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PRIVACY POLICY

PRIVACY POLICY

Updated January 1, 2019

 

1. Parts and Purpose

 

DENALI Group (hereinafter “Expe Series” or the “Data Controller”)

Chaussée de Bruxelles, 320. 1300 - Wavre.

BCE / VAT: BE 0568483544

Mail: info@denali.be

 

Expe Series establishes this Confidentiality Policy, the purpose of which is to transparently inform Users of the website hosted at the following address: www.air-games.com, (hereinafter the “Site”), of the way in which personal data is collected and processed by Expe Series.

 

The term "User" refers to any user, either any natural or legal person, who visits or interacts in any way with the Site.

 

As such, Expe Series determines all the technical, legal and organizational means and purposes for processing Users' personal data. Expe Series undertakes to take all the necessary measures to ensure that personal data is processed in accordance with the law of 8 December 1992 on the protection of privacy with regard to the processing of personal data (hereinafter -after, "the Law") and the European Regulation of April 26, 2016 on the protection of personal data with regard to the processing of personal data and on the free movement of such data (hereinafter the " Regulation ").

 

Expe Series is free to choose any natural or legal person who processes the personal data of users at his request and on his behalf (hereinafter the “Subcontractor”). Where applicable, Expe Series undertakes to select a Subcontractor offering sufficient guarantees as to the technical and organizational security measures for the processing of personal data, with regard to the Law and the Regulations.

 

2. Processing of personal data

 

Use of the Site by Users may result in the communication of personal data. The processing of this data by Expe Series, in its capacity as Data Controller, or by service providers acting in the name and on behalf of Expe Series, will comply with the Law and the Regulations.

 

Personal data will be processed by Expe Series, in accordance with the purposes mentioned below, via:

 

- the automated NJUKO registration form.

- the automated Sendinblue pre-registration form?

- website cookies

 

3. Purpose of processing personal data

 

In accordance with article 13 of the Regulations, the purposes of the processing of personal data are communicated to the User and are as follows:

 

- Ensure the execution of the services offered and agreed on the site.

- Ensure the control of the execution of the services offered.

- Carry out marketing and promotional information activities after prior consent of the user and until revocation of this consent.

- Answer user questions.

 

4. Personal data that may be processed

 

The User consents, when visiting and using the Site, that Expe Series collects and processes, according to the terms and principles described in this Privacy Policy, the following personal data:

 

- User information that they provide for contractual purposes and to allow the proper performance of reciprocal obligations, namely last name, first name, sex, date of birth, e-mail, postal code.

- With regard to each of the users' visits to the site, the information automatically collected is;

at. IP address, browser type and model, time zone, operating system;

b. all the information concerning the pages that the user has consulted on the site, in particular the url, the browsing time, etc.

 

5. Consent

 

By accessing and using the Site, the User declares to have read and given their free, specific, informed and unequivocal agreement to the processing of personal data concerning them. This agreement covers the content of this Privacy Policy.

 

The consent is given by the positive act by which the User has checked the box proposing the Privacy Policy in hypertext link. This consent is an essential condition for carrying out certain operations on the Site or for allowing the User to enter into a contractual relationship with Expe Series. Any contract between Expe Series and a User relating to the services and goods offered on the Site is subject to acceptance of the Privacy Policy by the User.

 

The User agrees that the Data Controller processes and collects, in accordance with the terms and principles included in this Privacy Policy, his personal data that he communicates on the Site or during the services offered by Expe Series, for the purposes indicated above.

 

The User has the right to withdraw his consent at any time. The withdrawal of consent does not compromise the lawfulness of the processing based on the consent previously given.

 

6. Retention period of Users' personal data

 

In accordance with article 13 §2 of the Regulations and the Law, the Data Controller only keeps personal data for the time reasonably necessary to enable the fulfillment of the purposes for which they are processed.

 

This duration is in all cases less than: 4 years

 

7. Data recipients and disclosure to third parties

 

Personal data may be transmitted to Expe Series agents, employees, subcontractors or suppliers who offer adequate data security guarantees, and who collaborate with the Expe Series in the context of the marketing of products or the provision of services. . They act under the direct authority of Expe Series, and are in particular responsible for collecting, processing or subcontracting this data.

 

In all cases, the recipients of the data and those to whom this data has been disclosed respect the content of this Privacy Policy. Expe Series ensures that they will process this data for the sole purpose provided, in a discreet and secure manner.

 

In the event that the data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed beforehand so that he expresses his consent to the use of this personal data.

 

8. Data Protection Officer (DPO)

 

The following person is appointed Data Protection Officer (hereinafter “DPO”): Customer service

 

The role of the DPO is to ensure the proper implementation of national and supranational provisions regarding the collection and processing of personal data.

