Satellic’s Website Privacy and Cookie Policy

15/10/2018

This Satellic’s Website Privacy and Cookie Policy (hereinafter “Policy”) sets forth the terms and conditions pursuant to which Satellic NV, Leonardo Da Vincilaan 19 A, bus 4 – Airport Plaza registered in 1831 Diegem with enterprise nr. 0556.799.596 (hereinafter “Satellic”) will process personal data in relation to the use of the Satellic’s website (hereinafter “Satellic’s Website”).

Satellic shall be the Controller according to article 4 (7) General Data Protection Regulation (GDPR) for all personal data provided and processed in relation to the use of the Satellic’s Website.

By accessing the Satellic’s Website, you (“You”) unconditionally accept this Satellic’s Website Privacy and Cookie Policy. If You do not agree to be bound by this Satellic’s Website Privacy and Cookie Policy, You should leave the Satellic’s Website immediately.

1. Definitions

This Policy forms an integral part of the Terms of Use of the Satellic’s Website. Any capitalised terms set forth in this Policy shall have the meaning as described to it in such Terms of Use.

“Controller”: Means the natural or legal person, alone or jointly with others, determines the purposes and means of the processing of personal data.

“Cookie”:  Is a small file of letters and numbers that is stored on Your browser or the hard drive of Your device, which is like computer memory.

“First and third-party cookies”: Whether a Cookie is 'first' or 'third' party refers to the domain placing the Cookie.
- First-party Cookies are those set by a website that is being visited by the user at the time (e.g. cookies placed by our website domain).
- Third-party Cookies are Cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website, this would be a third-party cookie

“Terms of Use”: Means the Terms of Use applicable to the use of the Satellic’s Website, as published on the Satellic’s Website and accessible via the following link.

“Persistent Cookies”: These Cookies remain on a user’s device for the period of time specified in the Cookie. They are activated each time that the user visits the website that created that particular Cookie.

“Session Cookies”: These Cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session Cookies are created temporarily. Once You close the browser, all session Cookies are deleted.

2. What Data Do We Collect From You

2.1. What Cookies do we use and why?

The Satellic’s Website uses following Cookies:

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The legal basis for the use of these Cookies are (i) article 6.1(a) of the GDPR insofar Your consent is given; (ii) article 6.1(b) of the GDPR, insofar You are identified as an identifiable natural person and the data processing is carried out for the purpose of contract fulfillment and (iii) article 6.1 (f) of the GDPR insofar the cookie is intended to facilitate, complete and personalise the use of the Satellic’s Website. We request Your consent before placing them on Your device. You give Your consent by clicking on the appropriate button on the banner displayed to You. If You do not wish to give consent or wish to withdraw Your consent to any Cookies at any time, You will need to delete, and block or disable Cookies via Your browser settings; see below for more information on how to do this. Please note that disabling these Cookies will affect the functionality of the Satellic’s Website and may prevent you from being able to access certain features on the Satellic’s Website.

How to Delete and Block our Cookies
Most web browsers allow some control of most Cookies through the browser settings. However, if You use Your browser settings to block all Cookies, You may not be able to access all or parts of the Satellic’s Website. Unless You have adjusted Your browser setting so that it will refuse Cookies, our system will issue Cookies as soon as You visit the Satellic’s Website.

Changing your Cookie Settings
The browser settings for changing Your Cookies settings are usually found in the 'options' or 'preferences' menu of Your internet browser. In order to understand these settings, the following links may be helpful. Otherwise You should use the 'Help' option in Your internet browser for more details.

More information. To find out more about Cookies, including how to see what Cookies have been set and how to manage and delete them, visit www.aboutcookies.org

2.2. Newsletter and Contact Form

On the Satellic’s Website, we offer You the possibility to register for our newsletter by specifying Your e-mail address.

In order to be able to check whether You are the owner of the given e-mail address and whether You agree to receive the newsletter, we send an automated e-mail to the specified e-mail address, which includes a link. After You have clicked on this link, the e-mail address will be confirmed, and we will add You to our mailing list. You can unsubscribe from the newsletter at any time.

Your personal data will only be processed for the purpose of sending You the newsletter. Article 6.1 (a) and article 6.1 (b) of the GDPR are the legal basis for the processing of Your personal data.

On the Satellic’s Website, we provide a contact form which You can use to contact us electronically. In doing so, the data You enter in the input mask are transmitted to us and saved. Insofar the data processing is carried out for the purpose of fulfilling Your inquiry, the legal basis for the processing of the data is article 6.1 (b) of the GDPR. If You have entered into a User Contract, Your personal data specified in the contact form will be stored in accordance with our Privacy Policy. If You have not concluded any User Contract, Your personal data specified in the contact form will be kept for a maximum period of 2 years.

