) on the protection of individuals with regard to the processing of personal data and on the free movement of such data,
  • the law of July 30, 2018 on the protection of individuals with regard to the processing of personal data.

The purpose of our privacy policy is to set out, in a clear and transparent manner, the nature of the personal data we collect, as well as to explain how it is processed. It applies to the following persons:

  • current or past clients and potential clients of SRL “D.C.”,
  • any person involved in any transaction with SRL “D.C.”, whether in his/her own name or as a representative of a legal entity (e.g. a company manager, legal representative, operational staff, etc.),
  • SRL “D.C.” partners or lenders, such as payment recipients or contact persons for lenders or corporate clients.

This Privacy Policy may be modified or supplemented at any time by SRL “D.C.”, in particular in order to comply with any legislative, regulatory, jurisprudential or technological developments. In such a case, the date of its update will be clearly identified at the top of this policy. These modifications are binding on the User as soon as they are put online. It is therefore advisable that the User regularly consults the present policy of confidentiality and use of cookies in order to be aware of its possible modifications.

1. IDENTITY OF THE DATA CONTROLLER

The data controller is SRL “D.C.”. registered at the ECB under the number 0666.835.507, RPM Mons-Charleroi, Tournai Division, having its registered office at 7700 Mouscron, rue des Brasseurs 8, e-mail: carescence@privacy.com

2. SOURCES OF PERSONAL DATA

We collect data from or about you from the following sources:

  • Training and execution of a contract with you,
  • The site e shop https://www.carescence.com/ and if necessary, the mini-sites if we decide to use them such as on third party social networks like Facebook, and others ..,
  • E-mail, SMS and other electronic messages between you and the SRL “D.C.”,
  • Calls made to our services ,
  • Offline and other registration forms that we collect by regular mail, promotions, events, etc., are not accepted.
  • Interactions with our ads. (For example, if you interact with one of our advertisements on a third-party site, we may receive information about that interaction).
  • Data from other sources such as third party Social Networks (such as Facebook, Google, … ) or market research (if your answers are not provided anonymously), third parties, public sources and data we receive when we take control of another company.

3. TYPES OF DATA COLLECTED

3.1 Personal contact information.

This includes any information you provide us that may enable us to contact you, such as your name, postal address, e-mail address, social network or telephone number, banking information.

3.2 Technical information about your computer/mobile device.

Any information about your computer or other technological device you use to access our website or one of our mobile applications, such as the Internet Protocol (IP) address, the address used to connect your computer or other device to the Internet, your type of operating system, and the type and version of your web browser. If you access our website or an application via a mobile device, the information collected will also include, if authorized, the unique identifier linked to your mobile device, advertising identifier, geolocation and other similar data related to the mobile device.

3.3 Information on the use of the communication/web site.

When you browse and interact with our website or newsletters, we use automatic data collection technologies to collect certain information about your actions. This includes information such as the links you click on, the pages or content you view and the length of time you spend there, and other similar information and statistics about your interactions, such as content response times, download errors, and the length of time you spend on certain pages. This information is recorded using automated technologies such as cookies (browser cookies, flash cookies) and web beacons, and is collected through third-party tracking as well. You have the right to object to the use of such technologies .

3.4. Market research.

This includes information you voluntarily share with us about your experience using our products and services.

3.5. Third party social network information.

This includes any information that you publicly share on a third party social network or any information that is part of your profile on a third party social network (such as Facebook) and that you allow the third party social network to share with us. For example, your basic account information (such as name, email address, gender, birthday, current city, profile picture, ID, friend list, etc.) and any other information or activity that you allow the third party social network to share. We receive your profile information from the third party social network (or a portion thereof) whenever you download or interact with our web application carescence on a third party social network such as Facebook, , whenever you use a social networking feature that is integrated into a Site, or whenever you interact with us through a third party social network. To learn more about how your information from a third party social network is obtained by SRL “D.C.”. or to object to the sharing of such information, you should visit the website of the applicable third party social network.

Therefore, we invite you to consult the account settings of your social networks to manage the information that may be collected and the use that is made of it.

