Introduction

By using our websites, you agree to our Privacy Policy and the Terms of Use set out below. The Privacy Policy relates to the collection and use of personal information that you provide to us through the use of our websites.

We reserve the right, at our discretion, to modify or remove portions of this Privacy Policy at any time. This Privacy Policy is in addition to all other terms and conditions applicable to our websites.

We make a point that our practices regarding the protection of your personal data are strictly in accordance with the laws applicable in the Grand Duchy of Luxembourg and within the European Union: the general regulations on the data protection (CE) 2016/679 of May 25, 2018.

Cookies

Cookies are small data files that can be sent from a website to the user's terminal (usually to the browser), where they are stored before being transmitted to the site at the next visit. A cookie cannot recover any other data from your device's hard drive, transmit computer viruses or acquire email addresses. Cookies can be used by both the site owner and third parties and can be easily disabled by you.

The user can prevent our website from using cookies at any time by using a relevant setting in the Internet browser, thereby permanently objecting to the placement of cookies. Furthermore, cookies that have already been placed can be deleted at any time via the Internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates cookies in his/her the Internet browser, some of our website functions may not be fully usable.

Collection of general data and information

This website collects a series of general data and information every time a person accesses the website. This general data and information is stored in the server’s log files. We record the browser types and versions used, the operating system used by the accessing system, the website from which an accessing system reaches our website, the sub-websites accessed via an accessing system on our website, the date and time of access to the website,  an Internet Protocol address (IP address), the Internet service providers of the accessing system, and other similar data and information used for security purposes in the event of attacks on our information technology systems.

When using this general data and information, we do not draw any conclusions about the data subject concerned. Rather, this information is required to correctly deliver the contents of our website. The anonymous data of the server log files are stored separately from all personal data provided by the data subject.

Registration on our website

Every user has the option of registering on this website by providing personal data. The personal data transferred to the controller is determined by the respective input mask used for registration. The personal data entered by the data subject are collected and stored exclusively for internal use. This personal data will not be disclosed to third parties.

When the data subject registers and voluntarily agrees to provide his/her personal data, we are able to provide the data subject with content or services which, due to the nature of the case, can only be offered to registered users. Registered users are free to modify the personal data given upon registration at any time or to delete it completely from the controller’s database. At any time, we will provide the data subject with information upon request about which of his/her personal is being stored.

Contact via the website

Due to legal regulations, this website contains information that enables quick electronic contact with us as well as direct communication with us, including a general email address. If a data subject contacts us via email or a contact form, the personal data transmitted by the data subject will be automatically stored for the purpose of processing or contacting the data subject. This personal data will not be disclosed to third parties.

Routine erasure of personal data

The controller will only process and store the data subject’s personal data for the period necessary to achieve the purpose of the storage.

Rights of the data subject

1. Right to confirmation

Every data subject shall have the right granted by EU regulations and directives to require the controller to confirm whether personal data concerning him/her is being processed. If a data subject wishes to exercise this right of confirmation, he/she may contact the controller or relevant employee at any time.

2 Right to information

At any time, any data subject whose personal data is being processed shall have the right, granted by EU regulations and directives, to obtain information from the controller free of charge on the personal data being stored about him/her and a copy of that information. Furthermore, EU regulations and directives provide that the data subject be given the following information:

· the purposes of the processing
· the categories of personal data being processed
· the recipients or categories of recipients to whom the personal data have been disclosed or will be disclosed, in particular recipients in third countries or international organizations
· if possible, the planned duration for which the personal data will be stored or, if not possible, the criteria for determining that duration
· the existence of a right to rectification or erasure of the personal data concerning him/her or of a restriction to the controller’s processing of said data or of a right to object to such processing
· the right to lodge a complaint with a supervisory authority
· if the personal data is not collected from the data subject: All available information about the origin of the data
· the existence of automated decision-making, including profiling in accordance with Article 22(1) and (4) of the GDPR and—at least in these cases—meaningful information on the logic involved, and the scope and envisaged consequences of such processing for the data subject

3. Right to rectification

Any person affected by the processing of personal data has the right granted by EU regulations and directives to demand the immediate rectification of inaccurate personal data concerning him/her. Furthermore, taking into account the purposes of the processing, the data subject has the right to demand the completion of incomplete personal data—including by means of providing a supplementary statement.

4. Right to erasure

Any person affected by the processing of personal data has the right granted by EU regulations and directives to require the controller to delete his/her personal data without delay, if one of the following reasons applies and if processing is not required:

· The personal data have been collected or otherwise processed for purposes for which they are no longer necessary.
· The data subject withdraws his/her consent on which the processing was based in accordance with Article 6 (1)(a) of the GDPR or Article 9 (2)(a) of the GDPR, and there is no other legal basis for the processing.
· The data subject objects to the processing in accordance with Art. 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to processing according to Art. 21(2) of the GDPR.
· The personal data have been unlawfully processed.
· The erasure of personal data is necessary to fulfil a legal obligation under EU or national law to which the controller is subject.
· The personal data were collected in relation to information company services offered pursuant to Art. 8(1) of the GDPR.

