1. The person responsible for processing your data
Contact email address: firstname.lastname@example.org
2. The data referred to
The categories of personal data concerning you that are processed by COVER GROUP are:
- Your identification data (surname, first name) and the data you give us to process your customers’ data;
- Your contact details (postal address and email address if applicable) and those that you communicate to us about your customers;
- Your telephone contact details (telephone, mobile phone) and those that you provide us with from your customers;
- Photographs, videos and digital format that you voluntarily provide us with;
- Your photographs, videos and any other information communicated by our Partners.
3. The processing of your personal data
We are aware and attentive to your right to be informed about the way in which your data is processed and the information that may identify you (surname, first name, address(es), date of birth, telephone number(s), email address(es), etc.) that you are likely to provide to COVER GROUP.
Your data will only be kept in the context of the performance of your contract, in the cases and according to the methods described below.
The only data to which we have access is that which you provide to us voluntarily.
When we ask you to provide personal data, you may refuse to do so. However, most of our products do require some personal data because they enable us to offer you a service. If you choose not to provide the required data that enables us to offer you a product or feature, you will not be able to use the product or feature in question.
We also combine data that we collect in different contexts (for example, from your use of COVER GROUP products) or that we obtain from third parties in order to improve our services and thus provide you with consistent and personalised IT services while respecting legitimate purposes.
When you download the Software and applications of COVER GROUP, COVER GROUP collects your personal and non-personal data in order to allow later an automatic update of the version of your Software.
By accepting the update of the Software and applications, you consent to COVER GROUP processing your data to allow the continuity and improvement of COVER GROUP’s services.
Your data is collected and processed in accordance with Belgian and international legislation, mainly the European Regulation of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data – hereinafter referred to as the “GDPR” – and the Belgian Law of 30 July 2018 on the protection of privacy with regard to the processing of personal data.
4. The processing of personal data of third parties
When you transmit your customers’ personal data to us, we store them in our application to enable you to access, use or process them for the duration of the services provided by COVER GROUP.
In this case, COVER GROUP acts as your subcontractor since the processing of your customers’ personal data is carried out on your behalf.
COVER GROUP does not check the way in which you collect personal data and does not have access to the data that you register on the platform, except in the event that a technical problem (connection problem, unavailability of data, etc.) occurs.
COVER GROUP reminds you that in this case, you are the data controller and that you must therefore imperatively respect your obligations linked to the GDPR and inform your customers of the fact that you are calling on COVER GROUP to store and record their personal data (see COVER’s obligations concerning sub-contracting below).
COVER GROUP is authorised to process on behalf of the data controller the personal data necessary to provide the following service(s):
- To facilitate invoicing for your customers by encoding their invoicing data;
- Drawing three-dimensional plans from real data (photographs of an existing plot of land by integrating the drawings produced using Cover’s software);
- Facilitate the search for data encoded by keywords.
The nature of the operations carried out on the data is:
- Storage, recording;
- Structuring, modifying and updating the data contained in the application database;
- The operations resulting from users’ requests concerning the exercise of their rights in relation to their personal data and conferred by the GDPR;
- The analysis of the data recorded in order to improve COVER’s services and improve its software.
The purpose(s) of the processing is:
- To reinforce your security measures concerning the encoding of data from the COVER software;
- To improve our services;
- To ensure internal relations between the members of COVER GROUP, its agents or subcontractors;
- To enable you to access your invoices and projects quickly and efficiently;
- To allow you to modify, store and secure the data encoded for your projects and concerning your customers;
- Execute our service provision contract.
The personal data processed are:
- The identification data (surname, first name) that you communicate to us to process your customers’ data;
- The contact details (postal address and email address if applicable) that you provide us with regarding your customers;
- The telephone contact details (telephone, mobile phone) of your customers;
- The photographs, videos and digital format of your customers.
The categories of persons concerned are: Individuals and contact persons of the companies that are your customers within the framework of the realisation of a project (design of 3D portals, verandas, etc.).
For the execution of the service subject of the present contract, the data controller provides COVER with all the information necessary for the execution of its mission (actual and current personal data of the customers whose data is being processed, proof that you have informed your customers of the processing of their personal data using the COVER software, etc.).
Subcontracting comes into effect from the date of entry into force of the service contract and ends at the end of the contract (termination, cancellation, end of term).
The service provision contract is the one you contract with COVER to use its software, its applications and/or the functionalities of its website.
Obligations of Cover as a subcontractor
COVER commits itself to you to:
1. To process the data only for the purpose(s) which is/are the subject of the subcontracting;
2. Process the data in accordance with your documented instructions. If COVER considers that an instruction constitutes a violation of the European Data Protection Regulation or any other provision of Union law or of the law of the Member States relating to data protection, it will inform you immediately. Furthermore, if COVER is required to transfer data to a third country or to an international organisation under Union law or the law of the Member State to which it is subject, it will inform you prior to the processing, unless the law concerned prohibits such information for important reasons of public interest.
3. Guarantee the confidentiality of the personal data processed;
4. Ensure that the persons authorised to process personal data under the contract:
- Undertake to respect confidentiality or are subject to an appropriate legal obligation of confidentiality;
- Receive the necessary training in the protection of personal data.
5. Take into account, with regard to its tools, products, applications or services, the principles of data protection from the design stage and data protection.
The subcontractor is allowed to use a “sub-contractor” to carry out certain processing activities (Amazon, OVH, Overworks, Mailjet, Pipedrive, Google Analytics).