 

The DPO can be contacted as follows:

 

info@denali.be

 

9. User rights

 

At any time, the User can exercise his rights by sending a message by e-mail to the following address: info@denali.be, or a letter by post addressed, attaching a copy of his identity card to the following address: Chaussée de Bruxelles, 320. 1300 - Wavre.

 

at. Permission to access

 

In accordance with article 15 of the Regulations, Expe Series guarantees the right of access to the User to his personal data. The User has the right to obtain access to said personal data as well as the following information:

 

the purposes of the processing;

the categories of personal data concerned;

the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular recipients who are established in third countries or international organizations;

where possible, the planned retention period for personal data or, where this is not possible, the criteria used to determine this period;

the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) of the Regulation, and, at least in such cases, useful information regarding the underlying logic, as well as the significance and intended consequences of this processing for the data subject

The Data Controller may require payment of a reasonable fee based on administrative costs for any additional copies requested by the User.

 

When the User submits this request electronically (through the electronic address for example), the information is provided in an electronic form in common use, unless the User requests otherwise. .

 

The copy of his data will be communicated to the User at the latest within one month after receipt of the request.

 

b. Right of rectification

 

Expe Series guarantees the right of rectification and erasure of personal data to the user.

 

In accordance with article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User first makes the necessary modifications himself from his user / other account, unless these cannot be carried out independently, in which case a request can be made to Expe Series.

 

In accordance with Article 19 of the Regulations, the Data Controller notifies each recipient to whom the personal data has been communicated of any rectification of the personal data, unless such communication proves impossible or requires disproportionate efforts. The data controller provides the data subject with information on these recipients if the latter so requests.

 

vs. Right to erasure

 

The User has the right to obtain the erasure of his personal data as soon as possible in the cases listed in article 17 of the Regulations.

 

When the Data Controller has made the personal data public and is required to erase them under the previous paragraph, the Data Controller, taking into account the technologies available and the costs of implementation, takes reasonable measures , including of a technical nature, to inform other controllers who process such personal data that the data subject has requested the erasure by those controllers of any link to such personal data, or of any copy or reproduction thereof.

 

The two preceding paragraphs do not apply insofar as this processing is necessary:

 

to the exercise of the right to freedom of expression and information;

to comply with a legal obligation which requires the processing provided for by Union law or by the law of the Member State to which the controller is subject, or to perform a task of public interest or falling within the exercise of the public authority vested in the controller;

to the establishment, exercise or defense of legal claims.

In accordance with Article 19 of the Regulations, the Data Controller notifies each recipient to whom the personal data has been communicated of any erasure of personal data or any limitation of the processing carried out, unless such communication proves impossible. or requires disproportionate effort. The data controller provides the data subject with information on these recipients if the latter so requests.

 

d. Right to restriction of processing

 

The User has the right to obtain the limitation of the processing of his personal data in the cases listed in article 19 of the Regulations.

 

In accordance with Article 19 of the Regulations, the Data Controller notifies each recipient to whom the personal data has been communicated of any limitation of the processing carried out, unless such communication proves impossible or requires disproportionate efforts. The data controller provides the data subject with information on these recipients if the latter so requests.

 

e. Right to data portability

 

In accordance with article 20 of the Regulations, Users have the right to receive from Expe Series personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transmit this data to another data controller without Expe Series obstructing it in the cases provided for by the Regulations.

 

When the User exercises his right to data portability in application of the previous paragraph, he has the right to obtain that the personal data is transmitted directly from one controller to another, when this is technically possible.

 

The exercise of the right to data portability is understood to be without prejudice to the right to erasure. This right does not apply to processing necessary for the performance of a task of public interest or relating to the exercise of public authority vested in the controller.

 

The right to data portability does not affect the rights and freedoms of third parties.

 

f. Right to object and automated individual decision-making

 

The User has the right at any time to oppose the processing of his personal data due to his particular situation, including the automation of data carried out by Expe Series. In accordance with article 21 of the Regulations, Expe Series will no longer process personal data, unless there are legitimate and compelling reasons for the processing which prevail over the interests and rights and freedoms of the User, or for the establishment, exercise or defense of legal claims.

 

When personal data is processed for prospecting purposes, the User has the right to object at any time to the processing of personal data concerning him for such prospecting purposes, including profiling to the extent where it is linked to such prospecting.

 

When the data subject objects to the processing for prospecting purposes, the personal data are no longer processed for these purposes.

 

g. Right of complaint

 

The User has the right to lodge a complaint concerning the processing of his personal data by Expe Series with the Data Protection Authority, competent for the Belgian territory. Further information can be found on the website: https://www.autoriteprotectiondonnees.be.

 

The lodging of a complaint is made at the following addresses:

 

Data Protection Authority

Rue de la Presse 35, 1000 Brussels

Phone. + 32 2 274 48 00

Fax. + 32 2 274 48 35

E-mail: contact@apd-gba.be

 

The User can also lodge a complaint with the court of first instance of his domicile.

