Privacy policy
1. Parties and Purpose
The https://lecercle.ai/ website (the “Site”) is published by Antidote SRL (hereinafter referred to as “We” or “Antidote”), whose registered office is at Volontaires 19, 1160 Auderghem and which is registered with the Brussels Register of Legal Persons under number 0773.969.928.
- Responsible editor: Tarik Hennen, Director.
- The host of the https://lecercle.ai/est website is GoDaddy.com, LLC.
Antidote SRL has drawn up this Privacy Policy in order to transparently inform Users of the website hosted at the following address: http://lecercle.ai/ (hereinafter the “Site”) of the manner in which personal data is collected and processed by Antidote SRL.
The term “User” refers to any individual or legal entity who visits or interacts in any way with the Site.
As such, Antidote determines all the technical, legal and organizational means and purposes of processing Users’ personal data. To this end, Antidote undertakes to take all necessary measures to ensure that personal data is processed in accordance with the Law of July 30, 2018, on the protection of individuals with regard to the processing of personal data (hereinafter, “the Law”) and the European Regulation of April 26, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter, “the Regulation”).
Antidote is free to choose any individual or legal entity that processes users’ personal data at its request and on its behalf (hereinafter the “Subcontractor”). Where applicable, Antidote undertakes to select a Subcontractor offering sufficient guarantees as to the technical and organizational security measures for the processing of personal data, with regard to the Law and the Regulation.
2. Processing of personal data
The use of the Site by Users may entail the communication of personal data. The processing of such data by Antidote, in its capacity as Data Controller, or by service providers acting in the name and on behalf of SRL, will comply with the Law and the Regulation.
Personal data will be processed by Antidote, in accordance with the purposes set out below, via :
- Forms (contact, application, appointment) ;
- exchanges by e-mail or post;
- the use of cookies.
3. Purpose of personal data processing
In accordance with Article 13 of the Regulation, the purposes for which personal data is processed are communicated to the User and are as follows:
- to provide you with advice and services in digital marketing and strategy;
- expand our business and develop new product or service offerings;
- improve service quality ;
- personalize our services according to your preferences;
- tailor our website and content to your interests and preferences.
4. Personal data likely to be processed
The User consents, when visiting and using the Site, that Antidote collects and processes, according to the terms and principles described in this Privacy Policy, the following personal data:
- surname, first name, address, sex/gender, nationality, photograph ;
- contact data, such as your telephone number and e-mail address;
- your social network profiles;
- bank details.
5. Consent
By accessing and using the Site, the User declares that he/she is aware of and gives his/her free, specific, informed and unequivocal consent to the processing of his/her personal data. This agreement covers the content of the present Privacy Policy.
Consent is given by the positive act by which the User has checked the box proposing the Privacy Policy in hypertext link. This consent is an indispensable condition for carrying out certain operations on the Site or for allowing the User to enter into a contractual relationship with Antidote. Any contract between Antidote and a User relating to the services and goods offered on the Site is subject to the User’s acceptance of the Privacy Policy.
The User consents to the processing and collection by the Data Controller, in accordance with the terms and principles set out in this Privacy Policy, of any personal data that the User communicates on the Site or in connection with the services offered by Antidote, for the purposes indicated above.
The User has the right to withdraw consent at any time. Withdrawal of consent does not compromise the lawfulness of processing based on consent previously given.
6. Retention period for Users’ personal data
In accordance with article 13 §2 of the Regulation and the Law, the Data Controller only keeps personal data for as long as is reasonably necessary to achieve the purposes for which it is processed.
This period is in any case less than : (i) 5 years for our customers (after the end of our commercial relationship, from the date of our last invoice or last significant contact); (ii) 12 months for prospects (from the date of our last significant contact with you).
7. Recipients of data and disclosure to third parties
Personal data may be passed on to Antidote’s employees, collaborators, subcontractors or suppliers who offer adequate data security guarantees and who collaborate with Antidote in the marketing of products or the provision of services. They act under the direct authority of Antidote, and are in particular responsible for collecting, processing or subcontracting such data.
