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PRIVACY POLICY
Updated on April 9, 2021

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1. Parts and Purpose

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Leadercom (hereinafter "Leadercom" or the "Data Controller")
8 rue d'Arlon, 1050 Ixelles, Belgium
BCE / VAT: BE43 363131828801
Mail: a.destro@leadercom.pro
Telephone: +32 477 28 17 66



Leadercom establishes this Privacy Policy, the purpose of which is to transparently inform Users of the website hosted at the following address: www.leadercom.pro, (hereinafter the " Site "), of the manner in which personal data is collected and processed by Leadercom.

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The term " User " refers to any user, either any natural or legal person, who visits or interacts in any way with the Site.

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As such, Leadercom determines all the technical, legal and organizational means and purposes for processing Users' personal data. To this end, Leadercom undertakes to take all the necessary measures to ensure that personal data is processed in accordance with the law of July 30, 2018, on the protection of individuals with regard to the processing of personal data (hereinafter: after, "the Law ") and to the European Regulation of April 26, 2016 on the protection of personal data with regard to the processing of personal data and on the free movement of such data (hereinafter the " Regulation ").

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Leadercom is free to choose any natural or legal person who processes the personal data of users at his request and on his behalf (hereinafter the " Subcontractor "). Where applicable, Leadercom undertakes to select a Subcontractor offering sufficient guarantees as to the technical and organizational security measures for the processing of personal data, with regard to the Law and the Regulations.

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2. Processing of personal data

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Use of the Site by Users may result in the communication of personal data. The processing of this data by Leadercom, in its capacity as Data Controller, or by service providers acting in the name and on behalf of Leadercom, will comply with the Law and the Regulations.

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Personal data will be processed by Leadercom, in accordance with the purposes mentioned below, via:

- A possible automated procedure
- The newsletter registration form
- The form for sending a request in the "Contact us" section
- The use of possible cookies

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3. Purpose of processing personal data

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In accordance with article 13 of the Regulations, the purposes of the processing of personal data are communicated to the User and are as follows:

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1. Ensure the execution of the services offered and agreed on the Site (for example registration for possible events)
2. Ensure the control of the execution of the services offered;
3. Carry out marketing and promotional information activities after the prior consent of the User and until revocation of this consent, for example sending promotions on the products and services of the Data Controller.
4. Respond to questions from the User
5. Produce statistics in order to improve the Website and the services offered
6. Improve the quality of the Site and of the products and / or services offered by the Data Controller.
7. Allow a better identification of the centers of interest of the User.

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4. Personal data that may be processed

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The User consents, when visiting and using the Site, that Leadercom collects and processes, in accordance with the terms and principles described in this Privacy Policy, the following personal data:

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1. User information that they provide for contractual purposes and to allow the proper performance of reciprocal obligations, namely name, first name, email address, postal address, IBAN number and bank details if necessary , and more generally, any information voluntarily given by the User.
2. Users' information by filling in forms or by contacting by telephone, email address or other means, for example the name, address, email address, telephone number of Users.
3. With regard to each of the users' visits to the Site, the information automatically collected is:

at. IP address, browser type and model, time zone, operating system
b. all the information concerning the pages that the User has consulted on the Site, in particular, the URL, the browsing time, etc.

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5. Consent

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By accessing and using the Site, the User declares to have read and given their free, specific, informed and unequivocal agreement to the processing of personal data concerning them. This agreement covers the content of this Privacy Policy.

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The consent is given by the positive act by which the User has checked the box proposing the Privacy Policy in hypertext link. This consent is an essential condition for carrying out certain operations on the Site or for allowing the User to enter into a contractual relationship with Leadercom. Any contract between Leadercom and a User relating to the services and goods offered on the Site is subject to acceptance of the Privacy Policy by the User.

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The User agrees that the Data Controller processes and collects, in accordance with the terms and principles included in this Privacy Policy, his personal data that he communicates on the Site or during the services offered by Leadercom , for the purposes indicated above.

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The User has the right to withdraw his consent at any time. The withdrawal of consent does not compromise the lawfulness of the processing based on the consent previously given.

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6. Retention period of Users' personal data

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In accordance with article 13 §2 of the Regulations and the Law, the Data Controller only keeps personal data for the time reasonably necessary to enable the fulfillment of the purposes for which they are processed.

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This period is in all cases less than: 36 months

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7. Data recipients and disclosure to third parties

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Personal data may be transmitted to Leadercom employees, employees, subcontractors or suppliers who offer adequate data security guarantees, and who collaborate with Leadercom in the context of the marketing of products or the provision of services. They act under the direct authority of Leadercom, and are responsible in particular for collecting, processing or subcontracting this data.