 

10. Cookies

 

The Site uses cookies to distinguish Users of the Site. This allows to provide Users with a better browsing experience and an improvement of the Site and its content. The purposes and methods of cookies are contained in this article.

 

at. General principles

 

A "Cookie" is a file temporarily or permanently placed on the User's hard drive when consulting the Website, with a view to subsequent connection. Thanks to cookies, the server recognizes the User's computer.

 

Cookies can also be installed by third parties with whom Expe Series collaborates.

 

Some of the cookies used by Expe Series are necessary for the proper functioning of the Site, others improve the User experience.

 

The User can personalize or deactivate cookies by configuring his browser.

 

By using the Website, the User expressly agrees with the management of cookies as described in this article.

 

b. Type of cookies and purposes pursued

 

Different types of cookies are used by Expe Series on the Site:

 

Technical cookies: they are necessary for the operation of the Website, allow the communication of the data entered and are intended to facilitate the User's navigation;

Statistical and audience measurement cookies: these cookies allow the recognition of the User and are used to count the number of Users of the Website over a certain period. As long as they also indicate browsing behavior, they are an effective way to improve the User's browsing experience, by showing him proposals and offers that may be of interest to him. They also allow Expe Series to identify possible bugs on the Website and to correct them.

Functional cookies: these cookies facilitate the use of the Website by retaining certain choices made (for example, username or language);

Tracking cookies: Expe Series uses tracking cookies via Google Analytics, to measure the interaction of Users with the content of the Site and to produce anonymous statistics. These statistics allow Expe Series to improve the Website. Google supports the explanation of these cookies at the following address: http://www.google.nl/intl/en_uk/policies/privacy/

vs. Cookie retention period

 

Cookies are kept for the time necessary to fulfill the purpose pursued. The cookies likely to be stored on the User's hard drive as well as their retention period are as follows:

 

13 months.

 

d. Managing cookies

 

If the User does not want the Website to place cookies on his hard drive, it is easy for him to manage or delete them by modifying the settings of his browser. The programming of the browser also allows the User to receive a notice or a notification as soon as a Website uses cookies and thus decide to accept this, or to refuse it.

 

If the User disables certain cookies, he accepts that the Website may not function optimally. Certain parts of the Website may therefore not be usable, or may be partially.

 

If the User thus wishes to manage and / or delete certain cookies, he can do so by using the following link (s):

 

For Users with a browser:

 

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=fr

Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences

Safari: https://support.apple.com/kb/ph21411?locale=fr_CA

If the User refuses to allow Google Analytics cookies to be used, he is invited to configure his browser accordingly, on the following website: http://tools.google.com/dlpage/gaoptout.

 

11. Limitation of liability of the Data Controller

 

The website may contain links to other websites owned by third parties unrelated to Expe Series. The content of these sites and their compliance with the law and regulations are not the responsibility of Expe Series.

 

The holder of parental authority must give his express consent so that a minor under 16 can disclose personal information or data on the website. Expe Series strongly advises people exercising parental authority over minors to promote responsible and secure use of the Internet. The Data Controller cannot be held responsible for having collected and processed information and personal data from minors under the age of 16 whose consent is not effectively covered by that of their legal parents or for incorrect data - especially concerning the 'age- introduced by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he is under 16 years of age.

 

Expe Series is not responsible for the loss, corruption or theft of personal data caused in particular by the presence of viruses or following computer attacks.

 

12. Security

 

The Data Controller implements organizational and technical measures to guarantee an appropriate level of security for the processing and collection of data. These security measures depend on the costs of implementation with regard to the nature, context and purposes of the processing of personal data. The Data Controller uses standard encryption technologies within the IT sector when transferring or collecting data on the Site.

 

13. Modification of the privacy policy

 

Expe Series reserves the right to modify this Privacy Policy in order to comply with legal obligations in this area. The user is therefore invited to regularly consult the Confidentiality Policy in order to be aware of the modifications and adaptations. Any such modification will be posted on the Site or sent by email for opposability purposes.

 
14. Android and Ios application

The Expe Series application collects your geolocation places in order to validate your shipment.
This data is also displayed on your personal tracking page. You are responsible for whether or not they are shared.
Geolocation is active when you start the expedition, and works in the background on your phone even if the app is no longer active.
This geolocation stops when you decide so in the application or when your expedition is finished or when you cut your geolocation data.

Your location can also be displayed publicly, anonymously when you are on the route and your expedition is in progress.

Your data is not sold or shared with third parties.

15. Applicable law and competent jurisdiction

 

This Privacy Policy is exclusively governed by Belgian law. Any dispute will be brought before the courts of the judicial district of the head office of Expe Series.

 

16. Contact

 

For any question or complaint relating to this Privacy Policy, the User can contact the Data Controller via the following address: info@denali.be