Privacy Policy

Privacy Policy regarding the processing of personal data of customers and website users

1. Introduction

Welcome to the ICT Vision website.

ICT Vision (hereinafter ‘ICT Vision’ or ‘we’) recognises the importance of respecting privacy and protecting the personal data of its customers and website visitors.

In this policy, we set out how we process your personal data.

2. Scope

This website is operated by ICT Vision. We act as the data controller when we process the personal data of our customers and website users.

It is important to us to create and maintain an environment in which our customers can be assured that their information will not be misused.

We comply with the applicable data protection regulations, in particular the General Data Protection Regulation 2016/679 (hereinafter ‘GDPR’) and the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.

These regulations concern the protection of your personal data and confer rights upon you in relation to such data.

The purpose of this policy is to inform you of what personal data we collect and how it will be used following your visit to our website, as well as to assure you that it will be processed correctly.

When you visit our website, this privacy policy and the terms of use apply.

The application of any terms and conditions other than this policy is expressly excluded, unless we have given our prior written consent. In the latter case, this policy will continue to apply in addition to any specific agreements.

Use of this website and its content is permitted only subject to compliance with this policy.

If you do not accept and comply with this policy in its entirety, you must cease using the website and its content.

3. Interpretation

Where terms defined in the GDPR appear in the provisions of this policy, they shall have the same meaning as in that Regulation.

This applies in particular to the following terms: ‘personal data’, ‘sensitive data’, ‘processing’, ‘data controller’, ‘purpose’, ‘legal basis’, ‘legitimate interest’, ‘consent’, ‘technical and organisational measures’, etc.

As a reminder, personal data is any information that enables the direct or indirect identification of an individual natural person, including first name and surname, age, postal address or email address, telephone number and any other element defined as personal data, such as an IP address.

4. Identity of the data controller

ICT Vision SRL
Avenue Louise 209A B.7
1050 Ixelles (Brussels)
Belgium

VAT No.: BE0798.804.304
BCE: 0798.804.304

Tel.: 02/318.16.48
Email: contact@ictvision.be
Website: https://ictvision.be

Data Protection Officer (DPO)

ICT Vision has not appointed a Data Protection Officer (DPO), as it is not subject to this obligation in view of its activities (Article 37 of the GDPR and the Belgian Act of 30 July 2018).

If you have any questions regarding the protection of your data, please contact us at the address above.

5. Personal data we collect about you

Most of our website is accessible without you having to provide any personal data.

We may collect and process your personal data in connection with our following activities.

5.1 Information you provide to us

This refers to information we receive directly from the data subject, in particular personal data collected via online forms on our website.

You provide us with personal information when, for example, you fill in an online form to contact us, download documents, book an appointment, request a quote or a demonstration of our solutions, register for an event, subscribe to a newsletter, etc.

This includes the following categories of personal data:

  • First name and surname
  • Email address
  • Telephone number
  • Company/organisation on whose behalf the request is made

Additional information may sometimes be requested (size of the organisation, the person’s role within the organisation, sector of activity, etc.).

The information we request is limited to what we need to process your enquiry as effectively as possible and to pursue our legitimate interest, namely to contact the person to find out how we can meet their needs.

5.2 Publicly available information

This refers to information we can find in publicly available sources, including:

  • The data subject’s public profile on LinkedIn
  • The website of the company or organisation on whose behalf the data subject is making the request
  • Official public registers (BCE/KBO, Belgian Official Gazette, etc.)
  • Professional directories

We may combine this publicly available information with the information you provide to us in order to verify the data we have previously collected and to manage and expand our activities, on the basis of our legitimate interest (Article 6(1)(f) of the GDPR).

5.3 Information we collect using cookies

When you visit our website, data about you is automatically but passively collected using cookies and is based on your online habits and behaviour.

We may collect information including:

  • Your IP address
  • The pages of our website that you visit
  • Your geolocation
  • The language used to view our website
  • Where you came from (if you found us via a search engine, an advertising campaign, social media, etc.)

You can find further information on how we use cookies in our Cookie Policy.

6. Purposes of processing your personal data

We collect the above information in order to better understand your needs and provide you with a better service, and in particular for the following purposes.

Customer relationship management

When you order a product or service via our website, we may use your personal data for the purposes of managing and monitoring our customer relationships.

This includes, in particular:

  • Providing you with the products and services you have ordered
  • Verifying your identity and financial details for the payment of our products and services
  • Managing contracts and contractual obligations
  • Improving our products and services
  • Investigating complaints regarding our products or services or relating to our website

Communication

We will respond to all enquiries you submit via our website, including requests for documentation, support, assistance or demonstrations regarding our products and services, event registrations, complaints, price enquiries and any other matter covered by an online form relating to our products and services or in connection with the website.

For example, we may use your personal data to call you back or contact you by email, LinkedIn or any other communication channel.

Direct marketing

We may use your personal data for direct marketing purposes, to provide you with specific information you have requested on our website or more general information about ICT Vision’s offering.

