PRIVACY POLICY OF LIVING STONE

 

1. Introduction

LIVING STONE N.V. respects your right to the protection of your Personal Data and ensures optimal protection of your data.

As a service provider regarding marketing and go-to-market strategies for technology companies and in the healthcare sector, Living Stone is a Controller responsible for the Processing of your Personal Data insofar as at the time of registration, you have given your express consent to Living Stone to use your Personal Data for the purposes set out in Article 6 below. In that case, the processing will take place on the basis of this Privacy Policy.

As Living Stone also manages and/or hosts website(s) for the client, Living Stone may act as the Processor when processing Personal Data on the instructions of the client. In such a case, the provisions of the Processing Agreement shall apply (available at https://livingstone.eu/verwerkersovereenkomst).

2. Applicability of the Privacy Policy

This Privacy Policy applies to all persons whose data are processed for the provision of services, client management, and/or seeking out potential clients by Living Stone (hereinafter “the Cooperation”) and who, at the time of registration, have given their explicit consent to have their Personal Data processed by Living Stone for the purposes set out in Article 6.

Living Stone will amend this Policy from time to time.

The use of the information collected and processed by Living Stone will be subject to the Privacy Policy that is in force at the time when this information is collected and processed. If Living Stone should make any material changes to the way in which it collects or processes Personal Data, it shall announce this change in a timely manner.

Users, as defined below, will be bound by any changes to the Privacy Policy as soon as they continue the collaboration after the announcement of these changes unless these changes are so fundamental that Living Stone believes it needs your express prior consent.

3. Definitions

The following definitions shall apply:

(1) “Data Subject”: The identified or identifiable natural persons whose Personal Data are processed in the context of the Cooperation.

(2) “Cookies”: Small files of letters and numbers that can be stored on your computer when you visit a website or view an advertisement. The primary purpose of cookies is to collect information about your visits to websites and to offer you personalised services;

(3) “Living Stone”: Living Stone N.V., with registered office at 9630 Zwalm, Oudenweg (Beerlegem) 42, with e-mail address info@livingstone.eu;

(4) “Personal Data”: All information relating to an identified or identifiable natural person is considered to be identifiable if any natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;

(5) “Cooperation”: The set of agreements and mutual rights and obligations that the parties have mutually agreed (explicitly or tacitly), and in particular the provision of services, client management and/or seeking out potential clients by Living Stone;

(6) “Processing”: An operation or a set of operations involving Personal Data or a set of Personal Data, whether or not carried out via automated processes, such as collecting, recording, organising, structuring, storing, updating or modifying, retrieving, consulting, using, providing by means of transmission, dissemination, or otherwise making available, aligning or combining, protecting, deleting, or destroying data;

(7) “Purposes”: The purposes for Processing as defined in Point 5;

(8) “Services”: The services provided by Living Stone in relation to marketing and go-to-market strategies for technology companies and in the healthcare sector, as well as, where applicable, in relation to the management and/or hosting of websites for the client;

(9) “Clients”: Companies that use the Services of Living Stone in order to develop and/or optimise their marketing and go-to-market strategies;

(10) “Controller”: The natural person who or legal entity, service, or another body that, alone or together with others, determines the purpose and means of the processing of the personal data;

(11) “Processor”: The natural or legal person, public authority, agency, or another body that processes Personal Data on behalf of the Controller.

4. Personal Data collected and processed by Living Stone

a) Personal Data that you make available to Living Stone

The Personal Data that you make available to Living Stone are:

(a) Your first name and surname;
(b) Your address, i.e. street and house number, postcode, town, and country;
(c) Your e-mail address
(d) Your (mobile) telephone number;
(e) Your date of birth;
(f) Any project-related communication;
(g) Information regarding your reliance on and your preferences, positive and negative experiences with regard to the Services provided by Living Stone and the Cooperation;
(h) Information regarding your use of the tools and documents provided by Living Stone, such as newsletters, white papers, etc.
(i) Data collected, stored, or used by Living Stone for quotations, invoicing, administrative support of the projects, time registration, inbound marketing, prospecting, and (project-related) communication.

You warrant that these data, which you have provided yourself during the Cooperation, are accurate and correct.

