Updated on August 4, 2020
1. Parties and Purpose
Ninedots bvba (hereinafter "iPurple" or the "Controller")
Arboretumlaan 46, 3080 Tervuren, Belgium
BCE / VAT : BE.0890.214.431
Telephone: +32 498 63 86 06
The term "User" refers to any user, either a natural or legal person, who visits or interacts in any way with the Site.
As such, iPurple determines all the technical, legal and organizational means and purposes of processing the personal data of the Users. To this end, iPurple undertakes to take all necessary measures to ensure that the processing of personal data complies with the Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data (hereinafter, "the Law") and the European Regulation of 26 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter, "the Regulation").
iPurple is free to choose any natural or legal person who processes the personal data of users at its request and on its behalf (hereinafter the "Subcontractor"). If necessary, iPurple undertakes to select a Subcontractor offering sufficient guarantees regarding the technical and organisational security measures for the processing of personal data, in accordance with the Law and the Regulation.
2. Processing of personal data
The use of the Site by Users may result in the communication of personal data. The processing of such data by iPurple, in its capacity as Data Controller, or by service providers acting in the name and on behalf of iPurple, shall be in accordance with the Law and the Regulations.
Personal data shall be processed by iPurple, in accordance with the purposes mentioned below, via:
an automated procedure (product purchase, event registration,...)
the newsletter registration form
sending surveys or questionnaires
3. Purpose of the processing of personal data
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:
1. to ensure the performance of the services proposed and agreed upon on the Site;
2. to control the performance of the services offered;
3. to carry out marketing activities and promotional information with the User's prior consent and until revocation of such consent, for example the sending of promotions on iPurple's products and services;
4. Answering the User's questions;
5. to compile statistics in order to improve the website, the services offered and the internal organization of operation;
6. to improve the quality of the Website and the products and/or services offered by iPurple;
7. to allow better identification of the User's areas of interest.
4. Personal data that may be processed
1. The information of Users that they provide for contractual purposes and to enable the proper performance of reciprocal obligations, i.e. surname, first name, address, IBAN number and bank details, etc.; and more generally, any information voluntarily provided by the User;
2. Information from Users by filling in forms or contacting by telephone, e-mail address or other means, for example the name, address, e-mail address and telephone number of Users;
3. With respect to each of the Users' visits to the Site, the information automatically collected is:
a. IP address, type and model of browser, time zone, operating system;
b. all information concerning the pages that the User has consulted on the Site, including the URL, navigation time,...
The User has the right to withdraw his/her consent at any time. Withdrawal of consent does not compromise the lawfulness of the processing based on the consent previously given.
6. Duration of storage of Users' personal data
In accordance with Article 13 §2 of the Regulation and the Law, the Data Controller shall only keep personal data for the time reasonably necessary to allow the fulfilment of the purposes for which they are processed.
This period is in any case less than: 1 year
7. Recipients of data and disclosure to third parties
Personal data may be transmitted to iPurple's employees, subcontractors or suppliers who offer adequate data security guarantees and who collaborate with iPurple in the marketing of products or the provision of services. They act under the direct authority of iPurple and are responsible for collecting, processing or subcontracting this data.
In the event that the data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed beforehand to express his consent to the use of such personal data.
8. Users' Rights
At any time, the User may exercise his rights by sending a message by e-mail to the following address: email@example.com, or a letter by post, enclosing a copy of his identity card to the following address: Arboretumlaan 46, 3080 Tervuren, Belgium
a. Right of access
In accordance with article 15 of the Rules, iPurple guarantees the User's right of access to his/her 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 organisations;
- where possible, the intended period of storage of the personal data or, where that is not possible, the criteria used to determine that period ;
- the existence of automated decision making, including profiling, as referred to in Article 22(1) and (4) of the Regulation, and, at least in such cases, relevant information concerning the underlying logic, as well as the importance and the expected consequences of the 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.
Where the User submits such a request electronically (e.g. via e-mail address), the information is provided in a commonly used electronic form, unless the User requests otherwise.
A copy of the User's data will be communicated to the User at the latest within one month after receipt of the request.
b. Right of rectification
iPurple guarantees the right of correction and deletion of personal data to the user.
In accordance with Article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or erased at any time. The User shall first make the necessary changes himself/herself from his/her user/other account, unless they cannot be made autonomously, in which case the request can be made to iPurple.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data have been communicated of any rectification of the personal data, unless such communication proves impossible or requires disproportionate efforts. The Controller shall provide the data subject with information about these recipients if the data subject so requests.
c. Right of erasure
The User has the right to obtain the deletion of his/her personal data as soon as possible in the cases listed in article 17 of the Regulations.
Where the Controller has made the personal data public and is required to erase them pursuant to the previous paragraph, the Controller, taking into account the available technologies and the costs of implementation, shall take reasonable measures, including technical measures, to inform the other controllers processing such personal data that the data subject has requested the erasure by those controllers of any link to such personal data, or any copy or reproduction thereof.
