Version applicable as from December 1st, 2020.
- Parties and Subject
Kulash LY SCRL (hereinafter “Welexit” or the “Data Controller”)
Avenue Minerve 37/25, 1190 Bruxelles
BCE / TVA: BE0719.917.667
Telephone: +32 (0)2 781 03 32
The term “User” refers to any user, either a natural or legal person, who visits or interacts in any way with the Site.
In this respect, Welexit determines all the technical, legal and organisational means and purposes of the processing of Users’ personal data. To this end, Welexit 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 concerning the processing of personal data (hereinafter, “the Law“) and the European Regulation of 26 April 2016 on the protection of individuals concerning the processing of personal data and the free movement of such data (hereinafter, “the Regulation“).
Welexit is free to choose any natural or legal person who processes users’ personal data at its request and on its behalf (hereinafter the “Subcontractor“). Where appropriate, Welexit undertakes to select a Subcontractor offering sufficient guarantees regarding the technical and organisational security measures for the processing of personal data, under the Law and the Regulation.
- Personal data processing
The use of the Site by Users may result in the communication of personal data. The processing of this data by Welexit, in its capacity as Data Controller, or by service providers acting in the name and on behalf of Welexit, will be following the Law and the Regulation.
- Purpose of personal data processing
Following article 13 of the Regulations, the purposes of the processing of personal data are communicated to the User and are as follows:
- to ensure the execution of the services proposed and agreed on the Site;
- to personalise the Site;
- answer the User’s questions;
- to improve the quality of the Site and the products and/or services offered by the Data Controller;
- to carry out newsletter, marketing and promotional information activities with the User’s prior consent and until the revocation of such consent;
- to maintain the security of the Site;
- sending statements, invoices and payment reminders, and collecting payments;
- to verify compliance with the general terms and conditions governing the use of the Site.
- Personal data that may be processed
- User information given by Users for contractual purposes and to enable the proper performance of reciprocal obligations, i.e. surname, first name, email address, telephone number, …; and more generally, any information voluntarily given by the User, whether via the Site, by email or on the telephone ;
- Concerning each of the User’s visits to the Site, the information automatically collected is:
a. IP address, browser type and model, time zone, operating system;
b. aggregate information regarding the pages that the User has viewed on the Site, including URL, navigational time, and web site navigational paths.
The User has the right to withdraw his consent at any time. Withdrawal of consent does not compromise the lawfulness of the processing based on the consent previously given.
- Storage duration 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 enable the purposes for which they are processed to be fulfilled.
This period is, in any case, less than 5 years.
- Recipients of data and disclosure to third parties
Personal data may be passed on to Welexit’s employees, collaborators, subcontractors or suppliers who offer adequate data security guarantees and who collaborate with Welexit in the context of the marketing of products or the provision of services. They act under the direct authority of Welexit and are in particular responsible for collecting, processing or subcontracting this data.
In case the data is disclosed to third parties for direct marketing or canvassing purposes, the User will be informed beforehand so that he can consent to the use of his personal data.
- User rights
At any time, the User may exercise his rights by sending a message by e-mail to the following address: firstname.lastname@example.org, or a letter by post, enclosing a copy of his identity card to the following address: Avenue Minerve 37/25, 1190 Brussels
a. Right of access
In accordance with article 15 of the Regulations, Welexit guarantees the User’s right of access to his/her personal data. The User has the right to obtain access to the 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 has been or will be communicated, in particular, recipients who are established in developing countries or international organisations;
- where possible, the intended period of retention of the personal data or, where this is not possible, the criteria used to determine this 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 charge 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 format, unless the User requests otherwise.
A copy of the User’s data will be sent to the User no later than one month after receipt of the request.
b. Right of rectification
Welexit guarantees the user’s right to correct and delete personal data.
Following Article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User first makes the necessary changes himself from his user/other account, unless they cannot be made autonomously, in which case the request can be made to Welexit.
In compliance with Article 19 of the Regulation, the Data Controller shall notify 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 Controller shall provide the person concerned with information about these recipients if the latter so requests.
c.Right to erasure
The User has the right to have his personal data erased as soon as possible in the cases listed in article 17 of the Regulations.
