Privacy and Cookie Policy

Object

This Charter has been prepared by Carthagena Management Ltd (Manu Claessens), with registered office at Cooper House, Lower Charlton Trading Estate 5, Shepton Mallet, Somerset, BA4 5QE, UK, registered with the Crossroads Bank for Enterprises in the United Kingdom under number 04860209 (hereinafter referred to as the “Controller”). The object of the present Charter is to inform visitors to the website at the address https://carthagenamanagement.co.uk/ (hereinafter referred to as the “Website”) with regard to the way in which the data is collected and processed by the Controller.

This Charter is based on the Controller’s wish to act in all transparency, in accordance with the Act of 8 December 1992 on the protection of privacy with regard to the processing of personal data and in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council 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, and repealing Directive 95/46/EC (hereinafter the “General referred to as the Data Protection Regulation”).

The Controller pays particular attention to the protection of the privacy of its users and therefore undertakes to take all necessary and reasonable measures to protect the personal data of these persons against loss, theft, distribution or unauthorized use. .

If the user wishes to respond to one of the provisions mentioned below, he can contact the Data Controller at the postal address or e-mail address indicated in the point “contact details” of this Charter.

Permission

By accessing and using the Website, the user declares to have taken note of the information listed below and accepts this Charter. This also means that the user expressly agrees to the collection and processing of personal data communicated by the user via the Website and/or on the occasion of the services offered by the Website by the Processing Manager for the processing of personal data. with a view to the objectives stated below, in accordance with the modalities and principles set out in the current Charter.

The user has the right to withdraw his consent at any time. The withdrawal of this consent does not affect the lawfulness of the processing that has already taken place on the basis of the prior consent.

What data do we collect?

By visiting and using the Website, the user expressly agrees that the Data Controller, in accordance with the modalities and principles described below, collects and processes the following personality data:

• The domain of the user (automatically picked up by the server of the controller), including the dynamic IP address
• The e-mail address of the user if the user has previously entered this, for example by posting messages or asking questions on the website, by communicating via e-mail with the controller, by participating in discussion forums, by identification to access a limited part of the website, etc
• The entirety of information related to the pages visited by the user on the website
• All information voluntarily provided by the user, for example in the context of surveys and/or registrations on the website, or by identifying access to a limited part of the website

It is possible that the Controller also collects data that is not of a personal nature. This data is classified as non-personal data and does not allow any particular person to be identified directly or indirectly. This data can therefore be used for whatever purpose, for example to improve the Website, to improve the products and services offered or to improve publications of the Controller.

In the case where personal data are combined with data of a non-personal nature, so that it is possible to identify the persons concerned, these data will be processed as personal data until the persons concerned can no longer be identified on the basis of the data in question.

Modes of Collection

The Processing Manager collects personal data in the following ways: web and contact forms, technical cookies, analytical cookies, functional cookies, performance cookies, commercial cookies and tracking cookies.

The purposes of the processing

The personal data is collected and processed solely for the following purposes:

• Ensuring management and control as regards the execution of the services offered
• Sending and tracking orders and invoicing
• Sending promotional information related to the products and services by the controller
• Sending free samples or offering services at more favorable conditions
• Answering user questions
• Realizing statistics
• Improving the quality of the website and the products and/or services by the controller
• Forwarding information regarding new products and/or services by the data controller
• Direct marketing purposes
• Allow the user’s interests to be better identified

The Controller may be required to carry out processing operations that have not yet been included/provided for in this Charter. In such a case, the Controller will contact the user before using his personal data, in order to inform the user of the changes and to give him the option, where appropriate, to refuse such use.

Duration of storage

The Controller only stores the personal data for the period that is reasonably necessary to achieve the intended purposes and in accordance with legal and regulatory requirements.

The personal data of a customer is stored for a maximum of 3 years after termination of the contractual relationship that binds the customer to the Controller.

Shorter retention periods will apply for certain categories of data, such as traffic data that are only kept for a period of 12 months.

At the end of the retention period, the Controller will make every effort to ensure that the personal data has been made unavailable.

