Cookie Policy
The present cookie policy (the “Cookie Policy”) governs the use of cookies and other trackers (such as tracking pixels) (the “Cookies”) by S-Mobile, a private limited company under Belgian law, having its registered office at avenue Louise, 137/box 17, 1050 Brussels (Belgium), registered with the Crossroads Bank for Enterprises under number 0679.763.825, identified with the Belgian General Administration of Taxes (VAT) under number BE0679.763.825, and entered in the register of legal entities of Brussels (“S-Mobile”, “we”, “our” or “us”).
When you visit our website, its subdomains and directories (the “Website”), as well as our PILIM application, or when you interact with us via any other means relating to information or communication technology, a variety of information may be placed or read by your device via our use of Cookies. A “device” being any internet-enabled device through which you may access our Website, among others, your computer, smartphone and tablet.
The present Cookie Policy forms an inherent part of our Privacy Policy, which can also be found on our Website.
The purpose of our Cookie Policy is to provide you (the “User”, “you” or “your”) with all the necessary information regarding the placement and use of Cookies on your devices when you visit our Website. This policy additionally aims to let you know how we, as well as third-party service providers, use those Cookies to collect information about you.
Please note that Cookies may be placed on and read by your device as from your first visit to our Website. We refer to articles 5 and 6 of our Cookie Policy for more details regarding any choices you have regarding the management of Cookies on your devices.
1. Contact and claims
Should you have any questions about this Cookie Policy or wish to file a complaint, or should you have any question relating to the processing of your personal data, you can address all your questions to us by sending an e-mail to privacy@pilim.net or by sending a letter to our postal address, as referenced above.
Should you ever have any questions regarding our use of Cookies or wish to file a complaint in this regard, we invite you to first contact us to resolve any issues you might encounter.
If you are unsatisfied with the way your question or complaint was handled, you have the right to file a complaint with the competent data protection authority, being the authority in the Member State of your habitual residence, your place of work, or the place of the alleged infringement of the applicable Data Protection Legislation.
The Applicable Data Protection Legislation refers to the Belgian Act of 30 July 2018 on the protection of natural persons in relation to the processing of personal data, the Act of 13 June 2005 on the electronic communication, and the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016 or “GDPR”), including future adaptations and revisions of the previous.
Notwithstanding the previous, the lead data protection authority in Belgium is the Belgian Data Protection Authority (“Autorité de protection des données” or “Gegevensbeschermingsautoriteit”), which can be reached via the following means of communication:
- by following the instructions and filling in the form accessible via this link;
- by sending a letter to Drukpersstraat 35 rue de la Presse, 1000 Brussels, Belgium;
- by calling the following number +32 (0)2 274 48 00;
- by sending an email to contact@apd-gba.be.
2. How do we use cookies?
2.1. What are cookies?
Cookies are small text files that are placed on or read by your device when you visit our Website.
Cookies generally do not contain personal data allowing us to directly or indirectly identify you. However, the personal data we collect and hold on you may be linked to the information collected by the Cookies in order to execute the purposes set out in the Privacy Policy. Please refer to article 7 below to read about your rights in this respect.
Should you wish to receive more information regarding Cookies, please refer to http://www.allaboutcookies.org/ or https://www.aboutcookies.org/.
2.2. Why do we use cookies?
Cookies allow our Website to collect and store information relating to your visit. That information may then be used for various goals. You will find some examples below:
- some Cookies are used to retain your preferences regarding the storage of Cookies on your terminal when you visit our Website;
- other Cookies on our website are used to identify and track user navigation of our Website, enabling us to tailor information to fit your interests and needs. These Cookies may for example follow your use of certain pages on the Website; or
- the Cookies we use may additionally refer to Cookies detecting fraudulent activities in order to allow you to safely visit our Website.
You can find out more about the various purposes relating to our use of Cookies on the Website by scrolling down to the table in article 4.
3. Types of cookies
3.1. Distinction based on ownership
A distinction can be made based on the person or entity owning the Cookie found on the Website. Our Website uses both first-party and third-party cookies :
- First-party Cookies are placed on your device directly by the Website; and
- Third-party Cookies are placed on your device by other websites or services.
