Privacy Policy General data protection policy

1. PRESENTATION

At Road21, we know that you care about your personal privacy. In this general privacy policy (the "Policy"), we describe how we collect personal data from you as a customer of Road21 (hereinafter "you", "your", "user") and why we collect it, what we do with your personal data, who we share it with, how we protect it, and what choices you can make about how we use your personal data. This Policy applies to all of your personal data collected and used, or processed by or on behalf of Road21, a private limited liability company organized and existing under the laws of Belgium, with its registered office at Groeningenlei 16 in Kontich (2550), registered with the register of legal entities under number BE 0759.432.596 (hereinafter "Road21", "us" or "we") in connection with your use of our website www.companions.be (the "Website"), the mobile application (the "App"), or other services (collectively, the "Services" or "Service").By accepting the terms of this policy, you agree that we may process your personal data in the manner described in this policy.At the end of this Policy, you will find some definitions of certain key terms used in this Policy which are capitalized (e.g. Personal Data, Processing, Data Controller...).

2. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

Road21
BE0693767061
Groeningenlei 162550 Kontich

3. WHO CAN YOU CONTACT FOR QUESTIONS OR REQUESTS? OUR DATA PROTECTION COORDINATOR - THE CONTACT POINT FOR DATA PROTECTION

We have appointed a data protection coordinator to handle your questions or requests regarding this policy or your personal data (and the way we process them); for example, if you want to exercise your rights, such as your right of access, rectification or restriction, portability... (You want to know more about the rights you have to your personal data? Read more in Chapter 7).You can contact the Data Protection Coordinator through the Data Protection Contact Point at:- hello@companions.be by email, or- 0476787034.We will do our best to answer your questions as soon as possible.

 4. KEY PRINCIPLES

We value the Personal Data entrusted to us and we are committed to processing your Personal Data in an honest, transparent and secure manner. The key principles are as follows:Legality: we only collect your Personal Data in a fair, lawful and transparent manner.Data minimization: we limit the collection of your Personal Data to what is directly relevant and necessary for the purposes for which it was collected.Purpose limitation: we will only collect your Personal Data for specified, explicit and legitimate purposes and will not further process your Personal Data in a way that is incompatible with those purposes.Accuracy: we will keep your Personal Data accurate and up-to-date.Data Security and Protection: we will implement appropriate technical and organizational measures to ensure an adequate level of data security and protection with respect to, among other things, the nature of your Personal Data to be protected. Such measures will provide for the prevention of unauthorized disclosure or access, accidental or unlawful destruction or accidental loss, or alteration and any other unlawful form of Processing. Access and rectification: we will process your Personal Data in accordance with your legal rights. Retention Limitation: we will retain your Personal Data in a manner consistent with applicable data protection laws and regulations and for no longer than is necessary for the purposes for which it was collected.Safeguards for international transfers: we ensure that your Personal Data transferred outside the EEA is adequately protected.Safeguards with respect to third parties: we will ensure that access to and transfer of your Personal Data to third parties is carried out in accordance with applicable law and with appropriate contractual safeguards. Legality of direct marketing and cookies: where we send you promotional materials or place cookies on your computer, we will ensure that we do so in accordance with applicable law.

 5. KEY PRINCIPLES

When we need your Personal Data, we will always clearly inform you which of your Personal Data we are collecting. Please note that in accordance with applicable data protection laws, your Personal Data may be processed if:you have given us your consent for the purposes of the Processing (as described in the privacy notice relating to that specific Processing). For the avoidance of doubt, you always have the right to withdraw your consent at any time; orit is necessary for the performance of a contract to which you are a party; orIt is required by law.The Services specifically collect information from you at various points including, but not limited to, the following:

 6. KEY PRINCIPLES

At Road21, we know that you care about your personal privacy. In this general privacy policy (the "Policy"), we describe how we collect personal data from you as a customer of Road21 (hereinafter "you", "your", "user") and why we collect it, what we do with your personal data, who we share it with, how we protect it, and what choices you can make about how we use your personal data. This Policy applies to all of your personal data collected and used, or processed by or on behalf of Road21, a private limited liability company organized and existing under the laws of Belgium, with its registered office at Groeningenlei 16 in Kontich (2550), registered with the register of legal entities under number BE 0759.432.596 (hereinafter "Road21", "us" or "we") in connection with your use of our website www.companions.be (the "Website"), the mobile application (the "App"), or other services (collectively, the "Services" or "Service").By accepting the terms of this policy, you agree that we may process your personal data in the manner described in this policy.At the end of this Policy, you will find some definitions of certain key terms used in this Policy which are capitalized (e.g. Personal Data, Processing, Data Controller...).