5. Right to restriction of processing

Any person affected by the processing of personal data has the right granted by EU regulations and directives to require the controller to restrict the processing of his/her personal data under any of the following conditions:

· The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
· the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
· the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
· The data subject has objected to processing pursuant to Art. 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

6. Right to data portability

Any person affected by the processing of personal data has the right granted by EU regulations and directives to receive the personal data concerning him/her, which he/she has provided to a controller, in a structured, commonly used and machine-readable format. He/she also has the right to transmit these data to another controller without hindrance from the controller to whom the personal data was given, provided that the processing is based on the consent pursuant to Article 6 (1)(a) of the GDPR or Article 9 (1)(b) 2(a) of the GDPR or on a contract pursuant to Article 6 (1)(b) of the GDPR, and the processing is carried out by automated means, unless the processing is necessary for the performance of a task of public interest or in the exercise of public authority assigned to the controller.

Furthermore, in exercising his/her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have his/her personal data transmitted directly from one controller to another, as long as this is technically feasible and does not affect the rights and freedoms of others.

7. Right to object

Any person affected by the processing of personal data has the right granted by EU regulations and directives to object to processing of personal data concerning him or her at any time, on grounds relating to his/her particular situation, which is based on point Article 6 (1) of the GDPR. This applies for profiling based on those provisions as well.

8. Automated individual decision-making, including profiling

Any person affected by the processing of personal data has the right granted by EU regulations and directives to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her; unless the decision (1) is necessary for entering into, or performance of, a contract between the data subject and a data controller, or (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or (3) is based on the data subject’s explicit consent.

If the decision (1) is required for the conclusion or performance of a contract between the data subject and the controller or (2) it is with the express consent of the data subject, we shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express his/her own position and to contest the decision.

9. Right to revoke a data protection consent

Any person affected by the processing of personal data has the right granted by EU regulations and directives to revoke consent to the processing of personal data at any time. If a data subject wishes to exercise this right to revoke consent, he/she may contact the controller or relevant employee at any time.

Privacy policy on the use of Facebook

A Facebook plug-in has been installed on its website. Facebook is a social network.

A social network is an Internet-based social meeting place, an online community that allows users to communicate with each other and interact in a virtual space. A social network can serve as a platform to exchange views and experiences and allows the Internet community to provide personal or business information. Facebook allows social network users to create private profiles, upload photos and socialize via friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If a data subject lives outside the US or Canada, those responsible for the processing of his/her personal data are Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

If a Facebook component (i.e. Facebook plug-in) has been installed on the controller’s website, then each time one of the website’s pages is visited, the data subject’s Internet browser will automatically trigger, via the Facebook plug-in, a representation of said plug-in to download. An overview of all Facebook plug-ins can be found at https://developers.facebook.com/docs/plugins/?locale=en_US . As part of this technical process, Facebook receives information about which specific subpages of our website the data subject visits.

If the data subject is simultaneously logged into Facebook while visiting our website, Facebook recognizes which specific subpages of our website the data subject visits. This recognition occurs every time he/she visits our website and during the entire duration of his/her stay on our website. This information is collected via the Facebook plug-in and assigned by Facebook to the data subject’s Facebook account. If the data subject activates one of the Facebook buttons integrated on our website, for example the ‘Like’ button, or if the data subject leaves a comment, Facebook assigns this information to the data subject’s personal Facebook account and saves this personal data.

If the data subject is logged in to Facebook when accessing our website, Facebook will always be notified via the Facebook plug-in that the data subject has visited our website; this happens regardless whether the person clicks on the Facebook plug-in or not. If the data subject does not wish for this information to be transferred to Facebook, he/she can prevent the transfer by logging out of his/her Facebook account before visiting our website.

Facebook’s data policy, which is available at https://www.facebook.com/full_data_use_policy, provides information on the collection, processing and use of personal data by Facebook. It also explains which options Facebook offers to protect the data subject’s privacy. In addition, there are various applications available to suppress data transmission to Facebook. The data subject is free to make use of such applications to suppress data transmission to Facebook.

Privacy policy on the use of Instagram

On this website Instagram plug-ins have been installed. Instagram is a service that qualifies as an audio-visual platform, allowing users to share photos and videos, and also disseminate such data to other social networks.  nstagram's operating company is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, USA.

If an Instagram plug-in (Insta button) has been installed on the controller’s website, then each time one of the website’s pages is visited, the data subject’s Internet browser will automatically trigger, via the Instagram plug-in, a representation of said plug-in to download. As part of this technical process, Instagram receives information about which specific subpages of our website the data subject visits.

If the data subject is simultaneously logged into Instagram while visiting our website, Instagram recognizes which specific subpages of our website the data subject visits. This recognition occurs every time he/she visits our website and during the entire duration of his/her stay on our website. This information is collected via the Instagram plug-in and assigned via Instagram to the data subject’s Instagram account. If the data subject activates one of the Instagram buttons on our website, the data and information transferred with it are assigned to the data subject’s personal Instagram account and saved and processed by Instagram.

