Privacy Policy

1. What is the scope of this Privacy Policy?

Raito BV (with registered office at BE-1150 Sint-Pieters-Woluwe (Belgium), rue René Devilliersstraat 45 and company number 0776.690.876) values the protection of privacy. This Privacy Policy informs you about our Processing activities regarding Personal Data, about your rights as a data subject and the measures taken by Raito BV to protect privacy.

This policy covers the collection and Processing of Personal Data in connection with the use of our Website, when you contact us or are contacted by us, including through our social media pages such as Facebook, LinkedIn and Twitter. The privacy policy related to Personal Data collected or Processed as a result of our services is described in the specific Processing agreements we enter into with our clients.

You are requested to read this Privacy Policy carefully, with the understanding that it may be amended from time to time in light of feedback received by us or changes in our Services and/or legal or regulatory provisions. In addition, when you visit our Social media pages (as defined below), you should consult the privacy policies of the specific social media providers to get a full picture of the Processing in this regard.

2. What do the terms used in this Privacy Policy mean?

A number of terms are capitalized in this Privacy Policy. They are defined below for ease of understanding:

GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the Processing of Personal Data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).

Breach: a breach of security resulting in accidental or unlawful destruction, loss, alteration or unauthorized disclosure of or access to Processed Personal Data.

Personal data: any information that allows you to be identified, within the meaning of the GDPR.

Processing: any operation or set of operations involving Personal Data or a set of Personal Data, whether or not carried out by automated means, such as collection, recording, organization, structuring, storage, updating, copying or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, assembly or combination, restriction, erasure or destruction.

Website: website of Raito BV (www.raito.io).

Social media pages: the social media pages of Raito BV, such as the pages on Facebook, LinkedIn and Twitter.

Usage Data: the Personal Data that is automatically collected or generated through the use of the Website or the Social media pages (including the type of device used by your and its identification and IP address, browser type and version, the time and date of the visit to the Website or the Social media pages as well as the pages visited and the time spent on them and other diagnostic data).

3. How do we collect Personal Data and what data do we collect?

We collect Personal Data through the Website, Social Media pages as well as through correspondence with you.

The Personal Data collected and Processed by Raito BV through the Website, Social Media pages and correspondence concern the contact data (name, e-mail address, address, telephone number, job title) of (i) our customers and clients, their personnel, employees, appointees and other useful contacts, (ii) suppliers and subcontractors, as well as their possible (sub)subcontractor(s), their personnel, employees, appointees and other useful contacts and (iii) other persons such as possible new customers/prospects, useful contacts within our industry, and network contacts.

In addition, through the Website, we collect Usage Data through tracking technologies and cookies. For example, the Website's server automatically recognizes the IP address and/or domain name of
the person visiting the Website. We refer in this regard to our Cookie Policy.

We do not collect or process sensitive data, nor Personal Data of minors. We therefore urge you not to transmit such data to us.

4. What in the purpose and legal basis for the Processing?

We process Personal Data for entering into and performing agreements, customer and supplier management, accounting and marketing activities such as sending promotional or commercial information.

As the case may be, the grounds for Processing are the performance of the contract, the fulfilment of legal and regulatory obligations and/or our legitimate interest.

All Personal Data shall be Processed only for the purpose for which it was collected and to the extent necessary to achieve that purpose. This limitation applies to the amount of Personal Data as well as
to the scope of Processing, retention period and accessibility.

If Personal Data needs to be Processed for a purpose other than the purpose for which they were initially collected, Raito BV will ensure that the Processing does not take place in a way that is incompatible with the purpose for which Personal Data were provided. If the desired finality is incompatible with the original finality for which Personal Data have been provided, Raito BV will seek your consent for the Processing in light of this new purpose, provided the consent is freely given. For marketing activities that are individualized (such as personalized emails, newsletters or invitations to events), you will be asked for your consent, which you may withdraw at any time, and this by means of a simple request to Raito BV as referred to in Article 14 of this policy, or through the means provided in the communication in question.

Raito BV does not use solely automated decision making.

5. How long do we Process Personal Data?

We keep Personal Data only as long as necessary for the purposes of the Processing for which it was collected, according to the type of relationship we have with you.

Personal Data that are not necessary for the execution of a contract, for the fulfilment of mandatory legal provisions resting on Raito BV or for the defence of our legitimate interest, in particular the data for the purpose of marketing activities, will be deleted or anonymized within a period of 1 year after the end of the relationship in the framework of which they were collected. The Personal Data necessary for the performance of the contract will be kept and Processed for the duration of the contract and thereafter for the period necessary to exercise our rights under the contract.

