Privacy and cookie notice
Website

First of all, you always remain in control of your data.

This Notice applies to anyone whose Personal Data we may collect, use, share, or otherwise process, and in particular to:

• Visitors and users of the Website (http://intelacy.be).
• (Representatives of) business partners who collaborate with APB (“Intelacy” is a brand name used by APB to provide services via intelacy.be) as part of APB’s business activities.
• (Representatives of) suppliers of goods or services, IT providers, consultants, lawyers, accountants, and other third parties in contact with APB.

• When you contact us or enter into a contract with us as a (potential) business partner or supplier, we may collect and process your contact details (such as your employer’s or company’s name, email address, or telephone number), financial data (such as bank account numbers and transaction details), and contractual data (such as the date and type of our agreement).
• If you contact us through any medium, we will collect information relating to your communication with APB, including both the content of your communications and related technical metadata.
• We also use cookies to collect information about your use of our Website.

• To respond to your requests.
• To manage newsletter subscriptions and send newsletters.
• To establish and/or maintain our contractual relationship.
• To provide you with the information you request and carry out our business activities.
• Finally, to make our Website available and improve it.

• Only those APB team members who require access in order to perform their duties may access your data.
• We also rely on a number of suppliers and service providers, such as—but not limited to—IT service providers, digital solution providers, and web hosting services. These parties are legally required to safeguard your privacy at all times and will only process your Personal Data in accordance with our purposes.
• Finally, third parties may be engaged to process your Personal Data. They may only do so for the purposes described above, on our behalf, and after signing a data processing agreement.

• You may request that we modify or delete your Personal Data at any time. To do so, please send an email to gdpr@apb.be and follow the procedure described in our full Privacy Notice.
• You may also request a copy of all information we have collected about you at any time by sending an email to the same address.

• We have implemented the necessary technical and organisational security measures.
• Your data is stored on highly secure servers within the European Union.
• To improve our services, APB may use the data you provide. However, APB will always process this data in a GDPRcompliant manner, using stateoftheart software and solutions.
• We have implemented internal procedures to ensure the confidentiality of our IT infrastructure and to ensure its responsible management.

If you would like to know more, we invite you to read our full Privacy Notice below, where everything is explained in more detail.

1.1 APB (hereinafter “we”, “us”, “our” or “APB”), with its registered office at Archimedesstraat 11, 1000 Brussels, and registered with the Crossroads Bank for Enterprises under enterprise number 0406.753.266, is the Data Controller responsible for processing your Personal Data, including in the context of using the website (https://intelacy.be) (hereinafter the “Website”).

1.2 In this Privacy Notice, “Personal Data” means any information relating to an identified or identifiable natural person. We may collect, use, share or otherwise process Personal Data relating to the following categories of individuals:

• Visitors and users of the Website (hereinafter “Visitors”).
• (Representatives of) business partners who work with APB in the context of its business activities (hereinafter “Business Partners”).
• (Representatives of) suppliers of goods or services, including IT suppliers, consultants, lawyers, accountants, and other third parties working with APB (hereinafter “Suppliers”).
• All other individuals whose Personal Data may be processed by APB (hereinafter “Other Individuals”).

1.3 The collection and processing of Personal Data are subject to strict conditions imposed by law. We act in accordance with:

• Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, on the free movement of such data and repealing Directive 95/46/EC (hereinafter “GDPR”); and/or
• All (future) applicable Belgian laws relating to the implementation of the GDPR or the processing of Personal Data.

1.4 By visiting or using our Website (https://intelacy.be), you acknowledge that you fully and unreservedly understand this Privacy Notice. This means that you are fully informed of how we collect, use and process your Personal Data, in accordance with the provisions of this Privacy Notice and for the purposes described herein.

1.5 This Privacy Notice applies only to the pages hosted on our Website and to the business activities carried out by APB. It does not apply to third-party pages and websites to which we may refer or include links, and whose privacy policies may differ. APB is therefore not responsible for the data on or processed by such third-party websites.

