Confidentiality policy

1. Parts and Purpose

easi Network srl (hereinafter”) easi Network srl ” or the” Data Controller ”)
Rue du Chainay 19 in 4450 Slins
ECB/VAT: BE0543.309.866
Email: eric.ansenne@easinetwork.be
Phone: +32 495 56 90 45

easi Network srl establishes this Privacy Policy, the purpose of which is to inform Users of the website hosted at the following address: www.easinetwork.be, (hereinafter the” Site ”), how personal data is collected and processed by easi Network srl.

The term” User ” refers to any user, i.e. any natural or legal person, who visits or interacts in any way with the Site.

As such, easi Network srl determines all the technical, legal and organizational means and purposes for the processing of Users' personal data. easi Network srl undertakes to take all necessary measures to ensure that personal data is processed in accordance with the law of 30 July 2018, relating to the protection of natural persons with regard to the processing of personal data (hereinafter, “the Loi“) and the European Regulation of 26 April 2016 on the protection of the data of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the” Regulation ”).

easi Network srl is free to choose any natural or legal person who processes the personal data of users at its request and on its behalf (hereinafter the” Subcontractor ”). Where appropriate, easi Network srl undertakes to select a subcontractor offering sufficient guarantees as to the technical and organizational security measures for the processing of personal data, in accordance with the Law and the Regulation.

2. Personal data processing

The use of the Site by Users may result in the communication of personal data. The processing of this data by easi Network srl, in its capacity as Data Controller, or by service providers acting in the name and on behalf of easi Network srl, will be in accordance with the Law and the Regulations.

Personal data will be processed by easi Network srl, in accordance with the purposes mentioned below, via:

• an automated procedure

3. Purpose of the processing of personal data

In accordance with article 13 of the Regulation, the purposes of the processing of personal data are communicated to the User and are as follows:

• Ensuring the promotion of the services offered and agreed on the site

4. Personal data that may be processed

The User agrees, during the visit and use of the Site, that easi Network srl collects and processes, in accordance with the methods and principles described in this Privacy Policy, the following personal data:

• User information that they give such as name, first name, email address, mobile number. And generally, any information that is voluntarily given by the user.

5. Consent

By accessing and using the Site, the User declares to have read and agreed to the processing of personal data concerning him in a free, specific, informed and unequivocal manner. This agreement covers the content of this Privacy Policy.

Consent is given by the positive act by which the User has ticked the box offering the Privacy Policy in a hypertext link. This consent is an essential condition to carry out certain operations on the Site or to allow the User to enter into a contractual relationship with easi Network srl. Any contract between easi Network srl and a User relating to the services and goods offered on the Site is subject to the acceptance of the Privacy Policy by the User.

The User agrees that the Data Controller processes and collects, in accordance with the methods and principles included in this Privacy Policy, his personal data that he communicates on the Site or during the services offered by easi Network srl, for the purposes indicated above.

The User has the right to withdraw their consent at any time. The withdrawal of consent does not compromise the legality of the processing based on the consent previously given.

6. Duration of storage of Users' personal data

In accordance with article 13 §2 of the Regulation and the Law, the Data Controller only keeps personal data for the time reasonably necessary to enable the fulfilment of the purposes for which they are processed.

This duration is in all cases less than: 1 year

7. Data recipients and disclosure to third parties

Personal data may be transmitted to agents, collaborators, subcontractors or suppliers of easi Network srl who offer adequate data security guarantees, and who collaborate with easi Network srl in the context of the marketing of products or the provision of services. They act under the direct authority of easi Network srl, and are in particular responsible for collecting, processing or subcontracting this data.

In all cases, the recipients of the data and those to whom this data has been disclosed respect the content of this Privacy Policy. easi Network srl assures that they will process this data for the only intended purposes, in a discreet and secure manner.

In the event that the data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed in advance so that he expresses his consent to the use of this personal data.

8. User Rights

At any time, the User may exercise his rights by sending a message by email to the following address: eric.ansenne@easinetwork.be, or a letter sent by post, attaching a copy of your identity card to the following address: Rue du Chainay 19 in 4450 Slins

a. Right of access

In accordance with article 15 of the Regulation, easi Network srl guarantees the right of access to the User's personal data. The User has the right to obtain access to said personal data as well as the following information:

• the purposes of the treatment;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular recipients established in third countries or international organizations;
• where possible, the envisaged period for which personal data will be stored or, where this is not possible, the criteria used to determine this duration;
• the existence of automated decision-making, including profiling, referred to in Article 22, paragraphs 1 and 4 of the Regulation, and, at least in such cases, useful information about the underlying logic, as well as the importance and the intended consequences of this processing for the data subject

The Data Controller may require the payment of reasonable fees based on administrative costs for any additional copies requested by the User.

When the User submits this request electronically (through the email address for example), the information is provided in a commonly used electronic form, unless the User requests otherwise.

The copy of his data will be communicated to the User no later than one month after receiving the request.

b. Right to rectification

easi Network srl guarantees the user the right to rectify and delete personal data.