 7. KEY PRINCIPLES

At Road21, we know that you care about your personal privacy. In this general privacy policy (the "Policy"), we describe how we collect personal data from you as a customer of Road21 (hereinafter "you", "your", "user") and why we collect it, what we do with your personal data, who we share it with, how we protect it, and what choices you can make about how we use your personal data. This Policy applies to all of your personal data collected and used, or processed by or on behalf of Road21, a private limited liability company organized and existing under the laws of Belgium, with its registered office at Groeningenlei 16 in Kontich (2550), registered with the register of legal entities under number BE 0759.432.596 (hereinafter "Road21", "us" or "we") in connection with your use of our website www.companions.be (the "Website"), the mobile application (the "App"), or other services (collectively, the "Services" or "Service").By accepting the terms of this policy, you agree that we may process your personal data in the manner described in this policy.At the end of this Policy, you will find some definitions of certain key terms used in this Policy which are capitalized (e.g. Personal Data, Processing, Data Controller...).

 8. KEY PRINCIPLES

At Road21, we know that you care about your personal privacy. In this general privacy policy (the "Policy"), we describe how we collect personal data from you as a customer of Road21 (hereinafter "you", "your", "user") and why we collect it, what we do with your personal data, who we share it with, how we protect it, and what choices you can make about how we use your personal data. This Policy applies to all of your personal data collected and used, or processed by or on behalf of Road21, a private limited liability company organized and existing under the laws of Belgium, with its registered office at Groeningenlei 16 in Kontich (2550), registered with the register of legal entities under number BE 0759.432.596 (hereinafter "Road21", "us" or "we") in connection with your use of our website www.companions.be (the "Website"), the mobile application (the "App"), or other services (collectively, the "Services" or "Service").By accepting the terms of this policy, you agree that we may process your personal data in the manner described in this policy.At the end of this Policy, you will find some definitions of certain key terms used in this Policy which are capitalized (e.g. Personal Data, Processing, Data Controller...).

 9. KEY PRINCIPLES

At Road21, we know that you care about your personal privacy. In this general privacy policy (the "Policy"), we describe how we collect personal data from you as a customer of Road21 (hereinafter "you", "your", "user") and why we collect it, what we do with your personal data, who we share it with, how we protect it, and what choices you can make about how we use your personal data. This Policy applies to all of your personal data collected and used, or processed by or on behalf of Road21, a private limited liability company organized and existing under the laws of Belgium, with its registered office at Groeningenlei 16 in Kontich (2550), registered with the register of legal entities under number BE 0759.432.596 (hereinafter "Road21", "us" or "we") in connection with your use of our website www.companions.be (the "Website"), the mobile application (the "App"), or other services (collectively, the "Services" or "Service").By accepting the terms of this policy, you agree that we may process your personal data in the manner described in this policy.At the end of this Policy, you will find some definitions of certain key terms used in this Policy which are capitalized (e.g. Personal Data, Processing, Data Controller...).

 10. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

We will retain your Personal Data in a manner consistent with applicable data protection laws. We will retain your Personal Data only for as long as necessary to comply with the law or for the purposes for which we process your Personal Data.

 11. KEEP YOUR PERSONAL DATA SAFE

We ensure that appropriate technical and organizational security measures are taken against unlawful or unauthorized access to or use of your Personal Data, as well as against accidental loss or damage to the integrity of your Personal Data. We continually update and test our security technology. We limit access to your Personal Data to those employees who need this information to provide you with benefits or services. In addition, we train our employees on the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking the necessary disciplinary actions to enforce the privacy responsibilities of our employees.Your Personal Data will only be processed by a third party Data Controller if that Data Controller agrees to comply with those technical and organizational data security measures.Maintaining data security means ensuring the confidentiality, integrity and availability of your Personal Data: (a) Confidentiality: we will protect your Personal Data from disclosure to third parties.(b) Integrity: we will protect your Personal Data from modification by unauthorized third parties.(c) Availability: we will ensure that authorized parties have access to your Personal Data when necessary.

 12. USE OF COOKIES, WEB BEACONS OR SIMILAR DEVICES

Cookies are pieces of data that a website sends to a user's hard drive for storage. Web beacons are transparent pixel images used in collecting information about web usage, email response and tracking.The website uses cookies and web beacons to improve functionality on the website (e.g., user ID and password notifications) and to collect traffic data (e.g., which pages are most popular). These cookies may be delivered in the context of a first party or a third party. Road21 may also use cookies and web beacons in conjunction with emails delivered by Road21. Our Website also records limited information (user-agent, HTTP-referrer, last URL requested by the user, client-side and server-side clickstream) about visits to our Website; we may use this information to analyze general traffic patterns and to perform routine system maintenance. You have many choices regarding the management of cookies on your computer. All major browsers allow you to block or delete cookies from your system. To learn more about your ability to manage cookies and web beacons, please review the privacy features in your browser.

