With this “Privacy Statement” the processing of your personal data is communicated by the following controller: Sherlock SEO Agency, with registered office at Werchtersesteenweg 143 3130 Betekom and registered in the K.B.O. under number VAT BE 0633.600.436.
This Privacy Statement provides the essential information by which your personal data is processed.
By providing your personal data on the website and by providing the email addresses listed on this website with Personal Data, you declare that you have read this Privacy Statement and also expressly agree to it, as well as to the processing itself.
Article 1 – Introduction
A. Who are we?
Sherlock SEO Agency values your privacy and considers it very important to process your personal data with due care and confidentiality.
We comply with European regulation 2016/679 of April 27, 2016 on the protection of personal data (General Data Protection Regulation, GDPR), as well as the Belgian Framework Law of July 30, 2018.
Through this “Privacy Statement” we wish to explain transparently how Sherlock SEO Agency, with registered office at Werchtersesteenweg 143 3130 Betekom and registered with the K.B.O. under number BE 0633.600.436 handles your personal data.
This privacy statement applies to all processing of personal data by Sherlock SEO Agency in its capacity as data controller This means that we determine the purposes and means of processing your personal data.
If you have any questions after reading our privacy statement, please feel free to send them to email@example.com.
B. To whom and when does this privacy statement apply?
This privacy statement applies to all customers and visitors to the www.sherlockseo.be website and all related activities. It also applies, for example, to prospects, service providers and to the commercial relationships that are established.
By providing your personal data on the website and by providing the email addresses listed on this website with Personal Data, you declare that you have read and expressly agree to this Privacy Statement, as well as to the processing itself.
Article 2 – Personal data
A. What does the processing of personal data mean?
A processing operation is an operation or set of operations involving personal data or a set of personal data, whether or not carried out by automated processes. The concept of “processing” can be interpreted broadly Thus, the collection, recording, organization, structuring, storage, updating or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of data are all examples of processing.
B. Personal data you communicate to us:
As a data controller, we process your personal data in the following circumstances:
- When you contact us via the contact form
- When you request information or express interest in our services
- When you submit your application
- When you register for our newsletter
- When you register for an event
C. What personal data do we collect?
We may process the following personal data about you. Depending on the situation, we will not necessarily process all of the personal data listed below:
- Your contact information: name, address and other contact information
- your contact history: emails sent and received,…
- work-related data: CV, education, degree, language skills, professional activities, reference checks,…
- identification data: identity card data,…
- financial data
- personal details: gender, date of birth, place of birth, marital status, nationality
D. Special categories of personal data
In principle, we do not process special personal data such as health data, political opinions, biometric data, sexual orientation, ethnic origin, …
Article 3 – Legal grounds for processing
Sherlock SEO Agency will only use your personal data on the following legal grounds:
- The processing is necessary for the performance of the agreement with our clients and to carry out our services
- The processing is necessary to fulfill our legal obligations
- We may also process your personal data on the basis of legitimate interest. We will process your personal data only for the predetermined purposes. Should we wish to use your data for other purposes, we will only do so upon receipt of your specific consent. In addition, we will provide appropriate technical and organizational measures to prevent unauthorized access to your personal data.
- We may process your personal data based on your specific consent.
Article 4 – Purposes of processing
4.1. General purposes:
Sherlock SEO Agency will use the Personal Data collected from you only for the following purposes and in compliance with the provisions of the General Data Protection Regulation:
- Operational purposes: To provide and improve this website and to include Personal Data in anonymous statistics, from which the identity of specific individuals or companies cannot be ascertained, with the legal basis being the legitimate interests of Sherlock SEO Agency to continuously improve its website and services
- Business purposes: to inform you of our services, to communicate our terms and conditions, to perform our services, to transfer our billing, to communicate with our customers and with job applicants
- Commercial purposes: Sending direct marketing, newsletters, invitations to events ,… based on your explicit, prior consent and taking into account your rights. You may withdraw your consent at any time. Given the nature of the data available and the fact that some information is publicly available, we consider the risk of violation of your rights to be minimal. For the application of the legitimate interest as the legal basis for processing personal data, will limit the impact on your privacy to the strict minimum by restricting the use of your data and building in the necessary access rights to avoid unauthorized access.
- Improving the user experience with the legal basis of your explicit, prior consent
You are not required to disclose your personal data, but understand that the provision of certain services becomes (partially) impossible if processing is refused.
Sherlock SEO Agency will not sell, rent or make your Personal Data commercially available to third parties except with your prior consent.
4.2. Where we process data
- We ourselves and our third-party processors will process your identifiable personal data only in the EEA (European Economic Area).