If the data subject is simultaneously logged in to Instagram while accessing our website, Instagram will always be notified via the Instagram plug-in that the data subject has visited our website; this happens regardless whether the person clicks on the Instagram plug-in or not. If the data subject does not wish for this information to be transferred to Instagram, he/she can prevent the transfer by logging out of his/her Instagram account before visiting our website.

Additional information and Instagram's privacy policy can be found at https://www.instagram.com/about/legal/privacy.

Privacy policy on the use of Google Analytics

The controller of this website has installed Google Analytics (with anonymization function). Google Analytics is a web analytics service. Web analytics involves the collection, analysis and evaluation of data about the behaviour of website visitors. Web analytics services collect data on topics such as the website via which a data subject has come to a website (so-called ‘referrer’), which subpages of the website a data subject accesses, and how often and for how long a subpage was viewed. Web analytics are primarily used to optimize a website and provide a cost-benefit analysis for online advertising purposes.

The operating company of Google Analytics is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of the Google Analytics feature is to analyse visitor flows on our website. Among other things, Google uses the data and information obtained to evaluate the use of our website, to compile online reports showing activity on our websites, and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject’s browser. For more information about what cookies are, please see above. Via this cookie, Google is able to analyse how our website is used. If Google Analytics has been installed on the controller’s website, then each time one of the website’s pages is visited, the data subject’s Internet browser will be automatically triggered by Google Analytics to submit data to Google for online analytics purposes. As part of this technical process, Google will be aware of certain personal data, such as the data subject’s IP address. This allows Google to, among other things, track the visitor’s origin and clicks, subsequently enabling commission settlements.

The cookie stores personal information, such as access time, the location from which access was made, and the frequency of site visits by the data subject. Upon each visit to our website, personal information, including the data subject’s IP address, is transferred to Google in the United States of America. This personal information is stored by Google in the United States of America. Google may transfer such personal data collected through this technical process to third parties.

As explained above, the data subject can prevent the placement of cookies through our website at any time by installing a relevant setting on his/her Internet browser, thereby permanently objecting to the placement of cookies. Such a setting would also prevent Google from placing a cookie on the data subject’s IT system. In addition, a cookie already placed by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the option of objecting to and preventing the collection of data by Google Analytics for the use of this website and the processing of this data by Google. To do so, the data subject should download and install a browser add-on at https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics. The installation of the browser add-on is viewed as an objection by Google. If the data subject's IT system is later deleted, formatted or reinstalled, the data subject must re-install the browser add-on to disable Google Analytics. If the browser add-on has been uninstalled or disabled by the data subject or any other person within his/her sphere of control, it can be reinstalled or reactivated.

For more information about Google's privacy policy, please see https://policies.google.com/privacy?hl=en.

Privacy policy on the use of YouTube

On this website YouTube plug-ins have been installed. YouTube is an internet video portal that allows users to publish or watch video clips for free and other users to watch, rate and comment on those clips for free. YouTube allows users to publish all types of videos, including complete film and television broadcasts, music videos, trailers or user-made videos.

YouTube's operating company is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, USA.

If a YouTube plug-in (YouTube button) has been installed on the controller’s website, then each time one of the website’s pages is visited, the data subject’s Internet browser will automatically trigger, via the YouTube plug-in, a representation of said plug-in to download. More information about YouTube can be found at https://www.youtube.com/yt/about/en/. As part of this technical process, YouTube and Google receive information about which specific subpages of our website the data subject visits.

If the data subject is simultaneously logged into YouTube while visiting our website, YouTube recognizes which specific subpages of our website the data subject visits. This recognition occurs every time he/she visits our website. This information is collected by YouTube and Google and associated with the data subject’s YouTube account.

If the data subject is simultaneously logged in to YouTube while accessing our website, YouTube and Google will always be notified via the YouTube plug-in that the data subject has visited our website; this happens regardless whether the person clicks on the YouTube plug-in or not. If the data subject does not wish for this information to be transferred to YouTube, he/she can prevent the transfer by logging out of his/her YouTube account before visiting our website.

YouTube's privacy policy, available at https://www.google.com/intl/en/policies/privacy/ , provides more information about the collection, processing, and use of personal information by YouTube and Google.

Privacy policy on the use of SoundCloud

On its website SoundCloud plug-ins have been installed. The SoundCloud plugins can be recognized by the SoundCloud logo on our site.

The operating company of SoundCloud is SoundCloud Limited, Berners House, 47-48 Berners Street, London W1T 3NF, UK.

When you visit our site, a direct connection between your browser and the SoundCloud server is established via the plugin. This enables SoundCloud to receive information that you have visited our site from your IP address. If you click on the „Like“ or „Share“ buttons while you are logged into your SoundCloud account, you can link the content of our pages to your SoundCloud profile. This means that SoundCloud can associate visits to our pages with your user account. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it will be used by SoundCloud. For more information on SoundCloud’s privacy policy, please go to https://soundcloud.com/pages/privacy.

If you do not want SoundCloud to associate your visit to our site with your SoundCloud account, please log out of your SoundCloud account.


Name and address of the controller

Ivan Boumans
info@ivanboumans.com