(b) Automatic processing of Personal Data

During the Cooperation, Living Stone will automatically collect and process some data relating to your browser or mobile device:

(a) Your IP address
(b) Your browser type
(c) Your mobile network provider
(d) The following information regarding your mobile device or browser:
o UID
o Manufacturer
o Model
o Platform
o OS version
o OS language
o OS user language
o Battery Level
o Battery charging (Yes/No)
(e) Application ID’s
(f) Cookie information
(g) Information relating to your use of online tools, including the pages you visit;

5. The lawfulness of the Processing of Personal Data

Your Personal Data will be processed by Living Stone:

(a) On the basis of the unambiguous, free, and informed consent that you have given Living Stone in this respect, and
(b) To promote the legitimate interests of Living Stone (in particular for the optimisation and expansion of its activities, services, and client base).

6. Purposes of the Processing of Personal Data

6.1 Your Personal Data will be collected and processed by Living Stone, solely for the following purposes:
(a) To enable the identification of the Data Subjects and their capacity (client, supplier, partner, representative, employee, appointed, (sub)contractor, interested party, prospect, etc.) during the Cooperation;
(b) The correct and smooth running of the Services provided by Living Stone and/or the Cooperation;
(c) To maintain the necessary administration to support the Services provided by Living Stone and/or the Cooperation (including project-related communication, preparing and communicating quotations, order forms and invoices, answering questions, providing requested information, etc.);
(d) Time registration with a view to invoicing and subsequent calculation;
(e) The optimal security of Services provided and/or Personal Data collected by Living Stone;
(f) Direct marketing, attracting (new) visitors and interested parties via search engines (e.g. Google), social media, and other channels (inbound marketing), and starting and/or maintaining further contacts via the website livingstone.eu and social media profiles of Living Stone;
(g) To allow Living Stone to analyse, personalise, and optimise your personal experience of the Services and Cooperation, as well as such experiences of other Clients, and to keep statistics of this;
Living Stone will not process your Personal Data in a way that is incompatible with the Purposes.
The use of Personal Data for other purposes will always be submitted to you for approval in advance.
6.2 Living Stone emphasises that you can object to the disclosure or use of your Personal Data for direct marketing purposes or targeted advertising based on your surfing behaviour.

Living Stone will deactivate the use of your Personal Data for direct marketing purposes and targeted advertising based on your surfing behaviour as from the receipt of your request by e-mail to info@livingstone.eu, with the subject: “Objection to the use of Personal Data for marketing purposes”.

7. Processing of Personal Data by subcontractor(s)

Living Stone may engage subcontractors for the processing of Personal Data for the Purposes described in Point 6.

Living Stone will only engage subcontractors who obtain the Personal Data from Living Stone, with the intention of processing these on the instructions of Living Stone (i) after having been transferred in accordance with Living Stone’s instructions, and (ii) in accordance with Living Stone’s commitment to the Users as set out in this Privacy Policy.

8. Sharing of Personal Data

We will not transfer your Personal Data to anyone outside Living Stone without your permission. However, you expressly accept that we share your Personal Data with:
– Our independent employees and staff members who carry out certain processing operations in accordance with our instructions and under our strict supervision,
– Public authorities or third parties, in so far as we are obliged to do so by the applicable legislation or a judicial order
– Living Stone’s suppliers with whom a direct marketing agreement has been concluded

Living Stone will share the Personal Data with subcontractors as defined in Point 7 only to the extent necessary for the Purposes.

9. Storage of Personal Data

Living Stone will store the Personal Data in a format that allows the identification of your data for the period necessary for the Purposes specified in Point 6.

10. Access to Personal Data and Portability, Rectification or Removal of Personal Data

(a) Access to and rectification of Personal Data

You can access, modify, or rectify your Personal Data by sending an e-mail to info@livingstone.eu together with a copy of your identity card in the attachment.

You may also obtain your Personal Data in a structured, common, and machine-readable form if you wish to transfer them to another Controller.

The list of Personal Data may change as the Services change.

Even after the modification and rectification of Personal Data, copies thereof may remain visible elsewhere, insofar as the Personal Data were shared with others or distributed pursuant to your privacy settings.

If you have any questions regarding the access to your Personal Data, please send an e-mail to info@livingstone.eu.

b) Right to Erasure of your Personal Data

Living Stone will remove your Personal Data from its databases and files after receiving your request by e-mail to info@livingstone.eu with the following subject: “Erasure of Personal Data”, together with a copy of your identity card in the attachment. You should indicate which Personal Data should be erased.

