General

In this privacy and cookie statement, the following terms shall have the following meanings:

• 'we': newphase bv, with registered office at Dries 23, 8510 Bellegem and registered in the Crossroads Bank for Enterprises under number 0795.689.713, e-mail: mailto:info@newphase.be and derivatives and
• 'you': any natural person using our website and/or our online platform. This privacy and cookie statement is also available online on our website.

Personal data

1. Protection of personal data

• Personal data: this is any information about an identified or identifiable natural person. An identifiable person is considered a natural person who can be directly or indirectly identified, in particular by means of an identifier such as a name, an identification number, data of a location, an online identifier or of one or more elements characterizing the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

We attach due importance to respecting and protecting your privacy and the confidentiality of your personal data. This privacy and cookie statement aims to inform you about the modalities related to the use of personal data and about the protection rules put in place to safeguard the confidentiality of this personal data.

We undertake to use personal data with discretion and to protect its confidential and private nature. All this is in accordance with the General Data Protection Regulation (GDPR), the Law of December 8, 1992 on the protection of privacy in relation to the processing of personal data (as amended) (hereinafter "the Law of December 8, 1992") and the other relevant legal regulations in force. We have taken legal and technical precautions to the best of our ability to prevent unauthorized access to and use of your personal data. Where it is impossible to fully guarantee security we will provide appropriate technical and organizational measures to protect personal data.

2. What personal data is collected, why and for what purposes?

• Processing: any operation or set of operations involving personal data or a set of personal data, whether or not carried out through automated processes, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of data.
• "Confidential processing": means that we process personal data confidentially in accordance with the legal requirements in force in Belgium, in particular the General Data Protection Regulation (GDPR) and the Law of December 8, 1992.

You are free to visit our website and gather the necessary information about our services without providing us with any personal data.

We may process the personal data of the following data subjects (e.g. visitors to this website, customers, contacts of customers etc). We may process the following personal data of the data subject (e.g. name, first name, national registration number, telephone number, address, e-mail address, account number, picture, family composition, education, function etc.) on the basis of the following legal grounds (consent of the data subject, necessity for the performance of the agreement, legal obligation, protection of vital interests, task of public interest or legitimate interest) for the following purposes (e.g. to fulfill legal obligations (customer management etc.), to execute the contract, to provide the data subject with informative news items related to the company, to improve the quality of services or information etc.):

Personal data	Legal Basis	Purpose
Name, first name, address, phone number, cell phone number, e-mail address	Legal obligation	Management of customer files
Name, first name, address, e-mail address, VAT number	Legal obligation	Sending out invoices
Name, first name, address, phone number, cell phone number, e-mail address	Necessity for the performance of a contract	To properly execute the agreement between the parties
Name, first name, address, phone number, cell phone number, email address, preferences, etc.	Need for processing an application	To properly respond to the application
Email address	Consent of data subject	Features informative news items

By providing personal data, the data subject grants express consent to the processing of such data for the above purposes. The data subject has the right to withdraw the given consent, insofar as the processing is based solely on the data subject's consent.

The data subject also expressly agrees that personal data may be communicated to subsequent recipients within the European Economic Area for the purpose of processing and in accordance with the legal provisions:

• https://www.one.com

We guarantee that these recipients will take the necessary technical and organizational measures to protect the personal data. If the data subject does not wish the personal data to be transferred to third parties and the processing is based solely on the data subject's consent, the data subject may oppose this either at the time the data subject provides the personal data or at any time through his/her right to object or his/her right to data erasure.

The retention period of personal data with us is six months. Upon expiration of this period, the personal data will be automatically deleted from the system. Personal data processed for personnel management purposes will be retained for the period necessary to comply with legal requirements (including in the areas of accounting and social legislation). If we wish to continue to use the personal data after the expiration of the retention period, we will request permission to do so again.

3. Rights

In accordance with the regulations in force, you have a legal right, on simple request and free of charge, to access, modify, delete or transfer your personal data. You also have the right, upon simple request and free of charge, to oppose the processing of your personal data for purposes such as direct marketing.

