1 General
1.1 Introduction
This privacy policy explains what you can expect from Houben, Erik (4Result) regarding your personal data when you contact us or use one of our services. In the following sections, we will inform you why we process your data, for what purpose we process it, why you must provide it to us, and how long we store it. We also mention whether there are other recipients of your personal data, whether we intend to transfer it to another country, and/or whether we make automated decisions or use profiling.
When collecting and using this data, the organization is subject to a variety of legislation that controls how such activities may be carried out and what safeguards must be built in to protect them.
The purpose of this policy is to establish the relevant legislation and describe the steps Houben, Erik (4Result) takes to ensure compliance with this legislation.
This control applies to all systems, people, and processes that constitute the organization’s information systems, including board members, employees, suppliers, and other third parties who have access to the systems of Houben, Erik (4Result).
1.2 Identity
Houben, Erik (4Result), with registered office at Schabartstraat 36, 3600 Genk, Belgium, registered in the Register of Legal Entities, with VAT number BE0638.714.613, herein legally represented by Erik Houben.
1.3 GDPR (General Data Protection Regulation)
The General Data Protection Regulation (GDPR) is one of the most important pieces of legislation regarding the manner in which Houben, Erik (4Result) carries out processing activities.
GDPR was transposed in Belgium by the ‘Data Protection Act’ of July 30, 2018.
Significant fines can be imposed in the event of a breach under the GDPR, which is intended to protect the personal data of European Union citizens. This policy of Houben, Erik (4Result) ensures that our compliance with GDPR and other relevant legislation is clear and demonstrable at all times.
1.4 Definitions
1.4.1 Personal data
Any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
1.4.2 Processing
Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
1.4.3 Controller
The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
1.4.4 Principles
Personal data must be:
a) processed lawfully, fairly, and in a transparent manner in relation to the data subject (‘lawfulness, fairness, and transparency’);
b) collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
c) adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’);
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organizational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures (‘integrity and confidentiality’).
The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).
1.5 Statement
Houben, Erik (4Result) will ensure that it complies with all the principles of the GDPR, both in current processing and in the introduction of new processing methods.
If you would like to know more about the organizational and technical measures Houben, Erik (4Result) takes to comply with the relevant legislation, please contact us at the following email address: erik.houben@4result.be.
2 Data transparency
2.1 What personal data do we collect?
We process various types of personal data relating to you that you provide to us yourself via our website or other communication channels.
When you visit our website, we collect and process:
Technical information regarding the device you use, such as your IP address, browser type, geographical location, and operating system.
Information regarding your browsing behavior, such as the time you spend on a page, which links you click, which pages you visit, and how often you visit a particular page.
When you fill out our contact form or contact us, we collect and process:
The personal identification data you provide to us, such as your name, email address, phone number, and organization.
The content of the message and its technical details (with whom among us you communicate, the date, the time, etc.);
Any other personal data you provide to us.
When you purchase training, coaching, or consulting services from us, we collect and process:
The personal identification data you provide to us, such as your name, email address, address, place of residence, phone number, organization, and position.
Any other personal data you provide to us.
When you sign up for our newsletter, we collect and process:
Personal identification data such as name and email address
When you negotiate, conclude, and execute an agreement with us, we collect and process:
Your personal identification data, such as your name, email address, employer, and position;
Your signature;
Any other personal data you provide to us during the term of the agreement.
When we deliver certain products or services to you, we collect and process:
Your contact and billing details
2.2 Why do we process your personal data?
We process your personal data for several reasons, including to enable you to visit our websites and to communicate with us. In this article, we provide an overview of all the reasons why we process your personal data.
We process your personal data for the following reasons:
a) To be able to offer you the requested information, products, and services in a personal and efficient manner;
b) To perform statistical analyses and to improve our websites and services;
c) To be able to process and execute the agreement to which you or your company or employer is a party, including the related administration;
d) To be able to defend ourselves and our interests in legal proceedings;
e) For security reasons and to be able to detect, prevent, and report abuse;
f) To inform any third party in the context of a possible merger with, acquisition of/by, or demerger by that third party, even if that third party is established outside the EU;
g) To comply with our legal obligations and any valid request from police, judicial, or governmental authorities.
2.3 Lawful processing of your personal data
The law requires us to clarify the legal basis we rely on to process your personal data (e.g., your consent). In this article, we indicate for each purpose, as mentioned above, which legal basis we use.
Data protection legislation requires us to specify exactly which legal basis we rely on to make the processing of your personal data lawful. We must do this for each of the purposes mentioned in 2.2.
For the purpose under (a), we rely on your consent. For sending newsletters, advertising, promotions, and offers, we will always request your explicit prior consent, which you can withdraw at any time. You can unsubscribe in the emails we send you.
For the purpose under (g), we must process your personal data to comply with our legal obligations.
For the purposes under (b) to (f), we process your personal data because it is necessary for the pursuit of our legitimate interests, which in this case relate to:
monitoring the quality level of our websites and services;
being able to conduct our administration and services in a normal and professional manner;
obtaining insight into how the websites are used;
our commercial interests in improving and expanding our customer relationships, activities, and services;
our interest in the context of safety and security;
2.4 Who receives your personal data?
We do not sell the personal data we have collected to third parties, nor do we disclose it to them, except in the cases described in this privacy policy or as communicated to you at the time of collection.
