Privacy Policy

The present privacy policy (the “Privacy Policy”) governs the processing of your personal data 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 (French-speaking section) (“S-Mobile”, “we”, “our” or “us”).

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The privacy and security of your (“you” or “your”) personal data are very important to us. The purpose of this Privacy Policy is to specify:

  • the (categories of) personal data we collect and process in relation to the services we provide through our website (the “Website”) and PILIM app (the “Application”);
  • the purposes for which we collect and process your personal data and the legal basis we rely on in this respect;
  • the retention period of your personal data;
  • with whom we may share your personal data;
  • when applicable, the transfer of personal data outside of the European Union or with international organisations;
  • which rights you may exercise in relation to (the processing of) your personal data; and
  • the security measures that are implemented to ensure protection and privacy of your personal data.

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We advise you to read our Privacy Policy carefully, as well as our Cookie Policy. The Cookie Policy forms an integral part of our Privacy Policy.

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1. General and contact information

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For the purpose of the Privacy Policy, we are to be considered the controller of your personal data. This means that the applicable data privacy legislation imposes certain obligations on us. The aforementioned legislation includes in particular:

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  • the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016, GDPR);
  • the Belgian Act of 30 July 2018 on the protection of natural persons in relation to the processing of personal data; and
  • the Act of 13 June 2005 on the electronic communication;

hereinafter collectively referred to as the “Applicable Data Protection Legislation”, including future adaptations and revisions of the previous.

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Should you have any questions regarding this Privacy Policy, or should you feel that your interests are not or are inadequately represented, please address your questions to us at privacy@pilim.net. 

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In addition, you have the right to lodge a complaint at or to request more information from the competent Data Protection Authority as explained in the Cookie Policy. Should you ever have any questions or complaints, we invite you to first contact us to resolve any issues you might encounter.

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2. Personal data we collect and process

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The personal data we collect and process about you will always be linked to the specific purposes set out hereunder.

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We may gather personal data that you choose to share directly with us, for instance when you contact with us by e-mail, when you create a user account on our Application or when you use the contact form on our Platform to reach out to us. We may also collect your personal data through any other communication or telecommunication technology, notably through automated means, such as Cookies for instance. Please refer to our Cookie Policy for more information relating to our processing of personal data via cookies and similar technologies.

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Please find below a more detailed overview of the relevant categories of personal data we gather and process, the purposes of the processing and more generally, how we process your personal data.

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2.1 PERSONAL DATA WE PROCESS WHEN YOU VISIT OUR PLATFORM

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  • PURPOSES

We use different types of cookies: 
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- Cookies that are technically essential and for functional purposes

These cookies are necessary for a website to function properly, and it is not possible to refuse them. However, we     don’t use such cookies to manage our Website and its content (including our cookies).

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- Cookies for sharing on social networks

We use Facebook Pixel to enable the sharing of the Website pages on social networks. These are therefore third-    party cookies (indirect cookies). This means that we do not control the information collected via these cookies; and

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- Cookies for analytical purposes

We also use Google Analytics, Google Ads Conversion Tracker and Facebook Pixel for analytical purposes. These     analysis tools install cookies which we use to quantify visits (traffic) to the Website. This allows us to know how     many times a given page has been read and to measure the conversation rate. We use this information solely to     improve the content of our Website and Application. These are third-party cookies (indirect cookies). This means that     we do not control the information collected via these cookies.

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  • LEGAL BASIS

- Technically essential and functional cookies: necessary for the performance of the service (article 6.1.b of the         RGPD); and

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- Other cookies (social network sharing and analytical): the use of these third-party cookies, for which we are the         joint controller, is subject to your prior consent (Article 6.1.a of the RGPD).

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You may refuse to have these cookies installed on your device. This will not prevent you from accessing our Website     or Application. However, certain functions may not be available.

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  • CATEGORIES OF PERSONAL DATA

We refer you to our Cookie Policy detailing the different data collected according to your choices.

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  • RETENTION PERIOD

Cookies generally have an expiration date. For example, some cookies are automatically deleted when you close     your browser (session cookies), while others stay on your computer for longer, sometimes even until you delete them     manually (permanent cookies).

