Subel asbl (hereinafter referred to as « Subel » or the « Data Controller »)
Rue de la gare 36, 1040 Etterbeek
Company number (BCE/VAT): BE0414 053 012
Register of legal entities: Brussels
Email: info@subel.be
Phone number: +32 016 801 211
Subel establishes this Privacy Policy to transparently inform Users of the website hosted at the following address: www.subel.be (hereinafter the « Site »), regarding how personal data is collected and processed by Subel.
The term « User » refers to any user, whether a natural or legal person, who visits or interacts in any way with the Site.
As such, Subel determines all technical, legal, and organizational means and purposes for processing Users’ personal data. Subel commits to taking all necessary measures to ensure that personal data processing complies with the law of July 30, 2018, concerning the protection of natural persons with regard to the processing of personal data (hereinafter, the « Law ») and the European Regulation of April 26, 2016, on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter the « Regulation »).
Subel is free to choose any natural or legal person who processes Users’ personal data on its behalf and under its instructions (hereinafter the « Processor »). If applicable, Subel undertakes to select a Processor providing sufficient guarantees regarding the technical and organizational security measures for processing personal data in compliance with the Law and the Regulation.
The use of the Site by Users may result in the communication of personal data. The processing of this data by Subel, in its capacity as Data Controller, or by service providers acting on behalf of Subel, will comply with the Law and the Regulation.
Personal data will be processed by Subel for the purposes mentioned below, via:
In accordance with Article 13 of the Regulation, the purposes of processing personal data are communicated to the User and are as follows:
By visiting and using the Site, the User consents to Subel collecting and processing, in accordance with the terms and principles described in this Privacy Policy, the following personal data:
By accessing and using the Site, the User acknowledges having read and freely, specifically, and unambiguously agreed to the processing of their personal data. This agreement covers the content of this Privacy Policy.
Consent is given through the positive act of checking the box referencing the Privacy Policy via a hyperlink. This consent is essential to perform certain operations on the Site or allow the User to establish a contractual relationship with Subel. Any contract binding Subel and a User regarding services and goods offered on the Site is subject to the User’s acceptance of the Privacy Policy.
The User consents to the Data Controller collecting and processing their personal data provided on the Site or through services offered by Subel for the purposes outlined above.
The User has the right to withdraw their consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent given before withdrawal.
In accordance with Article 13 §2 of the Regulation and the Law, the Data Controller retains personal data only for the time reasonably necessary to fulfill the purposes for which they are processed.
This period ranges from 6 to 12 months.
Personal data may be transmitted to Subel’s employees, collaborators, subcontractors, or suppliers who ensure adequate data security and collaborate with Subel in marketing products or providing services. They act under Subel’s direct authority and are responsible for collecting, processing, or subcontracting these data.
In all cases, recipients of the data and those to whom they have been disclosed comply with this Privacy Policy. Subel ensures that they process the data solely for the specified purposes, discreetly and securely.
If the data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed beforehand to give their explicit consent.
At any time, the User may exercise their rights by sending an email to the following address: info@subel.be or by sending a letter by post, attaching a copy of their identity card, to the following address: Rue de la gare 36, 1040 Etterbeek.
In accordance with Article 15 of the Regulation, Subel guarantees the User’s right to access their personal data. The User has the right to obtain access to their personal data as well as the following information:
If the User submits this request electronically (for example, via email), the information will be provided in an electronic format commonly used unless the User requests otherwise.
A copy of their data will be provided to the User no later than one month after the request is received.
Subel guarantees the User the right to rectify and erase personal data.
In accordance with Article 16 of the Regulation, incorrect, inaccurate, or irrelevant data may be corrected or deleted at any time. The User should first make the necessary modifications through their user account or other relevant means, unless such modifications cannot be made autonomously, in which case a request may be made to Subel.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data have been disclosed of any rectification of the personal data, unless such communication proves impossible or involves disproportionate effort. The Data Controller shall provide the data subject with information about these recipients upon request.
The User has the right to obtain the erasure of their personal data as soon as possible in the cases listed in Article 17 of the Regulation.
Where the Data Controller has made the personal data public and is obliged to erase them under the previous paragraph, the Data Controller, taking into account available technology and implementation costs, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested the erasure of any links to, or copies or replications of, those personal data.
