Privacy Policy 

1. DEFINITION 

Personal Data

All information about an identified or identifiable natural person. An identifiable person is one who can be indentified directly or indirectly, inparticular by an identifier such as a name, an identification number, location data, an online identifier or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Accomodata

info@accomodata.be

Processing

Means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as a collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction. 

2. SUBJECT

This Privacy Policy contains the terms and conditions applicable to the processing of Personal Data that you disclose to Accomodata .

3. WHICH DATA DOES ACCOMODATA TRACK/PROCESS?

The following personal data is tracked/processed:                 

• Identification (name, address, telephone number,...)

• Electronic identification data (IP-adresses,...)

• Electronic localisation data (GSM, GPS,...)

Accomodata does not track sensitive Personal Data.

4. FOR WHAT PURPOSE ARE YOUR PERSONAL DATA?

Your Personal Data will be kept for the following purposes:

• Execution or conclusion of (an) agreement(s)

• Relationship management (customers (CRM) and/or suppliers)

• Direct marketing

5. WHAT DOES ACCOMODATA DO WITH YOUR PERSONAL DATA?

Accomodata is concerned about the protection of your privacy and personal data. 

It has therefore already taken the initiatives it deems necessary to comply with the current privacy legislation, in particular the Act of 8 December 1992 on the protection of privacy with regard to the processing of Personal Data (hereinafter referred to as the "Privacy Act"), its implementing decrees, the amendments thereto and as recently updated and still to be amended pursuant to the General Data Protection Regulation (hereinafter referred to as the "GDPR").[1]
 

Accomodata undertakes to comply with this legal framework and, where necessary, to take additional measures and implement adjustments as a result of the update.

The Personal Data requested by Accomodata are therefore always limited to the data that we consider necessary and sufficient for the correct performance of our services.

We strive to ensure that the Personal Data processed by us are correct and are updated in the event of any change. 

Your Personal Data is always kept for a specific period of time, in function of our services and/or the legal requirements with which Accomodata must comply (e.g. accounting obligations). 

Finally, we guarantee adequate protection (including encryption) against unauthorized or unlawful processing and against accidental loss, destruction or damage of your Personal Data, depending on the state of the art and the sensitivity of the Personal Data concerned.

[1] Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).

6. PROCESSING LEGITIMACY (OPT-IN)

For direct marketing purposes, Accomodata will always request your explicit consent for the use of your Personal Data. Not withstanding your consent, you have the right at any time to object to the processing of your Personal Data for direct marketing purposes.  info@accomodata.be If you change your mind after your opt-in, you can withdraw your consent to the further processing of your Personal Data at any time by contacting us at info@accomodata.be or by sending your request to the following address:

Oscar Delghuststraat 60

9600 Ronse

7. YOUR RIGHTS

7.1 General

Accomodata strives for transparency with regard to the processing of your Personal Data. When Accomodata processes your Personal Data, you may request us to be informed thereof in a concise and comprehensible manner.

Where applicable, you have the right to request Accomodata to inspect, rectify or delete your Personal Data, or to restrict the processing you are involved in. You can also object to the processing of your Personal Data and you have a right to a data transfer.

7.2. Right of access

When we process your Personal Data, you have the right to inspect this data and you can also request the following information from us:

• The processing purposes;

• The categories of Personal Data concerned;

• The recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or 

• international organisations;
  

• If possible, the period for which it is expected that the Personal Data will be stored or, if that is not possible, the criteria for determining that period;

• Where we do not obtain your Personal Data directly from you, the information available on the source of your Personal Data

If you request more than one copy, we reserve the right to charge an administrative fee for this.

7.3. Right of amendments

If you find that the Personal Data processed by us is incorrect or incomplete, you can ask us to make the necessary amendments or additions.

7.4. Right to be forgotten

You have the right to require Accomodata to delete the Personal Data that we process from you, but only in one of the following cases:

• Your Personal Data is no longer necessary for the purposes for which it has been collected or otherwise processed by Accomodata;

• You withdraw your consent to the processing of your Personal Data and there is no other legal basis for Accomodata  to further process

• your Personal Data; 
  You may object to the processing of your Personal Data on account of a specific situation relating to you, unless Accomodata provides compelling

• legitimate grounds for the processing that outweigh your interests, rights and freedoms or that are connected with the institution, exercise or
  substantiation of a legal claim;
  Your Personal Data has been unlawfully processed; It must be deleted to comply with a legal obligation that rests on Accomodata.
  