Access to the data and copies

By means of a written, dated and signed request addressed to the Processing Manager at the address mentioned under the point “contact details” of the current Charter, the user can obtain the written communication free of charge, after his identity has been verified (by attaching a copy of his identity card). or a copy of the personal data that has been acquired.

The Controller may require the user to pay all reasonable costs, based on the administrative costs for each additional copy requested by the user.

As soon as the user submits this request electronically, the information will also be delivered electronically, unless the user wishes otherwise.

The copy of his data will be communicated to the user no later than one month after receipt of his request.

Right to improvement

By means of a written, dated and signed request addressed to the Processing Manager at the address mentioned under the point “contact details” of the current Charter, the user can, after his identity has been verified (by enclosing a copy of his identity card), within a reasonable period of time and at the latest within the period of one month, request the correction of his personal data free of charge if they contain errors, are incomplete or irrelevant, as well as request that his data be supplemented if they turn out to be incomplete.

The right to object to the processing

By means of a written, dated and signed request addressed to the Processing Manager at the address mentioned under the point “contact details” of the current Charter, the user can at any time, for reasons related to his personal situation and after his identity has been verified (by to enclose a copy of his identity card), to oppose, free of charge, the processing of his personal data:

• When the processing is necessary for the performance of a task carried out in the public interest or when the processing is part of the exercise of official authority vested in the controller
• When the processing is necessary for the performance of a task carried out in the public interest or for a task in the exercise of official authority
• Where the processing is necessary for the purposes of the legitimate interests pursued by the controller, provided that the interests or fundamental rights and freedoms of the data subject which require the protection of personal data do not override that interest (in particular where the data subject has a child).

The Controller may refuse to implement the user’s opposition if it establishes the existence of compelling and legitimate reasons justifying the processing, which override the interests or the rights and freedoms of the user, or if they are used for the purposes of a dispute in court, the conduct of a defense in court or for the exercise of rights. In the event of a dispute, the user can appeal against this in accordance with the provisions of the point “objection and complaints” of the current Charter.

By means of a written, dated and signed request addressed to the Processing Manager at the address mentioned under the point “contact details” of the current Charter, the user can at any time and after his identity has been verified (by enclosing a copy of his identity card), object without any justification and free of charge to the processing of his personal data if this data was collected for direct marketing purposes (including profiling).

If the personal data is used in the context of scientific or historical research or for statistical purposes in accordance with the General Data Protection Regulation, the user has the right to object to the processing of his personal data, for reasons related to his personal situation, unless the processing is necessary for a task in the exercise of official authority.

The Processing Manager is obliged to reply to the user’s question within a reasonable period of time and at the latest within one month and must motivate his answer if he does not intend to grant a favorable response to the user’s question.

The right to restriction of processing

By means of a written, dated and signed request addressed to the Processing Manager at the address mentioned under the point “contact details” of the current Charter, the user can, after his identity has been verified (by attaching a copy of his identity card), obtain the limitation of the processing of his personal data, in the following cases:

• When the user disputes the accuracy of a data and only for the period necessary for the controller to verify it
• When the use is unauthorized or when the user prefers the limitation of the operation to the erasure of the data
• When the user needs this restriction for a dispute, exercise or defense in law, although this is no longer necessary for the continuation of the purposes of the processing
• During the period necessary to examine the merits of an application for opposition, in other words, the period necessary for the controller to balance the legitimate interests of the controller and those of the controller user

The Controller will inform the user as soon as the restriction of operation is lifted.

The right to erasure (right to be forgotten)

By means of a written, dated and signed request addressed to the Processing Manager at the address mentioned under the point “contact details” of the current Charter, the user can, after his identity has been verified (by attaching a copy of his identity card), obtain the erasure of the personal data relating to him, if one of the following reasons applies:

• The data is no longer necessary with regard to the purposes of the processing
• The user has withdrawn his consent to the processing of his data and there is no legal basis for further processing
• The user opposes the processing and there is no overriding legitimate motive for further processing and/or the user exercises his special right to object with regard to direct marketing purposes (including profiling)
• The personal data has been the subject of an unauthorized use
• Personal data of a personal nature must be erased in order to comply with a legal obligation (under European Union law or the law of a Member State) to which the controller is subject
• The personal data was collected in the context of an offer to provide services by the information society aimed at children

