Cogitus has always been careful to protect the personal data that it is called upon to process. To this end, Cogitus undertakes to fully comply with the regulations in force applicable to the processing of personal data and, in particular, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (also entitled the General Data Protection Regulation or RGPD ”) and the Belgian law of July 30, 2018 relating to the protection of individuals with regard to the processing of personal data.
We would like to provide you with information below concerning the data we collect, the purposes we pursue when processing your data, the retention period, the rights you have in terms of respect for privacy and the way in which you can exercise them.
The person responsible for processing personal data on the Cogitus site is Cogitus SPRL with its registered office at Avenue des Bouleaux 30 at 4053 Embourg – Belgium registered with the Crossroads Bank for Enterprises under number 0644.637.254.
For any question: email: firstname.lastname@example.org
This means that Cogitus defines the purposes and means of processing your personal data.
- What types of data do we have on you?
You will therefore find here a list of the data that Cogitus could have:
Personal data that you share with us. We process personal data that you spontaneously communicate to us. This communication can be by telephone (for example when you call us to ask us a question), in writing, electronically or send us an SMS or an e-mail via our contact form.
In particular the following data:
- Last name
- First name
- Telephone number (gsm)
- E-mail adress
- BCE number, VAT number, your bank details in the context of a contractual relationship.
- any other personal data that you have voluntarily communicated to us.
- your IP address
- Purposes and legal bases of the processing?
Cogitus processes the personal data of Internet users, potential customers or current customers as well as the personal data communicated by its customers or those of its independent
employees for the following purposes:
– Perform our obligations arising from the conclusion of a contract for the provision of legal or IP services with you. The legal basis being the conclusion of an online contract with us and the acceptance of our general conditions of sale;
– Communicate with you in order to answer your questions or your requests, subject to your explicit consent;
– enable us to improve the use you make of our site, the legal basis being your consent to the use of our cookies and our legitimate interest in order to be able to offer you an optimal website;
– comply with legal and regulatory obligations, in particular with regard to the fight against money laundering or with regard to accounting requirements, the legal basis being the law or regulation which requires us to collect personal data and the processing requested;
– send you invitations, promotions, offers, for similar services, customer events, as well as general information about our activities that may be of interest to you. This communication is legally based on our legitimate interest or your explicit consent as the case may be. Likewise, subject to your prior express consent, we may share your personal information with third party partners, who may send you commercial communications in connection with the services. However, you can, at any time, refuse these direct marketing communications by notifying us or via the unsubscribe link that will be found in our communication. The legal basis for this processing is your explicit consent;
– carry out satisfaction studies or surveys in order to adapt and improve our services. The legal
basis is your explicit consent;
– help us to establish, exercise or defend legal claims. These may be situations in which we need to seek legal advice in relation to a legal proceeding or we are required by law to retain or disclose certain information as part of the legal process. . The basis of our processing is our legitimate interest and compliance with legal and regulatory provisions.
– The security of our services and website. In this case, we use your personal data to help us verify the activities of users of our services, our website, to ensure security and prevent any activity that is potentially illegal or in violation of our terms or policies. This processing is based on our legitimate interest that we have to contribute to the security of our services and our assets.
In the event that the legal basis for the processing is our legitimate interest, Cogitus ensures that the impact of the processing on the protection of your privacy is as limited as possible and that, in any case, the balance between the interests legitimate rights of Cogitus and its partners and the possible impact on the protection of your privacy is not disturbed. If you still have objections to this processing, you can exercise your right to object, which is explained below.
Cogitus will not sell or rent your personal data to third parties, unless you have given permission to do so.
- How long do we keep your data?
We process your personal data for the time necessary for the mission you have entrusted to us. Once our assignment is complete, we will keep your personal data for as long as necessary to meet our accounting and regulatory obligations.
As part of the prospecting, we will process your personal data to inform you of our news or to offer you related services or to send you invitations to events as long as you do not oppose this processing. This possibility will be offered to you in each of our communications. In the event that you no longer receive our emails or prospecting letters, we will immediately remove your data from our mailing list.
If there is a question that is not followed by a contract between us, we will delete your personal data from our systems if we do not contact you after a period of 3 months. However, we can keep your personal data for a longer period if the law or a regulation requires it.
- What are your rights?