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  • RECIPIENTS

- Google;

- Apple;

- Facebooks;

- Linkedin; and

- Instagram;

Communication of your data to our service providers and subcontractors (IT service providers or hosts among others)     may also be necessary.

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2.2 PERSONAL DATA WE PROCESS WHEN YOU VISIT OUR PLATFORM

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CREATION OF A USER ACCOUNT

  • PURPOSES

If you wish to benefit from our services, your data will be processed in order to create an account on our Website.

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  • LEGAL BASIS

The processing of this data is essential for the execution of the conditions of use which bind you to the Platform     (article 6.1.b) GDPR).

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  • CATEGORIES OF PERSONAL DATA

This concerns your identification data (full name, address, email address, phone number, date and place of birth,     nationality, ID number, passport number, gender, language, bank account details).

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  • RETENTION PERIOD

The data is processed for a period of ten (10) years from the closure of your account.

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  • RECIPIENTS

This data will be communicated to the tax administration. Communication to our service providers and     subcontractors (IT service providers, accountant, auditor) may be necessary.

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ADMINISTRATION AND ACCOUNTING

  • PURPOSES

The data you send us is processed to ensure the administrative management as well as the accounting and tax     management of your account or the services that you order from us.

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  • LEGAL BASIS

The processing of this data is essential for the execution of the agreement which binds us (article 6.1.b) GDPR), in particular the establishment of invoices, the tracking of orders, the notification of a modification of our conditions of use or of the Privacy Policy (including new purposes).

The processing of this data is also necessary for the fulfillment of our legal obligations, in particular under the Code of Economic Law and the VAT Code in tax and accounting matters (article 6.1.c) GDPR).

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  • CATEGORIES OF PERSONAL DATA

These are:

- your identification data (last name, first name, email, address, telephone number, company number, VAT number);

- invoices issued and payments; and

- your financial data (bank account number).

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  • RETENTION PERIOD

The data is processed for a period of ten (10) years from the closure of your account.

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  • RECIPIENTS

This data will be communicated to the tax administration. Communication to our service providers and subcontractors (IT service providers, accountant, auditor) may be necessary.

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NEWSLETTER

  • PURPOSES

If you have subscribed to our information service, we process your data to provide you with free newsletters.

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  • LEGAL BASIS

The data is processed on the basis of the execution of the service supply contract (article 6.1.b) of the GDPR).

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  • CATEGORIES OF PERSONAL DATA

These are your first name, last name and email address.

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  • RETENTION PERIOD

The data is processed until you terminate this service.

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  • RECIPIENTS

The communication of your data to our service providers and subcontractors (IT service providers, emailing and direct mail, etc.) may also be necessary.

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PERSONAL DATA WE PROCESS WHEN YOU PROVIDE SERVICES TO THE PLATFORM

  • PURPOSES

The data that you transmit to us is processed to manage our contractual relationship: management of orders, offers, delivery, invoicing and payment and evaluation of the supplier's service (if applicable).

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  • LEGAL BASIS

The processing of data is essential for the execution of the contract. Without processing this data, we cannot execute the contract (article 6.1.b) GDPR).

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  • CATEGORIES OF PERSONAL DATA

This could be:

- your identification data (first name, last name, spouse’s information); 

- your contact data (email address, telephone number);

- your data relating to the profession (company, function); 

- your financial/accounting information (bank account number, account holder); 

- data relating to the monitoring of services.

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  • RETENTION PERIOD

Your data is kept for ten (10) years from the closure of your account.

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  • RECIPIENTS

This data will be communicated to the tax administration. Communication could also be necessary with regard to our service providers (IT service providers, accountant, auditor).

In the event of a dispute, the communication of your data to our lawyer, other parties or their lawyers, the courts, experts, technical advisers, notaries, mediators, arbitrators or bailiffs, banking or insurance organizations may be necessary.

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3. International data transfers

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Our offices are located in Belgium and the personal data we collect is stored on servers in Europe.  

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However, for the purposes set out in article 2, your personal data may be transferred to other jurisdictions outside the European Economic Area (EEA), and therefore not bound by the GDPR. Your data may also be hosted on servers outside the EEA.

