Privacy Policy

1  General

This notice explains how, as a data controller, Isabel NV/SA (“we”, “us”, “our”), with offices at Keizerinlaan 13-15, 1000 Brussels (phone: +32 2 545 17 11), processes personal data relating to you we collect through the www.isabel.eu and www.seven.isabel.eu websites and/or Isabel 6 and Seven applications.

 

2 Information we collect

When you register your company for the use of Isabel 6 and/or Seven, we collect the following types of personal data:

  1. About you, as legal representative of the company:
    1. Identification data: name, professional email, professional phone number, signed copy of an official identity document (ID card, passport…);
    2. Work information: employer, work address;
  2. About your company’s billing contact:
    1. Identification data: name, professional email, professional phone number, professional fax number;
    2. Work information: job title, employer;
  3. About your company’s users:
    1. Identification data: name, professional email, professional phone number, professional fax number, signed copy of an official identity document (ID card, passport…), PKI card user ID (if used);
    2. Identification data for itsme® registration: National Registration Number, itsme® identifier;
    3. Personal characteristics: gender, date of birth, language;
    4. Work information: job title, employer, work address.

We may collect some of the above information from data.be, when you provide us with your company number; this avoids you from having to complete all the fields manually.

When you use Isabel 6 and/or Seven, we collect the following types of personal data:

  1. Identification data: PKI card user ID or itsme® identifier, identification information of your company’s financial transactions counterparties; and
  2. Data relating to security: history of transactions encoded and/or validated.

When you register to our newsletter, we collect your name, language and email address.

When you contact us through our websites, we collect the following types of personal data about you:

  1. Identification data: your name and title, email address, phone number (optional) and IP address;
  2. Data relating to security: security logs, connection and activity logs, and the user agent of your web browser;
  3. The messages you are sending us.

While you browse our websites, we collect the following types of personal data about you:

  1. Identification data: your IP address;
  2. Data relating to security: security logs, connection and activity logs, and the user agent of your web browser;
  3. When you allow us, we also collect data relating to your use of the websites such as the pages you consulted or if you already visited our websites in the past.

When you register for and attend a webinar, we collect the following types of personal data about you, through Zoom, the platform hosting the webinars:

  1. Identification data: your name, email address and IP address;
  2. Data relating to your company: its name and VAT number;
  3. Data relating to security: security logs, connection and activity logs, and the user agent of your web browser;
  4. The questions you may send during the webinar.

 

3  Cookies

We use cookies on our websites to improve your user experience and, where you consent to it, to know you better.

A cookie is a small text file that is downloaded onto your computer or smartphone when you access a website. It allows the website to recognise that computer or smartphone and store some information about your preferences or past actions.

We use four types of cookies on our websites:

  1. Essential cookies: these cookies are required for the websites to function properly and to provide you with the services you are requesting. You may block and delete these cookies using your web browser parameters, but this may prevent the websites to function properly.
  2. Analytics cookies: these cookies are placed only after we have received your consent. They are used to measure the number of unique visitors of our websites and the number of pages viewed.
  3. Advertising cookies: these cookies are placed only after we have received your consent. They are used to get to know you better and to offer you advertising that suits you better.
  4. Tracking cookies: these cookies are placed only after we have received your consent. They are used to get to know you better and to recognize you when you visit our websites several times.

 

The following cookies may be placed by our websites, depending on your web browser parameters and given consent:

Cookie Name Type Purpose Storage Duration
TS[ID] Essential Session cookie. Session duration
renderid Essential Session cookie. Session duration
LANGUAGE Essential Stores the preferred language of the user. 1 year
PROFILE Essential Stores the preferred profile of the user. 1 year
cookiebar Essential Stores the information related to the consent for the use of non-essential cookies. 15 days
moove_gdpr_popup Essential Stores the information related to the consent for the use of non-essential cookies. 1 year
pll_language Essential Stores the preferred language of the user. 1 year
_dc_gtm_UA-[ID] Analytics Session cookie used for Google Tag Manager. Session duration
_ga Analytics Google analytics anonymous visitor counting. 2 years
_gat_UA-[ID] Analytics Google analytics anonymous visitor counting. 1 day
_gcl_au Advertising This cookie is used by Google AdSense for experimenting with advertisement efficiency across websites using their services. 3 months
_gid Analytics Google analytics anonymous visitor counting. 1 day
_hjid Analytics This cookie is set by hotjar to store a random user ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID. 1 year
_hjIncludedInSample Analytics Determines if the user’s navigation should be registered in a certain statistical placeholder. Session duration
fr Advertising Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. 3 months
_fbp Advertising Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. 3 months
IDE Advertising / Tracking Stores an identifier used by DoubleClick (Google) to track you across visited webpages and to provide you with personalised ads. 2 years