  
  

7.5. Right to limitation of processing 

In certain cases, you may request Accomodata to limit the processing of your Personal Data, in particular:

• If you dispute the correctness of your Personal Data, for a period that allows Accomodata to verify the correctness of your Personal Data;

• The processing would be unlawful, but you do not want your Personal Data to be deleted;

• Accomodata no longer needs your Personal Data for processing purposes, but you need it yourself to set up, exercise or substantiate a legal claim;

• You may object to the processing of your Personal Data on account of a specific situation relating to you, awaiting an answer to the question whether the justifiable grounds of Accomodata outweigh your interests, rights and freedoms or relating to the institution, exercise or substantiation of a claim.
  
  Any limitation of your Personal Data will result in it being marked by Accomodata for the purpose of limiting its processing in the future.
   
  

7.6. Right of transferability of your Personal Data

In certain cases, you have the right to obtain the Personal Data relating to you that you have provided to Accomodata in a structured, common and machine-readable form, and you have the right to transfer that data to another data processor. The cases in question are as follows: 

1. The processing of Personal Data is based on your consent or is necessary for the perormance of the contract
   
   AND

2. Processing shall be carried out by means of automated processes

Both of the above conditions must be met. If this is not the case, you do not have a right to transferability.

Finally, the right to transferability should not affect the rights and freedoms of others (e.g. if the data concern more than one data subject). Accomodata reserves the right to refuse the transferability if it believes that the rights and freedoms of others are being harmed

8. SECURITY OF YOUR PERSONAL DATA

Where relevant, the measures taken by Accomodata may include the following:

• The pseudonymisation and encryption of your personal data;

• The ability to ensure the confidentiality, integrity and availability of its processing systems and services on an ongoing basis; 

• The possibility, in the event of an incident, of restoring the availability of, and access to, the Personal Data in a timely manner;

• The establishment of a procedure for periodical testing, assessing and evaluating the effectiveness of technical and organisational measures to safeguard processing.

Where Accomodata itself is responsible for the storage of your Personal Data, this is done on its own secure devices, media, servers and/or other material or immaterial carriers.

9. NOTIFICATION OF INFRINGEMENTS

 Accomodata is required by law to report any breach of your Personal Data to the supervisory authority without unreasonable delay and, if possible,          no later than 72 hours after it becomes awareof it.

 

Where appropriate, and where the breach is likely to pose a high risk to your rights and freedoms, Accomodata undertakes to report the breach of         your Personal Data to you as well, unless one of the following conditions is met:

• Accomodata has taken appropriate technical and organizational protection measures to make your Personal Data incomprehensible to unauthorized persons (encryption, pseudonymization, etc.) and these measures have been applied to your Personal Data to which the breach relates
  

• Following the ascertainment of the infringement, Accomodata has taken the necessary measures to ensure that the infringement is no longer likely to pose a high risk to your rights and freedoms
  

• The communication would require a disproportionate effort. In that case, Accomodata will instead make a public announcement or take a similar measure on the basis of which you will be informed equaly effective
  

10. THIRD-PARTY PROCESSING

applicable privacy legislation, in particular the Privacy Act and the GDPR. 

By means of a Processing Agreement, these third parties undertake, when processing your Personal Data in the context of an assignment outsourced to them by Accomodata, to act in full compliance with the applicable privacy legislation, in particular the Privacy Act and the GDPR.

Accomodata may rely on certain third party service providers who have their own privacy policies regarding the information it needs to provide tothem for your purchase related transactions, such as payment gateways and other payment transaction processors.

Where appropriate, we encourage you to review the privacy policies of these service providers so that you understand how your Personal Data is handled by these providers.

Please note in particular that certain providers may be located in a jurisdiction other than Belgium or the European Union or may have facilities there. When you choose to proceed with a transaction involving the services of an external service provider, your information may be subject to the laws of the jurisdiction or jurisdictions in which that service provider or its facilities are located.

For example, if you are located in Canada and your transaction is processed by a payment gateway in the United States, your personal information used in completing that transaction may be disclosed under U.S. law, including the Patriot Act

11. AMENDMENTS

12. COMPLAINTS AND REMARKS  

 If you have a complaint or remark about this Privacy Policy or the processing of your Personal Data by Accomodata, or if you notice a breach of the processing of your Personal Data, please contact Accomodata in first instance.

commission@privacycommission.be ).

13. APPLICABLE LAW AND COMPETENT COURT    

13.1 Applicable law              

13.2. Competent court                

The courts of the judicial district of Ghent, department Ghent, are competent to take knowledge of any dispute arising between Accomodata and the data subject whose Personal Data are processed by or on behalf of Accomodata.