1. General

1. This privacy policy (“Privacy Policy”) governs the processing of your personal data as part of your use of our website (the “Website”). This processing is carried out by SDM-Valorum NV, headquartered at Luitenant Lippenslaan 60, 2140 Antwerp (“we” or “us”), registered under the number 0505 640 412, in accordance with the applicable data protection legislation.
2. By using our Website, you acknowledge that you have read this Privacy Policy carefully and agree to it without reservation. We reserve the right to modify the Privacy Policy at our discretion. Any changes will be communicated via the Website. You confirm that you understand the purposes for which your personal data is processed. You also agree that your continued use will be understood as continued consent. You can withdraw your consent at any time by sending an email to info@sdm-valorum.be.
3. Please note that we may use so-called ‘cookies’ or similar technologies as part of the Website and/or Services. Cookies are small text files placed on the hard drive of a device, containing certain information, including sometimes personal data. For more information regarding our use of cookies, please read our cookie policy (LINK).
4. This Privacy Policy was last updated on 19/06/2018.

2. What & Why We Process Data

1. When you use the Website and/or Services, we process personal data relating to you. Such personal data includes:

When	What	Why (Purpose)	Legal Basis
Website use, newsletter registration, contacting us	Personal identification data	Customer management	Consent and legitimate interest

2. Generally, we obtain the personal data mentioned above directly from you. However, if you choose to register via a social media account (such as Facebook or Google Plus), this data is collected through your social media profile. We advise you to consult the privacy policy of your social media service provider to see which data is processed by them when you use the social media login feature. We do not send any personal data provided via the Website to social media providers unless you consent to it. In addition to the above purposes, we may also process your personal data:

1. 1. • To provide you with information about products and services in a personalized and efficient way, whether via the Website, email, telephone, or social media channels.
      • To process your personal data so we can provide the Services.
      • For direct marketing purposes, i.e., to provide you with targeted communication, promotions, offers, and other advertisements from us or selected partners. We will ask for your prior consent for this.
      • To perform statistical analyses to improve our Website and/or Services or to develop new products or services.
      • To transfer data to a financial institution or payment service provider to enable them to meet their legal obligations.
      • To transfer data to the police or judicial authorities as evidence of possible criminal offenses or if there are reasonable suspicions of an unlawful act or crime committed by you through your registration or use of the Website or Services.
      • In the context of a possible merger, acquisition, or split by a third party, even if that third party is located outside the EEA.

3. If your registration or use of the Website or Services is considered (a) a violation of the terms or intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Services, (c) a danger to the Website or Services or our systems or subcontractors due to viruses, Trojans, spyware, malware, or any other malicious code, or (d) illegal, unlawful, discriminatory, or offensive, we may process your data in the interest of ourselves, our partners, or third parties.

3. Who We Share Data With

1. We do not transmit your personal data to third parties in an identifiable way unless required to provide the Services without your explicit consent.
2. We may use external processors to provide the Website and/or Services. We ensure that third-party processors may only process your personal data on behalf of us and based on written instructions from us. We guarantee that all external processors are carefully selected to ensure the safety and integrity of your personal data.
3. We may share anonymized and/or aggregated data with other organizations that may use this data to improve products and services and to tailor marketing, presentation, and sales of products and services.

4. Where We Process Data

1. We and our external processors will only process your identifiable personal data within the EEA.
2. We may transfer your anonymized and/or aggregated data to organizations outside the EEA. If such a transfer occurs, we will ensure that appropriate safeguards are in place to guarantee the safety and integrity of your personal data and that all rights related to personal data are guaranteed under applicable mandatory law.
3. If there is a transfer of your personal data and/or anonymized and/or aggregated data, the following legal transfer mechanism will apply:

Which Service	Country outside EEA	Legal Transfer Mechanism
Google Analytics Mailchimp LinkedIn Facebook	USA USA USA USA	EU-US Privacy Shield EU-US Privacy Shield EU-US Privacy Shield EU-US Privacy Shield

5. How We Process Data

1. We will make every effort to process only the personal data necessary to achieve the purposes stated in this Privacy Policy. We will process your personal data in a lawful, fair, and transparent manner. We will make every effort to keep personal data accurate and up-to-date.
2. Your personal data will only be processed for as long as necessary to achieve the purposes outlined in this Privacy Policy or until you withdraw your consent. Please note that withdrawing consent may prevent you from using the Website and/or Services in whole or in part. If you have registered on our Website, we will delete your personal data if you delete your profile unless a legal or regulatory obligation or court or administrative order prevents us from doing so.
3. We will take appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft and from accidental loss, manipulation, or destruction. Access by our staff or staff of our external processors is only possible on a need-to-know basis and is subject to strict confidentiality obligations. You understand, however, that safety and security are best-effort obligations that can never be guaranteed.

6. Your Rights

1. 1. You have the right to request access to all personal data we process about you. Access requests that are clearly submitted with the intent to cause harm or nuisance to us will not be honored.
   2. You have the right to request that any inaccurate or incorrect personal data about you be corrected free of charge. If you have registered on our Website, you can correct much of this data yourself via your profile. If such a request is submitted, you must also include proof that the personal data in question is incorrect.
   3. You have the right to withdraw your previously given consent for the processing of your personal data. You can withdraw consent at any time by sending an email to info@sdm-valorum.be or by deleting your profile (if applicable).
   4. You have the right to request that personal data relating to you be deleted if it is no longer necessary in light of the purposes set out in this Privacy Policy or if you withdraw your consent for its processing. However, please note that a request for deletion will be evaluated in light of legal or regulatory obligations or court or administrative orders that may prevent us from deleting the relevant personal data.
   5. Instead of deletion, you can also request that we restrict the processing of your personal data if (a) you dispute the accuracy of the data, (b) the processing is unlawful, or (c) the data is no longer necessary for the stated purposes, but you need it to defend yourself in legal proceedings.
   6. You have the right to object to the processing of personal data if you can demonstrate that there are serious and legitimate reasons related to your specific circumstances that justify such an objection. However, if the intended processing is classified as direct marketing, you have the right to object to such processing free of charge and without justification.
   7. When your personal data is processed based on consent or a contract and the processing is carried out by automated means, you have the right to receive the personal data you provided to us in a structured, commonly used, and machine-readable format, and, if technically feasible, you have the right to transfer this data directly to another service provider. The technical feasibility of this is solely assessed by us.
   8. If you wish to submit a request to exercise one or more of the rights listed above, you can send an email to info@sdm-valorum.be. In this request, you must clearly indicate which right you wish to exercise and why. It must also be dated and signed, and accompanied by a digitally scanned copy of your valid ID card proving your identity. We will notify you promptly upon receipt of such a request. If the request is justified, we will comply with it as soon as reasonably possible and no later than thirty (30) days after receiving the request.
   9. If you have a complaint about how we process your personal data, you can always contact us via info@sdm-valorum.be. If you remain dissatisfied with our response, you are free to submit a complaint to the Belgian Data Protection Authority. For more information, visit www.gegevensbeschermingsautoriteit.be.