We may share personal data with affiliated entities or with third parties who perform data processing on our behalf. When these service providers act as data processors on our behalf, we do not allow them to use or disclose this data in a manner that is inconsistent with the cases described in this privacy policy. We require these data processors to guarantee the privacy and security of the personal data they process on our behalf.
We may also disclose your personal data:
when required to do so by certain legislation or a legal process;
when required to do so by government authorities;
when we believe that disclosure of this data is necessary and appropriate to prevent physical harm or financial loss, or in connection with an investigation into suspected or actual fraudulent and illegal activities.
We reserve the right to transfer personal data in the event that we sell part or all of our business or assets. Should such a sale occur, we will take all reasonable measures to encourage the recipient to process the personal data provided to us correctly and in a manner consistent with our privacy policy.
2.5 How long do we keep your personal data?
We retain your personal data only to the extent and for as long as necessary to achieve the purposes mentioned in point 2.2.
Your personal data is only processed for as long as necessary to achieve the purposes mentioned in point 2.2 above or until you withdraw your consent for processing. We will de-identify your personal data when it is no longer needed for these purposes, unless:
There is a prevailing interest of Houben, Erik (4Result) or third parties in keeping your personal data identifiable;
A legal or regulatory obligation or a judicial or administrative order prevents us from de-identifying the data.
2.6 Security and confidentiality
Houben, Erik (4Result) guarantees that the processing of your personal data takes place in an adequate, correct, and secure manner. Appropriate technical and organizational measures have been taken to prevent any loss, falsification, or unlawful modification of, as well as unauthorized access to, the personal data.
3 Data Management
3.1 Rights of data subjects
The data subject also has rights under the GDPR. These consist of:
the right to information
the right of access
the right to rectification
the right to erasure
the right to restrict processing
the right to data portability
the right to object
rights related to automated decision-making and profiling.
Each of these rights is supported by appropriate procedures within the client’s company that make it possible to take the necessary measures within the timeframes set by the GDPR.
These timelines are shown below.
3.2 Right of access, rectification, erasure, and portability
By law, you can ask us what information we hold about you and you can ask us to correct this information if it is incorrect. If we have requested your consent to process your personal data, you can withdraw that consent at any time.
If we process your personal data for reasons of consent or to perform a contract, you can ask us to provide you with a copy of the information in a machine-readable format so that you can transfer it to another provider.
If we process your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
3.3 Right to restriction or objection
The data subject has the right to object to processing based on the following legal grounds:
For the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
In the context of the legitimate interests of the controller
After an objection has been made, Houben, Erik (4Result) must justify the grounds on which the processing is based and suspend processing until this has been done. When personal data is used for direct marketing, we have no choice but to stop processing the data.
3.4 Consent
The data subject has the right to withdraw their consent when the legal basis for processing their personal data is that of consent (i.e., the processing is not based on another justification permitted by the GDPR, such as a contractual or legal obligation).
Before excluding the data subject’s personal data from processing, it must be confirmed that consent is indeed the basis of the processing. If not, the request may be rejected on the grounds that the processing does not require the data subject’s consent. Otherwise, the request must be granted.
In many cases, giving and withdrawing consent will be available electronically, i.e., online, and this procedure is not required.
When the consent relates to a child (defined in Belgium as under the age of 13), the giving or withdrawal of consent must be approved by the person who holds parental responsibility for the child.
3.5 Automated decision-making and profiling
The data subject has the right not to be subject to automated decision-making when the decision has a significant effect on them, and can insist on human intervention where necessary. The data subject also has the right to express their point of view and contest decisions.
There are exceptions to this right, namely if it concerns a decision:
necessary for a contract
permitted by law
based on the explicit consent of the data subject.
When assessing these types of requests, it must be evaluated whether the aforementioned exceptions apply in the specific case in question.
3.6 Request
To submit a request regarding your personal data by email, you can use the following email address: erik.houben@4result.be.
4 Data Governance
4.1 Compliance
We have effective technical, organizational, and physical safeguards in place to protect your personal data against accidental or unlawful destruction, accidental loss, unauthorized modification, disclosure or access, against misuse, and any other unlawful processing of the personal data in our possession.
The security measures taken vary according to the type of data processed and how it was collected and/or stored. When you provide certain personal data online, we use Secure Socket Layer (SSL) technology, which meets the industry standard for encryption on the internet. This technology protects the personal data you provide by making all data sent from your computer to our server inaccessible. We also use digital certificates to assure you that you are connected to secure channels.
4.2 Complaints
Have you reviewed our privacy policy in full but not yet found an answer to your question? Then please ask your question regarding your privacy via erik.houben@4result.be. We will answer your question there as soon as possible.
If you do not receive an answer or you are not satisfied with the answer received, you have the right to file a complaint with the supervisory authority.
In Belgium, this is the “Data Protection Authority (GBA)”. More information about this can be found on their website.
4.3 Adjustments
This policy was updated on 2021-04-14.
This privacy policy may be adjusted if our services or applicable legislation require it. This means that we are constantly looking for better services tailored to you. It is possible that new applications will be introduced where we will collect or want to use your data in a different way. Naturally, we will let you know when there are significant changes, and we will ask for your consent if necessary.