– Your right of consultation
You have the right to be informed at any time by Cogitus whether or not your personal data is being processed and, if Cogitus is processing it, to consult this information and to receive additional information about:
- the purposes of the processing;
- the categories of personal data concerned;
- recipients or categories of recipients (in particular recipients established in third countries);
- if possible, the retention period or, if this is not possible, criteria for determining this period;
- the existence of your privacy rights;
- the right to lodge a complaint with the supervisory authority;
- what information we have about the source of the data if we obtain personal data from a third party; and
- the existence of the automated decision-making process.
You also have the right to obtain a free copy of the processed data, in an understandable format. Cogitus may request reasonable compensation to cover its administrative costs for any additional copies that you request.
– Your right to rectify personal data
You have the right to have incomplete, incorrect, inappropriate or obsolete personal data rectified. To keep your data up to date, we ask you to notify us of any changes, such as a move for example.
– Your right to erase your data (the right to be forgotten ’)
You have the right to have your personal data deleted without unreasonable delay. However, the Law on the protection of privacy sets some limits to this right which is therefore not applicable to all data.
– Your right to restriction of the processing
You have the right to obtain the restriction of the processing of your personal data and in particular in the context of the use of your data for direct marketing purposes.
– Your right to the portability of your personal data
You have the right to recover ’your personal data. However, the Law on the protection of privacy sets some limits to this right which is therefore not applicable in all situations.
– Your right to object to the processing of your personal data
You have the right to object, on the basis of your particular situation, to the processing of your personal data. Cogitus will stop processing your personal data, unless Cogitus can prove compelling and legitimate grounds for processing which are more important than yours or when the processing of personal data concerns the finding, exercise or defense of legal rights (eg filing a complaint with a court).
- How do you practically exercise your privacy rights?
You can exercise any prerogative listed in point 9 by submitting a request electronically to email@example.com or in writing to the following address:
Avenue des Bouleaux, 30 – 4053 Embourg
In all cases, we provide you with a succinct, transparent, understandable and easily accessible answer.
- Communication to the supervisory authority
You can address complaints relating to the processing of your personal data by Cogitus to the Data Protection Authority, rue de la Presse 35, 1000 Brussels / +32 (0) 2 274 48 00
Cogitus has implemented numerous technical, physical and organizational security measures in order to ensure the integrity, confidentiality and availability of the data of the persons who come to interact with Cogitus.
Cogitus has, in particular, implemented security techniques to protect personal data stored in computer servers against unauthorized access, inappropriate use, alterations, illegal or accidental destruction and accidental loss.
Cogitus is committed to a process of monitoring and continuous improvement of its security procedures in order to take into account new technologies or new risks.
Cogitus has also set up contracts and imposed specific obligations with its subcontractors, partners or its staff so that the manual and electronic processing of any personal data is treated confidentially and under appropriate security measures in order to » avoid any misuse of this data. If you suspect any misuse, loss or unauthorized access to your personal information, please notify us immediately at the above address.
- Who has access to my personal data?
In principle, we do not share your personal data apart from the Cogitus experts concerned by your case.
We may, however, share your personal data with third parties in the following cases;
– following a court decision or in order to comply with a law;
– within the framework of the entrusted mission where we have to deal with an external collaborator (lawyers, bailiff, consultants, IT service providers, trademark agent, etc.) in Belgium or abroad in accordance with your instructions;
– as part of the services of our subcontractors who must have access to your personal data as part of their missions (eg: IT security, marketing, etc.). In this case, a specific subcontracting contract is concluded with the third party service provider who would have access to your personal data.
– We share your personal data with the following categories of people:
– employees of tax administrations or any other public body when the law or any other regulation requires that your personal data be communicated;
– third-party service providers who work on our behalf including in particular accountants, lawyers, bailiffs, external consultants, auditors, IT service providers, communications companies.
- Will my personal data be transmitted outside European Union?
Cogitus may transfer your personal data outside European Union when this is necessary in the processing of our mission such as the registration of a trademark internationally or the defense of your rights via an employee or a partner located abroad.
In the event that Cogitus is required to communicate your personal information to partners or employees located outside the European Economic Area, standard contractual clauses adopted by the European Commission would be imposed on the recipient if the protection of personal data does not is not sufficiently protected in the destination country.
- Modifications and amendments