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In all cases, the recipients of the data and those to whom this data has been disclosed respect the content of this Privacy Policy. Leadercom ensures that they will process this data for the sole purpose provided, in a discreet and secure manner.

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In the event that the data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed beforehand so that he expresses his consent to the use of this personal data.

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8. User rights

 

At any time, the User can exercise his rights by sending a message by email to the following address: a.destro@leadercom.pro , or a letter by post addressed, attaching a copy of his identity card at the following address: 8 rue d'Arlon, 1050 Ixelles, Belgium

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at. Permission to access

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In accordance with article 15 of the Regulations, Leadercom guarantees the right of access to the User to his personal data. The User has the right to obtain access to said personal data as well as the following information:

 

  • the purposes of the processing;

  • the categories of personal data concerned;

  • the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular recipients who are established in third countries or international organizations;

  • where possible, the planned retention period for personal data or, where this is not possible, the criteria used to determine this period;

  • the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) of the Regulation, and, at least in such cases, useful information regarding the underlying logic, as well as the significance and intended consequences of this processing for the data subject

 

The Data Controller may require payment of a reasonable fee based on administrative costs for any additional copies requested by the User.

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When the User submits this request electronically (through the electronic address for example), the information is provided in an electronic form in common use, unless the User requests otherwise. .

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The copy of his data will be communicated to the User at the latest within one month after receipt of the request.

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b. Right of rectification

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Leadercom guarantees the right of rectification and erasure of personal data to the user.

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In accordance with article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User first makes the necessary modifications himself from his user / other account, unless these cannot be carried out independently, in which case a request can be made to Leadercom.

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In accordance with Article 19 of the Regulations, the Data Controller notifies each recipient to whom the personal data has been communicated of any rectification of the personal data, unless such communication proves impossible or requires disproportionate efforts. The data controller provides the data subject with information on these recipients if the latter so requests.

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vs. Right to erasure

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The User has the right to obtain the erasure of his personal data as soon as possible in the cases listed in article 17 of the Regulations.

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When the Data Controller has made the personal data public and is required to erase them under the previous paragraph, the Data Controller, taking into account the technologies available and the costs of implementation, takes reasonable measures , including of a technical nature, to inform other controllers who process such personal data that the data subject has requested the erasure by those controllers of any link to such personal data, or of any copy or reproduction thereof.

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The two preceding paragraphs do not apply insofar as this processing is necessary:

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  • to the exercise of the right to freedom of expression and information;

  • to comply with a legal obligation which requires the processing provided for by Union law or by the law of the Member State to which the controller is subject, or to perform a task of public interest or falling within the exercise of the public authority vested in the controller;

  • to the establishment, exercise or defense of legal claims.

 

In accordance with Article 19 of the Regulations, the Data Controller notifies each recipient to whom the personal data has been communicated of any erasure of personal data or any limitation of the processing carried out, unless such communication proves impossible. or requires disproportionate effort. The data controller provides the data subject with information on these recipients if the latter so requests.

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d. Right to restriction of processing

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The User has the right to obtain the limitation of the processing of his personal data in the cases listed in article 19 of the Regulations.

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In accordance with Article 19 of the Regulations, the Data Controller notifies each recipient to whom the personal data has been communicated of any limitation of the processing carried out, unless such communication proves impossible or requires disproportionate efforts. The data controller provides the data subject with information on these recipients if the latter so requests.

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e. Right to data portability

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In accordance with article 20 of the Regulation, Users have the right to receive from Leadercom personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transmit this data to another data controller without Leadercom obstructing it in the cases provided for by the Regulation.

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When the User exercises his right to data portability in application of the previous paragraph, he has the right to obtain that the personal data is transmitted directly from one controller to another, when this is technically possible.

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The exercise of the right to data portability is understood to be without prejudice to the right to erasure. This right does not apply to processing necessary for the performance of a task of public interest or relating to the exercise of public authority vested in the controller.

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The right to data portability does not affect the rights and freedoms of third parties.

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f. Right to object and automated individual decision-making

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The User has the right at any time to oppose the processing of his personal data due to his particular situation, including the automation of data carried out by Leadercom. In accordance with article 21 of the Regulations, Leadercom will no longer process personal data, unless there are legitimate and compelling reasons for the processing which prevail over the interests and rights and freedoms of the User, or for the establishment, exercise or defense of legal claims.

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When personal data is processed for prospecting purposes, the User has the right to object at any time to the processing of personal data concerning him for such prospecting purposes, including profiling to the extent where it is linked to such prospecting.

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When the data subject objects to the processing for prospecting purposes, the personal data are no longer processed for these purposes.

