Privacy settings

1. General information – Purpose of this Privacy Statement

This Privacy Statement describes the practices, the roles and responsibilities of Cyber Security Management] as a Data Controller regarding the collection and use of your Personal Data, and sets forth your rights under the applicable Data Protection Laws.  

This Privacy Statement completes and supplements our current Terms and Conditions.

We understand that you are aware of, and care about your Personal Data and we ensure that any of the Personal Data we use is Processed in accordance with the applicable Data Protection Laws.

This Privacy Statement will be updated from time to time to reflect regulatory changes and/or technological developments and implementation into our data processing activities. Any updates to this Privacy Statement will be notified to you in due time through posting the updated version on our Website(s) or through other available channels. 

This Privacy Statement applies as of the date stated above and replaces prior versions as of this date.

2. Definitions of the terms used in this General Privacy Statement

• “Cyber Security Management" ("we", "our", "us" means CYBER SECURITY MANAGEMENT a Belgian registered company under No. BE 867.076.367] with its registered headquarters located at: Rue de Livourne, 7 in 1060 Brussels, Belgium;

• "website User" means every person (you), who has accessed our website(s) on his/her PC or other mobile device;

• "Data Controller" means the natural or legal person, public authority, agency or any other body or organisation, which alone, or jointly with others, determines the purposes (why) and means (how) of the processing of your Personal Data. For the purposes of this Privacy Statement the Data Controller is CYBER SECURITY MANAGEMENT;

• "Data Processor" means a natural or legal person, public authority, agency or any other body or organisation that processes your Personal Data on behalf of, and for the purposes established by the Data Controller;

• "Data Protection Act" means the Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data (“Law of 30 July 2018”) entered into force on 5 September 2018, transposing Regulation (EU) 2016/679 (the General Data Protection Regulation) into national law and repealing the Belgian Law of 8 December 1992;

• “Data Protection Laws” mean any and all applicable European or national data protection laws and regulations, as amended from time to time, including the Data Protection Act;

• “General Data Protection Regulation” (“GDPR”) means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC;

• "Data Subject" ("you" or "yours") means a person to whom specific Personal Data relates to, and who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific concerning physical, physiological, mental, economic, cultural or social identity;

• "Personal Data" means any information relating to an identified or identifiable natural person;

• "Privacy Statement" means the current Privacy Statement;

• "Process" or "Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction;

• "Sub-processor" means any processor engaged by a Data Processor who agrees to receive Personal Data exclusively intended for the Processing activities to be carried out on behalf of a Data Controller in accordance with Data Controller's written contractual terms and instructions;

• “Third Party” means any natural or legal person, public authority, agency, body or organisation, other than the Data Subject, Data Controller, Data Processor and persons who, under the direct authority of the Data Controller or Data Processor, are authorized to Process Personal Data;

• "Websites" mean our website(s): https://www.cybersecuritymanagement.com

3. Our contact details

For the purpose of the applicable data protection laws, we are the responsible entity (the ‘Data Controller’) for the processing of the Personal Data you provide to us when you visit our Websites and/or install and use our App.

CYBER SECURITY MANAGEMENT

Parc de l’Alliance
Boulevard de France, 7 bat C
1420 Braine l’Alleud
+32 477 42 39 02
info@cs-m.be
www.cybersecuritymanagement.be

For additional information on how we collect and process your personal data, or for exercising your rights under the applicable Data Protection Laws, you may contact CSM via e-mail or via regular mail at the address mentioned above.

4. Personal Data we may collect and process

4.1. Personal Data we process when you are using our Website(s)

CYBER SECURITY MANAGEMENT operates the following Website(s):

• https://www.cybersecuritymanagement.com

For the purpose of the applicable Data Protection Laws, we are the responsible legal entity (the ‘Data Controller’) for the Processing of Personal Data you provide to us when you visit or otherwise make use of our Websites.

When accessing and using our Websites we may collect and Process:

Data provided to us when you contact us via a contact form on our Website(s), via e-mail, or subscribe to our Newsletter, such as:

• name and surname;
• e-mail address;
• GSM number;
• content of your message;
• any other information you may choose to provide to us

Our Website(s) may provide links to a number of third party websites. We have no control over the manner in which these third party websites collect and process your personal data when you make use of them. When visiting those links, make sure you review first their privacy statements or privacy notices prior to providing any personal data to them.

