We understand that your trust in us is 4INCH NV's most important asset (hereinafter referred to as "4INCH", "we" or "us"). As such, your privacy is essential for us. This privacy declaration (hereinafter referred to as "Privacy Declaration") is applicable, inter alia, to (i) our websites www.4inch.be, www.snugr.be or any of their subdomains (hereinafter referred to as the "Website"), (ii) visiting our offices and (iii) all (commercial) relations between 4INCH and its customers, prospects and business partners.
This Privacy Declaration includes information about the personal data collected by 4INCH, as well as the manner in which 4INCH uses and processes this personal data.
4INCH wishes to emphasize that it always attempts to act in accordance with (i) the Belgian Privacy Law of 8 December 1992 on privacy protection in relation to the processing of personal data (i.e. as long as still in force), (ii) the EU Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC and/or (iii) all (future) Belgian laws regarding the implementation of this Regulation.
Visiting the Website, creating a demo account for the purpose of using the 4INCH demo, creating an account in order to use the 4INCH services, subscribing for the newsletter and/or a seminar, webinar or event implies your express approval (through disclosure of your personal information or opt-in) of the Privacy Declaration and consequently how we collect, use and process your personal data.
Types of personal data
4INCH can collect and process the following personal data:
- First name
- Residence or Company address
- Invoicing address
- Email address
- Telephone number (landline/mobile phone)
- User name
- Company name
- Information concerning your use of the Website, the 4INCH platform, Snugr, (hereinafter referred to as the "Platform") (including, but not limited to IP address, browser type, operating system)
- The log-in details of your mobile device, as well as geographical location data (where appropriate)
- Communication preference
- All personal data freely provided to 4INCH (e.g. in light of correspondence with 4INCH).
4INCH also automatically collects anonymous information regarding your use of the Website and 4INCH services or via the Platform. As such, 4INCH shall, for example, automatically log which sections of the Website, Platform and/or App you visit, which web browser you use and which website you visited when you obtained access to the Website. We cannot identify you through these data, but it allows 4INCH to draw up statistics regarding the use of the Website, or the Platform.
Methods of personal data collection
These personal data are collected in the context of:
- Requesting a quote
- Creating a (demo) account
- Collaboration with 4INCH
- Visiting the Website
- Visiting the offices of 4INCH
- Your use of 4INCH services, whether or not via the Website, or the Platform, and whether or not using a mobile device
- Subscribing to the newsletter and/or the blog (via the Website or not)
- Subscribing for a webinar, seminar and/or event
- The verification of your identity (e.g. when you contact customer support)
- Incoming and outgoing correspondence with 4INCH
- Communicating ideas to 4INCH with regards to improving the services, or the Platform
- The exchange of business cards
- A connection made between the Platform and social network platforms
The personal data collected by 4INCH are therefore expressly and voluntarily provided by you.
Use of personal data
4INCH can use your personal data for the following purposes:
- Registration of visitors when visiting the 4INCH offices
- Creating a (demo) account and confirmation thereof
- Performance of the agreement with 4INCH (incl. follow-up thereof)
- Providing 4INCH services, whether or not via the Website, or the Platform, and whether or not using a mobile device
- Providing support/assistance (e.g. in case of problems)
- Send targeted marketing and advertising, updates and promotional offers based on your communication preferences and – where applicable – upon explicit consent Issuing invoices and collecting payment
- Sending newsletters and/or blog
- Sending a confirmation upon subscription for a webinar, seminar, event
- Optimising the quality, management and content of the Website, or the Platform
- Creating statistics
- Drawing up a quote
- Conducting customer satisfaction studies, surveys and other market research
- Security of 4INCH offices
Processing takes place on the following legal grounds, as the case may be:
- You have given consent to the processing of your personal data for one or more specific purposes
- Processing is necessary for the performance of the agreement with 4INCH or in order to take steps at your request prior to entering into an agreement
- Processing is necessary for compliance with a legal obligation to which 4INCH is subject
- Processing is necessary in order to protect your vital interests or of another natural person
- Processing is necessary for the performance of a task carried out in the public interest
- Processing is necessary for the purposes of the legitimate interests pursued by 4INCH or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data (in particular when you are a child).
Disclosure of personal data to third parties
4INCH shall not disclose your personal data to third parties, unless it is necessary in the context of providing 4INCH services and optimising them (including but not limited to maintenance works, payment processing, the delivery of services to 4INCH (e.g. subcontracting) and database management). In this respect, your personal data may be disclosed to payment providers, software providers, cloud partner, datacentre, external IT-consultants and service providers.