Even after erasure of Personal Data, copies thereof may remain visible elsewhere, to the extent that the Personal Data were shared with others or distributed pursuant to your privacy settings. Living Stone shall take reasonable measures to inform third parties to whom your Personal Data have been transferred of your request to erase any reproduction of your Personal Data.

Erased Personal Data will under no circumstances remain on Living Stone’s backup for more than ninety (90) days.

11. Restriction on processing

You are entitled to request Living Stone to restrict the processing of your Personal Data if:
– You dispute the accuracy of the Personal Data;
– The Processing is unlawful, and you prefer a restriction on processing instead of the erasure of the data;
– Living Stone no longer needs your Personal Data for the Purposes described in Article 6, although you will need them for the institution, performance, or substantiation of a legal claim;
– You have objected to the processing.

If you wish to send Living Stone a request to restrict the processing of your Personal Data, you should do so by sending an e-mail to info@livingstone.eu together with a copy of your identity card in the attachment.

12. Right of objection

You have the right to object to the processing of your Personal Data if you invoke serious and justified reasons relating to your particular situation.

“Serious” means that you must demonstrate the reasons why the processing may adversely affect you. “Justified” refers to data which would demonstrate that the processing is carried out without any legal basis or is unlawful.

If you wish to object to any processing of your Personal Data, please send an e-mail to info@livingstone.eu together with a copy of your identity card in the attachment

13. Security and Confidentiality of your Personal Data

Living Stone will take all technical and organisational measures to ensure the security and confidentiality of your Personal Data in order to avoid the unintentional, unauthorised, or unlawful (i) destruction, modification, adaptation, or loss of Personal Data and/or (ii) disclosure of or access to the Personal Data, and/or (iii) ways of Processing.

The security measures will be in accordance with the applicable legislation concerning the protection of Personal Data and will be tailored to the risks inherent in the Processing and the nature of the Personal Data being processed, taking into account the state of the art and the implementation costs this entails. Living Stone will immediately inform you of any breach of this security or confidentiality unless a legal prohibition to do so is in place.

Living Stone will implement all measures necessary to ensure that its employees comply with the obligations regarding your Personal Data and will have the employees who need access to this Personal Data sign an individual confidentiality agreement.

The Living Stone Program and website may contain links to other websites. Living Stone is not liable or responsible for the privacy policy and/or use of the privacy of other websites. You should, therefore, make enquiries about the privacy policy of the website in question.

You should also avoid unauthorised access to your Personal Data as much as possible by carefully selecting and adequately protecting your passwords where appropriate, and by limiting access to your computer and browser by always logging out of your user account after each use.

14. Transfer of Personal Data to Third Countries

In order for the Services to function properly, Living Stone must be able to transfer personal data to countries outside the European Union. These countries may not provide an adequate level of protection compared to the level of protection of personal data in the European Union. If Living Stone transfers your information to countries outside the European Union, it will take the necessary measures to ensure that your privacy rights remain protected to the same extent as provided for in this Policy.

By making your Personal Data available to Living Stone, you expressly consent to the transfer of your Personal Data outside the European Union in the manner described above.

15. Reporting of a breach

If there has been a breach in connection with your Personal Data that poses a high risk to your rights and freedom, Living Stone will explicitly inform you of this.

More specifically, Living Stone will inform you of:
– The nature of the breach;
– The data communicated to the data protection authority;
– The measures taken.

16. Cookies

During your use of the Program, small text files, so-called ‘cookies’, may be automatically downloaded to your computer. The downloading of cookies to your computer will always be subject to the provisions below. This cookie policy gives you clear and complete information about the cookies Living Stone uses and their purpose.
a) What is a cookie?

A cookie is a small file of letters and numbers that can be stored on your computer when you visit a website or view an advertisement. The primary purpose of cookies is to collect information about your visits to websites and to offer you personalised services.

They are pieces of information that are stored on your computer by the server and that take care of the maintenance and operation of the website. They store a simple, random identification code on your computer.

The cookies on your computer are managed by your web browser.

b) Why do we use cookies?