3. How Do We Use Your data?

Satellic takes reasonable steps to ensure that Your data are and remain relevant to its intended use.

Satellic uses the data collected about You for the following general purposes:

  • to communicate with You in general;
  • to respond to Your questions and comments;
  • to measure Your interest in our products, services, and in the Satellic’s Website and to improve them;
  • to notify You about our special offers, products or services or those of our partners that may be of interest to You;
  • to solicit information from You i.e. through surveys;
  • to prevent potentially prohibited or illegal activities;
  • to enforce our Terms of Use.

4. With Whom Do We Share Your data?

All the personal data that You provide to us will remain strictly confidential. This data is preserved in the internal database of Satellic and will not be disclosed to third parties. Your data will not be passed on to third parties for direct marketing purposes. The data shared with Google Analytics, does not contain personal data, only anonymised information.  

However, Satellic may share Your data with affiliates or successors of Satellic and with the interregional entity Viapass.

We also may share Your data if we believe, in our sole discretion, that such disclosure is necessary to comply with the law.

5. Your Choices with Respect to the Collection and Use of Your data

As discussed above, You can choose not to provide us with any personal data. Note, however, that some data may be needed to take advantage of certain features offered on the Satellic’s Website.

6. How Do We Protect Your Data?

We want You to feel confident about using the Satellic’s Website, and that is why we are committed to protecting the data we collect. We have implemented significant and appropriate technical and organizational measures to help protect the personal data that You provide to us from certain risks such as unauthorised access, use or disclosure.

However, You must remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others. Hence, we can thus not guarantee that we will be able to protect Your personal data at all times and in all circumstances.

7. External Links

If any part of the Satellic’s Website provides a link to another website, please be aware that those external websites do not operate under this Policy. We recommend that You examine the privacy statements posted on those websites in order to understand their procedures for collecting, using, and disclosing personal information.

8. Changes to Policy

Satellic may change or modify Policy in the future. If we make any material change to this Policy, we will notify You of such changes by posting a message on the Satellic’s Website or by sending You an e-mail or another type of notification, and we will indicate when those changes will become effective.

You can always find the most recent version of our Policy on our Satellic’s Website.

9. Your rights concerning Your Personal Data

Subject to the conditions laid down in the applicable data protection legislation, You have the following rights with respect to Your personal data:

  • The right to obtain access to the personal data we hold about You and to obtain a copy of this data, pursuant article 15 of the GDPR;
  • The right to obtain the rectification of Your inaccurate personal data and the right to have incomplete personal data to be completed;
  • The right to obtain the erasure of Your personal data pursuant article 17 of the GDPR;
  • The right to obtain the restriction of processing of Your personal data pursuant article 18 of the GDPR.
  • The right to receive the personal data You have provided to Satellic in a structured, commonly used and machine-readable format and to transmit those data to You or to another (i.e. the right to data portability) pursuant article 20 of the GDPR.
  • The right to withdraw at any time Your consent to the processing of Your personal data without affecting the lawfulness of the processing, if the processing is based on such consent pursuant article 7 of the GDPR.

On grounds relating to Your particular situation, You also have the right to object at any time to the processing of Your personal data on the basis of the legitimate interest of Satellic acting as Controller pursuant article 21 of the GDPR. Satellic shall perceive Your objections unless compelling legitimate grounds for the processing which override Your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Where Your personal data are processed for direct marketing purposes, You also have the right to object at any time to processing of Your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

To this end, to exercise all relevant rights, queries must be submitted as follows: send a completed written Data Subject Request Form, duly signed and dated, together with a copy of Your identity card, to Satellic’s customer support (support@satellic.be).

If You have a complaint concerning the processing of Your personal data, please contact dataprivacy@satellic.be or write to our Data Privacy Officer at 1831 Diegem, Airport Plaza Leonardo Da Vincilaan 19 A Bus 4. Our Data Protection Officer will then analyse Your complaint and work with You to resolve the matter.

Satellic will answer Your query or complaint without undue delay and in any event within one month after having received Your query or request. Taking into account the complexity and the number of requests, that period may be further extended to two more months. You will be informed of such an extension during the first month following the receipt of the request, and the reasons for the delay will also be specified.

If You still feel that Your data has not been handled appropriately in accordance with the law, You can lodge a complaint to the Belgian Privacy Commission pursuant article 77.1 of the GDPR: by post to Drukpersstraat 35, 1000 Brussels, per e-mail to commission@privacycommission.be or by phone +32 2 274 48 00.