Last modified on May 7th 2020.
First of all, we are excited that you are interested in November Five.
In this privacy statement we document the way Personal Data is processed by us.
It is possible that we will ask you to share certain Personal Data with us, including but not limited to your first name, last name, e-mail address.
We only collect Personal Data that is necessary to inform you about our products and services, to execute agreements with you and to contact you.
The legal grounds for the processing of your Personal Data are the execution of an agreement, a legal obligation, our legitimate interests and, in some cases, your consent.
The processing of your Personal Data is subject to this privacy statement. In case you have questions or remarks, please contact privacy@novemberfive.co.
By providing Personal Data you are deemed to have acknowledged the use of your Personal Data in accordance with this privacy statement.
We will also ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our Website.
“Affiliated Company” means a company which November Five is affiliated to, provided that such company meets the conditions for an “affiliated company” as set out in Article 1:20 of the Belgian Company code.
“Controller” has the meaning as defined in the General Data Protection Regulation 2016/679. November Five will be qualified as the Controller, which determines the purposes and means of the processing of Personal Data.
“Personal Data” has the meaning as defined in the General Data Protection Regulation 2016/679, which is any information relating to an identified or identifiable natural person (also called the “data subject”).
“Processor” has the meaning as defined in the General Data Protection Regulation 2016/679, which processes Personal Data on behalf of the Controller.
“November Five” is the tradename/company name of November Five, a company with registered office situated 2000 Antwerp, Scheldestraat 11, registered in the Belgian Crossroad Bank for Enterprises with number 0820.822.413.
“Website” means the website novemberfive.co .
In this article 2 we have set out:
(a) the general categories of Personal Data that we may process;
(b) the purposes for which we may process Personal Data; and
(d) the legal bases of the processing.
We may process data about your use of our Website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Website navigation paths, as well as information about the timing, frequency and pattern of your service use.
The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the Website and services.
The legal basis for this processing is our legitimate interests, namely monitoring and improving our Website and services.
We may process your Personal Data that are provided in the course of the use of our services ("service data"). The service data may be processed for the purposes of operating our Website, providing our services, ensuring the security of our Website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent or our legitimate interests.
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process any of your Personal Data identified in the other provisions of this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your Personal Data set out in this article 2, we may also process any of your Personal Data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person's Personal Data to us, unless we ask you to do so.
Every time you submit Personal Data, we shall handle this information in accordance with the stipulations of this privacy statement and any legal obligations applicable to the processing of Personal Data, including the General Data Protection Regulation (GDPR) 2016/679.
We shall establish appropriate measures and procedures to secure and protect the Personal Data we collect via the Website or via electronic correspondence.
In this way, we undertake to prevent, as far as can be reasonably expected, illegal processing of Personal Data and unintentional loss or liquidation of your Personal Data. However, despite these precautions, we cannot guarantee that your Personal Data is protected when it gets displayed or reported via unsecured means in another way than via the Website or otherwise communicated.
We optimize the security of your Personal Data by limiting the access to your Personal Data to persons on a “need-to-know” basis (for example: only November Five employees or associates who need your Personal Data for the purposes as described in article 2 will have access to the data).
Without being exhaustive, November Five collects your Personal Data in the following cases:
We can combine the Personal Data we collect via the Website with information which you provide us in another way or which third parties deliver to us.
Personal Data will be kept and processed by us for the duration that is required in relation to the purposes of the processing depending on whether we have a contractual relationship with you or not.
Client data and supplier or subcontractor data will be removed from our systems after 7 years after the termination of the agreement involved, except for the Personal Data that we have to store for a longer duration based on specific legal obligations or in case of pending litigation(s).
Data collected through the Website or through any other channel will not be kept longer than 2 years after the last useful contact between us and you.
Notwithstanding the other provisions of this article 4, we may retain your Personal Data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We avoid the collection of Personal Data that are not relevant for the purposes set out in this article 4.
We will not transfer your Personal Data to third parties outside the European Economic Area, except to subcontractors or employees who retain the Personal Data on servers in the United States, have undertaken to do so under the Privacy Shield or in accordance with the European Commission’s Standard Contractual Clauses and thereby provide an adequate level of security for the processing of Personal Data.
Furthermore, we will not transfer your Personal Data to third parties inside the European Economic Area without your permission, except:
Any transfer of Personal Data to one of the third parties mentioned in the list above, is in accordance with the stipulations of the General Data Protection Regulation (GDPR) 2016/679.
We ensure that measures are taken to make sure that third parties cannot use your Personal Data for other purposes than the purposes mentioned exhaustively in article 2, and that these third parties have taken the necessary technical and organizational measures to protect these data.
We will have data processing agreements in place with the aforementioned third parties in order to ensure the security of the Personal Data.
Finally, we shall take all necessary precautionary measures to assure that our employees and associates who have access to Personal Data will process these Personal Data exclusively in accordance with this privacy statement and the obligations under the applicable privacy regulations.
By virtue of both Belgian and European legislation concerning data protection, you have the rights as mentioned below. If you want to exercise these rights, you have to send us a written request and provide a copy of your ID card to privacy@novemberfive.co
Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
We will provide you with information within one (1) month of receipt of the request on the action that will be taken. We can extend this one-month period to a maximum of three (3) months, in which case you will be informed about the reasons for such delay within one (1) month of the original request.
You have the right to instruct us to provide you with any Personal Data we hold about you, providing the rights of other data subjects are not affected.
We kindly ask you to help to make sure that the Personal Data in our records are as accurate and up-to-date as possible. If you believe that the Personal Data submitted to us are incorrect or incomplete, please notify us as described above. We will correct or adapt your Personal Data as soon as possible.
In some circumstances you have the right to the erasure of your Personal Data without undue delay. Those circumstances include:
However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary:
In the following circumstances you have the right to restrict the processing of your Personal Data:
Where processing has been restricted on this basis, we may continue to store your Personal Data. However, we will only process it with your explicit consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.
You have the right to object to our processing of your Personal Data.
If you wish to exercise your right to data portability, we will send the Personal Data in a structured, commonly used and machine-readable format to a controller of your choice.
To the extent that the legal basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time. However, withdrawal will not affect the lawfulness of processing before the withdrawal.
The right to complain to a supervisory authority
You can file a complaint with the Data Protection Authority (“Gegevensbeschermingsautoriteit”) by sending an e-mail to contact@apd-gba.be or by sending a written request to the Data Protection Authority with registered address located at 1000 Brussels, Drukpersstraat 35.
The Website may contain links to websites of third parties which are not controlled by us. Although we will do our utmost to make sure that the links on the Website lead exclusively to websites which share the safety and confidentiality standards of November Five, we are not responsible for the protection and confidentiality of data, among Personal Data which you submit on other websites after you have left the Website.
Before submitting Personal Data we recommend that you proceed carefully and consult the privacy statement which applies to the website concerned.
We may update this privacy statement from time to time by publishing a new version on our Website.
You should check this page occasionally to ensure you are happy with any changes to this privacy statement.
We may notify you of changes to this privacy statement by email.
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