Privacy policy on the processing of customer and website user personal data 


Introduction
Welcome to the Easi website. Easi ("Easi" or "we" or "us") recognises the importance of respecting the privacy and protecting the personal data of customers and visitors to our website. This policy details how we process your personal data.


SCOPE OF APPLICATION
This website is managed by Easi. We act as data controller when processing the personal data of our customers and users of our website . 
It is important for us to create and maintain an environment in which our customers can be confident that their information will not be misused. We comply with applicable data protection regulations, including the General Data Protection Regulation 2016/679  (hereinafter "GDPR" or "RGPD" ), as well as relevant national legislation. These regulations relate to the protection of your personal data and give you rights in relation to that data. 
The purpose of this policy is to tell you what personal data we collect and how it will be used when you visit our website, and to ensure that it is processed correctly. 
When you visit our website, this privacy policy and the terms of use apply. The website's terms of use supplement this privacy policy and can be consulted by users at the following address: https://easi.net/fr/legal/website-terms-of-use
The application of any conditions other than this policy is expressly excluded, unless we give our prior written consent. In the latter case, this policy will continue to apply in addition to the specific agreements. Use of this website, the platform and their content is only permitted subject to compliance with this policy. If you do not accept and comply with this policy in its entirety, you must stop using the website, the platform and their content.


INTERPRETATION 
Where terms defined in the GDPR appear in the clauses of this policy, they shall be understood as in the regulation in question. 
This applies in particular to terms used in this policy such as "personal data", "sensitive data", "processing", "controller", "purpose", "legal basis", "legitimate interest", "consent", "technical and operational measures", etc.
As a reminder, personal data is any information that can directly or indirectly identify an individual natural person, including first and last name, age, postal or e-mail address, telephone number and any other element defined as personal data, such as an IP address.


IDENTITY OF THE DATA CONTROLLER
Our official contact details are as follows : 
Easi SA
The gates of Europe
Avenue Robert Schuman 12
1401 Nivelles
Belgium
+32 67 28 10 00
info@easi.net
VAT number : BE0465.741.144


PERSONAL DATA WE COLLECT ABOUT YOU
Most of our website is accessible without you having to provide any personal data.
We may collect and process your personal data for the following purposes:  


INFORMATION YOU GIVE US
This refers to information that we receive directly from the data subject, in particular personal data collected via online forms on our site. 
You provide us with personal information when, for example, you complete an online form to contact us, download documents, make an appointment, request a demonstration of our solutions, register for an event, subscribe to a newsletter, etc. These are the following categories of personal data:
•    first and last name
•    e-mail address
•    telephone number
•    company/organisation on whose behalf the request is made
Additional information is sometimes requested (size of the company, role of the person in the organisation, etc.). The information we request is limited to what we need to be able to process your request as effectively as possible and to pursue our legitimate interest, i.e. to contact the person again to find out what we can do to meet their needs.
 

PUBLICLY AVAILABLE INFORMATION 
This is information that we can find in publicly available resources, such as the data subject's public profile on LinkedIn, the website of the company/organisation on whose behalf the data subject is applying, and any other source of information in the public domain on the Internet. We may combine publicly available information with information you provide to us in order to verify data we have previously collected and to manage and expand our business.


INFORMATION WE COLLECT USING COOKIES
When you visit our site, data about you is automatically but passively collected using cookies and is based on your Internet habits and behaviour. In particular, we may collect information about your IP address, the pages of our website that you visit, your geolocation, the language you use to visit our site, where you came from (if you found us via a search engine, an advertising campaign, social networks, etc.). 
You can find out more about how we use cookies in our cookie policy at https://easi.net/fr/legal/cookie-policy .

PURPOSES OF PROCESSING YOUR PERSONAL DATA  
We collect the above information in order to better understand your needs and provide you with a better service, and in particular for the following purposes: 


CUSTOMER RELATIONSHIP MANAGEMENT
When you order a product or service via our website, we may use your personal data for the purposes of managing and monitoring our relationship with our customers. This purpose includes but is not limited to: 
o    provide you with the products and services you have ordered;
o    verify your identity and financial details for the payment of our products and services;
o    managing contracts and contractual obligations ; 
o    improve our products and services;
o    investigate complaints about our products or services or in connection with our website;


COMMUNICATION 
We will respond to all requests you submit to us via our website, including requests for documentation, support, assistance or demonstrations about our products and services, event registrations, complaints, price requests and any other purpose of an online form relating to our products and services or in connection with the website. By way of example, we may use your personal data to call you back by telephone or to communicate with you by e-mail, LinkedIn or any other communication channel.


DIRECT MARKETING
We may use your personal data for direct marketing purposes, to provide you with specific information you have requested on our site or more general information about Easi's offering, but also to send you invitations to events or workshops, e-newsletters, etc. We will only carry out our marketing on the basis of your explicit consent or if you have a contractual relationship with us and the information sent is related to the contract entered into. We will only carry out our marketing on the basis of your explicit consent or if you have a contractual relationship with us and the information sent is relevant to the contract entered into.