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For the purposes described in Article 3, APB may process the following categories of your Personal Data:

Categories

• Category 1: (professional) identification and contact details
  
  • Relevant data subjects:
    
    • Website Visitors
    • (Potential) Business Partners
  • Details
    
    • First name, last name, telephone number, email address, address and country
  • Context
    
    • By contacting us via telephone, email, or any other communication channel
• Categorie 2: contractual data (insofar as it constitutes Personal Data)
  
  • Relevant data subjects:
    
    • (Potential) Suppliers
  • Details
    
    • Data relating to agreements you have concluded or are considering concluding with APB
  • Context
    
    • When concluding, or considering the conclusion of, an agreement with us
• Categorie 3: informatie over uw bezoek aan en gebruik van onze Website
  
  • Relevant data subjects:
    
    • Website Visitors
  • Details
    
    • See Article 9 – Cookies
  • Context
    
    • Through the placement of cookies (see Article 9 – Cookies)

We only process your Personal Data if we have a specific purpose and a legal basis to do so. Moreover, we only process what is relevant for achieving each specific purpose.

3.1 General purposes

Categories

• Category 1: (professional) identification and contact details
  
  • Legal basis:
    
    • Necessary for the performance of a contract (Art. 6(1)(b) GDPR); or
    • Our legitimate interests (Art. 6(1)(f) GDPR); or
    • Your consent (Art. 6(1)(a) GDPR); or
    • Legal obligation (Art. 6(1)(c) GDPR)
  • Purpose
    
    • We may process your (professional) identification and contact details as described in Category 1 to provide our services, conduct our business activities, manage any contractual relationship we may have with you, respond to your queries, and provide you with information.
    • We will primarily process this data on the basis of Article 6(1)(b) GDPR. Where processing cannot be considered necessary for the performance or conclusion of a contract, we rely on our legitimate interests following a balancing test. If reliance on legitimate interests is not possible, we will request your consent.
• Category 2: contractual data
  
  • Legal basis:
    
    • Necessary for the performance of a contract (Art. 6(1)(b) GDPR)
  • Purpose
    
    • We may process your contractual data to manage the commercial and contractual relationship we (will) have with you (e.g. for payment and invoicing purposes).
• Category 3: website usage information
  
  • Legal basis:
    
    • Your consent (Art. 6(1)(a) GDPR); and/or
    • Our legitimate interests (Art. 6(1)(f) GDPR)
  • Purpose
    
    • We may process information about your visit to and use of our Website in order to:
      
      • facilitate access to and use of the Website;
      • analyse, adapt and improve its content; and
      • personalise your user experience.
      • etc.
    • We will primarily process this data on the basis of Article 6(1)(b) GDPR. Where processing cannot be considered necessary for the performance or conclusion of a contract, we rely on our legitimate interests following a balancing test. If reliance on legitimate interests is not possible, we will request your consent.
    • Further details are provided in Article 9 – Cookies.

3.2 Direct marketing

If we obtained your electronic contact details in the context of our services, we may use them to send you promotional emails about similar services, based on our legitimate interest.

Promotional material relating to non-similar services will only be sent if you have given your prior consent.

We may also share certain Personal Data with our processors for direct marketing purposes related to our services.

You may unsubscribe at any time, free of charge and without justification, by clicking the unsubscribe link in each email or by emailing gdpr@apb.be.

3.3 Disclosure to third parties

We treat your Personal Data as confidential and will not disclose it to third parties other than as set out in this Privacy Notice or where required by law.  

We may share Personal Data with service providers (e.g., IT support, hosting, cybersecurity and other specialised providers). Such third parties may not disclose your Personal Data to others, except where disclosure to their own vendors or subprocessors is necessary to perform the services, or where legally required.

We will not sell or rent your Personal Data to third parties, except as described in this Privacy Notice or where you have given your prior explicit consent.

In the event of a full or partial reorganisation, a transfer of APB’s activities or bankruptcy, your Personal Data may be transferred to new entities or third parties. Where reasonably possible, you will be informed in advance.