4.2. Personal data we process when you are using our app.

When you are visiting our website(s) we collect and Process your Personal Data as Data Controller for the purpose of the applicable Data Protection Laws.

When installing, activating and using our App, we may collect, Process and store certain of your Personal Data, as follows:

4.2.1. data related to your PC or mobile device, such as:

1. your choice of language, as recorded in your mobile device OS (NL/FR/EN);

4.2.2. data provided when you contact us, such as : 

1. the name(s),(e-mail) addresses and phone number(s) mentioned in your messages to us;
2. the content of any message sent to us;
3. any other information you chose to provide to us upon our request, such as proof of your identity;

4.2.3. data related to transactions you have completed, allowing you to review your communication history.

We collect and process your Personal Data for the purposes of:

1. […]
2. to notify you about the changes in our services, or any other aspects connected to our commercial activities, including but not limited to, changes to our Privacy Statement;
3. to measure or understand the effectiveness of advertising we serve to you, and to deliver the relevant and personalized advertising to you (based on your consent)
4. to provide you, from time to time, with information on similar products and/or services we offer.

4.3. Personal Data of children

Our website(s) are not intended for the use of children (under 18 years old).

We do not knowingly collect and Process any Personal Data from individuals who are under the age of 18.

4.4. Why do we process your Personal Data

We process this data for a number of purposes:

• to operate, maintain and optimize our website(s) and related systems;
• to allow you to use our website(s) and make it more convenient for you to do so;
• to ensure that our website(s) are used properly and securely;  
• to further develop and update our website(s); 
• to respond to the requests you submit via the contact form on our website(s);
• for marketing purposes regarding our products and services;
  to enable us to comply with our obligations under applicable laws, the exercise or defense of legal claims, or to exercise our rights;
• other purposes for which you have given us your explicit and informed consent;

4.5. How long do we keep your Personal Data

We retain your (personal) data for no longer that it is necessary when using our website(s), except where we are under a legal obligation to retain your (personal) data longer.

4.6. Processing Personal Data for new purposes

We may want to use your Personal Data for purposes not initially set forth in this Privacy Statement, but in such case we will inform you of such new purposes and, where required by law, will ask for your to consent to such new purposes.

4.7 Processing of data not obtained from the data subject

We do not collect or process personal data that has not been obtained from the data subject. If this should be the case, we will inform you of these new purposes and, if required by law, we will ask you to consent to these new purposes.

5. Use of cookies, web beacons and similar technologies

We use cookies, web beacons and similar technologies to monitor and analyze how you make use of our Website(s). This information allows us to optimize your browsing experience and provide you with personalized information according to your expressed options.

A cookie is a small (temporary) text file that our Website(s) saves on your computer or mobile device when you visit our Website(s). These cookies are used to save your preferences to be used during a later visit (e.g. your choice of language). Additionally, cookies may also be used for marketing and remarketing purposes. 

A web beacon is a transparent graphic image, usually no larger than 1x1 pixels, used to monitor which web pages are visited on our websites. A web beacon is often used in combination with other cookies.

When we use cookies, web beacons and similar technologies in connection with our Websites, we will use the functions available to us to allow collection of non-personal or anonymized data only. (For example, if we use Google Analytics, we will use the function available within Google Analytics for anonymizing your IP-address). Turning off your browser's cookies will prevent our web beacons from monitoring your activity on our Websites. The web beacons will still account for your visit, but your unique information will remain anonymous.

Our Website(s) provide you with options for enabling/disabling different categories of cookies used on our Websites. Currently our Website(s) make use of:

• functional cookies (strictly necessary for the good functioning of our websites),
• analytical cookies (related to determining how visitors use our websites) and
• marketing and remarketing cookies (used for optimizing our marketing campaigns based on the browsing behaviour of visitors on our websites). 

Additionally, you may also choose to configure your browser’s standard privacy and security settings, by installing certain browser specific add-ons (such as “Google Analytics Opt-out Browser” add-on, which is currently available for most commonly used web browsers). You may review these settings and change them prior to, or after you visit our website(s). You may also choose to block or delete cookies. If you choose to change these settings after you have visited our website(s) (e.g.:  deleting all cookies), next time you visit our website(s) you may be asked to consent again to our use of cookies, web beacons and similar technologies. 