Third-party Cookies are generally used to give you access to additional services on our Website. We endeavour to identify these Cookies before they are placed so that you can decide whether or not you wish to accept them. However, we are not the owners of these Cookies and we only exercise limited control over them. The functionalities and modalities of these Cookies are for the most part subject to the decisions of their owner.
Below, you will find additional information regarding the websites and services of third parties placing Cookies on our Website:
- We use Cookies for the collection of anonymous statistical information provided by Google Analytics and Google Ads Conversion Tracker. Information about your use of our Website (including your IP address, login information, browser type, operating system, the full URLs, referring URLs and information on actions taken or interaction with our Website) may additionally be transmitted to Google and stored on their servers.
To learn more about Google Analytics and Google Ads Conversion Tracker’ use of Cookies, you can follow this link. For more information on how Google uses information from sites or apps that use its services, you can visit the following link. To opt out of being tracked by Google Analytics and Google Ads Conversion Tracker across all websites, click here.
- Our Website also makes use of social media pixels (Google, Apple, Facebook, LinkedIn, Instagram). When you visit our social media pages or otherwise share content on or with such social media, these third-party services may place Cookies on your device. You can use the following link to obtain more information regarding the use of Cookies by Facebook (Facebook Pixel).
3.2. Distinction based on purpose
Cookies may be distinguished based on the purpose for which they are used. We identify these purposes in article 3 hereunder.
3.3. Distinction based on duration
Cookies may be distinguished based on the duration for which they are stored before they expire. In terms of duration, we may use two different types of Cookies on our Website:
- Session Cookies: These Cookies are temporary Cookies that remain on your device until you leave our Website; and Persistent Cookies: These Cookies remain stored on your device for much longer or until you manually delete them. How long the Cookie remains on your device will depend on the duration or “lifetime” of the specific Cookie (seven (7) days for instance), as well as your browser settings, as set out below.
4. Which cookies do we use?
4.1.Strictly necessary cookies
These cookies allow you to navigate our Website or allow us to provide certain features necessary to its functioning.
These Cookies are pre-enabled as they do not require your consent.
You are however free to switch them off (for more information, scroll down to articles 5 and 6). Please note that in such instance, our Website would not be able to provide its basic functions and would therefore not properly operate.
E.g. Cookie allowing to remember the chosen option in the Cookie banner
Cookie name
/
Cookie purpose
/
Cookie owner
/
Retention period
/
4.2. Functionality cookies
These Cookies improve your experience by retaining your preferences and the choices you make on our Website.
E.g. Cookies allowing to remember your language preferences on our Website
Cookie name
/
Cookie purpose
/
Cookie owner
/
Retention period
/
4.3. Performance cookies
These Cookies help us gather data about how you use our Website and enable us to improve the performance of our Website.
E.g. Cookies helping us to gather statistical data on how you use our Website, such as the time you spend on a page, which pages you visit etc.
Cookie name
_gat
_ga
_gid
Cookie purpose
These are all Google Analytics Cookies helping us to gather statistical data on how Clients use our Website._gat is used to throttle the request rate to limit the collection of data on high traffic sites._ga and _gid are used to generate statistical data on how you use our Website.
Cookie owner
Retention period
_gat and _gid (Persistent – 1 day)_ga (Persistent – 2 years)
_gcl
Associated with Google Ads Conversion Tracking, this Cookie is used to measure the effectiveness of advertising campaigns run via Google Ads. _gcl helps the Website to understand which ads and clicks lead to conversions, such as submissions for instance.
_gcl (Persistent – 90 days)
fbc
This Facebook Pixel cookie is used to help track user interactions with the Website for advertising and analytics purposes, i.e. measuring the effectiveness of Facebook ad campaigns.
fbc is used for tracking Facebook ad clicks that lead users to the Website and attributing any conversions back to a specific ad.
fbc (Persistent – 90 days)
Cookie name
_gat_ga_gid
Cookie purpose
These are all Google Analytics Cookies helping us to gather statistical data on how Clients use our Website._gat is used to throttle the request rate to limit the collection of data on high traffic sites._ga and _gid are used to generate statistical data on how you use our Website.
Cookie owner
Retention period
_gat and _gid (Persistent – 1 day)_ga (Persistent – 2 years)
Cookie name
_gcl
Cookie purpose
Associated with Google Ads Conversion Tracking, this Cookie is used to measure the effectiveness of advertising campaigns run via Google Ads. _gcl helps the Website to understand which ads and clicks lead to conversions, such as submissions for instance.