RECRUITMENT
When you submit a CV or apply for a job on the Easi website, we will use your personal data for recruitment purposes and may contact you by email or telephone.
IMPROVING OUR WEBSITE
We will constantly use and analyse data from visitors to our website to improve our users' experience.
 

LEGAL OBLIGATIONS
We are also authorised to retain personal data to meet legal and regulatory obligations and compliance requirements.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA 
We endeavour to process your personal data in strict compliance with the applicable legislation and more particularly on the following legal bases listed in articles 6.1, (a), (b), (c) and (f) of the GDPR:


CONSENT OF THE PERSON CONCERNED
If you are not yet a customer, we will ask for your consent to inform you electronically about our events, products and services for promotional purposes.
By submitting an online form on our site, you agree to the transfer of your personal data to Easi and understand that Easi will process your personal data in accordance with this privacy policy. 
You retain the right to withdraw your consent at any time.


PERFORMANCE OR PREPARATION OF A CONTRACT 
We may process your personal data where this is necessary for the performance of our obligations under a contract for the supply of our products or services to which you are a party or for its preparation (for example, when submitting a quotation). 


LEGAL OBLIGATION
In some cases, the processing of personal data and its transmission to third-party recipients (e.g. to public authorities in the context of public procurement or the fight against money laundering) is necessary to comply with a legal obligation.  


LEGITIMATE INTEREST 
Direct marketing operations (prospecting) constitute a legitimate interest on the basis of the GDPR. The processing of personal data on the basis of a legitimate interest does not require your explicit consent. We distinguish three categories of activities based on the legal basis of legitimate interest:
1) Contact the people concerned who have submitted an online form
We consider that it is in our legitimate interest to contact data subjects who have submitted an online form on our site, as we will contact them to follow up their requests. This task will be entrusted directly to our sales team, who will use the means available for this purpose (telephone, e-mail, LinkedIn, etc.). However, we never send collective commercial mailings to data subjects who have not explicitly subscribed to our newsletters by completing an online form.
2) Keep Easi customers informed of developments at Easi
A customer may receive e-newsletters without explicit consent. These e-newsletters contain information that we feel will be useful to the customer, for example information about new features in Easi solutions, invitations to Easi events & workshops, a summary of the latest articles on the Easi blog, etc.
We do our utmost to ensure that the information provided by each data subject remains relevant. However, if they no longer wish to receive our e-newsletters, they can unsubscribe or change their preferences at any time. Each e-newsletter includes a link to unsubscribe as well as a link to change e-mailing preferences.
3) Contacting potentially interesting prospects 
Our sales team systematically contacts companies where Easi can add value. To do this, our sales people consult public information sources such as the internet, LinkedIn and other databases. Where they find personal information (e.g. the name of a company's sales manager), they may process that personal data to the extent necessary to fulfil Easi's legitimate interest in contacting that person with a personalised Easi offer.
Data subjects approached in this way will never receive direct marketing communications from Easi.

USE AND SHARING OF YOUR PERSONAL DATA WITH THIRD PARTIES 
Easi is obliged not to sell, rent or disclose the personal data collected to third parties, unless otherwise specified at the time the data is collected. 
We may share your personal data with companies belonging to the same group and/or subsidiaries or any third party with whom you have asked us to share your personal data, such as Facebook or other social media if you have asked us to connect you with your account. 
We may also share your personal data, on the basis of our legitimate interest, with third parties who assist us in the provision of our products and services. Insofar as these service providers act as subcontractors, they will not be authorised to use or disclose the data for purposes other than those strictly necessary for the performance of their activities. Our subcontractors are obliged to comply with the GDPR, and therefore to protect the confidentiality and security of the personal data they process on our behalf. These obligations are set out in a subcontracting agreement concluded as part of each collaboration. 
We may disclose your personal data in order to enforce our policy, to comply with our legal obligations or in the interests of security, in the public interest or for law enforcement purposes in any country where we have entities or subsidiaries. For example, we may respond to a request from a law enforcement agency, regulatory body or public authority. We may also disclose data in connection with actual or potential litigation or to protect our property, safety, personnel or other rights or interests.
In the event of a sale to or merger of Easi's business with another company, your data will be provided to the potential acquirer's advisor and will be transferred to the new owners of the business. In this event, we will take appropriate steps to ensure the integrity and confidentiality of your personal data. The use of your personal data will, however, remain subject to this policy.


RETENTION PERIOD FOR YOUR PERSONAL DATA
Once you have provided us with your personal data, it will be processed in Easi's files and kept for the period necessary for the processing concerned.
If you are an Easi customer, we will retain your personal data (such as invoices and communications) for the period required by applicable accounting legislation. After the business relationship has ended, your data will only be retained for as long as is necessary to comply with any applicable limitation periods. You may ask us to delete your data previously, in which case we will delete, to the extent technically possible, all data held by us, except that which we are legally obliged to retain.
If you are not an Easi customer, we will have to make a decision based on the information we receive. We will delete your information if we become aware that it is no longer accurate and we are unable to correct the errors (for example, if we receive a "failed delivery" message in response to an email). In the event of prolonged inactivity of your account (visits to the site, clicks on a collective e-mail, personal contacts with our sales representatives), your personal data will be automatically deleted from our systems in accordance with the legislation in force. We will also delete your information at your request.
If you are a job applicant, your CV and personal data will be kept on our system for as long as is necessary to assess your application and to draft a job offer. At your request, we may delete your previous data.


