Effective since: 25 May 2018
We deeply respect the privacy of our users and treat their personal data strictly confidentially and in accordance with the legislation in force.
It is required to read this Policy carefully. If you have any other questions, do not hesitate to contact us at email@example.com.
1.1 Phibonacci (hereinafter, « PHIBONACCI ») respects the privacy of its users (hereinafter, the “Users”).
1.2 PHIBONACCI processes the personal data transmitted to it in accordance with the legislation in force, and, in particular, Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, applicable from 25 May 2018 (hereinafter the “General Data Protection Regulation” or briefly “GDPR”).
1.4 The User acknowledges having read the information below and authorizes PHIBONACCI to process, in accordance with the provisions of the Policy, the personal data that he/she communicates on the Website.
1.5 The Policy is valid for all pages hosted on the Website and for the registrations of this Website, as well as all company pages managed by PHIBONACCI on social networks, who is jointly responsible with the social network for the processing of data of visitors to the page. It is not valid for the pages hosted by third parties to which PHIBONACCI may refer and whose privacy policies may differ. PHIBONACCI cannot therefore be held responsible for any data processed on these websites or by them.
2.1 Simply visiting the Website shall take place without having to provide any personal data, such as first name, surname, postal address, email address, etc.
2.2 As part of the Service, the User may be required to provide certain personal data. In this case, the data controller is:
PHIBONACCI is a registered trade name and a registered trademark of the entity Phibonacci Management Consulting BV, registered under enterprise number 0883.950.805 in the Belgian Crossroads Bank for Enterprises (CBE).
3.1 By completing any form on the Website and using the Service, the User allows, in particular, PHIBONACCI to record and store, for the purposes mentioned in point 4, the following information:
3.2 The User also authorizes PHIBONACCI to record and store the following data for the purposes mentioned in point 4:
3.4 When the User accesses the Website, the servers consulted automatically record certain data, such as:
3.5 No nominative data identifying the User is collected through the cookies and servers consulted. This information is kept for statistical purposes only and to improve the Website.
3.6 We also collect some of your data through other companies.
4.1 We process your data for various purposes. For each purpose, only the data relevant to the pursuit of the purpose in question are processed. The processing consists of any operation (manual or automated) on personal data. PHIBONACCI collects, stores and uses its Users’ data for the following purposes, in particular:
4.2 The legal basis of the processing of your personal data is based on:
We have a legitimate interest in providing you with this information and interacting with you, especially to respond to your requests or improve our services, prevent abuse and fraud, control the regularity of our operations, exercise, defend and preserve our rights, for example in litigation, as well as evidence of a possible violation of our rights, manage and improve our relations with you, continually improve our website and our products/services, unless such interests are supplanted by your interests or your fundamental rights and freedoms requiring the protection of your personal data. We take care in any case to maintain a proportionate balance between our legitimate interest and respect for your privacy.
If the legal basis of our treatment is your consent, you have the right to withdraw it at any time without prejudice to the lawfulness of the processing performed prior to withdrawal.
In the context of direct marketing, this means that you can unsubscribe at any time from newsletters and other commercial communications from us. You will be put in “opt-out”. You can unsubscribe by sending us an email at the following address: firstname.lastname@example.org or by clicking on the unsubscribe link at the bottom of each email.
5.1 According to the regulations on the processing of personal data, the User has the following rights:
5.2 In order to exercise his rights, the User sends a written request, accompanied by a copy of his identity card or his passport, to the data controller (see 2.2.):
5.3 PHIBONACCI will then take the necessary steps to satisfy this request as soon as possible and in any case within one month of receipt of the application. If necessary, this period can be extended by two months, given the complexity and the number of requests.
6.1 PHIBONACCI will keep the personal data of its Users for the duration necessary to achieve the objectives pursued (see point 4).
6.2 PHIBONACCI may also continue to keep personal data concerning the de-registered User, including all correspondence or request for assistance sent to PHIBONACCI in order to be in a position to reply to all questions or complaints that may be sent to it, and in order to comply with all applicable laws, namely in tax matters or as part of other legal requirements.