In accordance with article 16 of the Regulation, incorrect, inaccurate or irrelevant data can be corrected or deleted at any time. The User first makes the necessary changes himself from his user/other account, unless these cannot be made independently, in which case the request can be made to easi Network srl.

In accordance with article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data has been communicated of any correction of the personal data, unless such communication proves impossible or requires disproportionate efforts. The data controller provides the data subject with information on these recipients if the data subject requests it.

c. Right to erasure

The User has the right to obtain the deletion of his personal data as soon as possible in the cases listed in article 17 of the Regulation.

Where the Data Controller has made the personal data public and is required to delete the personal data under the preceding paragraph, the Controller, taking into account available technologies and implementation costs, shall take reasonable measures, including technical measures, to inform other controllers who process such personal data that the data subject has requested the deletion by these controllers of any link to such personal data, or All copy or reproduction of these.

The two preceding paragraphs do not apply insofar as this treatment is necessary:

• to the exercise of the right to freedom of expression and information;
• to comply with a legal obligation that requires the processing provided for by Union law or by the law of the Member State to which the data controller is subject, or to perform a task in the public interest or in the exercise of public authority vested in the controller;
• to the establishment, exercise or defense of legal claims.

In accordance with article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data has been communicated of any erasure of personal data or any limitation of the processing carried out, unless such communication proves impossible or requires disproportionate efforts. The data controller provides the data subject with information on these recipients if the data subject requests it.

D. Right to restrict processing

The User has the right to obtain the limitation of the processing of his personal data in the cases listed in article 19 of the Regulation.

In accordance with article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data has been communicated of any limitation of the processing carried out, unless such communication proves impossible or requires disproportionate efforts. The data controller provides the data subject with information on these recipients if the data subject requests it.

e. Right to data portability

In accordance with article 20 of the Regulation, Users have the right to receive from easi Network srl the personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transmit this data to another data controller without easi Network srl obstructing it in the cases provided for by the Regulation.

When the User exercises his right to data portability pursuant to the preceding paragraph, he has the right to obtain that personal data be transmitted directly from one data controller to another, when technically possible.

The exercise of the right to data portability is without prejudice to the right to erasure. This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in the data controller.

The right to data portability does not affect the rights and freedoms of third parties.

f. Right to object and automated individual decision-making

The User has the right at any time to object to the processing of their personal data due to their particular situation, including the automation of the data carried out by easi Network srl. In accordance with article 21 of the Regulation, easi Network srl will no longer process personal data, unless there are legitimate and compelling reasons for the processing that prevail over the interests and rights and freedoms of the User, or for the establishment, exercise or defense of legal claims.

When personal data is processed for prospecting purposes, the User has the right to object at any time to the processing of personal data concerning him for such prospecting purposes, including profiling insofar as it is linked to such prospecting.

If the data subject objects to processing for direct marketing purposes, the personal data is no longer processed for these purposes.

G. Right to complain

The User has the right to file a complaint concerning the processing of his personal data by easi Network srl with the Data Protection Authority, competent for Belgian territory. More information can be found on the website: https://www.autoriteprotectiondonnees.be.

Complaints can be lodged at the following addresses:

Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Tel. + 32 2 274 48 00
Fax. + 32 2 274 48 35
Email: contact@apd-gba.be

The User may also file a complaint with the court of first instance in his place of residence.

9. Limitation of liability of the Data Controller

The website may contain links to other websites owned by third parties not linked to easi Network srl. The content of these sites and their compliance with the Law and Regulations are not the responsibility of easi Network srl.

The holder of parental authority must give express consent for a minor under 16 years of age to disclose personal information or data on the website. easi Network srl strongly advises persons exercising parental authority over minors to promote responsible and secure use of the Internet. The Data Controller cannot be held responsible for having collected and processed information and personal data from minors under 16 whose consent is not effectively covered by that of their legal parents or for incorrect data - in particular concerning age - entered by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he is under 16 years of age.

easi Network srl is not responsible for the loss, corruption or theft of personal data caused in particular by the presence of viruses or as a result of computer attacks.

10. security

The Data Controller implements organizational and technical measures in order to guarantee an appropriate level of security for the processing and collection of data. These security measures depend on the costs of implementation in view of the nature, context and purposes of the processing of personal data.

The Data Controller uses standard encryption technologies within the IT sector when transferring or collecting data on the Site.

11. Modification of the Privacy Policy

easi Network srl reserves the right to modify this Privacy Policy in order to comply with legal obligations in this area. The user is therefore invited to regularly consult the Privacy Policy in order to be aware of the changes and adaptations. Such modification will be posted on the Site or sent by email for the following purposes:
opposability.

12. Applicable law and competent jurisdiction

This Privacy Policy is exclusively governed by Belgian law. Any dispute will be brought before the courts of the judicial district of the head office of easi Network srl.

13. Contact

For any question or complaint relating to this Privacy Policy, the User may contact the Data Controller via the following address: eric.ansenne@easinetwork.be