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Where your personal data is transferred to third parties residing in such jurisdictions, we will implement appropriate safeguards in our agreement with such third parties to ensure that your personal data receives an adequate level of data protection and at least equivalent to the level to which you are entitled under the GDPR. To this end, we assess the level of data protection in the country of transit or destination, taking into account in particular the relevant decisions taken by the European Commission. We may use the Standard Contractual Clauses adopted by the European Commission and any other appropriate solution, as required or permitted by Applicable Data Protection Legislation.

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4. Your data protection rights

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Under Applicable Data Protection Legislation, you have certain rights in relation to your personal data that we collect and process.

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If you would like further information about your rights as listed below or if you wish to exercise them, please do not hesitate to send us an e-mail to privacy@pilim.net. We simply ask you, when exercising your data protection rights, to identify yourself correctly so that we can respond to your request within the time limits indicated below.

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Exercising your rights is free of charge and will be carried out within one (1) month of receipt of your request. We may extend this period by a further two (2) months for a total period of three (3) months if your request is particularly complex. If we decide to extend the initial deadline, we will inform you of this decision in good time. 

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In cases where we consider that your request is manifestly unfounded or excessive, we reserve the right to charge you an administrative fee for processing your request, or even to refuse to process it. You will be informed of our decision within the above-mentioned time limits.

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Below is a brief overview of the rights you may exercise in relation to your personal data (subject to our legal and contractual obligations):

  • Withdrawal of consent: you have the right to withdraw your consent for all processing activities subject to it;
  • Right of access: you have the right to request a copy of the data we process and store about you, in an understandable format;
  • Right of rectification: you have the right to ask us to correct, amend or supplement your personal data;
  • Right to erasure: you have the right to ask us to erase the personal data we process or store about you;
  • Right to restrict processing: in certain circumstances, you have the right to ask us to restrict the processing of your personal data. If you exercise this right, the relevant personal data will remain in our possession, but we will not be able to process it further;
  • Right to object to processing: where we process and collect your personal data on the basis of our legitimate interest, you have the right to object to the processing of that data;
  • Right to the portability of your data: this means that we may, at the request of the data subject, provide him or her with his or her personal data and/or provide it to third parties in a structured and machine-readable form.

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5. Security of your personal data

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We use generally accepted and reasonable technical and organizational methods, in line with current technological developments in operational security, to provide protection against the loss, misuse, alteration or destruction of any personal data we store and process.

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Our technical and organizational measures are frequently updated in order to adapt these measures to new technical and organizational procedures and to guarantee the ongoing security of your personal data.

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Our Website and Application may contain links to other websites or Internet resources (the “Third Party Sites”), which may also collect personal data, in particular by means of cookies or other technologies. We are not responsible for and have no control over these Third-Party Sites or their collection, use or disclosure of your personal data. We invite you to examine the privacy policies of these Third-Party Sites in order to understand how they collect and process your personal data.

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6. Amendments to the Privacy Policy

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We may adapt and amend our Privacy Policy from time to time, in particular to take account of new data protection practices and to give you better control over your personal data.

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We will always make our Privacy Policy available on the Website in its most recent version. You can also ask us to send you the current or previous versions of our Privacy Policy by sending us an e-mail to privacy@pilim.net. At the top of this document, you will be able to check the date on which we last modified our Privacy Policy.

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7. Your questions and queries

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You undertake to provide us with accurate personal data. You can change your personal data at any time by sending us an e-mail to privacy@pilim.net. We cannot be held responsible for any failure of our services due to incorrect information provided by you.

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If you have any questions about our Privacy Policy or if you feel that your interests are not or are not adequately represented, please send all your questions to the above e-mail address.

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8. Applicable law and dispute resolution

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Our Privacy Policy is governed by and interpreted in accordance with Belgian law, unless mandatory legal provisions state otherwise.

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You have the right to lodge a complaint with the competent data protection authority, i.e. the authority of the Member State of your habitual residence, your place of work or the place of the alleged breach of Applicable Data Protection Legislation.

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The lead data protection authority is the Belgian Data Protection Authority (“Autorité de protection des données” or “Gegevensbeschermingsautoriteit”), which can be reached via the following means of communication:

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  • 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;