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Privacy Policy

1. Introduction

This version of this privacy policy is effective from May 25, 2018. On this date, the General Data Protection Regulation (“GDPR”) comes into effect, which protects natural persons in connection with the processing of personal data and regarding the free movement of such data. This GDPR also replaces the Belgian Law of December 8, 1992.

On the one hand, the GDPR defines a number of rights for natural persons whose personal data is processed, but on the other hand, it also imposes specific obligations on organizations and companies that process such personal data.

This Privacy Policy describes how and when we collect, use, and share your personal data and information when you use our website, available at https://www.pionira.be/en/ and any subsite or application managed by or on our behalf (hereinafter referred to as the “service(s)” or “Website(s)”).

2. General

By visiting our Website or using our services, by completing and submitting a contact form and/or contacting one of our employees, in any manner whatsoever, you acknowledge and agree that your personal data will be processed as described in this Privacy Policy.

Nevertheless, you may object to certain processing activities at any time in specific cases; please refer to §9 below for this. Also, do not hesitate to contact us if you have further questions and/or comments regarding this Privacy Policy; please refer to §11 below for this.

3. Nature of the personal data we process

In the context of our services, we have reduced the processing of personal data to a strict minimum. The personal data processed by us specifically includes:

  • your first name and last name;
  • your phone number;
  • your address;
  • your email address, to the extent that it contains personal data.

We may also process data related to your personal interests, as provided by you during the registration process or otherwise.

We also collect and process data gathered through your use of our Website (browsing). This data may include the date and time of your visit (timestamp), the type of browser you use, your IP address, and the pages visited.

In this regard, we may also collect non-personal data, such as browser type or IP address, the operating system you use, or the domain name of the website through which you visited our Website. This data is used by us exclusively to gain further insights into how our users utilize the respective website(s), in order to improve functionalities and user experience. For this, please refer in particular to the provisions regarding the placement and use of cookies in §10 below.

4. Objectives of personal data processing

Our processing of this personal data has several objectives:

  • if you give us explicit consent for this: to send you newsletters or other messages that may contain commercial offers (by email or to your physical address);
  • when you enter into an agreement with us: to identify you in accordance with the applicable legal provisions (name, first name, physical address, email, etc.);
  • where applicable, to authenticate you as a client / user of our Website;
  • if you also provide your email address, we use this personal data to transmit information that is primarily necessary for the execution of our agreement(s) with you: sending notifications, confirmations, possibly invoices and reminders, etc.

Certain data that may qualify as personal data, such as customer number, invoice number, etc., may be generated by us. This data is processed by us solely within the framework of the execution of the agreement(s) you have concluded with us.

However, this transfer and provision is limited to processing that is strictly necessary in the context of our services, including administrative management, providing information to and by customer service, etc.

5. Transfer of your personal data to third parties

In the context of certain of our services, we use one or more external service providers, specifically for hosting and managing our website and any specific functionalities associated with it (e.g., sending newsletters, announcements, making reservations, etc.). The processing of personal data by these third parties is limited to purely technical support.

Apart from such processors, your personal data is only used by our internal employees who are authorized to do so.

However, we may disclose your personal data to third parties in response to a request for information if we believe that the disclosure is in accordance with applicable laws, regulations, or legal procedures, or as otherwise required by applicable laws, rules, regulations, or contractual provisions, or if we believe that your actions are not in accordance with the spirit or language of our user agreements or policies, or to protect the rights, property, and safety of ourselves or others.

Where applicable, when the provision of the relevant service requires it, or to support technical, administrative, and/or financial processing, your personal data may be transferred to and processed by one or more third parties. We have concluded a separate agreement with these companies, in which the processing of personal data is explicitly regulated, and the possible exercise of data subjects’ rights has been included.

Furthermore, in accordance with the relevant legal provisions, your personal data may be transferred to government authorities.

6. No transfer of personal data to third parties for promotional purposes

Unless we have obtained your explicit and prior consent, we do not transfer your personal data to third parties for promotional purposes or commercial use by the latter.

7. Technical security measures

We have implemented appropriate technical and operational measures to ensure that your personal data is protected against unauthorized access, deletion, or alteration.