3.6 Payment and financial information.

Any information we need to fulfill an application, or that you use to become a lender, partner, or provider of LLC “D.C.” such as your credit or debit card information (cardholder name, card number, expiration date, etc.) or other forms of payment (if available). In any event, we or our payment service provider(s) handle payment and financial information in accordance with applicable laws, regulations and security standards.

3.7. Calls to our Services.

Communications with one of our Services may be recorded or listened to, in accordance with applicable laws, for local operational reasons (e.g., for quality or training purposes). You will be informed of the recording of your call at the beginning of the call.

3.8 Sensitive personal information.

We only process sensitive data for marketing purposes if you have given your explicit consent. If we process this personal data for other purposes, we will use the following legal grounds: (i) detection and prevention of criminal activity (including fraud prevention); and (ii) compliance with applicable law (e.g. to comply with diversity reporting).

3.9. Children’s Personal Data

We will not knowingly collect personal data from children under the age of 13. However, if we become aware that such personal data has been collected unintentionally, we will delete it immediately. D.C.” LLC may, however, obtain personal data from children under 13 years of age directly from the parent or legal guardian with the explicit consent of that person.

3.10. It is possible that the data controller may also collect data of a non-personal nature.

This data is qualified as non-personal data because it does not allow the direct or indirect identification of a particular person. They may therefore be used for any purpose, for example to improve the website, the products and services offered or the advertising of the data controller.

In the event that non-personal data are combined with personal data in such a way that identification of the persons concerned is possible, such data will be treated as personal data until such time as their linkage to a particular person is made impossible.

4. PURPOSES OF THE PROCESSING OF PERSONAL DATA

We use your Personal Information for the following purposes:

  • Execute our contracts with you,
  • respond to your requests (e.g. technical problem, question/complaint about a service, general question, etc.).
  • improve and develop new products and services
  • gain in efficiency
  • with your consent when necessary, to provide you with information about goods or services (e.g. marketing communications, campaigns or promotions). To do this, we use e-mail, advertisements, SMS, telephone calls and postal mailings to the extent permitted by applicable law. Some of our campaigns and promotions take place on third party websites and/or social networks. This use of your Personal Data is voluntary, which means that you may object to the processing of your Personal Data for these purposes.
  • define the products and services likely to interest you and present them to you.
  • offer you advertisements and interact with you on third party social networks. To learn more about how these features work, what profile data We obtain about you and how to object to this processing of your Personal Data, you should consult the privacy policies of the relevant third party social networks.
  • with your consent when necessary, to
    • (i) analyze your preferences and habits,
    • (ii) anticipate your needs based on our analysis of your profile,
    • (iii) enhance and personalize your experience on our website and applications,
    • (iv) ensure that the content of our website and applications is optimized for you and your computer or device,
    • (v) provide you with targeted advertising and content. The use of your Personal Data is voluntary, which means that you may object to the processing of your Personal Data for this purpose.
  • verify your identity and other activities related to fraud detection.
  • protect our assets and personnel,
  • conduct an internal survey or market research, or evaluate the effectiveness of advertising campaigns.

If the data controller carries out processing of personal data that is not yet provided for in this privacy policy, it will contact the user before reusing his/her personal data, in order to inform him/her of the changes and give him/her the possibility, if necessary, of refusing such use.

5. DISCLOSURE OF YOUR PERSONAL DATA

The SRL “D.C.” informs you that it may also use authorized service providers to facilitate the collection and processing of the data you have communicated to us.

SRL “D.C.” has previously made sure that its service providers implement adequate guarantees and comply with strict conditions regarding confidentiality, use and protection of data.

In the event that the recipients of your personal data may be located in a third country of the European Union, SRL “D.C.” will ensure that the recipient benefits from privacy protection guarantees similar to the European legislation on personal data or, failing that, will require the recipient to sign the standard contractual clauses adopted to ensure adequate protection of personal data in cross-border and international transfers.