 13. DISCLOSURE OF PERSONAL DATA

For the purposes for which we collect your Personal Data, we may disclose your Personal Data to the following categories of recipients:(a) Authorized personnel of Road21;(b) Affiliates and subsidiaries of Road21;d) Our advertising, marketing and promotional agencies: to help us deliver and analyze the effectiveness of our advertising campaigns and promotions; e) Business partners: trusted companies who may use your Personal Data to provide you with the Service(s) you have requested and/or who may provide you with marketing materials (provided you have given consent to receive such marketing materials). We ask such companies to always act in accordance with applicable law and this Policy and to take great care to maintain the confidentiality of your Personal Data. For example, Road21 may share your personal data with Lemon Companies. (f) Service Providers: companies that provide services for or on behalf of Road21, for the purpose of providing such services. (g) Other parties where required to do so by law or as necessary to protect Road21: Road21 may share your Personal Data with other third parties: to comply with law, regulatory requests, court orders, subpoenas or legal process; to monitor or enforce compliance with Road21's policies and agreements; andto protect the rights, property or safety of Road21 and/or its customers;h) Other parties in connection with business transactions: Road21 may share your Personal Data with other third parties in connection with a divestiture of all or part of Road21's business, or otherwise in connection with a merger, consolidation, change of control, reorganization or liquidation of all or part of Road21's business;(i) Other parties with your consent or at your direction: Road21 may share your Personal Data with third parties when you consent to or request such sharing; and (j) Any other third party that is communicated to you by Road21 before your Personal Data is shared with that third party. Please note that third parties referred to in (c) through (j) above - in particular, service providers who may offer products and/or services to you through Sypergood’s services or through their own channels - may separately collect Personal Data from you. In such a case, these third parties will be solely responsible for the control of such Personal Data and your dealings with them will be governed by their terms. From time to time, we may cooperate or make arrangements with another party to provide specific benefits and/or services to you as a customer. We will provide such partners with the information we reasonably believe is necessary to enable them to provide such benefits or services to you. If you do not wish to receive marketing communications from our partners or us, you may indicate your preference not to be contacted by sending a letter, calling or emailing the Road21 administrative offices at the contact information below to notify us of your preference.

 14. INAPPLICABILITY OF PRIVACY STATEMENTS OF LINKED WEBSITES OR OTHER THIRD PARTIES

This policy covers only Road21's use and disclosure of your personal information. Because the Services contain links to other websites, please be aware that we are not responsible for the privacy practices of such other websites and we are not liable for the misuse of Personal Data by those websites. We encourage you to be aware that when you go to another website, you should carefully read their privacy statement.

 15.  LEGAL INFORMATION

The requirements of this Policy are in addition to and do not replace other requirements that exist under applicable data protection laws. In the event of any conflict between what is written in this Policy and the requirements of applicable data protection laws, the applicable data protection laws will prevail.By using (any of) the Services, you agree to the terms and conditions contained in this Policy and/or to any other agreement we may have with you. If you do not agree to any of these terms, you should not use any of the Services. You agree that any dispute over privacy or the terms in this Policy, or any other agreement we may have with you, will be governed by the laws of Belgium. Any dispute relating to this Policy or the Website will be settled exclusively by the courts of Antwerp.As our organization, our customers and our benefits change from time to time, it is expected that this Policy will also change. We reserve the right to change the Policy at any time, for any reason, without notice to you, other than posting the changed Policy on the Website and in the App. We may email periodic reminders of our notices and terms and will email Road21 customers about material changes, but you should check our Website periodically to see the current Policy in effect and any changes to the Policy. The provisions herein supersede any previous notices or statements regarding our Privacy Policy.

 16. CONTACT

If you have any questions, concerns or complaints about our policy, or if you have any concerns about privacy at Road21 or the use of the Services in general, or to exercise your rights, such as your rights of access, rectification, restriction, portability..., you may contact the Data Protection Coordinator at the Contact Point for the purposes of this policy (see Chapter 3 "Who can you contact if you have questions or requests?").

 17. DEFINITIONS

In this policy, the following terms have the following meanings: 
(a) Contact Point: the point of contact where you can address your questions, requests or complaints about this Policy and/or (the processing of) your Personal Data to the Data Protection Coordinator.
(b) Data Processor: the organization that determines for which purposes and in which manner your Personal Data are processed. Specifically, this means Road21.
(c) Data Processor: the person or organization that processes your Personal Data on behalf of the Controller.
(d) Data Protection Coordinator: the person appointed by Road21 in the relevant jurisdiction to handle your queries and requests.
(e) EEA means the European Economic Area (= Member States of the European Union + Iceland, Norway and Liechtenstein).
(f) Personal data is any data that directly relates to you or that allows your identification, such as, for example, your name, telephone number, e-mail address, bank account details, (geo)location, etc. 
(g) Processing means the collection of, access to and all uses of your Personal Data.

18. UPDATES

The Privacy Policy was last updated on 08/07/2022