7.1 The User is informed that he has the right to lodge a complaint with the Data Protection Authority:
Data Protection Authority
Rue de la Presse 35
Tel : +32 (0)2 274 48 00
8.1 PHIBONACCI has taken the appropriate organizational and technical measures to ensure a level of security adapted to the risk and that, to the extent possible, the servers hosting the personal data processed prevent:
8.2 In this respect, employees of PHIBONACCI who have access to this data are subject to a strict confidentiality obligation. Nevertheless, PHIBONACCI may in no way be held liable in the event that this data is stolen or hijacked by a third party despite the security measures adopted.
9.1 PHIBONACCI treats personal data as confidential information. It will not communicate them to third parties under any condition other than those specified in the Policy, such as to achieve the objectives set out and defined in point 4, or under the conditions in which the law requires it to do so.
9.2 PHIBONACCI may communicate its Users’ personal information to third parties to the extent that such information is necessary for the performance of a contract with its Users. In such case, these third parties will not communicate this information to other third parties, except in one of the two following situations:
9.3 The communication of this information to the aforementioned persons shall, in all circumstances, be limited to what is strictly necessary or required by the applicable regulations.
10.1 PHIBONACCI transfers data to a country outside the European Economic Area only when that country ensures an adequate level of protection within the meaning of the legislation in force and, in particular, within the meaning of the General Data Protection Regulation (for more information on the countries offering an adequate level of protection, see: here), or within the limits permitted by the legislation in force, for example by ensuring the protection of data by appropriate contractual provisions.
10.2 The information processed by PHIBONACCI will be transferred or transmitted, or stored and processed, in the United States or other countries other than the country in which you live, for the purposes described in this Policy. These data transfers are necessary to provide the services or processing set forth in the Policy, and to operate and provide you with our Products worldwide. We use standard contractual clauses approved by the European Commission and we rely on the European Commission’s adequacy decisions concerning certain countries, where appropriate, for data transfers from the European Economic Area to the United States and other countries. If you have any questions in this regard, do not hesitate to contact us at the following address: email@example.com.
11.1 The personal data will not be used for direct marketing purposes for articles or services that would not be identical or similar to those to which the User has already subscribed, unless the User has previously explicitly consented to such use by ticking the boxes provided for this purpose (“opt-in”).
11.2 When the User has given his consent to the use of this information for direct marketing purposes, the latter retains the right to object to such use at any time, upon request and free of charge. The User may simply communicate his request by writing to the following address: firstname.lastname@example.org.
12.1 Persons under the age of 18 and persons who do not have full legal capacity are not allowed to use the Website. PHIBONACCI asks them not to provide their personal data. Any infringement found in this provision must be reported without delay to the following address: email@example.com.
13.1 By informing Users through the Website or email, PHIBONACCI may modify and adapt the Policy, in particular to comply with any new legislation and/or regulations applicable (such as the General Data Protection Regulation applicable from 25 May 2018), the recommendations of the Belgian Data Protection Authority, the guidelines, recommendations and best practices of the European Data Protection Board and the decisions of the courts and tribunals on this issue.
14.1 Failure by PHIBONACCI to invoke – at any given time – a provision of this Policy, may not be interpreted as a waiver to subsequently make use of its rights under the said provision.
14.2 The invalidity, expiration or the unenforceable nature of all or part of one of the above or below mentioned provisions shall not give rise to the invalidity of all the Policy. Any fully or partially invalid, lapsed or unenforceable provision shall be deemed not to have been written. PHIBONACCI undertakes to substitute this provision with another which, to the extent possible, fulfils the same objective.
15.1 The validity, interpretation and/or implementation of the Policy are subject to Belgian law, to the extent permitted by the provisions of applicable private international law.
15.2 In the event of a dispute relating to the validity, interpretation or implementation of the Policy, the courts and tribunals of Antwerp have exclusive jurisdiction, to the extent permitted by the provisions of applicable private international law.
15.3 Before taking any step towards the judicial resolution of a dispute, the User and PHIBONACCI undertake to attempt to resolve it amicably. To this end, they shall first contact each other before resorting, where appropriate, to mediation, arbitration, or any other alternative method of dispute resolution.
Your application has been received successfully.
A confirmation has been sent to the provided email.
Please check your spam or junk folder,
in case you do not find a confirmation in your inbox.