Some of the cookies we use are “session cookies” and some are “persistent cookies”. Session cookies are automatically deleted at the end of your browsing session (thus the name “session cookies”). Persistent cookies remain longer on your device, for the duration established for each specific persistent cookie and will be automatically deleted at the end of their lifetime (persistent cookies remember your browsing choices, such as your choice of the language).

We have taken the necessary steps to ensure that the use of cookies, web beacons and other similar technologies on our Websites is the least privacy intrusive as possible. However, depending on your choice for accepting or refusing cookies, you may or may not be able to use some or all of our Websites’ features

To optimize your visit to our Websites, we recommend you accept our pre-existing cookie settings during your first visit. If you choose not to, or you change your mind, you may always deactivate or modify the existing cookies settings, by accessing our cookies notice.

Additional information about browser settings and cookies could be found on  http://www.allaboutcookies.org/.

6. Disclosure and transfer of personal data

We do not disclose, share or transfer your Personal Data with any Third Party, except:

• where you explicitly consented for us to do so; or
• to our service providers that are bound by legally enforceable contractual terms, as required by Data Protection Laws, to allow Processing on our behalf in accordance with this Privacy Statement; or
• if we are required to do so pursuant to law (e.g. in response to a judicial or court order); or
• to any legal established entity that we acquire in whole or in part, or any entity that we are, in whole or in part, acquired by, merged into or merged with; or
• as otherwise stated in this Privacy Statement or permitted by the applicable Data Protection Laws. 

We will not transfer your Personal Data outside of the European Economic Area unless:

• you have explicitly consented to the proposed transfer; or
• the transfer is strictly necessary for the conclusion or the performance of a contract concluded between you and us; or
• the transfer is necessary for the establishment, exercise or defence of our legal claims;
• an adequate level of protection of your Personal Data is ensured as determined by the European Commission; and
• appropriate safeguards are in place, as established by the European Commission.

We reserve the right to disclose Personal Data to respond to authorized information requests from government authorities or law enforcement authorities, or when otherwise required by law.

7. Security of your personal data

Ensuring the confidentiality and security of your Personal Data is paramount to us. To secure and protect your privacy and Personal Data you make available to us through the use of our Websites and our App, we maintain adequate physical, technical and organizational safeguards consistent with our legal obligations and consistent with industry standards. Access and processing of your Personal Data is permitted to authorized personnel only. Additionally, we train all our personnel about the importance of maintaining the confidentiality and of the privacy and security of your Personal Data. 

8. Your rights

The Data Protection Laws that protect your Personal Data grants you certain rights.  

Subject to the conditions stated under the applicable Data Protection Laws and the Belgian Data Protection Act of 30 July 2018, you may:

• contact us requesting information on what Personal Data we have on you;
• rectify any erroneous Personal Data you (may) have submitted to us via our Websites;
• export your Personal Data to a Third Party of your choosing;
• object or restrict, under specific circumstances, the Processing of your Personal Data;
• request the removal of your Personal Data, where such removal is permitted under the applicable Data Protection Laws.

We will respect those rights and you may contact CSM to exercise those rights. 

When you contact us, please be specific as to what information you require, or what right(s) you wish to exercise. In order to prevent any abuse or identity fraud, we may ask you to provide additional information and/or to provide an adequate proof of your identity. A response to your request shall be provided within the timeframe established by the applicable law(s).

If you believe that your rights with regard to the protection of your personal data are not uphold, you may submit a complaint to CSM or, alternatively, you may choose to file your complaint with :

Belgian Data Protection Authority
Rue de la Presse 35, 1000 Brussels
tel: +32 (02) 274 48 00
contact@apd-gba.be
www.dataprotectionauthority.be

9. Contacting CSM

Should you have questions with regard to this General Privacy Statement or wish to exercise any of any of the rights provided to you under the applicable Data Protection Laws, you may do so by submitting an e-mail request to CSM. Alternatively, you may address your questions or exercise your rights by regular post at

Cyber Security Management

CSM
Parc de l’Alliance
Boulevard de France 7 bat C
1420 Braine l’Alleud