The Living Stone website uses cookies and similar technologies to distinguish your usage preferences from those of other Data Subjects. Cookies are stored on your computer for three reasons:

– They help to improve the functioning of the website;
– They help to understand the interests of the Data Subjects; and
– They allow the effectiveness of the content of the website to be measured.

This helps Living Stone to provide you with a better user experience when you visit the website or use the Services and allow Living Stone to optimise the website and the Services.
The information obtained by means of cookies does not allow us to collect data that identify you as their user. It only allows the identification of the computer being used.

c) What types of cookies are used?

The following cookies are used:

• “Session cookies”: Temporary cookies that are deleted as soon as you close your web browser.

• “Functional cookies”: Cookies that are used to transmit signals over a network or to perform a service you have requested (e.g. to play back sound or images). Our website uses these cookies to improve user-friendliness.

• “Web analytics cookies”: Cookies used to create anonymous statistics in order to improve the functioning of our Website. For example, our website uses Google Analytics (i.e. a web analytics service that uses cookies to create anonymous summary statistics), including Google Display Network (i.e. a collection of websites that display AdWords ads) and Google’s DoubleClick Platform (i.e. technology that enables digital advertising to be created, managed and transactions to be carried out).

• “Third Party Cookies”: Computer applications of third parties that allow users to share the content of our website with other people or express their opinion about the content of our website to other people. This is particularly the case with buttons such as “Share” and “Like” of social networks such as Facebook, Google+, Twitter, etc. For more information, please visit the following social networking sites:
http://www.facebook.com/about/privacy/ –
http://www.google.com/intl/nl/policies/privacy/.

You should review the privacy policies of these social networks to learn about the purposes (including advertising) of the use of navigation information that can be collected using these application buttons.

Most cookies have a permanent duration. They are automatically deleted after a period of two years after your last visit to our website, or when you, as a user, explicitly take an action to this effect (by deleting the history or the software that monitor the cookies).

d) How can you manage cookies?

You have various options for managing cookies. By changing your settings, you can change your navigation on the internet as well as the access conditions for certain services that require the use of cookies. You can always choose to disable all cookies or to change your cookie requirements using the means described below.

The settings of your web browser:

Each browser has different cookie settings. You can choose to set your browser so that cookies are stored on your workstation or that they are deleted altogether, either systematically or on the basis of the sender. You can also set your browser to ask you each time whether you want to accept or reject cookies, even before a cookie is stored on your computer.

The configuration is different for each browser. This is described in the Help menu of your browser, which will allow you to know how you can adjust your cookie requirements. The procedure for each browser is described in the following manuals:

– For Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
– For Safari: https://www.apple.com/legal/privacy/en-ww/cookies/
– For Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=us
– For Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
– For Opera: http://help.opera.com/Windows/10.20/en/cookies.html

You may block the above Google Analytics advertising functions, for example, via Google’s “Advertising settings”, via Google’s “Advertising settings for mobile apps”, or via Google’s Analytics Opt-out Browser Add-on (for more information: http://www.google.com/intl/en/analytics/privacyoverview.html).

e) Consent

The use or storage of cookies and similar technologies on your computers or mobile devices is always subject to your permission unless they are placed for the sole purpose of carrying out the transmission of a communication via an electronic communications network or providing a service expressly requested by you when this is strictly necessary for this purpose.

When you do not or no longer accept the use of cookies by Living Stone, it is possible that some parts of the website do not (or no longer) work properly.

For further information about this Cookie Policy, please contact us at info@livingstone.eu.

For further information on how to delete or block cookies, please visit the following website: http://www.aboutcookies.org

17. Questions or comments

You may always send a message to info@livingstone.eu if you have any questions or comments in connection with the protection of your Personal Data during and/or after the Cooperation. We will do everything we can to address your concerns.

18. Complaints

If you are still not satisfied with the way in which your Personal Data are processed, you have the right to submit a complaint to the Belgian Privacy Committee.

You can contact them at commission@privacycommission.be or by letter to Drukpersstraat 35, 1000 Brussels.

By accepting this Privacy Policy:

– You confirm that you are fully informed of this Privacy Policy and are aware that it will be updated from time to time;
– You expressly consent to Living Stone collecting and processing your Personal Data as set out in Point 4, for the Purposes set out in Point 5;
– You expressly agree to Living Stone using cookies as described in Point 16.

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