The third party companies and/or organizations with whom we share your Personal Information are :

  • Our Service Providers such as our freelancers, IT service providers, website developers, support services and promotions, etc.). They are only authorized to access and use your Personal Data on our behalf and to perform the specific tasks we have asked them to perform, based on our instructions. They are required to ensure the confidentiality and security of your Personal Data.
  • Credit reporting agencies/debt collection agencies. Credit reporting agencies and debt collection agencies are external companies that we use to help us verify your creditworthiness or to collect outstanding payments, to the extent permitted by applicable law.
  • Third parties, (i) if required by applicable law, (ii) in response to legal process, (iii) in response to a request from an appropriate law enforcement agency, (iv) to protect our rights, privacy, safety or property, or those of the general public, (v) to enforce the terms and conditions of any contract or our website, or (VI) in the context of an acquisition or merger.

We do not license or sell your Personal Data to third party companies for their own marketing purposes.

With your consent, when necessary, we share your personal data with our partners established in Belgium and Europe.

6. RETENTION OF YOUR PERSONAL DATA

The General Regulation on the Protection of Personal Data (RGPD) lists retention periods for personal data depending on the purpose for which the data was collected. For example, the data retention periods can be as follows:

  • 36 months (3 years) : the personal data of persons who have not been active for 3 years in our database will be either deleted or anonymized. Deleted personal data will be kept in an opposition base/list in order to not request them in the future and to be able to justify our processing and compliance with regulations. Personal data may also be anonymized in order to keep it for statistical purposes.
  • 13 mois : tous les 13 mois, nous redemanderons le consentement des visiteurs de notre site web https://www.carescence.com/ pour le traitement des cookies.
  • 1 mois : lorsque votre demande pour la rectification, l’effacement, ou la restitution de vos données personnelles a été acceptée.

As a result, we take all reasonable steps to ensure that your personal data is only processed for the time corresponding to the purpose of the collection referred to in point 4.

  • i) for the duration of our business relationship and you have not withdrawn your consent to use your personal data for marketing purposes.
  • (ii) your personal data is necessary for any of the other purposes described in this Privacy Policy and that we have a valid legal basis for doing so,
  • (iii) for the time prescribed for tax obligations or necessary to protect our rights.

We may also retain your personal data as legal evidence in the event of a dispute, but we will not actively use it.

Retention periods are therefore not universal and may vary according to circumstances.

7. SECURITY AND STORAGE OF YOUR PERSONAL DATA

We use a variety of reasonable measures and standards to ensure the confidentiality and security of your Personal Data, including technical and organizational measures against unauthorized access, misuse, alteration, unlawful or accidental destruction or accidental loss of data, both online and offline. However, these protections do not apply to information you share in the public space, such as on third-party social networks.

We store your Personal Data in operating environments that apply sufficient security measures to prevent unauthorized access.

However, we ask you to consider that, despite our best efforts to protect your personal data from potential risks and exposures, there is no absolute security in the online world. Therefore, we would be obliged to support our computer security efforts by also taking the necessary measures on your part to protect and secure your personal data, such as, for example, by refraining from disclosing on our website any data that is particularly sensitive or not required in the context concerned, by using strong passwords, by not communicating your password to others, by logging out of your account every time you leave the computer).

8. YOUR RIGHTS TO YOUR PERSONAL DATA

You have the following rights concerning your Personal Information, which you can exercise by filling out the form adapted to your request.

8.1. Right of access and communication of data: Article 15 of the DPMR

You, your successors, representatives and/or relatives have the right to access, review and request a physical or electronic copy of the information held about you. You also have the right to request information about the source of your Personal Data.

However, due to the obligation of security and confidentiality in the processing of personal data incumbent on SRL “D.C”, your request will be processed on condition that you provide proof of your identity, in particular by producing a scan of your valid identity card (in case of request through our dedicated electronic form) or a signed photocopy of your valid identity card.

If the requested information is provided by someone other than you, without providing proof that the request is legitimately made on your behalf, the request will be rejected.

The SRL ” D.C ” informs you that it will be entitled, if necessary, to oppose requests that are manifestly abusive (due to their number, repetitive or systematic nature).

To help you in your approach, we ask you to make your request in writing by filling out the form opposite and returning it to the postal address mentioned in our point 1, or to the email address carescence@privacy.com

8.2. Right to rectify data: Article 16 of the RGPD and the right to limit processing: Article 18 and Article 4.3 of the RGPD

Under this right, the legislation entitles you to request the rectification, updating, blocking or deletion of data concerning you which may prove to be inaccurate, erroneous, incomplete or obsolete.