The two preceding paragraphs shall not apply where processing is necessary:
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data have been disclosed of any erasure of personal data or restriction of processing, unless such communication proves impossible or involves disproportionate effort. The Data Controller shall provide the data subject with information about these recipients upon request.
The User has the right to obtain restriction of processing in the cases listed in Article 19 of the Regulation.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data have been disclosed of any restriction of processing, unless such communication proves impossible or involves disproportionate effort. The Data Controller shall provide the data subject with information about these recipients upon request.
In accordance with Article 20 of the Regulation, Users have the right to receive their personal data from Subel in a structured, commonly used, and machine-readable format. Users have the right to transmit these data to another controller without hindrance from Subel in cases provided for by the Regulation.
When the User exercises their right to data portability in accordance with the previous paragraph, they have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
The exercise of the right to data portability shall be without prejudice to the right to erasure. This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
The right to data portability shall not adversely affect the rights and freedoms of others.
The User has the right to object at any time to the processing of their personal data due to their specific situation, including data processing carried out by Subel. In accordance with Article 21 of the Regulation, Subel shall no longer process personal data unless there are compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the User, or for the establishment, exercise, or defense of legal claims.
When personal data are processed for direct marketing purposes, the User has the right to object at any time to the processing of personal data concerning them for such marketing purposes, including profiling to the extent that it is related to such direct marketing.
When the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
The User has the right to lodge a complaint regarding the processing of their personal data by Subel with the Data Protection Authority competent for Belgian territory. More information can be found on the website: https://www.autoriteprotectiondonnees.be.
A complaint can be submitted to the following addresses:
Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Tel. +32 2 274 48 00
Fax. +32 2 274 48 35
Email: contact@apd-gba.be
The User may also lodge a complaint with the court of first instance of their place of residence.
A “Cookie” is a file temporarily or permanently stored on the User’s hard drive when visiting the Site, to facilitate future connections. Thanks to cookies, the server recognizes the User’s device.
Cookies may also be installed by third parties with whom Subel collaborates.
Some cookies used by Subel are necessary for the proper functioning of the Site, while others improve the User’s experience.
The User may customize or disable cookies by adjusting their browser settings.
By using the Site, the User expressly agrees to the management of cookies as described in this article.
Different types of cookies are used by Subel on the Site:
If the User does not want the Site to place cookies on their hard drive, they can manage or delete them by modifying their browser settings. The browser settings also allow the User to receive a notification whenever a website uses cookies, enabling them to decide whether to accept or refuse them.
If the User disables certain cookies, they accept that the Site may not function optimally. Some parts of the Site may become partially or completely unusable.
If the User wishes to manage or delete certain cookies, they can do so via the following links:
For Users using:
Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
Microsoft Edge: http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq
Chrome: https://support.google.com/accounts/answer/61416?hl=en
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Safari: https://support.apple.com/en-us/guide/safari/sfri11471/mac
If the User wishes to disable Google Analytics cookies, they can do so by configuring their browser accordingly at: http://tools.google.com/dlpage/gaoptout.
The Site may contain links to other websites owned by third parties unrelated to Subel. The content of these sites and their compliance with the Law and the Regulation are not the responsibility of Subel.
The holder of parental authority must give express consent for a minor under 16 to disclose information or personal data on the Site. Subel strongly encourages parents and guardians to promote responsible and secure internet use. The Data Controller cannot be held responsible for collecting and processing personal data from minors under 16 whose consent is not effectively covered by their legal guardians, or for inaccurate data (such as age) entered by minors. Under no circumstances will the Data Controller process personal data if the User specifies that they are under 16 years old.
Subel is not responsible for the loss, corruption, or theft of personal data caused, in particular, by the presence of viruses or cyberattacks.
The Data Controller implements organizational and technical measures to ensure an appropriate level of security for data processing and collection. These security measures depend on the implementation costs, the nature, context, and purposes of the personal data processing.
The Data Controller uses standard encryption technologies in the IT sector during the transfer or collection of data on the Site.
Subel reserves the right to modify this Privacy Policy to comply with legal obligations. The User is encouraged to consult the Privacy Policy regularly to be aware of any modifications and adaptations. Such changes will be displayed on the Site or sent via email to ensure enforceability.
This Privacy Policy is exclusively governed by Belgian law. Any dispute shall be brought before the courts of the judicial district where Subel’s registered office is located.