We take reasonable measures to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, as stated in our General Terms and Conditions, you expressly acknowledge and accept that – in general – the transmission of information via the internet is never completely secure, private, or confidential. Therefore, all information sent or received from the Website or by using one of the services provided by us may be intercepted, decrypted, accessed, and/or used by third parties, even if technology is used where such information exchanges are encrypted.

In any case, we will continue to make the necessary efforts to ensure that your personal data is protected in accordance with applicable legislation and best practices.

8. Code of Conduct for Employees

Certain of our employees have access to your personal data mentioned above, in connection with which they are bound by a strict code of conduct. This code of conduct includes, among other things:

  • the commitment to confidentiality of personal data to which they have access in the context of their assignment;
  • the commitment to process personal data solely in the performance of their duties;
  • respecting the relevant legal provisions.

9. Right to rectification, objection, erasure, and restriction of processing

We offer you the possibility to exercise your right to rectification, objection, erasure, and/or restriction of processing of personal data for various services we offer.

Right to Rectification

If you are a client or a registered user of the services provided by us, you can adjust, update, or modify your personal information that you have provided to us in connection with your account and user profile, if and when applicable. Please send us a written request for this, as specified below.

Automatic Data Erasure

Unless otherwise agreed, all personal information collected via the Website or the services provided by us will be automatically deleted after a period of ten years following the termination of the agreement between you and us. Consequently, your data will be retained for the legally prescribed limitation period.

Exercise of Rights The exercise of these rights can be done as follows:

  • in writing: by sending a registered letter to , stating the rights you wish to exercise, and including a copy of your identity card (front and back);
  • electronically: by sending a registered letter to , stating the rights you wish to exercise, and including a scan of your identity card (front and back).

Please note that the exercise of one or more of the above rights:

  • for one specific service does not necessarily affect your data processed in the context of another service provided by us (e.g., if you have different logins or customer numbers). If you wish to implement this change or correction for one or more of our other services as well, you will need to repeat this request one or more times, as applicable;
  • may in certain cases be wholly or partially refused or restricted, which refusal we will justify in our response, where applicable with reference to the Frequently Asked Questions. These reasons may include, by way of example: the fact that we must retain certain data for a legally defined retention period, if the processing of personal data is essential in the context of the execution of the agreement, …);
  • may in certain cases result in the complete or partial suspension or termination of the contractual relationship concerning the provision of such service.

10. Cookies

We may use information about you to personalize and improve our services and to offer content or features that match user profiles or interests and to monitor and analyze trends, usage, and activities in connection with our services. In doing so, we use various technologies to collect information, which includes sending cookies to your computer or device.

Cookies are small data files stored in the device’s memory that allow us to improve our services and your user experience, see which pages are popular, and record the number of visits to our Website.

We use both functional cookies and analytical cookies.

Functional cookies are essential for the use of our websites, store user preferences, among other things, and are not shared with third parties. Analytical cookies help us improve our site by providing us with information on how users interact with our websites, such as the number of visitors to the website, the pages they visit, and the time they spend on the website. These cookies do not collect information that identifies a visitor.

All information collected by these cookies is aggregated and therefore anonymous.

Most internet browsers allow you to delete cookies from your hard drive, reject cookies, or receive a warning before a cookie is installed. Consult the instructions or help function of your internet browser for more details, or visit www.allaboutcookies.org.

Please note that if you choose to block, delete, or reject cookies, this may negatively impact the availability and functionality of the Website and the services provided by us.

11. Questions and Complaints; Exercise of Data Subject Rights

If you have any further questions about how we use personal data, if you wish to view, correct, update, or delete your personal data, or if you wish to file a complaint, please contact us via the following email address: .

Regarding the exercise of your rights: to prevent us from making your personal data available, modifying it, restricting its processing, or erasing it as a result of a request from a third party (and thus not yourself), we ask you to submit a copy of your identity card (front and back) along with the request – which must be in writing, dated, and signed – to the following email address or by letter, addressed to the address mentioned at the top.

Where applicable, you may file a complaint with the Belgian Data Protection Authority, Drukpersstraat 35, 1000 Brussels.

12. Changes to this Privacy Policy

We reserve the right to revise this Privacy Policy from time to time.

In addition to such changes being announced on our Website(s), we may, in certain cases, send you an additional notification, and/or display a separate message on the Website or within the user area. In any case, we encourage you to review the most current version of this Privacy Policy when you visit our Website, so that you remain informed about our processing activities and the ways in which we protect your privacy and personal data.