- We may transfer your anonymized and/or aggregated data to organizations outside the EEA. If such a transfer occurs, we will ensure that appropriate safeguards are in place to ensure the security and integrity of your personal data, and that any rights with respect to personal data that you might enjoy under applicable mandatory law are guaranteed. For example, we use Active Campaign and Zoom.
- Both Active Campaign and Zoom provide the ability to adjust certain settings so that these tools can be used in compliance with the GDPR. Taking this into account as well as the limited transfer of data via these tools, we ensure the highest possible level of protection for your data.
- By providing your Personal Data on the website and by providing the email addresses listed on this website with Personal Data, you declare that you are aware of and also expressly agree to the transfer to third countries.
Article 5 – From whom we may receive personal data
We may receive your personal information directly from you, or through public sources, or because of third parties.
If we will further process your data obtained from external sources for purposes other than those for which it was collected, we will seek your explicit consent to do so.
Article 6 – With whom may we share your data?
We will not share your information with third parties unless:
- We are required by law to do so
- You have given us your explicit consent
- When necessary to accomplish any of the above purposes
If we need to use external service providers (“processors”) in the context of our services (for example, in the context of ICT, payroll, the rollout of business processes,…) then these processors will process personal data on our behalf. They can neither use this data for purposes other than those predetermined nor for their own purposes. To ensure all rights and obligations, a “processor agreement” is signed with these processors.
Also, some of our employees will have access to your personal data. To this end, contractual agreements were established with the employees involved with a view to ensuring confidentiality and data protection.
Article 7 – How long do we keep your data?
Personal data will be kept and processed by us for a period necessary in function of the purposes of the processing and in function of the contractual relationship between yourself and Sherlock SEO Agency
This takes into account the relevant laws and regulatory requirements on record keeping.
We may also retain them to fulfill our legal obligations, respond to inquiries and resolve any disputes, satisfy our legitimate interests and enforce our rights.
Article 8 – Your rights
The following rights regarding your own personal data can be exercised at any time upon simple request.
8.1. Right of access and inspection:
You have the right to access your personal data at any time free of charge. If your request is manifestly unfounded or excessive, we may still charge you a reasonable fee in light of the administrative costs incurred by us. However, in the same case, we may choose not to act on your request. You will always be informed of the reasons if applicable.
8.2. Right of rectification, deletion and restriction:
You are free to disclose or not disclose Your personal information to Sherlock SEO Agency. In addition, you always have the right to ask us to correct, supplement or delete your personal data.
8.3. Right to object:
You always have a right to object to the processing of your personal data for serious and legitimate reasons or for purposes of direct marketing.
8.4. Right of transferability:
You have the right to obtain your personal data in a structured format and/or transfer it to other responsible parties.
8.5. Right to withdraw consent:
If the processing is based on your prior consent, you of course have the right to withdraw that consent.
8.6. Exercise of your rights:
You can exercise your rights by contacting us to do so, either by e-mail, to firstname.lastname@example.org, by mail to Werchtersesteenweg 143 3130 Betekom. In doing so, additional identification may be requested for identification.
For other requests (collaborations/disputed content/placed links), please contact us via the contact page.
8.7. Automated decisions and profiling:
While processing your personal data, no profiling methods are used with adverse automatic impact on the services received.
8.8. Right to file complaint:
If for some reason you should be dissatisfied with our data protection policy, you can of course contact us so that we can find a solution with you. Should this fail, you still have the right to lodge a complaint with the Belgian Data Protection Authority, Printing Press Street 35, 1000 Brussels, Tel +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35, e-mail: email@example.com.
Article 9 – Security and confidentiality
9.1. We have developed security measures adapted at the technical and organizational levels to avoid the destruction, loss, falsification, modification, unauthorized access or inadvertent notification to third parties of personal data collected as well as any other unauthorized processing of this data.
9.2. Under no circumstances can Sherlock SEO Agency be held liable for any direct or indirect damage resulting from an erroneous or unlawful use by a third party of the personal data.
9.3. You must comply with safety regulations at all times. Thus, you are solely responsible for the use made from the website of your computer, IP address and of your identifying information, as well as for its confidentiality.
Article 10 – Links to other websites
10.1. Sherlock SEO Agency is not responsible for the content of websites linked from Sherlock SEO Agency by the administrator or visitors. The visitor is aware that the privacy of other websites may differ from Sherlock SEO Agency.
10.2. A link to a website cannot be regarded as an explicit approval of the content of that website and cannot be guaranteed to be correct.
Article 11 – Questions or complaints
If you have any questions regarding our privacy statement or if you wish to make a complaint, please find below our contact information:
Article 12: Changes to the privacy statement
Sherlock SEO Agency has the right to make changes to its privacy statement. The latest version of the privacy statement can always be consulted on the website.
Version date: May 26, 2021