Cookie owner
Retention period
_gcl (Persistent – 90 days)
Cookie name
fbc
Cookie purpose
This Facebook Pixel cookie is used to help track user interactions with the Website for advertising and analytics purposes, i.e. measuring the effectiveness of Facebook ad campaigns.fbc is used for tracking Facebook ad clicks that lead users to the Website and attributing any conversions back to a specific ad.
Cookie owner
Retention period
fbc (Persistent – 90 days)
4.4. Marketing cookies
These Cookies are used to gather information about you and display ads that are relevant and engaging for you so that our Website can be better tailored to your interests and needs.
These Cookies can follow you when you use other websites since they are usually installed by third parties.
Our Website does not show advertising. However, certain information relating to your visit may be collected and used by the owners of the third-party Cookies for displaying advertisements on other websites.
To opt out of being tracked by marketing Cookies, follow the instructions in articles 5 and 6 below.
E.g. Cookies used by social media platforms, displaying personalized advertisements when you log into your social media account
Cookie name
fbp
Cookie purpose
This Facebook Pixel cookie is used to help track user interactions with the Website for advertising and analytics purposes, i.e. measuring the effectiveness of Facebook ad campaigns.
fbp is used to identify and track users across the Website for retargeting and personalized advertising purposes.
Cookie owner
Retention period
fbp (Persistent – 90 days)
Cookie name
fbp
Cookie purpose
This Facebook Pixel cookie is used to help track user interactions with the Website for advertising and analytics purposes, i.e. measuring the effectiveness of Facebook ad campaigns.fbp is used to identify and track users across the Website for retargeting and personalized advertising purposes.
Cookie owner
Retention period
fbp (Persistent – 90 days)
5. Consent
When you visit the Website for the first time, we ensure that we obtain your consent to the use of Cookies on the Website by way of the Cookie banner (“Cookie Banner”), after which the banner will disappear.
You will be prompted to accept or refuse the use of Cookies on our Website. You may also restrict their use by choosing which Cookies you allow on your device.
We will remember your choices for your entire Website visit and during a six (6)-months’ period. You may change your Cookie settings or withdraw your consent at any time by following the instructions referenced under article 6 below.
To the extent required by the applicable law, we will always request your consent before collecting personal data using Cookies.
6. Cookie management
Some people prefer not to allow Cookies to be installed on their devices. You have the right to refuse the placement of Cookies, or the Cookies being read by your device. Below, we set out some options you have at your disposal in that regard.
Please note that if you choose to restrict or disable the use of Cookies, some areas of our Website and/or our services, as well as the features, may not function as intended.
6.1. Cookie settings tool
You can resummon the Cookie Banner at any time to recalibrate the Cookies you wish to be placed on or read by your device. This can be done through our Cookie settings tool […].
6.2. Cookie management in your browser
You may also restrict or disable the use of Cookies through your web browser. It is possible to delete currently installed Cookies on your device. Each type of web browser offers ways to be notified about, to restrict, and delete Cookies. Please visit the websites of the different browsers to learn how to block the storage of Cookies:
If you use multiple devices to view and access our Website, such as your computer, smartphone or tablet, you may have to ensure that each browser on each device is adjusted to suit your Cookie preferences. Please note that if you choose to restrict or disable the use of Cookies through your browser, some areas of our Website and/or our services, as well as the features, may not function as intended.
7. Your rights
Should we collect personal data through our Cookies, please note that there are certain rights that you can exercise:
- Withdrawal of consent (see articles 5 and 6 above).
- Right of access.
- Right of rectification.
- Right of erasure.
- Right to restrict the processing.
- Right to object to the processing.
- Right to data portability.
For more information regarding the exercise of your rights, we refer to the applicable article in our Privacy Policy.
8. Changes to Cookie Policy
We may bring adaptations and improvements to the Cookie Policy from time to time. These changes will mainly be made to account for new case law and practices developing in the data protection field, to ensure your control over your personal data.
The most current version of the Cookie Policy will always be displayed on the Website and can be requested via email (privacy@pilim.net). On top of this Cookie Policy, you will be able to check the date on which we last implemented changes to the policy. Please contact us should you wish to consult earlier versions thereof.