Privacy Policy

Preamble

The purpose of this policy is to explain transparently to the concerned individuals how their data is processed and to inform them about the measures taken to preserve its confidentiality and security.

We inform you that this policy may be modified at any time. It is therefore advisable to consult it regularly.

1. Data Controller

The data controller for the collected and processed data is the name of your company, hereinafter referred to as 'We, our, us'.
We are established at the address of your company.
Our BCE number is n°

As the data controller, we must comply with several obligations such as, for example: ensuring your rights, notifying you of any security breaches, maintaining a register, etc.

2. What data do we process?

Only adequate, relevant, and limited data to the purpose of the processing can be processed.
The methods of collection and the data processed may vary depending on the purposes of the processing.

Collected and processed data Collection methods
Purpose: Customer management, which includes contracts, invoices, and accounting, as well as customer account management.
Collected data:
  • identification data (name, first name, age, address, phone number)
  • electronic identification data
  • billing data

3. How do we justify your processing?

The processing of personal data includes any possible operation on this data, such as its collection, recording, use, or storage.

Any data processing must necessarily be based on a legal basis determined by the GDPR.

Purpose of use Legal basis for processing
Customer management, which includes contracts, invoices, and accounting, as well as customer account management. The legal basis is the performance of a contract concluded with you (Article 6.1.b) GDPR).

4. Are my data retained?

Data cannot be retained longer than necessary.
It is therefore necessary to set the retention period in this policy.

Purposes Retention period

5. Are my data shared?

We share your data within the scope of our activities with our staff or with our duly authorized suppliers or subcontractors.
For example, we may share your data with our accountant, our email service provider, the post office, etc.

We share your data with supervisory authorities, courts, and government agencies when a legal obligation, regulation, or judicial process requires us to do so.

We may also transmit your data in good faith, considering that this action is required to comply with any applicable regulation but also to protect and defend our rights or those of other users of our services.

In all circumstances, we ensure the protection of your data through confidentiality agreements.
We maintain a list of our subcontractors, but for security reasons, it is only communicated upon request and as soon as possible. You can contact us at the following address contact@trackoh.com

6. Are my data transferred abroad?

Some of your data is transferred within the European Union. Within this area, personal data benefits from the same level of protection as in Belgium.

We do not transfer data outside the European Union.

If we were to transfer data outside the Union or grant access to a subcontractor, provider, or third party located outside the Union, this is only authorized if and only if:
- The European Commission has issued an adequacy decision granting an adequate and equivalent level of protection to that provided by European legislation, personal data will be transferred on this basis.
- Appropriate safeguards have been implemented in accordance with the GDPR, such as the Commission's Standard Clauses, approved binding corporate rules, an approved code of conduct, or consent.

7. What are my rights as a data subject?

You have rights as a data subject. These rights are as follows: the right to access your collected data, including the right to know if we process your data; the right to have a copy of the processed data; the right to rectify the processed data if it is incorrect, incomplete, or irrelevant; the right to be forgotten, i.e., the right to ask us to delete your data if it is no longer necessary for the processing(s) or if you withdraw your consent; the right to data portability, i.e., the right to ask us to transfer or share your data.

Furthermore, you have the right to object to processing when it is based on our legitimate interest or the right to withdraw your consent when the processing is based on it.

You can also limit the processing of your personal data:
- If you dispute the accuracy of this data. Pending the evaluation of the interests at stake before exercising the right to object to the processing of some of your personal data.
- If the processing of your personal data is unlawful, but you nevertheless do not wish to exercise your right to data erasure.
- If we no longer need your personal data, but you need it in the context of legal action.

To exercise these rights, you can contact us at the following address contact@trackoh.com.

We remind you that these rights are not absolute. If we have a legal obligation that prevents us from complying with the exercise of your rights, we will inform you accordingly.

8. Where can I file a complaint?

If you need more information about your rights, contact us.
You can exercise your rights by sending an email to the following address: [email] or by postal mail to the following address: [address].
You can always contact our data protection officer.

We will respond to your request as soon as possible and no later than one month after receiving your request, we will inform you of the actions taken.
Depending on the complexity of your request or the number of requests we receive from other individuals, this period may be extended by two months. In this case, we will inform you of this extension within one month of receiving your request.

In all circumstances, when communicating this information, we are always obliged to consider the rights and freedoms of other individuals.

You can always file a complaint with the Data Protection Authority:
www.autoriteprotectiondonnees.be/
Rue de la Presse, 35 in 1000 Brussels
Tel.: +32 (0)2 274 48 00
Fax: +32 (0)2 274 48 35
Email: contact@apd-gba.be

For more information on complaints and possible remedies, you are invited to consult the following address of the Data Protection Authority:
https://www.autoriteprotectiondonnees.be/introduire-une-plainte

You can also file a complaint with the court of first instance of your domicile.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against any accidental or unlawful alteration or loss, or against any unauthorized use, disclosure, or access.

We take all reasonable measures under the principles of privacy by design and privacy by default to implement the necessary safeguards and secure the processing of your data.

Trackoh commits to providing a detailed list of security measures implemented to protect the processed personal data upon request.

10. Cookies

We use cookies on our website.

For more information on our Cookie Policy, please visit our website under the 'Cookies Policy' tab.

11. Applicable Law and Jurisdiction

This policy is governed by Belgian law.

Any dispute relating to the interpretation or execution of this Policy will be subject to the exclusive jurisdiction of the courts of the judicial district of Charleroi.

12. Update of this policy

We reserve the right to modify this privacy policy to reflect legislative or regulatory changes or to adapt it to our practices.

We therefore invite you to consult it regularly.

Last updated on April 7, 2025.