The two preceding paragraphs shall not apply to the extent that such processing is necessary:
- for the exercise of the right to freedom of expression and information;
- to comply with a legal obligation which requires the processing to be carried out in accordance with Union law or the law of the Member State to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- the establishment, exercise or defence of legal claims.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data have been disclosed of any erasure of personal data or any restriction on the processing operation carried out, unless such notification proves impossible or involves a disproportionate effort. The controller shall provide the data subject with information about such recipients if the data subject so requests.
d. Right to limit processing
The User has the right to obtain the limitation of the processing of his/her personal data in the cases listed in article 19 of the Regulations.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data have been communicated of any limitation of the processing carried out, unless such communication proves impossible or requires a disproportionate effort. The Controller shall provide the data subject with information about such recipients if the latter so requests.
e. Right of data portability
In accordance with Article 20 of the Regulation, Users have the right to receive from iPurple their personal data in a structured, commonly used and machine-readable format. Users have the right to transmit such data to another controller without iPurple obstructing it in the cases provided for in the Rules.
Where the User exercises its right to data portability pursuant to the previous paragraph, the User has the right to have personal data transmitted directly from one data controller to another, where this is technically possible.
The exercise of the right of data portability shall be without prejudice to the right of erasure. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
The right of data portability shall not prejudice the rights and freedoms of third parties.
f. Right of opposition and automated individual decision-making
The User has at any time the right to object to the processing of his/her personal data due to his/her particular situation, including the automation of the data carried out by iPurple. In accordance with article 21 of the Regulations, iPurple will no longer process personal data, unless there are legitimate and compelling reasons for the processing that prevail over the interests and rights and freedoms of the User, or for the ascertainment, exercise or defence of legal rights.
Where personal data is processed for canvassing purposes, the User has the right to object at any time to the processing of personal data concerning him/her for such canvassing purposes, including profiling insofar as it is related to such canvassing.
Where the data subject objects to the processing for canvassing purposes, the personal data shall no longer be processed for such purposes.
g. Right to complain
The User has the right to lodge a complaint regarding the processing of his personal data by iPurple with the Data Protection Authority, competent for the Belgian territory. More information can be found on the website: https://www.autoriteprotectiondonnees.be.
You can lodge a complaint at the following addresses:
Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Phone + 32 2 274 48 00
Fax + 32 2 274 48 35
The User may also file a complaint with the Court of First Instance of his domicile.
a. General principles
A "Cookie" is a file that is temporarily or permanently deposited on the User's hard disk when consulting the Website, with a view to later connection. Thanks to cookies, the server recognises the User's computer.
Cookies can also be installed by third parties with whom iPurple collaborates.
Some of the cookies used by iPurple are necessary for the proper functioning of the Website, while others make it possible to improve the User's experience.
The User can personalize or disable cookies by setting up his browser.
By using the Website, the User expressly agrees with the management of cookies as described in this article.
b. Type of cookies and purposes
Different types of cookies are used by iPurple on the Site:
- Technical cookies: they are necessary for the operation of the Website, allow the communication of the data entered and are intended to facilitate the navigation of the User;
- Cookies for statistical and audience measurements: these cookies allow the recognition of the User and are used to count the number of Users of the Website over a certain period of time. Since they also indicate browsing behaviour, they are an effective means of improving the User's browsing by displaying proposals and offers that may be of interest to him/her. They also allow iPurple 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 introduced (for example, user name or language);
- Tracking cookies: iPurple uses tracking cookies via Google Analytics, AdWords, Bing, Facebook, Twitter services, to measure the interaction of Users with the content of the Website and to produce anonymous statistics. These statistics allow iPurple to improve the Website. Google supports the explanation of these cookies at the following address: http://www.google.nl/intl/en_uk/policies/privacy/.
c. Cookie Retention Time
Cookies are kept for the time necessary to achieve the intended purpose. The cookies that may be stored on the User's hard drive and their retention period are as follows: 20 days
d. Cookie management
If the User deactivates certain cookies, he/she accepts that the Website may not function optimally. Certain parts of the Website may therefore not be usable, or may only be partially usable.
If the User wishes to manage and/or delete certain cookies in this way, he or she can do so by using the following link(s):
For Users with the following browser:
- Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
- Microsoft Edge: http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq
- Chrome: https://support.google.com/accounts/answer/61416?hl=fr
- Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
- Safari: https://support.apple.com/kb/ph21411?locale=fr_CA
10. Limitation of liability of the Data Controller
The website may contain links to other websites owned by third parties not related to iPurple. The content of these sites and their compliance with the Law and Regulations is not the responsibility of iPurple.
The holder of parental authority must give his express consent for a minor under 16 years old to disclose personal information or data on the website. iPurple strongly advises persons exercising parental authority over minors to promote a responsible and secure use of the Internet. The Data Controller cannot be held responsible for having collected and processed information and personal data of minors under 16 years of age whose consent is not effectively covered by that of their legal parents or for incorrect data - in particular regarding age - entered by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he/she is under 16 years of age.
iPurple is not responsible for the loss, corruption or theft of personal data caused in particular by the presence of viruses or as a result of computer attacks.
The Data Controller implements organisational 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 in relation to the nature, context and purposes of the processing of personal data.
The Data Controller uses standard encryption technologies within the IT sector when transferring or collecting data on the Site.
13. Applicable law and jurisdiction