As a temporary principle, the limitation allows the data to be “frozen” for the necessary time: it will only be kept but can only be processed with the consent of the person concerned. The limitation can be requested in four cases:

– when the individual challenges the accuracy of the data, the time required for corrections,

– when the processing is unlawful but the person does not want the data to be deleted,

– when the data are no longer necessary for the processing consented to, but the person wants them to be kept so that they can be produced in court,

– or when the person exercises his/her right to object to the treatment.

Finally, you can also define general and specific guidelines regarding the fate of personal data after your death. Where appropriate, the heirs of a deceased person may require that the death of their loved one be taken into consideration and/or that the necessary updates be made.

To help you in your approach, in particular if you wish to exercise, on your own behalf or on behalf of one of your deceased relatives, we ask you to make your request in writing by completing the form opposite and returning it to us at the postal address mentioned in our point 1, or at the e-mail address carescence@privacy.com.

8.3. Right to object: Article 21 of the DPMR and the right to object to profiling: Article 13 of the DPMR.

The exercise of the right of opposition is only possible in one of the two following situations:

  • when the exercise of this right is based on legitimate grounds ;
  • or when the exercise of this right is intended to prevent the data collected from being used for commercial prospecting or profiling purposes.

Profiling consists in crossing and analyzing personal data to associate the profile of the person analyzed with a specific category (for example a woman in her fifties, a sportswoman, mother of several children…). This makes it possible to predict the behaviors and preferences of the person (who should have the same habits as the people in his category), which is useful for example to send targeted advertisements.

To help you in your approach, we ask you to make your request in writing by filling in the form opposite and returning it to the postal address mentioned in our point 1, or to the email address carescence@privacy.com.

8.4. Right to data portability: Article 20 of the DPMR

You have the right to request the transfer of certain personal data to us, either directly to you or to another company. This right applies to personal data that we process electronically, either with your consent or on the basis of a contract with you. Where technically possible, we will ensure the transfer of your personal data.

To help you in your approach, we ask you to make your request in writing by filling in the form opposite and returning it to the postal address mentioned in our point 1, or to the email address carescence@privacy.com.

8.5. Right to oblivion: Article 17 of the GDPR

You have the right to ask us to delete your personal data if :

  • We no longer need it for the initial purposes;
  • You withdraw your consent for us to process them;
  • You object to us sending you commercial messages;
  • We process your personal data unlawfully;
  • A law of the European Union or a member state of the European Union requires SRL “D.C” to delete your personal data.

To help you in your approach, we ask you to make your request in writing by filling in the form opposite and returning it to the postal address mentioned in our point 1, or to the email address carescence@privacy.com.

Please note, however, that we may be required to retain some of your Personal Data after you have requested it in order to fulfill our legal or contractual obligations. We may also be permitted by applicable law to retain some of your Personal Data to meet our business needs.

8.6. Right to Withdraw Consent: Section 7.3 of the GDSP Regulations

The person concerned has the right to withdraw his or her consent at any time (article 7.3 of the GDPR).

LLC “D.C.” ensures that withdrawal of consent given electronically is done in a very simple manner such as by a simple click, keystroke or by scanning the screen.

Once you have withdrawn your consent, SRL “D.C.” will stop all treatment based on your consent. However, operations that were carried out on the basis of a validly given consent prior to the withdrawal remain lawful.

When your consent has been collected by a method other than the digital method, you may withdraw your consent by completing the form opposite and returning it to the postal address mentioned in our point 1, or to the e-mail address carescence@privacy.com.

9. DELAY TO ANSWER YOU

The SRL “D.C” undertakes to respond to your request for access, rectification or opposition or any other additional request for information within a reasonable period of time, which may not exceed 1 month from receipt of your request.

10. Complaint to the competent authority

If you consider that SRL “D.C” does not comply with its obligations with regard to your Personal Data, you can address a complaint or a request to the Belgian Data Protection Authority located at rue de la Presse, 35, 1000 Brussels, Tel: +32 (0)2 274 48 00, https://www.autoriteprotectiondonnees.be/, website: contact@apd-gba.be.