However, the erasure of the data does not apply in the following 5 cases:

• As soon as the processing is necessary for the exercise of the right to freedom of expression and the right to information
• As soon as the processing is necessary to comply with a legal provision that requires processing as provided for by the law of the European Union or by the law of one of the Member States to which the Controller is subject, or when the processing is necessary for the fulfillment of a task in the public interest or for a task in the exercise of public authority
• As soon as the processing is necessary for reasons of public interest in the field of public health
• As soon as the processing is necessary for archiving purposes in the public interest, for scientific or historical research or for statistical purposes, and provided that the right to erasure can make it impossible or seriously impair the realization of the purposes of the processing
• As soon as the processing is necessary for the dispute, exercise or defense in law.

The Processing Manager is obliged to reply to the user’s request for erasure within a reasonable period of time and at the latest within one month and must justify his answer if he does not intend to grant a favorable response to the user’s request.

The user also has the right to obtain, free of charge, within the same modalities, the abolition or prohibition of use of all personal data concerning him which, taking into account the purpose of the processing, is incomplete or irrelevant or of which registration, communication or storage are prohibited or have been kept for a longer period than necessary and permitted.

The right to “data portability”

By means of a written, dated and signed request addressed to the Processing Manager at the address mentioned under the point “contact details” of the current Charter, the user can at any time and after his identity has been verified (by enclosing a copy of his identity card), to obtain his personal data free of charge in a structured and commonly used format, readable by machines, with a view to transferring them to another controller:

• If the processing of the data is carried out using automated processes
• If the processing is based on the user’s consent or on an agreement concluded between the latter and the Controller

Under the same conditions and following the same modalities, the user also has the right to demand from the Controller that the personal data concerning him be transferred directly to another controller for the processing of personal data, insofar as this is technically possible.

The right to data portability does not apply to processing necessary for a task carried out in the public interest or in the exercise of official authority vested in the Controller.

Recipients of the data and disclosure to third parties

The recipients of the collected and processed data are, in addition to the Controller himself, the staff members or other subcontractors, the carefully selected commercial partners, located in Belgium or the European Union, who cooperate with the Controller in the context of the commercialization of the products. or the provision of services.

In the hypothesis in which the data would be disclosed to third parties for direct marketing or prospecting purposes, the user will be informed about this in advance in order to allow him to accept or not the processing of his data by third parties.

By means of a written, dated and signed request addressed to the Processing Manager at the address mentioned under the point “contact details” of the current Charter, the user can at any time and after his identity has been verified (by enclosing a copy of his identity card), oppose the transfer of his data to third parties free of charge.

The Controller complies with all applicable legal and regulatory provisions and will in any case ensure that its partners, employees, subcontractors and other third parties who have access to the personal data comply with the current Charter.

The Controller reserves the right to disclose the user’s personal data if a law, legal process or order from a public authority makes such disclosure necessary.

No transfer of personal data will take place outside the European Union.

Use and management of «cookies»

General principles.  This article provides information regarding the use of cookies on the Website.

The current cookie management policy applies to the Website. These are managed by the Controller.

The Website uses cookies to make navigation more accurate and reliable. Some of these cookies are indispensable for the proper functioning of the Website, others allow to improve the user’s experience.

Most web browsers are configured to accept cookies automatically. If the user wishes to personalize its management, he must change the settings of his web browser. He will find more information on this subject under the point “management of cookies” of the current provision.

By visiting and using the Website, the user expressly consents to the management of cookies described below.

Definition of Cookies.  A “cookie” is a data file or text file that the server of a Website will temporarily or permanently store on the user’s device (hard drive of his computer, tablet, smartphone or any other similar device) by using the browser of the user. The cookies can also be installed by third parties with whom the Controller collaborates.

The cookies store certain information, such as the language preferences of the visitors or the contents of the shopping cart. Other cookies store statistics related to the users of the Website or ensure that graphs are displayed correctly and that the applications on the website work properly. Still other cookies allow the content and/or the advertising of the Website to be adapted to the user.