Where Personal Data is transferred outside the EEA to a country that does not ensure an adequate level of protection, appropriate safeguards will be implemented to ensure that your rights are respected by the recipient.

3.4 Legal requirements

In exceptional circumstances, we may be legally obliged to disclose Personal Data pursuant to a court order or mandatory legal obligation. Where reasonably possible, we will inform you in advance, unless such notification is legally restricted.

We retain your Personal Data for as long as necessary to fulfil the purposes described in Article 3, including for the duration of any contractual relationship with APB.

We may also retain your Personal Data to comply with applicable legislation or legal obligations, including postcontractual retention requirements. Therefore, the retention periods listed below do not apply where the law requires us to delete certain Personal Data more quickly or retain it for a longer period — for example, in connection with statutory limitation periods relating to invoicing, payments, accounting, taxation and regulatory compliance.

Retention periods

Data

• Category 1: identification and contact details
  
  • Retained only as long as necessary to communicate with you, and never longer than two (2) years after the first request or initial contact.
  • Where a contractual relationship exists, we will retain such data only as long as necessary for the purposes described in this Privacy Notice, up to a maximum of seven (7) years after the end of the contractual relationship.
    
• Category 2: contractual data
  
  • Retained for the duration of the contractual relationship and for seven (7) years thereafter.
    
• Category 3: website usage information
  
  • See Article 9 – Cookies
    

You are not legally or contractually obliged to provide your Personal Data. You retain the right at all times to refuse its processing. Please note, however, that certain functionalities of the Website may be affected or unavailable as a result.

5.1 Right of access and right to obtain a copy

You have the right to request access to your Personal Data at any time and to be informed of the purposes for which it is processed.

5.2 Right to rectification, erasure and restriction

You have the right to request the rectification of your Personal Data if you believe it is inaccurate.

You may also request restriction of processing if you believe your data is inaccurate and you have informed us.

You further have the right to request the erasure of your Personal Data, insofar as anonymisation is not possible.

5.3 Right to object

You have the right to object to the processing of your Personal Data where you have serious and legitimate grounds for doing so.

You also have the right to object to the use of your Personal Data for direct marketing purposes, without the need to provide any justification.

5.4 Right to data portability

You have the right to obtain your Personal Data in a structured, commonly used format and/or to have such data transferred to another data controller.

5.5 Right to withdraw consent

Where the processing of your Personal Data is based on your prior (explicit) consent, you may withdraw that consent at any time.

5.6 Automated decision-making and profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects or otherwise significantly affects you.

5.7 Exercising your rights

You may exercise your rights by contacting us and enclosing a copy of the essential elements of your identity document, such as your name and date of birth:

• By email: gdpr@apb.be
• By postal mail: Archimedesstraat 11, 1000 Brussels, Belgium

5.8 Right to lodge a complaint

You may lodge a complaint with APB’s supervisory data protection authority:

Data Protection Authority (APD – GBA)

• Address: Drukpersstraat 35, 1000 Brussels, Belgium
• Tel: +32 (0)2 274 48 00
• Fax: +32 (0)2 274 48 35
• Email: contact@apd-gba.be

This is without prejudice to proceedings before the civil courts.

If you reside in another EU Member State, you may lodge a complaint with your national supervisory authority (a list of supervisory authorities for each EU Member State can be found here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en).

If you have suffered damage resulting from the processing of your Personal Data, you may file a claim for compensation.

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We have implemented appropriate technical, organisational and physical security measures to prevent the destruction, loss, alteration, unauthorised access to or accidental disclosure of your Personal Data to third parties, as well as any unauthorised processing of such data.

Should any of these events nevertheless occur and affect your Personal Data, we will notify you without undue delay of the data breach, including a brief description of the potential consequences and recommendations for measures to mitigate any possible adverse effects.

We shall not be liable in any way for direct or indirect damage caused by the unlawful or improper use of Personal Data by a third party.

We reserve the right to amend or update this Privacy Notice at any time in order to reflect changes in our Personal Data processing practices or changes in applicable legislation. In such cases, we will inform you and invite you to review the updated version.

