1. General

This privacy policy (“Privacy Policy”) governs the processing of your personal data as part of your use of our Website (the “Website”) and the services related thereto (collectively referred to as the “Services”). Such processing is carried out by Sarah Wilson as data controller, with registered office at De Wingerd 6, 2460 Kasterlee (“we”, “us”), in accordance with applicable data protection laws.
By using our Website and/or our Services, you acknowledge that you have carefully read this Privacy Policy and agree to it without reservation. We reserve the right to change the Privacy Policy from time to time according to our sole discretion. Such change will be communicated through the Website.
By clicking the privacy opt-in checkbox on forms on the Website, you represent that you have indeed read and agree to this Privacy Policy. You declare that you understand the purposes for which your personal data are processed. You also agree that your continued use will be understood as continued consent. You may withdraw your consent at any time by sending a request to info@sarahwilson.be
Please note that we may use so-called ‘cookies’ or similar technology as part of the Website and/or the Services. Cookies are small text files placed on the hard disk of a device, which contain certain information, sometimes including personal data. For more information regarding our use of cookies, please read our Cookie Policy (https://www.sarahwilson.be/cookie-statement/).
This Privacy Policy was last updated on 22/12/2022.

2. What & why we process data

When you use the Website and/or Services, we process personal data relating to you. Such personal data includes:
When Which Why (purpose) Legal basis
Use of Website Personal identification data Customer management
Application procedures Justified interest
Use of Services Direct marketing Consent (if applicable)
Applying for a job vacancy
Downloading marketing material offered
Contacting us

In principle, we obtain the personal data mentioned above directly from you. We do not forward any of the personal data you provide via the Website to social media providers unless you consent. In addition to the above purposes, we may also process your personal data:
To provide you with the information on products and services you request in a personalis(de and efficient manner, whether via the Website, email, telephone or social media channels.
To process your personal data so that we can provide the Services.
For direct marketing purposes, i.e. to provide you with targeted communications, promotions, offers and other advertisements from us or our selected partners. For this, we will seek your prior consent.
To perform statistical analysis to improve our Website and/or Services, or develop new products or services.
To provide to a financial institution or payment service provider, to enable your financial institution and the payment service provider to comply with their legal obligations.
To transfer to the police or judicial authorities as evidence of possible crimes or if there are reasonable suspicions of an unlawful act or crime committed by you through your registration with or use of the Website or the Services.
In the context of a possible merger with, acquisition of/by or demerger by a third party, even if that third party is located outside the EEA (European Economic Area).
If and when your registration on the Website or use of the Website or Services may be considered (a) a violation of the terms and conditions or intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Services, (c) a threat to the Website or Services or systems of us or our subcontractors due to viruses, Trojans, spyware, malware, or any other form of malicious code, or (d) illegal or unlawful, discriminatory or offensive in any way, we may process your data in the interests of ourselves, our partners or third parties.

3. With whom we share data

We do not transmit your personal data in an identifiable manner to third parties if this is not required to provide the Services, without your explicit consent to do so.
We may use third-party processors to provide you with the Website and/or Services. We ensure that third party processors may only process your personal data on our behalf, and upon written instructions from us. We ensure that all third-party processors are selected with due care to ensure the security and integrity of your personal data.
We may transfer anonymised and/or aggregated data to other organisations that may use this data to improve products and services and to organise the marketing, presentation and sale of customised products and services.

4. Where we process data

We ourselves and our third-party processors will only process your identifiable personal data in the EEA.
We may transfer your anonymised and/or aggregated data to organisations outside the EEA. If such a transfer takes place, we will ensure that appropriate safeguards are in place to ensure the security and integrity of your personal data, and that any rights in relation to personal data that you might enjoy under applicable mandatory law are guaranteed.
If there is a transfer of your personal data and/or anonymised and/or aggregated data, the following legal protection mechanism will be put in place:
Which Country outside EEA Legal transfer mechanism
HubSpot USA EU – US Privacy Shield
Facebook USA EU – US Privacy Shield
Google USA EU – US Privacy Shield
LinkedIn USA EU – US Privacy Shield

5. How we process data

We will make every effort to process only the personal data necessary to achieve the purposes set out in this Privacy Policy. We will process your personal data in a lawful, fair and transparent manner. We will make every effort to keep personal data accurate and up-to-date.
Your personal data will only be processed for as long as necessary to achieve the purposes set out in this Privacy Policy or until such time as you withdraw your consent to its processing. Please note that withdrawal of consent may imply that you are no longer able to use all or part of the Website and/or Services. If you have registered with our Website, we will delete your personal data when you delete your profile, unless a legal or regulatory obligation or a court or administrative order would prevent us from doing so.
We will take appropriate technical and organisational measures to keep your personal data safe from unauthorised access or theft and from accidental loss, manipulation or destruction. Access by our staff or staff of our third-party processors is only possible on a need-to-know basis and is subject to strict confidentiality obligations. However, you understand that care for safety and security are only best-efforts obligations that can never be guaranteed.

6. Your rights

You have the right to request access to any personal data we process about you. However, requests for access made with the apparent intention of causing inconvenience or damage to us will not be processed.
You have the right to request that any personal data about you that is incorrect or inaccurate be corrected free of charge. If you have registered on our Website, you can correct many of these details yourself via your profile. If such a request is made, you must also enclose with this request proof that the personal data for which correction is requested is incorrect.
You have the right to withdraw your previously given consent to the processing of your personal data. You may withdraw your consent at any time by sending an e-mail to info@sarahwilson.be or by deleting your profile (if applicable).
You have the right to request that personal data relating to you be deleted if it is no longer necessary in light of the purposes set out in this Privacy Policy or if you withdraw your consent to its processing. However, you should note that a deletion request will be assessed by us in light of legal or regulatory obligations or administrative or court orders that may prevent us from deleting the personal data in question.
In lieu of deletion, you may also request that we restrict the processing of your personal data if (a) you contest the accuracy of such data, (b) the processing is unlawful or (c) the data are no longer necessary for the stated purposes, but you need them to defend yourself in legal proceedings.
You have the right to oppose the processing of personal data if you can prove that there are serious and legitimate reasons relating to special circumstances that justify such an opposition. However, if the intended processing is classified as direct marketing, you have the right to oppose such processing free of charge and without justification.
Where your personal data are processed on the basis of consent or on the basis of a contract and the processing is carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and, if technically feasible, you have the right to transmit such data directly to another service provider. The technical feasibility of this will be assessed solely by us.
If you wish to make a request to exercise one or more of the rights listed above, please send an e-mail to info@sarahwilson.be This request should clearly state which right you wish to exercise and why. It should also be dated, signed and accompanied by a digitally scanned copy of your valid ID card proving your identity. We will immediately inform you of the receipt of such request. If the request proves to be valid, we will comply with it as soon as reasonably possible and no later than thirty (30) days after receipt of the request.
If you have a complaint about our processing of your personal data, you can always contact us at the e-mail address info@sarahwilson.be If you remain dissatisfied with our response, you are free to lodge a complaint with the competent data protection authority, the Commission for the Protection of Privacy (CBPL). For more information, visit http://www.privacycommission.be