1. Data controller

The controller for the processing described in this statement is:

ALMO Consulting BV Company number: 0734.532.005 · VAT: BE0734532005
Kwikstaartlaan 13, 3080 Tervuren, Belgium
info@almo-consulting.be · +32 494 62 74 81

We have not appointed a data protection officer, as we are not required to (Article 37 GDPR).

2. Summary

Activity Purpose Personal data Legal basis Retention
Website Security and operation of the website; understanding how it is used IP address, browser, pages requested, time; usage statistics Article 6(1)(f) Server logs: a short period for security purposes. Analytics: as long as needed to understand use of the website over time
Online tools Returning the requested result; security and abuse prevention Uploaded files and submitted addresses; IP address, browser, requests, time Article 6(1)(f) Files and addresses: not stored. Server logs: a short period for security purposes
Enquiries Responding to your enquiry Name, contact details, message content Article 6(1)(f), or 6(1)(b) where it leads to a contract 2 years after the last contact, unless it becomes part of a client file
Clients and invoicing Performing contracts, invoicing and bookkeeping Contact and contract data of clients and their representatives; invoices Article 6(1)(b) and 6(1)(c) Bookkeeping records: 10 years. Other client data: duration of the contract, then until the limitation period for claims has expired or statutory retention obligations end, whichever is later
Processing for ALMO Invest Operating the website and web analytics of almo-invest.com.pl Visitor data of that website Determined by ALMO Invest as controller As set out in the ALMO Invest privacy statement

3. Our website (almo-consulting.eu / almo-consulting.be)

When you visit our website, our servers record technical data: your IP address, browser, the pages you request and the time of your visit. Server logs are kept for a short period for security purposes.

We use cookieless, self-hosted web analytics to understand how the website is used: pages visited, referrer, browser and device type, and approximate country. This data is kept for as long as needed to understand use of the website over time.

No cookies are set, and the analytics store nothing on your device. If you use the light and dark display switch, your choice is remembered in your browser.

Legal basis: legitimate interests (Article 6(1)(f) GDPR) - the security and operation of the website, and understanding how it is used.

4. Online tools (md.almo-consulting.eu, api.datatoolset.eu)

Files you upload for conversion and addresses you submit for lookup are processed only to return the result and are not stored.

Server logs are kept for a short period for security purposes and to prevent abuse.

Legal basis: legitimate interests (Article 6(1)(f) GDPR) - providing the tools you use, and keeping them secure and free from abuse.

5. Enquiries by email and telephone

If you contact us by email or telephone, we process your name, contact details and the content of your message in order to respond.

Enquiries that do not lead to a contract are deleted 2 years after the last contact. Correspondence that becomes part of a client file is kept as described under "Clients and invoicing".

Legal basis: legitimate interests (Article 6(1)(f) GDPR) in responding to enquiries or, where the enquiry leads to a contract, taking steps at your request before entering into a contract and performing it (Article 6(1)(b) GDPR).

6. Clients and invoicing

We process the contact and contract data of our clients and their representatives, and the invoices we issue, to perform our contracts and meet our accounting and tax obligations. Invoices are issued electronically and our bookkeeping is done by an external accountant.

Bookkeeping records are kept for 10 years, as required by law. Other client data is kept for the duration of the contract, then until the limitation period for claims has expired or statutory retention obligations end, whichever is later.

Where a client engages us for project work, the client is usually the controller for the personal data processed in that project. We then act as processor and process that data only on the client's documented instructions. Personal data processed in project work is shared only with the recipients listed below or as required to deliver the agreed services.

Legal basis: performance of a contract (Article 6(1)(b) GDPR) and compliance with a legal obligation (Article 6(1)(c) GDPR).

7. Processing on behalf of ALMO Invest sp. z o.o.

We operate the website and web analytics of almo-invest.com.pl as processor for ALMO Invest sp. z o.o. For that processing, ALMO Invest is the controller. See its privacy statement: almo-invest.com.pl/prywatnosc.

8. Recipients

Depending on the activity, personal data may be disclosed to the following categories of recipients:

  • hosting and content-delivery providers;
  • email service providers;
  • our bank and electronic invoicing platform;
  • our external accountant;
  • public authorities, where the law requires it.

Our service providers act as processors under contract. We do not sell personal data.

Personal data is processed within the European Economic Area. Where a provider may access data from outside the EEA, this is covered by the EU Standard Contractual Clauses or an adequacy decision.

9. Security and backups

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration and loss.

Backups are encrypted, kept in Belgium and overwritten on a fixed rotation, so data we delete disappears from the backups when the rotation expires.

10. Your rights

Under the General Data Protection Regulation (GDPR - Regulation (EU) 2016/679) you have the right to:

  • access your personal data and receive a copy;
  • rectification of inaccurate or incomplete data;
  • erasure of your data;
  • restriction of processing;
  • object (Article 21 GDPR) to processing based on legitimate interests, on grounds relating to your particular situation;
  • data portability for data you provided to us under a contract or consent;
  • withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of earlier processing.

To exercise these rights, contact us at info@almo-consulting.be. We reply within one month of receiving your request.

We do not make decisions based solely on automated processing, including profiling, within the meaning of Article 22 GDPR.

11. Right to lodge a complaint

If you believe that our processing of your personal data infringes the GDPR, you can lodge a complaint with the Belgian Data Protection Authority:

Gegevensbeschermingsautoriteit / Autorité de protection des données Drukpersstraat 35 / Rue de la Presse 35, 1000 Brussels
www.gegevensbeschermingsautoriteit.be
contact@apd-gba.be

You can also complain to the supervisory authority of the EU Member State where you live or work, or where the alleged infringement took place.

12. Changes to this statement

We may update this statement. The "Last updated" date at the top of this page shows when it was last revised.

This statement is available in English, Dutch and French; all three language versions are equally authoritative.

For questions about this statement or how we handle your personal data, contact us at info@almo-consulting.be.