Use of cookies on the website.  The Website uses the following types of cookies:

• Essential or technical cookies: these cookies are essential for the operation of the website and ensure good communication and facilitate browsing
• Statistical or analytical cookies: these cookies allow visitors to be recognized and counted, as well as to save their browsing behavior when they visit the Website. This facilitates the user’s browsing and allows the user to more easily find what they are looking for
• Functional cookies: these cookies allow to activate specific functions of the Website in order to improve the user-friendliness and the user’s experience, especially since the cookies remember the preferences of the user (for example the language)
• Performance-related cookies: These cookies store information related to how the Website is used by users. They also allow to evaluate and continuously improve the performance of the Website (for example by tracking the number of visitors, by identifying the pages and the most popular clicks), and to better tailor the commercial offers to the user’s personal preferences
• Advertising and commercial cookies: these are files that have the purpose of collecting data relating to the profile of the users and these files can be installed or read by third parties with whom the Controller collaborates in order to improve the effectiveness of a publicity or a web page measure and adapt to user interests
• The Tracking Cookies: The Website uses tracking cookies through Google Analytics to assist the Data Controller in processing how users interact and interact with the Website’s content, and generate anonymous visitor statistics. These statistics make it possible to improve the Website on a permanent basis and to offer the user relevant content. The Processing Manager uses Google Analytics in order to form a picture of the website traffic, the origin of this traffic and the webpages visited. This means that Google acts as a subcontractor. The information collected by Google Analytics is generated anonymously. For example, it is not possible to identify the persons who visit the Website.

The Controller can also use cookies and beacons to collect information regarding the surfing habits of users on the various websites and applications that belong to its advertising network. A beacon is an invisible graphic file that tracks the user’s browsing on one or more websites and/or applications. In addition, several commercial cookies may be installed by the advertisers when distributing their advertisement.

The commercial cookies do not contain any personal data. The information and beacons collected with the help of commercial cookies are used to measure the effectiveness of the advertising and to better personalize the advertising on the Website, as well as on other websites belonging to the advertising network or for which the Processing Manager provides advertising services.

The storage period of the cookies varies according to their type: the essential cookies are generally stored until the browser is closed, while functional cookies remain valid for 1 year and cookies related to performance for 4 years.

The Processing Manager authorizes the public search engines to visit the website via “spiders”, with the aim of making access to and the content of the Website accessible via these search engines, without the Controller granting any right to archive the Website. The Controller reserves the right to revoke such consent at any time.

In order to be able to make offers that might interest the user, the Controller may conclude agreements with advertising agencies via the Internet. These receive permission from the Processing Manager to place advertising advertisements on the Website. As soon as the user visits the Website, these advertising agencies can also collect information.

The management of the cookies.  The majority of browsers are set up to automatically accept cookies, but all browsers allow you to personalize the settings according to the user’s preferences.

If the user does not want the Website to place cookies on his computer/mobile device, he can easily manage or delete the cookies by changing the settings of his browser. The user can also program his browser to be notified when he receives a cookie, so that the user can decide whether or not to accept it.

If the user wishes to block and/or manage certain cookies, he can do so by following the following link associated with his browser:
– Internet Explorer: http://windows.microsoft.com/en-us/windows-vista /block-or-allowcookies
– Chrome: https://support.google.com/accounts/answer/61416?hl=en
– Firefox: https://support.mozilla.org/en-US/kb/enable-and -disable-cookies-websitepreferences
– Safari: http://support.apple.com/kb/PH5042
– Opera: https://www.opera.com/help/tutorials/security/privacy /

If the user does not wish to accept cookies from Google Analytics, he can indicate this via the cookie message that appears when he uses the website for the first time, or by changing the settings of his browser so that cookies are saved. refused.

To stop being tracked by Google Analytics on any website, the user can use the following website: http://tools.google.com/dlpage/gaoptout

If the user deactivates certain cookies, it is possible that certain parts of the website cannot be accessed and/or used, or that they may only be partially accessible and/or usable.

Safety

The Processing Manager ensures the appropriate technical and organizational measures to guarantee a level of security with regard to the processing of the data collected, in accordance with the risks that may arise with regard to the processing of the data and adapted to the nature of the data to be protected. data. The Controller takes into account the state of knowledge, the costs of the works and the nature, scope, context and purpose of the processing, as well as the risks to the rights and freedoms of users.