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g. Right of complaint

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The User has the right to lodge a complaint concerning the processing of his personal data by Leadercom with the Data Protection Authority, competent for the Belgian territory. Further information can be found on the website: https://www.autoriteprotectiondonnees.be.

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The lodging of a complaint is made at the following addresses:

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Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Phone. + 32 2 274 48 00
Fax. + 32 2 274 48 35
E-mail: contact@apd-gba.be

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The User can also lodge a complaint with the court of first instance of his domicile.

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9. Cookies

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The Site uses cookies to distinguish Users of the Site. This allows to provide Users with a better browsing experience and an improvement of the Site and its content. The purposes and methods of cookies are contained in this article.

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at. General principles

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A "Cookie" is a file temporarily or permanently placed on the User's hard drive when consulting the Website, with a view to subsequent connection. Thanks to cookies, the server recognizes the User's computer.

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Cookies can also be installed by third parties with whom Leadercom works.

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Some of the cookies used by Leadercom are necessary for the proper functioning of the Site, others improve the User experience.

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The User can personalize or deactivate cookies by configuring his browser.

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By using the Website, the User expressly agrees with the management of cookies as described in this article.

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b. Type of cookies and purposes pursued

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Different types of cookies are used by Leadercom on the Site:

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  • Technical cookies: they are necessary for the operation of the Website, allow the communication of the data entered and are intended to facilitate the User's navigation;

  • Statistical and audience measurement cookies: these cookies allow the recognition of the User and are used to count the number of Users of the Website over a certain period. As long as they also indicate browsing behavior, they are an effective way to improve the User's browsing experience, by showing him proposals and offers that may be of interest to him. They also allow Leadercom to identify possible bugs on the Website and to correct them.

  • Functional cookies: these cookies facilitate the use of the Website by retaining certain choices made (for example, username or language);

  • Tracking cookies: Leadercom uses tracking cookies via Google Analytics, to measure the interaction of Users with the content of the Site and to produce anonymous statistics. These statistics allow Leadercom to improve the Website. Google supports the explanation of these cookies at the following address: http://www.google.nl/intl/en_uk/policies/privacy/

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vs. Cookie retention period

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Cookies are kept for the time necessary to fulfill the purpose pursued. The cookies likely to be stored on the User's hard drive as well as their retention period are as follows:

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36 months

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d. Managing cookies

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If the User does not want the Website to place cookies on his hard drive, it is easy for him to manage or delete them by modifying the settings of his browser. The programming of the browser also allows the User to receive a notice or a notification as soon as a Website uses cookies and thus decide to accept this, or to refuse it.

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If the User disables certain cookies, he accepts that the Website may not function optimally. Certain parts of the Website may therefore not be usable, or may be partially.

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If the User thus wishes to manage and / or delete certain cookies, he can do so by using the following link (s):

For Users with a browser:

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If the User refuses to allow Google Analytics cookies to be used, he is invited to configure his browser accordingly, on the following website: http://tools.google.com/dlpage/gaoptout.

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10. Limitation of liability of the Data Controller

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The website may contain links to other websites owned by third parties unrelated to Leadercom. The content of these sites and their compliance with the law and regulations are not the responsibility of Leadercom.

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The holder of parental authority must give his express consent so that a minor under 16 can disclose personal information or data on the website. Leadercom strongly advises people exercising parental authority over minors to promote responsible and secure use of the Internet. The Data Controller cannot be held responsible for having collected and processed information and personal data from minors under the age of 16 whose consent is not effectively covered by that of their legal parents or for incorrect data - especially concerning the 'age- introduced by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he is under 16 years of age.

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Leadercom is not responsible for the loss, corruption or theft of personal data caused in particular by the presence of viruses or following computer attacks.

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11. Security

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The Data Controller implements organizational and technical measures to guarantee an appropriate level of security for the processing and collection of data. These security measures depend on the costs of implementation with regard to the nature, context and purposes of the processing of personal data.

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The Data Controller uses standard encryption technologies within the IT sector when transferring or collecting data on the Site.

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12. Modification of the Privacy Policy

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Leadercom reserves the right to modify this Privacy Policy in order to comply with legal obligations in this area. The user is therefore invited to regularly consult the Confidentiality Policy in order to be aware of the modifications and adaptations. Any such modification will be posted on the Site or sent by email for opposability purposes.

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13. Applicable law and competent jurisdiction

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This Privacy Policy is exclusively governed by Belgian law. Any dispute will be brought before the courts of the judicial district of the head office of Leadercom.

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14. Contact

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For any question or complaint relating to this Privacy Policy, the User can contact the Data Controller via the following address: a.destro@leadercom.pro

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