6. To whom do we transfer Personal Data?

Raito BV may transfer the Personal Data to its staff members and affiliated companies, as well as to other persons, such as suppliers and cooperating partners, who will process such data on behalf of Raito BV. This transfer will only occur as far as these persons provide sufficient guarantees regarding appropriate technical and organizational measures so that the Processing meets the requirements of the GDPR and the protection of your rights or as far as the transfer is necessary within the applicable legal or regulatory framework, taking into account the purposes of the Processing. Please note that Raito BV may be obliged to transfer Personal Data to governmental authorities.

To the extent required by the GDPR, Raito BV will enter into an agreement with the (sub)Processors in which the purpose of the Processing is defined and the Processor commits, among other things, to respect the confidentiality of the Personal Data, to limit the Processing to what is in accordance with the instructions of Raito BV or with what is permitted by law and to cooperate in the exercise of the rights granted to you by the GDPR.

We will transfer Personal Data outside the European Economic Area or EEA only to countries that comply with data protection laws and where the means of transfer ensure adequate protection of your data.

7. What technical and organizational measures do we take?

To ensure that Personal Data receives an adequate level of protection, we have established appropriate internal procedures and entered into agreements with third parties with whom we share Personal Data. We take the necessary technical and organizational measures to process your Personal Data according to an adequate security level and to protect it against destruction, loss, falsification, modification, unauthorized access or notification by mistake to third parties, as well as any other unauthorized Processing of the Personal Data. The specific measures taken by Raito BV in this regard are described in the Information Security Policy, a copy of which is available to you upon request.

In the event of a Breach and violation of the availability, integrity or confidentiality of Personal Data, Raito BV will notify the Personal Data Breach to the Data Protection Authority within 72 hours of becoming aware of it, unless the Breach is unlikely to pose any risk to your rights and freedoms. Raito BV will notify the Personal Data Breach to you if it is likely that the Breach poses any risk to your rights and freedoms.

Under no circumstances can Raito BV be held liable for any direct or indirect damage resulting from an erroneous or unlawful use by a third party of the Personal Data.

8. How do we record Processing Activities?

To the extent required by law, Raito BV will keep a register of the Processing activities carried out by it or under its responsibility. In that case, the register will contain the information required by the
GDPR, such as the name and contact details of the Data Protection Officer, the Processing purposes, the description of the categories of data subjects, of Personal Data and of recipients, the retention period, etc.

9. What are YOUR rights as a data subject?

In connection with the Personal Data, you have the following rights as guaranteed by the GDPR .

  • Right of inspection: you have the right to acquaint yourself, free of charge, with the Personal Data we Process and to be notified of the purposes for which we Process it.
  • Right of correction: you have the right to obtain the correction of Personal Data, as well as to complete incomplete Personal Data.
  • Right to erasure or restriction of the Personal Data: you have the right to request Raito BV to erase the Personal Data or restrict its Processing as stipulated by the GDPR, except when Raito BV may refuse to do so for the fulfilment of a legal obligation, the performance of the contract or our legitimate interest, as regards the Personal Data collected for these purposes.
  • Right to data portability: you have the right to obtain the Personal Data you have provided to us in a structured, common and machine-readable form or to have it transferred to another controller.
  • Right to object: you have the right to object to the Processing of your Personal Data for serious and legitimate motives, except where Raito BV may refuse to do so for the performance of a legal obligation, the performance of the contract or our legitimate interest, as regards the Personal Data collected for these purposes.
  • Right to withdraw consent: If the Processing of Personal Data is based on prior consent, you have the right to withdraw this consent.

To exercise the aforementioned rights, please contact us by email at the following email address info@raito.io. We reserve the right to contact you and request additional information in order to verify your identity. You will receive confirmation of your request within thirty (30) days free of charge, it being understood that this period can be extended by an additional thirty (30) days, provided that Raito BV considers the request in question to be complex.

We make every effort to handle Personal Data in a careful and lawful manner in accordance with applicable regulations. If, nevertheless, you consider that your rights would have been violated and we do not deal with your concerns in an appropriate manner, you are free to lodge a complaint with: Data Protection Authority, Drukpersstraat 35, 1000 Brussels (Tel. 02 274 48 00 - Fax. 02 274 48 35 - E-mail: contact@apd-gba.be)

10. Which law applies and which court has jurisdiction?

This Policy Statement shall be governed by and construed in accordance with Belgian law. All disputes relating to this Policy Statement, including its interpretation, as well as disputes relating to the protection of Personal Data shall fall within the exclusive jurisdiction of the courts of the district of Brussels, without prejudice to mandatory legal provisions to the contrary. Before taking any legal action, all parties concerned shall take all possible measures to settle their dispute amicably.

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