If it is necessary that 4INCH discloses your personal data to third parties in this context, the third party is required to use your personal data in accordance with the provisions of this Privacy Declaration.
Notwithstanding the foregoing, it is however possible that 4INCH discloses your personal data:
- To the competent authorities (i) if 4INCH is obliged to do so under the law or under legal or future legal proceedings and (ii) to safeguard and defend our rights;
- If 4INCH, or the majority of its assets, are taken over by a third party, in which case your personal data – which 4INCH has collected – shall be one of the transferred assets;
- For the purpose of identifying similar profiles to your own, except if you have expressly opted out in this respect.
In all other cases, 4INCH will not sell, hire out or pass on your personal data to third parties, except when it (i) has obtained your permission to this end and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your personal data.
Storage of personal data
Unless a longer storage period is required or justified (i) by the law or (ii) through compliance with another legal obligation, 4INCH shall only store your personal data for the period necessary to achieve and fulfil the purpose in question, as specified in the Privacy Declaration under 'Use of personal data'.
Your privacy rights
In light of the processing of your personal data, you enjoy the following privacy rights:
- Right of access to personal data which 4INCH possibly has concerning you;
- Right to rectification, completion or update of your personal data;
- Right to delete your personal data ('right to be forgotten') (4INCH wishes to point out that in this context certain services will no longer be accessible and/or can no longer be provided if you delete resp. request deletion of certain required personal data);
- Right to limit the processing of your personal data;
- Right to transferability of your personal data;
- Right to object to/oppose the processing of your personal data;
If you wish to invoke your privacy rights, as defined below, please contact 4INCH.
In principle, you can exercise these rights free of charge. In addition, you can always, via your personal account, update, modify and/or verify your personal data which you were required to submit when creating your (demo) account.
If you no longer wish to receive newsletters or information about our services, you can unsubscribe at any time by clicking the "unsubscribe" button underneath each of 4INCH's emails.
Security of personal data
4INCH undertakes to take reasonable, physical, technological and organisational precautions in order to avoid (i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data.
4INCH shall store all personal data which it has collected in the cloud (with data centre(s) within the EU). Notwithstanding 4INCH's security policy, the checks it carries out and the actions it proposes in this context, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the internet, or any method of electronic storage is 100% secure, 4INCH is, in this context, not in a position to guarantee absolute security.
Finally, the security of your (demo) account will also partly depend on the confidentiality of your password in obtaining access to or the Platform. 4INCH will never ask for your password, meaning that you will never be required to communicate it personally. If you have nonetheless communicated your password to a third party – for example because this third party has indicated that it wishes to offer additional services - this third party shall have access to your (demo) account and your personal data via your password. In such cases, you are liable for the transactions which occur as a result of the use made of your (demo) account. 4INCH therefore strongly advises you, if you observe that someone has accessed your (demo) account, to immediately change your password and contact us.
Cross-border processing of personal data
Any transfer of personal data outside the European Economic Area (EEA) to a recipient whose domicile or registered office is in a country which does not fall under the adequacy decision enacted by the European Commission, shall be governed by the provisions of a data transfer agreement, which shall contain (i) the standard contractual clauses, as referred to in the 'European Commission decision of 5 February 2010 (Decision 2010/87/EC)', or (ii) any other mechanism pursuant to privacy legislation, or any other regulations pertaining to the processing of personal data.
Update Privacy Declaration
4INCH is entitled to update this Privacy Declaration by posting a new version on the Website. As such, it is strongly recommended to regularly consult the Website and the page explaining the Privacy Declaration, to make sure that you are aware of any changes.
The Website may potentially contain hyperlinks to other websites. When you click on one of these links, you may be redirected to another website or internet source that could collect information about you through cookies or other technologies. 4INCH does not bear any responsibility, liability or control authority over these other websites or internet resources, nor about their collection, use and disclosure of your personal data. You must check the privacy declarations of these other websites and internet sources in order to be able to judge whether they act in accordance with the Privacy Legislation.
If you have questions about this Privacy Declaration, or the manner in which 4INCH collects, uses or processes your personal data, please contact us:
- Via post: 4INCH sa, 2 Rue Jean Burgers, 7850 Enghien (Belgium), attn. DPO
In case you are not satisfied with the way 4INCH handled your questions and/or remarks or have any complaints about the way 4INCH collects, uses and and/or processes your personal data, note that you have the right to lodge a complaint with the Privacy Commission.