1. Why this privacy policy?

Every individual (referred to hereinafter as the "User" or "You") who visits and/or uses the Copl website along with its related services (referred to hereinafter as the "Website"), or utilises our Copl services, discloses a portion of their personal data. Personal data refers to data that can directly or indirectly identify you as a natural person.

We collect and process your personal data in accordance with the Belgian Law of July 30, 2018, on the protection of personal privacy with regard to the processing of personal data ("Privacy Law") and the European Regulation of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("Regulation" or "GDPR").

By using the Website or our services, the User declares that they have read and expressly consent to the collection and processing of their personal data as described in this document.

We reserve the right to make changes to our Privacy Policy at any time.

2. Who processes your personal data?

2.1 Data controller

Copl is the data controller for the processing of your personal data and determines which personal data are collected, the purposes, and the processing method.

2.2 Subcontractor(s)

Copl is free to use subcontractors. A subcontractor is a natural or legal person who processes your personal data at the request and on behalf of the data controller. The subcontractor must ensure the security and confidentiality of your data and always act on behalf of the data controller.

Copl uses the following categories of subcontractors: Hosting companies, CRM, social networks (for advertising), Amazon Web Services, IT maintenance, password management software.

3. What is the legal basis for processing your data?

In accordance with the Privacy Law and GDPR, we process your personal data on the following legal basis:

Based on the execution of the contract of which you are a party or on contractual measures taken at your request for the use of our Website and the provision of our services and/or products.
Based on our legal obligations regarding the management of the contractual relationship, including invoicing.
On the basis of our legitimate interest in sending information and newsletters to our customers.
On the basis of your explicit consent for sending promotional offers (direct marketing).

4. What personal data is collected?

The processing of your personal data is limited to what is strictly necessary to achieve the purposes pursued by Copl. The categories of data subject to processing are listed below:

Personal identification data (name, first name, pseudonym)
Contact details (phone number and email address)
Electronic identification data (IP address, localisation, cookies)
Personal information (relationship status)

Copl may obtain personal data in various ways:

When you register and use our Website and/or services;
By filling out questionnaires (for example, during your registration);
Through social networks (for example, when you contact us via Facebook);
By placing cookies (see our Cookie Policy).

In addition, we use cookies to recognise the User and provide a personalised user experience, remember User choices, and identify and correct any errors on the Website. More information about our use of cookies can be found in our Cookie Policy.

5. Why is your personal data collected and processed?

Copl collects your personal data to provide you with an optimal, personalised, and secure user experience. The processing of your personal data is essential for the proper functioning of the Website and the delivery of our services. In case of missing, incorrect, or incomplete data, Copl reserves the right to suspend or cancel certain actions.

Copl commits to processing your personal data solely for the following purposes:

Customer management;
Dispute management;
Personalised marketing and advertising if you have explicitly consented. In this case, you can withdraw your consent at any time.

When you visit our Website, certain data is collected for statistical purposes. This data allows us to optimise your user experience. By visiting the Website, you expressly agree to the collection of this data for statistical purposes.

6. Who receives your personal data?

Your personal data is intended for internal use. However, Copl reserves the right to transmit or communicate your personal data to third parties, such as through the emails forwarded to connect you with our Professionals. By using our Website or our Services, you expressly consent to this potential transfer of data. The data is stored on Copl's servers at Amazon Web Services.

7. How long are your data retained?

Your data is retained for as long as necessary to achieve the purposes for which it was collected. It will be removed from our database once it is no longer needed for the intended purpose or if you have validly exercised your right to erase your data.

8. What are your rights?

8.1. Assurance of fair and lawful processing

Your personal data is always processed in accordance with the legitimate purposes outlined in section 5. It is collected and processed in an appropriate, relevant, and non-excessive manner and is not retained longer than necessary to achieve the purposes.

8.2. Right of access

Upon proving your identity, you have the right to obtain information about the processing of your data. You have the right to know the purposes of the processing, the categories of data concerned, the categories of recipients to whom the data is disclosed, the criteria used to determine the data retention period, and the rights you can exercise regarding your data.

8.3. Right of rectification

Inaccurate or incomplete personal data can be corrected, either directly by the User on their user profile or by sending a written request to info@copl.eu.

8.4 Right to erasure (or "Right to be forgotten")

You have the right to have your personal data erased in the following cases:

Your personal data is no longer necessary for the purposes for which it was collected;
You withdraw your consent for data processing, and there is no other legal basis for processing;
You have validly exercised your right to object;
Your data has been unlawfully processed;
Your data must be erased to comply with a legal obligation.

8.5. Right to restriction of processing

In certain circumstances, you have the right to request the restriction of the processing of your personal data, especially if the accuracy of the data is contested, or if the data is required for legal proceedings or during the time that Copl needs to verify whether you can validly exercise your right to erasure.

8.6. Right to object

You have the right to object to the processing of your personal data for direct marketing, profiling, or for the legitimate interests pursued by the data controller. Copl will cease processing your personal data unless it can demonstrate compelling legitimate grounds for processing that outweigh your right to object.

8.7. Right to data portability

You have the right to receive all personal data you have provided to us in a structured, commonly used, and machine-readable format. Upon request, this data can be transferred to another provider unless it is technically impossible.

8.8. Right to withdraw consent

You can withdraw your consent for the processing of your personal data at any time, for instance for direct marketing purposes.

9. Security measures

In accordance with the Privacy Law and GDPR, Copl commits to implementing technical and organizational measures (referred to as "security measures") to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and any other form of unlawful processing or use.

These security measures ensure a level of security appropriate to the risk associated with the processing. To determine the appropriate security measures, Copl takes into account current technological capabilities, implementation costs, the nature, scope, context, and purposes of the processing, as well as the risks to the rights and freedoms of data subjects.

Copl aims to make all reasonable efforts to ensure that its processing systems and services meet the requirements of ongoing confidentiality, integrity, availability, and resilience, considering the current technological capabilities and implementation costs.

10. Notification of personal data breach

In compliance with the Privacy Law and GDPR, Copl will promptly, but no later than within 24 hours of becoming aware, notify the User of a breach related to personal data. This notification will be accompanied by all relevant documentation that enables the User, if necessary, to inform the data protection authority and/or the affected individuals about the breach. Copl will provide the User with the following information: the nature of the data breach, the categories and approximate number of affected individuals, the categories and approximate number of affected personal data, the likely consequences of the data breach, and the measures taken to mitigate the breach or limit its potential negative effects.

Unless it is suspected that the breach poses no risk to the rights and freedoms of natural persons, Copl will promptly, and if possible no later than within 72 hours of becoming aware of the breach, notify the supervisory authority on behalf of and for the account of the User regarding the breach of personal data.

If it is suspected that the breach poses a high risk to the rights and freedoms of natural persons, Copl will promptly notify the affected individuals on behalf of and for the account of the User regarding the breach of personal data.

The decision to notify the data protection authority and/or the data subjects of a data breach rests with Copl.

11. How can you exercise your rights?

To exercise your rights, you need to send us a written request and proof of identity to the email address info@copl.eu. We will respond as quickly as possible, and no later than one (1) month after receiving the request.

12. Possibility to lodge a complaint

If you are not satisfied with the processing of your personal data by Copl, you have the right to lodge a complaint with the Authority for the Protection of Personal Data (https://www.gegevensbeschermingsautoriteit.be/).

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