More specifically, in accordance with the applicable regulations and under the conditions in force, the data subject has the following rights:

• Right of inspection: the data subject always has the possibility to request his personal data (incl. processing purposes, categories of personal data, expected storage period) for inspection.
• Right to rectification: the data subject always has the possibility of having his personal data corrected or completed.
• Right to data deletion: the data subject has the possibility, under conditions, to request the deletion of his personal data by simple free request.
• Right to restriction of processing: the data subject has the possibility, under certain conditions, to request a restriction of the processing of his personal data towards the future.
• Right to object: the data subject has the possibility, under certain conditions, to object to the processing of their personal data for direct marketing purposes, among others.
• Right to portability: the data subject has the possibility to obtain and transfer his personal data to third parties in a structured, common and machine-readable form.

If you wish to exercise any of these rights, please contact us in writing using the contact information above. We will contact you within 30 days of your request.

Cookies

1. Storing cookies

We strive to provide you with clear information about how cookies are used on our websites and how they are stored on your device (computer, tablet, smartphone, etc.) in order to make your visit to our websites more enjoyable and better suited to your needs and preferences.

2. What are cookies and what do we use cookies for?

Cookies are small data or text files that are placed and stored on your computer or mobile device when you visit a website. Cookies help us optimize your visit to our website by performing a number of useful tasks, such as improving a website's security and overall user experience. For example, the website can remember the pages you have visited and your preferences (such as username, language, font size and other preferences) so that you do not have to re-enter them each time you visit the website. Other cookies are to allow analysis of information such as the number of visits to a website. Still other cookies are used for marketing purposes.

For optimal use of our website, it is therefore advisable to activate and/or accept cookies on your computer or mobile device. Without enabled cookies, we are not able to guarantee you a trouble-free visit on our website, as your visit may be interrupted or delayed and you may not be able to access or use certain parts of a website. If you nevertheless wish to delete or block cookies, you can adjust your browser settings.

Although most Internet browsers are set to accept cookies by default, you can delete cookies already placed and limit or block the placing of new cookies by adjusting your browser settings. How to adjust browser settings varies by browser. More information about your browser settings can be found at aboutcookies.org or in the "Help" menu of your Internet browser.

If you delete or block cookies, it does mean that you must then reset your preferences each time you visit and that some parts of the website may not work (properly).

3. What cookies do we use?

Session-based and persistent cookies are used on our websites:

• Session-based cookies are temporary cookies that disappear as soon as you close the browser
• Persistent cookies are cookies that remain on your computer even after you close the browser

These cookies are used for the following purposes:

• Processes: Process cookies allow the website to function and provide services you expect, such as navigation, access to secure areas, etc. Since the website cannot function properly without these cookies, process cookies are : Process cookies allow the website to function and provide services you expect, such as navigation, access to secure areas, etc. Since the website cannot function properly without these cookies, process cookies are essential.
• Preferences: Preference cookies allow the website to remember your preferences related to the website, such as language, font size, etc. These cookies are not necessary, but they do improve the user experienceas you do not have to re-enter your preferences over and over again.
• Security: Security cookies are used to authenticate you, prevent fraudulent use of login credentials, protect user data, etc. These cookies are essential to our secure websites.
• Advertising: Advertising cookies tailor the ads that appear on a website to you by collecting certain information about you, such as the types of websites you visited, choices made by you on websites, etc. This information is used to determine which ads appear. We work with advertising partners including the following: (at this time, the website is not being advertised and is not applicable).
• PerformancePerformance cookies collect information about how you interact with a Web site. This information includes the pages you visit most often, your activity on the website and how often you return. This collected data is normally used anonymously and analyzed for statistical purposes in order to improve the website and browsing experience.
  If you do not want data about your website visit to be passed on to Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout?hl=nl).

Contact

Any questions?

We are the controllers of your personal data. If, after reading this privacy and cookie statement, you still have questions or comments about the protection of your personal data or about cookies, please contact us using the contact details above. We will contact you within 30 days of your request.

For additional information regarding the protection of personal data, please contact the Data Protection Authority at 1000 Brussels, Rue du Printing Press 35, tel: 02/274.48.00, e-mail: contact@apd-gba.be, www.gegevensbeschermingsautoriteit.be.