This Privacy Notice shall be governed, interpreted and enforced in accordance with Belgian law, which shall apply exclusively to any dispute.

The courts of Brussels shall have exclusive jurisdiction to settle any disputes arising from or relating to the interpretation or implementation of this Privacy Notice.

9.1 Wat zijn cookies en waarom gebruiken we ze?

A “cookie” is a small file placed on the hard drive of your computer by APB’s server. The information stored in these cookies can only be read by APB and only for the duration of your visit to the Website.

Our Website uses cookies and similar technologies to distinguish your usage preferences from those of other users. The cookies we use are safe and help us provide you with a better user experience when visiting our Website.

9.2 Types of cookies

There are many different types of cookies, which can be distinguished based on their functionality, origin or storage period. Below, we provide a general description of the types of cookies that are relevant in the context of a website. Article 9.3 contains a detailed overview of the specific cookies used on our Website.

Type

• Essential / strictly necessary cookies
  
  • Function: these cookies are necessary for the functioning of a website and cannot be disabled. They are usually set in response to actions taken by you, such as setting privacy preferences, logging in or filling in forms. They ensure proper communication and facilitate navigation (e.g. returning to a previous page).

• Functional cookies
  
  • Function: these cookies enhance usability by remembering your preferences (e.g., language choice) and offering personalisation and advanced features. Refusing these cookies may affect performance, limit certain features, and restrict access to some Website content. Functional cookies may be set by the Website publisher or by thirdparty providers whose services are integrated into the Website.

9.3 Overview of cookies

• Performance / analytical cookies
  
  • Function: these cookies collect information about website usage, such as the number of visitors, time spent on pages, and error messages. They help improve website performance and do not identify you personally.

• Targeting / advertising cookies
  
  • Function: these cookies are used to deliver content that is more relevant to you, measure advertising effectiveness, and limit ad repetition. They may track visits across websites and share information with advertising partners.

• First-party & third-party cookies
  
  • Function: first‑party cookies are set by the servers or domains of the Website publisher from which the service is provided. Third‑party cookies are set by servers or domains not managed by the Website publisher but by partner organisations. Only those third parties have access to the cookies and information they collect. For more information, please consult the cookie policies of those third parties on their respective websites. Please note that we have no control over the content of those policies or over third‑party cookies.

Domain: https://intelacy.be

Cookie name

• _ga_SBEC8D1B7
  
  • Type: Analytical
  • Description: used by Google Analytics to maintain session state
  • Bewaarperiode: 1 year and 1 month

• x-ms-cpim-csrf
  
  • Type: Essential
  • Description: prevents Cross-Site Request Forgery (CSRF) attacks
  • Bewaarperiode: session

• x-ms-cpim-trans
  
  • Type: Functional
  • Description: Azure AD B2C authentication transaction storage
  • Bewaarperiode: session

• culture
  
  • Type: Functional
  • Description: stores language and country preferences
  • Bewaarperiode: 4 weeks and 2 days

• culture
  
  • Type: Functional
  • Description: stores language and country preferences
  • Bewaarperiode: 1 year and 1 month

• _ga
  
  • Type: Analytical
  • Description: distinguishes users via a randomly generated client ID
  • Bewaarperiode: 1 year and 1 month

9.4 Your consent

Upon your first visit to our Website, you will be asked whether you accept non-essential cookies. You may change your cookie preferences at any time via the hyperlink at the bottom of the Website and withdraw your consent.

You may refuse or block cookies via your browser settings. Disabling cookies may affect Website functionality.

Browser support links:

• Google Chrome: https://support.google.com/chrome/answer/95647
• Safari: https://support.apple.com/kb/PH19214
• Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d  
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox  

Some browsers offer a “Do Not Track” (DNT) option. Third-party cookie providers may or may not respond to such signals.

More information about cookies:

http://www.allaboutcookies.org/

More information about online behavioural advertising and privacy:

http://www.youronlinechoices.eu/