Data subjects’ right to information
It is your responsibility to provide information to the persons concerned by the processing operations at the time of data collection.
Exercise of personal rights
As far as possible, COVER helps you to fulfil your obligation to comply with requests to exercise the rights of data subjects: right of access, rectification, deletion and opposition, right to limit processing, right to data portability, right not to be subject to an automated individual decision (including profiling).
Where data subjects make requests to the processor to exercise of their rights, COVER must send these requests as soon as they are received by email to your contact person.
After your agreement, COVER will notify the competent supervisory authority, in your name and on your behalf, of violations of personal data as soon as possible and, if possible, no later than 72 hours after becoming aware of them, unless the violation in question is not likely to give rise to a risk to the rights and freedoms of natural persons.
The subcontractor undertakes to implement the following safety measures:
- The anonymization of personal data;
- The means to ensure the continued confidentiality, integrity, availability and resilience of the processing systems and services;
- The means to restore the availability of and access to personal data within an appropriate timeframe in the event of a physical or technical incident.
Fate of data
At the end of the provision of services related to the processing of these data, COVER GROUP undertakes to:
- Destroy all personal data or
- Return all personal data to the data controller or
- Return personal data to the processor designated by the data controller. The return must be accompanied by the destruction of all existing copies in COVER GROUP’s information systems. Once destroyed, COVER GROUP must justify in writing the destruction.
Data Protection Officer
COVER GROUP provides the data controller with the name and contact details of its Data Protection Officer, if it has appointed one in accordance with Article 37 of the European Data Protection Regulation or, failing this, its contact person.
Register of categories of processing activities
COVER GROUP declares that it keeps a written record of all categories of processing activities carried out on behalf of the controller.
6. Purposes of data processing
COVER GROUP collects and processes your data only for specific and limited purposes to ensure that:
- The fulfilment of our contractual commitments;
- The management of your files (invoicing, administrative management, etc…);
- The communication and promotion of our offers, services and new products following your registration or following the conclusion of the contract with COVER GROUP;
- Invitations to the events we organise;
- The improvement of our services;
- The internal relations between the members of COVER GROUP, its agents or subcontractors.
7. Collection of data
We collect your personal data when we request your details in order to fulfil our contractual obligations. We need to be able to identify you in order to send you quotes with a price and, more generally, in order to manage your file following the conclusion of a service contract with COVER GROUP.
Your data is also processed through the use of the COVER GROUP Software.
We thus collect your data when you synchronise or import data from a device. Your data is used to help you and to improve our services.
In particular, we collect information about how you use our services, such as the types of content you view or interact with on the COVER GROUP Software, the features you use, the actions you perform, and the time, frequency and duration of your activities.
As described below, we collect information about the computers, telephones, connected televisions and other web-connected devices you use that integrate with our products and services from such devices. We may then cross-reference your data with our own databases to improve and enhance our services.
8. How long do we keep your data?
COVER GROUP will only keep your data for the time reasonably necessary for the purposes for which it was collected, and in accordance with legal requirements.
For invoicing data: this data may be kept for a maximum of 7 years after the closure of your file. At the end of the retention period, your data necessary for invoicing will be automatically deleted.
For data related to the improvement of our services and the respect of our contractual commitments to you: this data may be kept for as long as you use our services and will be deleted within one year following your request to no longer keep your personal data.
9. Data disclosure
Your data may be passed on to persons acting on our behalf and for our account, such as members of our staff, for processing in accordance with the purposes for which it was collected. We may also use subcontractors to manage your data, provided they are of sufficient quality to comply with personal data protection legislation.
10. Right of access, rectification, limitation, deletion and portability
In accordance with the General Regulations on Data Protection (GDPR), you have the right to access your data, to rectify any inaccuracies, or to delete them.
You will be asked to sign your written request and attach a copy of your identity card. If you so request, the information will only be provided orally after precise verification of your identity.
If you wish COVER GROUP to delete your data permanently, you must also give specific reasons for your request. We undertake to do so as soon as possible, except of course for the information necessary for the establishment of our invoicing, in order to comply with the legal accounting provisions.
For any request relating to your rights, you can contact COVER by email: email@example.com that will process your request within one month of receipt. Please note that this deadline may be extended by 2 months, depending on the complexity and number of requests.
You also have the right to a limitation of the processing of your data, as well as the right to object to the processing of data whose lawful basis is your consent.
You also have the right to obtain the erasure, as soon as possible, of personal data concerning you when such data is no longer necessary for the purposes for which it was collected or otherwise processed;
11. Security and confidentiality of your data
Access to your data is limited to COVER managers and staff, agents, Distributors and its subcontractors who must have access to it, and who observe strict standards of confidentiality in the processing of your personal data.
During your visit to our website, cookies may be placed on the hard disk of your computer or on your device. Cookies are small files that are used to store information on web browsers. In particular, they are used to store and receive information on devices such as computers or telephones. Your web browser has the ability to block these cookies or to receive a warning when a cookie has been installed or to have cookies removed from your hard drive.
Cookies used from our website:
- Essential Cookies: Functional cookies allow us to ensure the consistency of your browsing session. We can thus record a specific cookie during your browsing on the internet.
- Cookies relating to the choice of your language on the Site and/or the application.
- Cookies for monitoring traffic: this cookie enables us to check that you have accessed a page or a set of pages on our site.
We, therefore, invite you to consult it regularly to be aware of any possible modifications. New versions will be uploaded to our website, updating the date in the last paragraph.
For further information or if you wish to send us recommendations, please contact us at firstname.lastname@example.org.