This also includes sending invitations to events, newsletters, etc.

We will only carry out marketing activities on the basis of your explicit consent or if you have a contractual relationship with us and the information sent is related to the contract entered into.

Recruitment

When you submit a CV or apply for a job on the ICT Vision website, we will use your personal data for recruitment purposes, where necessary to contact you by email or telephone.

Improving our website

We will continuously use and analyse data from visitors to our website to improve the user experience.

Legal obligations

We are also authorised to retain personal data to comply with legal and regulatory obligations, as well as compliance obligations and requirements.

7. Legal basis for the processing of your personal data

We endeavour to process your personal data in strict compliance with applicable legislation and, more specifically, on the following legal bases set out in Articles 6(1)(a), (b), (c) and (f) of the GDPR:

Consent of the data subject

If you are not yet a customer, we will ask for your consent to send you electronic communications about our events, products and services for promotional purposes.

By submitting an online form on our website, you agree to provide your personal data to ICT Vision and acknowledge that ICT Vision will process it in accordance with this privacy policy.

You retain the right to withdraw your consent at any time.

Performance or preparation of a contract

We may process your personal data where such processing is necessary for the performance of our obligations under a contract for the provision of our products or services to which you are a party, or for the preparation of such a contract (for example, when providing a quotation).

Legal obligation

In certain cases, the processing of personal data and its transfer to third-party recipients is necessary to comply with a legal obligation.

Legitimate interest

Direct marketing activities (prospecting) constitute a legitimate interest under the GDPR.

The processing of personal data on the basis of a legitimate interest does not require your explicit consent.

We distinguish between three categories of activities based on the legal ground of legitimate interest:

1) Contacting data subjects who have submitted an online form

We consider that contacting data subjects who have submitted an online form on our website falls within our legitimate interest, as we will contact these individuals to follow up on their enquiries.

This task will be carried out directly by our sales team, who will use the available means for this purpose (telephone, email, LinkedIn, etc.).

However, we never send bulk marketing emails to data subjects who have not explicitly subscribed to our newsletters.

2) Keeping ICT Vision customers informed of developments at ICT Vision

A customer may receive newsletters without having given their explicit consent.

These newsletters contain information we consider useful to the customer, such as details of new features in ICT Vision solutions, invitations to events, a summary of the latest articles published on our blog, etc.

We do our utmost to ensure that the information provided to each data subject remains relevant.

However, if a data subject no longer wishes to receive our newsletters, they may unsubscribe or change their preferences at any time.

Each newsletter includes a link to unsubscribe, as well as a link to adjust email preferences.

3) Contacting potentially interested prospects

Our sales team endeavours to systematically contact companies to which ICT Vision is likely to bring added value.

To do this, our sales representatives consult public sources of information such as the internet, LinkedIn and other databases.

Where they find personal data, they may process such personal data to the extent necessary in the context of ICT Vision’s legitimate interests.

Data subjects approached in this way will never receive unsolicited direct marketing communications from ICT Vision without an appropriate legal basis.

8. Use and sharing of your personal data with third parties

ICT Vision is obliged not to sell, rent or disclose the personal data collected to third parties, except where specified at the time of collection.

We may share your personal data with:

  • Any third party with whom you have asked us to share your personal data, such as LinkedIn or other social media platforms if you have asked us to link your account.
  • Third parties who assist us in providing our products and services.

Our data processors will not be permitted to use or disclose the data for any purposes other than those strictly necessary for the performance of their duties.

They are required to comply with the GDPR and to protect the confidentiality and security of the data processed on our behalf.

These obligations are set out in a data processing agreement entered into for each collaboration.

We may also disclose your personal data in order to:

  • Enforce our policy
  • To comply with our legal obligations
  • To protect security, the public interest or other rights and interests

In the event of a sale or merger of ICT Vision’s business with another company, your data will be disclosed to the potential purchaser’s adviser and transferred to the new owners of the business.

In this case, we will take appropriate measures to ensure the integrity and confidentiality of your personal data.

9. Retention period for your personal data

Once you have provided us with your personal data, it will be processed in ICT Vision’s records and retained for as long as is necessary for the relevant processing.

Active customer data
Duration: For the duration of the business relationship.
Legal basis: Performance of the contract.

Data relating to inactive customers
Retention period: 3 years after the last activity.
Legal basis: Legitimate interest (marketing).

Prospect data (non-customers)
Retention period: 3 years after the last contact.
Justification: Legitimate interest (APD recommendation).

Invoices and accounting documents
Retention period: 10 years.
Justification: Legal obligation (Belgian accounting law).

Newsletter data
Retention period: Until you unsubscribe.
Reason: Consent (which may be withdrawn at any time).

Job applications (CV, covering letter)
Retention period: Up to 2 years after the application.
Legal basis: Legitimate interest (future opportunities).

Login logs
Retention period: 1 year.
Justification: Legal obligation (network security).

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