Where the Data Controller has made the personal data public and is required to erase them pursuant to the previous paragraph, the Data Controller, taking into account the available technologies and the costs of implementation, shall take reasonable measures, including technical measures, to inform the other data controllers who process such personal data that the data subject has requested the erasure of any links to such personal data, or any copy or reproduction thereof, by these data controllers.
The two preceding paragraphs shall not apply insofar as such processing is necessary:
- to 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 under Union law or the law of the Member State to which the controller is subject, or to perform a task carried out in the public interest or 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 communicated of any erasure of personal data or any restriction on the processing carried out unless such communication proves impossible or involves a disproportionate effort. The data controller shall provide the person concerned with information on these recipients if the latter so requests.
d. Right to limit processing
The User has the right to limit the processing of his personal data in the cases listed in article 19 of the Regulations.
According to article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data has been communicated of any limitation on 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
Following Article 20 of the Rules, Users have the right to receive from Welexit personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transmit these data to another data controller without Welexit obstructing them in the cases provided for in the Regulation.
When the User exercises his right to data portability according to the previous paragraph, he 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 to erasure. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in the controller.
The right of data portability does not affect the rights and freedoms of third parties.
f. Right of opposition and automated individual decision-making
The User has the right at any time to object to the processing of his personal data due to his particular situation, including the automation of the data by Welexit. Under article 21 of the Regulations, Welexit 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 establishment, exercise or defence of legal rights.
When personal data is processed for prospection purposes, the User has the right to object to the processing of personal data concerning him or her at any moment, including profiling insofar as it is related to such prospection.
Where the person concerned objects to the processing for prospecting purposes, the personal data is no longer processed for such purposes.
g. Right of complaint
The User has the right to complain about the processing of his personal data by Welexit with the Data Protection Authority, competent for the Belgian territory. Further information can be found on the website: https://www.autoriteprotectiondonnees.be.
Complaints can be submitted to 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 residence.
a. General principles
A “Cookie” is a file that is temporarily or permanently deposited on the User’s hard disk when consulting the Website, for later connection. Thanks to cookies, the server recognises the User’s computer.
Cookies can also be installed by third parties with whom Welexit collaborates.
Some of the cookies used by Welexit are necessary for the proper functioning of the Website, others allow the User’s experience to be improved.
The User can personalise or deactivate cookies by configuring his browser.
By using the Website, the User expressly agrees with the management of cookies as described in this article.
b. Types and purposes of cookies
Different types of cookies are used by Welexit 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 User’s navigation;
- Cookies for statistical and audience measurement: these cookies enable the recognition of the User and are used to count the number of Users of the Website over a certain period. Since they also indicate browsing behaviour, they are an effective means of improving the User’s browsing, by displaying proposals and offers likely to be of interest to the User. They also enable Welexit 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: Welexit uses tracking cookies via Google Analytics to measure the interaction of Users with the content of the Website and to produce anonymous statistics. These statistics enable Welexit to improve the Website. Google supports the explanation of these cookies at the following address:
c. Cookie Retention Time
Cookies are kept for the time necessary to achieve the intended purpose.
d. Cookie management
If the User deactivates certain cookies, he 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 can do so by using the following link(s):
For Users with the following browsers:
- 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
If the User does not want Google Analytics cookies to be used, he or she is invited to set his or her browser to this effect on the following website: http://tools.google.com/dlpage/gaoptout.
- Liability limitation of the Data Controller
The website may contain links to other websites owned by third parties not related to Welexit. Welexit is not responsible for the content of these sites and their compliance with the Law and Regulations.
The holder of parental authority must give his express consent for a minor under the age of 16 to disclose personal information or data on the website. Welexit strongly advises persons exercising parental authority over minors to promote responsible and secure use of the Internet. The Data Controller cannot be held responsible for collecting and processing 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 – particularly concerning age – entered 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.
Welexit 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 with regard 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.
- Applicable law and competent jurisdiction