 

You may block and delete cookies by following the instructions provided by your web browser provider:

 

4  Processing purposes

Your personal data is processed for the following purposes:

  1. Where it is necessary for the performance of a contract between you and us or in order to take steps, at your request, to enter into a contract:
    1. To allow users to register for the use of our services;
    2. To provide you with the Isabel 6 and/or Seven services;
    3. To provide you with support when you face issues in your use of the Isabel 6 and/or Seven services;
    4. To provide you with information when you request them and to answer your messages when you contact us;
    5. To ensure the security of our services, including your data;
    6. To bill your use of our services;
    7. To allow you to participate in our webinars.
  2. Where you have given your consent, by subscribing to our newsletter:
    1. To allow us to send you promotional offers and information on our products.
  3. Where necessary for our legitimate interests, as listed below, and where not overridden by your interests or fundamental rights and freedom:
    1. To keep trace of our business relationships with you, as our existing or prospect customer;
    2. To send existing customers information on the evolution of our products; you may request these communications to stop at any time through an unsubscription link present at the bottom of every communications;
    3. To ensure the security of our websites and their databases;
    4. To get non-nominative information on the visitors that consult our websites;
    5. To support you in completing your registration with the Isabel 6 and/or Seven product when your registration was not fully completed.

For these purposes, we have conducted a balancing test, as the law requires, and have determined that, taking into account the limited personal data collected, the processing performed and your reasonable expectations, our legitimate interest in conducting this processing is not overridden by your interests or fundamental rights and freedom.

Where it is necessary for us to comply with our legal obligations.

5  Disclosure and Transfer of personal data

In order to deliver our service to you and for the above purposes, we need to share your personal data with:

  1. Isabel NV/SA personnel with access on a “need to know” basis and to contractors who have signed a confidentiality agreement with us.
  2. Your bank and your financial transactions’ counterparties’ bank.
  3. Third party processors, located in Belgium, who support us in the processing of your personal data only on our instructions and who are subject to appropriate confidentiality clauses:
    1. Zetes, who manufactures our PKI cards.
    2. Flexmail, who allows us to send bulk mailings for newsletters and marketing campaigns.
    3. Zoom, who hosts our webinars.
  4. Government institutions or supervisory authorities in compliance with our reporting obligations.

 

6  Data Security and Retention

Your personal data is and will be kept strictly confidential.

 

We take all reasonable steps to protect your personal data. This includes setting up processes and procedures to minimise the unauthorised access to, or disclosure of your personal data. We ensure that the third parties we share your personal data with also have adequate security measures in place.

 

We will store your personal data for as long as it is necessary to achieve the purposes defined in section 4 (Processing Purposes), with maximum retention periods as defined below:

  1. Data collected when you use the Isabel 6 and/or Seven services will be kept for 10 years after the end of the contract, as required by Belgian law;
  2. Data collected when you contact us with question will be retained until we have answered your questions;
  3. Technical logs will be kept for a maximum of 180 days;
  4. Data backups, created for security reasons, are kept for 4 weeks;
  5. Data collected for statistics purpose are kept for 14 months;
  6. Data collected for marketing purpose will be kept for as long as we have your consent.

 

7  Children

Users of Isabel 6 and/or Seven services must be at least 18 years old.

 

8  Automated decision-making and profiling

No automated decisions will be taken about you nor will profiles be made as part of the processing described in this notice.

 

9  Your rights

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provided us in a structured, machine-readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular when we do not have to process your personal data to meet a contractual or other legal requirement).

 

Where we have asked for your consent, you may withdraw this consent at any time; however, this will not affect processing that have already taken place before the withdrawal. You may withdraw your consent by deleting the cookies linked to our domain.

 

You may exercise the above-mentioned rights by contacting us as described in the “Contact us” section below.

 

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information that we are required to keep by law or that we have a compelling legitimate interest to keep.

 

If you have unresolved concerns, you have the right to complain to the Data Protection Authority: https://www.dataprotectionauthority.be/

 

10  Contact us

If you have any questions about this Privacy Notice or wish to contact us for any reasons in relation to the processing of your personal data, please contact our Data Protection Officer at Isabel NV/SA, by sending an email to privacy@isabelgroup.eu, or by sending a dated and signed request to Isabel NV/SA, Keizerinlaan, 13-15, 1000 Brussels, Belgium.

 

11  Updates to this Privacy Notice

We reserve the right to modify this notice at any time, but will in any case do so in accordance with the applicable laws and regulations. We will inform you by email, when possible, of any substantial changes to this notice.

 

This notice was last modified and revised on the 07/01/2020.