TRANSFER OF YOUR PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
We may transfer your personal data to third parties located in third countries (outside the European Economic Area (EEA)). This transfer of data outside the EEA is legal if the recipient of the data is located in a country that ensures an adequate level of protection confirmed by an adequacy decision of the European Commission. Some of these countries may not have equivalent data protection legislation to protect the use of your personal data. In such cases, we have examined the possibility of applying adequate precautionary measures such as those in force in the EU, for example by means of standard contractual clauses. In certain specific cases, we ask for your prior consent to be able to transfer your personal data outside the EEA. For more information on the transfer of data, please follow the procedure described in the article "Rights of the data subject".

YOUR RIGHTS REGARDING THE COLLECTION AND PROCESSING OF YOUR PERSONAL DATA 
Data protection legislation provides data subjects with various rights relating to the processing of personal data, so that they can continue to exercise sufficient control over the processing of their personal data. 
You have the right to see what information we hold about you and to obtain a copy of the information we hold. If your personal data has changed, you have the right to ask us to correct, complete or delete any out-of-date, incorrect or incomplete information we hold about you. You also have the right to restrict the processing of your data and to object to the processing of your personal data. In addition, you have the right to receive the personal data concerning you that you have provided to a data controller in a structured, commonly used and machine-readable format and to transmit this data to another data controller.
We have appointed a Data Protection Officer (DPO) who can be contacted by e-mail at dpo@easi.net or by post at Easi SA - Data Protection, 1400 Nivelles, Avenue Robert Schuman 12, for any questions you may have regarding the processing of your personal data. The DPO will also respond to your requests to exercise your rights. This request is free of charge. 
In order for Easi to respond to your request, you may be required to provide certain information such as your full name, email address and customer account number. 
Easi undertakes to reply as soon as possible, but this period may not exceed one (1) month from receipt of the request. If you submit your request electronically and do not request another method of communication, the information will be provided to you in electronic form. If you so request, the information may be communicated to you verbally, provided that your identity has been established by other means.
Easi may refuse to grant your request if it is unfounded or excessive, particularly in view of the existence of other requests from you or others. Easi shall bear the burden of proving that the request is excessive or unfounded. 
You may lodge a complaint about the processing of your personal data with the competent authority in the Member State where you are normally resident, where you work or where the breach is alleged to have occurred. 
In Belgium, complaints may be lodged with the Data Protection Authority, Rue de la presse 35, 1000 Brussels (tel: +32 22744800, e-mail: contact@apd-gba.be ).
Visit https://www.autoriteprotectiondonnees.be/citoyen for more information on your rights.

COOKIES & SIMILAR TECHNOLOGIES
The Easi website uses cookies for three reasons: (i) to provide our visitors with the most effective web experience (for example, when a visitor has selected a language, the site will automatically display in the selected language on the next visit); (ii) to analyse the behaviour of our visitors in order to improve their experience and the performance of the site; and (iii) to help us present quality advertising that will be of most interest to our visitors.
You can find our Cookie policy at https://easi.net/fr/legal/cookie-policy for more information on the use of cookies.


SAFETY
When Easi receives or transmits data via its website, we take all reasonable steps to ensure the security of your data. We have implemented reasonable technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed. However, you should bear in mind that the Internet is an open system and we cannot guarantee that unauthorised third parties will never be able to circumvent these measures or use your personal data for improper purposes. Easi cannot therefore be held responsible for the security of the transmission of your personal data over the Internet.
 

APPLICABLE LAW AND COMPETENT COURTS 
Our website, this policy and all related disputes are governed by Belgian law. In the event of a dispute, the courts of Easi's registered office shall have sole jurisdiction.
 

CHANGES TO THE PRIVACY POLICY 
Easi reserves the right to amend this policy at any time in order to ensure that users of the Site comply with applicable law and to ensure that this policy reflects the way in which we process your personal data at any given time.
Any changes shall not affect contracts concluded previously, which shall remain subject to the policy in force at the time the said contract was concluded and as accepted by the user at the time of acceptance.  The updated version of this policy will be published on the same web page and will come into force as soon as it is published. 
Users are invited to familiarise themselves with this policy each time they use our services, without it being necessary to formally notify them.  
 

CONTACT US
If you wish to exercise any of the aforementioned rights, if you have a complaint about the processing of your data or for any other related matter, you can contact us via the following e-mail addresses: dpo@easi.net , or you can write to the following address:


Easi SA - Data protection
The gates of Europe
Avenue Robert Schuman 12
1401 Nivelles
Belgium
+32 67 28 10 00
VAT number : BE0465.741.144

This policy, published on April 16th, 2018, was updated on September 4th, 2024.