When receiving or sending data on the Website, the controller always uses encryption technology that is recognized within the IT sector as the industry standard. The Controller has taken the necessary security measures to protect the information obtained through the Website and to avoid loss, misuse or alteration.

Electronic and telephone communication and communication by post

Communication by mail.  If the user transmits his postal address to the Processing Manager via the Website, this data will be stored in the Data Controller’s address file in order to answer his questions and to keep the user informed about the products and services offered by the Processing Manager. Unless opposed by the user, the Controller may communicate the data relating to the user to third parties (such as groups of companies and commercial partners) for direct marketing purposes. If the user does not want his data to be used for direct marketing purposes, he can indicate this when registering on the Website.

The user can consult, correct or delete his data in the data file of the Data Controller at any time. To do this, he will have to contact the Controller at the address stated in the point “contact details” of the current Charter, stating his name and exact address details (correct spelling). The Controller undertakes to remove this data from the list that it shares with other companies or organisations.

Telephone communication. If the user transmits his telephone number to the Controller via the Website, he can receive a telephone call:

• From the Controller in order to provide him with information regarding future products, services or events
• From corporate groups and commercial partners with which the Controller is contractually bound

If the user no longer wishes to receive telephone calls, he can contact the Processing Manager at the address stated under the point «contact details» of the current Charter, stating his name and exact address details (correct spelling). The Controller undertakes to remove this data from the list that it shares with other companies or organizations

If the user communicates his mobile phone number to the Processing Manager via the Website, he will only receive messages (SMS/MMS) from the Processing Manager that are necessary to answer the user’s questions or to inform him about the orders that he posted online.

Communication by email.  If the user communicates his e-mail address to the Processing Manager via the Website:

• Can he receive emails from the Controller in order to provide him with information regarding future products, services or events (with direct marketing purposes), provided that the user has expressly agreed to this because he is already a customer of the Controller and has communicated his e-mail address to the Controller
• Can he receive e-mails from groups of companies and from companies/organizations with which the Controller is contractually connected, for direct marketing purposes, insofar as the user has expressly consented to this?

If the user no longer wishes to receive such e-mails, he can contact the Processing Manager at the address stated under the point «contact details» of the current Charter, stating his name and exact address details (correct spelling).

The Controller undertakes to remove this data from the list that it shares with other companies or organisations.

The Robinson List.  If the user of any company registered on the Robinson list no longer wishes to receive e-mails or telephone calls, he can contact the Robinson service of the Belgian Direct Marketing Association:
– www.robinsonlist.be
– Free telephone number: 0800-91 887
– By post : BDMA, Robinson list, Buro & Design Center, Esplanade du Heysel B46, 1020 Brussels

Objections and complaints

The user can submit an objection to the Belgian Commission for the Protection of Privacy at the following address:
Commission for the Protection of Privacy, Drukpersstraat, 35, 1000 Brussels.
Phone. +32 2 274 48 0
Fax. + 32 2 274 48 35
commission@privacycommission.be

The user can also file a complaint with the Court of First Instance of his place of residence. For more information regarding complaints and possibilities of redress, the user is invited to consult the following address of the Belgian Commission for the Protection of Privacy: https://www.privacycommission.be /de/node/19254

Contact details

For any question and/or complaint, in particular with regard to the clarity and accessibility of the current charter, the user can contact the Controller:
By e-mail : info@carthagenamanagement.co.uk
By post : Carthagena Management Ltd Attn Manu Claessens – Cooper House, Lower Charlton Trading Estate 5, Shepton Mallet, Somerset, BA4 5QE, UK

Applicable law and competent courts

The present Charter is governed by English law. Any dispute relating to the interpretation or implementation of this Charter shall be governed by English law and shall be subject to the exclusive jurisdiction of the courts of the judicial district of Bristol, United Kingdom

Miscellaneous provisions

The Controller reserves the right to change the provisions of the current Charter at any time. The changes will be published with notification of their entry into force.

This version of the charter dates from 16/05/2018.