Privacy Policy – Cyclop SRL

Introduction

This personal data protection policy (the “Privacy Policy”) informs you of the ways in which we process your personal data (the “Data”) and of your rights. We believe that the confidentiality and security of your personal data is extremely important.

Cyclop.com is committed to protecting your privacy and personal data in compliance with applicable Belgian and European data protection legislation, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data (the “Framework Act”).

1. Controller

The data controller responsible for the processing of your personal data is:

CYCLOP SRL
Brussels
Belgium
BE 0735530907
Operating under the name “Cyclop.com”

For all questions about the processing of your personal data, please contact our data protection officer at: privacy@cyclop.com

2. Scope of Application

This Privacy Policy applies to all visitors and users of the Cyclop.com website and services. It explains how we collect, process, use and transfer your personal data.

The Privacy Policy was last updated on [Current Date]. We reserve the right to modify this Privacy Policy at any time. Any substantial changes will be clearly communicated to you. We advise you to consult this document regularly.

3. Types of Personal Data Processed

We collect and process only the personal data that is necessary for the purposes described in this Privacy Policy. The categories of personal data we may process include:

Basic identification data (name, address, email address, telephone number)
Account information (username, password)
Technical data (IP address, browser type, device information)
Usage data (pages visited, features used, time spent on the website)
Communication data (inquiries, feedback, correspondence)
Marketing preferences (subscription status, interests)
Transaction data (if applicable)
Any other information you voluntarily provide to us

4. Purposes of Processing

We process your personal data for the following purposes:

To provide and improve our services
To create and manage your user account
To respond to your inquiries and requests
To send you service-related communications
To ensure the security and proper functioning of our website
To analyze and improve the user experience
To comply with legal obligations
For direct marketing purposes, where you have given your consent
For other purposes for which you have given specific consent

5. Legal Basis for Processing

We process your personal data based on one or more of the following legal grounds:

Your consent
The necessity to perform a contract with you
The necessity to comply with our legal obligations
Our legitimate interests, which do not override your fundamental rights and freedoms
The performance of a task carried out in the public interest (if applicable)

Where the processing is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

6. Data Retention Period

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Specific retention periods vary depending on the category of data and the purpose of processing. The criteria used to determine our retention periods include:

The period needed to provide you with our services
Legal obligations requiring us to keep data for a certain period
Statute of limitations under applicable law
Potential disputes and the need for evidence
Guidelines issued by relevant data protection authorities

7. Recipients of Your Personal Data

Your personal data may be shared with the following categories of recipients:

Our employees and contractors who need access to provide our services
Third-party service providers who process data on our behalf (e.g., hosting providers, payment processors)
Professional advisers (e.g., lawyers, accountants)
Government authorities and law enforcement, when required by law

All third parties processing data on our behalf are required to provide sufficient guarantees to implement appropriate technical and organizational measures to ensure the protection of your data.

8. International Data Transfers

Your personal data is primarily stored and processed within the European Economic Area (EEA). However, in some cases, your data may be transferred to countries outside the EEA.

When transferring your data outside the EEA, we ensure a similar degree of protection by implementing at least one of the following safeguards:

Transferring to countries that have been deemed to provide an adequate level of protection by the European Commission
Using specific contracts approved by the European Commission (Standard Contractual Clauses)
Implementing supplementary measures as recommended by the European Data Protection Board

9. Cookies and Similar Technologies

Our website uses cookies and similar technologies to improve your browsing experience, analyze site traffic, and personalize content. Under Belgian law, we categorize cookies as follows:

Cookies that do not require consent:

Strictly necessary cookies: These cookies are essential for the proper functioning of our website and cannot be disabled.

Cookies that require consent:

Analytics cookies: These cookies help us understand how visitors interact with our website.
Advertising cookies: These cookies are used to deliver personalized advertisements.
Social media cookies: These cookies enable social sharing features and connections to social networks.

In accordance with Belgian law, we will only place cookies that require consent after you have expressly given your consent through our cookie banner. We do not use cookie walls to force consent.

For more information on the specific cookies we use, their purposes, and how to manage your preferences, please refer to our Cookie Policy.

10. Your Rights

Under the GDPR and Belgian data protection law, you have the following rights:

Right of access: You can request information about the personal data we hold about you.
Right to rectification: You can request correction of inaccurate or incomplete data.
Right to erasure: You can request that we delete your personal data in certain circumstances.
Right to restriction of processing: You can request that we limit the processing of your data in certain circumstances.
Right to data portability: You can request to receive your data in a structured, commonly used and machine-readable format or have it transferred to another controller.
Right to object: You can object to the processing of your personal data at any time, particularly for direct marketing purposes.
Rights related to automated decision-making: You have the right not to be subject to a decision based solely on automated processing that produces legal effects.

To exercise your rights, please contact us at privacy@cyclop.com. We will respond to your request within one month. This period may be extended by two additional months where necessary, taking into account the complexity and number of requests.

11. Security Measures

We have implemented appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include:

Encryption of sensitive data
Regular testing, assessment, and evaluation of the effectiveness of our security measures
Regular data backup procedures
Access controls and authentication procedures
Staff training on data protection and security
Data protection impact assessments where necessary

12. Data Breaches

In case of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Belgian Data Protection Authority without undue delay and, where feasible, not later than 72 hours after having become aware of it.

If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly, unless we have implemented appropriate measures to protect the data or it would involve disproportionate effort.

13. Complaints

If you believe that our processing of your personal data infringes data protection laws, you have the right to lodge a complaint with the Belgian Data Protection Authority:

Belgian Data Protection Authority (GBA/APD)
Rue de la Presse 35, 1000 Brussels
Tel: +32 2 274 48 00
Email: contact@apd-gba.be
Website: https://www.dataprotectionauthority.be/

However, we encourage you to contact us first so that we can try to resolve your concern.

14. Children’s Privacy

Our services are not directed to children under the age of 13. In accordance with Belgian law, we do not knowingly collect personal data from children under 13 without parental consent. If we become aware that we have collected personal data from a child under the age of 13 without verification of parental consent, we will take steps to delete that information.

15. Changes to the Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The revised policy will be posted on our website with the updated revision date. We encourage you to periodically review this page for the latest information on our privacy practices.

16. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Email: privacy@cyclop.com
Phone: [Phone Number]
Address: [Company Address]

By using our website, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.