In all cases, the recipients of the data and those to whom the data has been disclosed comply with the contents of this Privacy Policy. Antidote assures you that they will process your data only for the purposes intended, in a confidential and secure manner.
8. User rights
The User may exercise his rights at any time by sending an e-mail to the following address: legal@lecercle.ai, or a letter by post, enclosing a copy of his identity card, to the following address: 19 Avenue des Volontaires, 1160 Auderghem.
a. Right of access
In accordance with Article 15 of the Regulation, Antidote guarantees the User’s right of access to his/her personal data. The User has the right to obtain access to 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 recipient to whom the personal data have been or will be disclosed, in particular recipients established in third countries or international organizations;
- where possible, the intended retention period for 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, useful information concerning the underlying logic, as well as the significance and expected consequences of such 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 (by e-mail address, for example), the information is provided in a commonly used electronic form, unless the User requests otherwise.
The User will be sent a copy of his or her data no later than one month after receipt of the request.
b. Right of rectification
Antidote guarantees the user the right to rectify and delete personal data.
In accordance with Article 16 of the Regulations, incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User shall first make the necessary changes himself/herself from his/her user/other account, unless they cannot be made autonomously, in which case the request may be made to Antidote.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom personal data has been communicated of any rectification of personal data, unless such communication proves impossible or would require disproportionate effort. The Data Controller shall provide the data subject with information about such recipients if the data subject so requests.
c. Right to erasure
The User has the right to obtain the deletion of his personal data as soon as possible in the cases listed in Article 17 of the Regulation.
Where the Controller has made the personal data public and is required to erase it pursuant to the preceding paragraph, the Controller shall, taking into account available technology and implementation costs, take reasonable steps, including technical steps, to inform other controllers who process such personal data that the data subject has requested the erasure by such controllers of any links to, or copies or reproductions of, such personal data.
The two preceding paragraphs do not apply insofar as such processing is necessary:
- the exercise of the right to freedom of expression and information;
- to comply with a legal obligation which requires the processing and is provided for by Union law or by the law of the Member State to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
- the establishment, exercise or defense of legal claims.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom personal data has been communicated of any erasure of personal data or restriction of processing carried out, unless such communication proves impossible or requires disproportionate efforts. The data controller shall provide the data subject with information on these recipients upon request.
d. Right to limit processing
The User has the right to obtain the limitation of the processing of his/her personal data in the cases listed in Article 19 of the Regulation.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom personal data has been communicated of any restriction on the processing carried out, unless such communication proves impossible or requires disproportionate efforts. The Data Controller shall provide the data subject with information about such recipients if the data subject so requests.
e. Right to data portability
In accordance with Article 20 of the Regulation, Users have the right to receive from Antidote personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transfer this data to another data controller without Antidote having to object in the cases provided for in the Regulation.
Where the User exercises her right to data portability pursuant to the preceding paragraph, she has the right to obtain that personal data be transmitted directly from one data controller to another, where technically possible.
The exercise of the right to data portability is without prejudice to the right to erasure. This right does not apply to processing that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
The right to data portability does not affect the rights and freedoms of third parties.
f. Right to object and automated individual decision-making
The User has the right at any time to object to the processing of his/her personal data due to his/her particular situation, including the automation of data carried out by Antidote. In accordance with Article 21 of the Regulation, Antidote will no longer process personal data unless there are compelling legitimate grounds for the processing which override the interests and rights and freedoms of the User, or for the establishment, exercise or defense of legal claims.
Where personal data is processed for canvassing purposes, the User has the right to object at any time to the processing of his/her personal data for such canvassing purposes, including profiling insofar as it is linked to such canvassing.
If the data subject objects to the processing for canvassing purposes, the personal data will no longer be processed for these purposes.
g. Right to complain
The User has the right to lodge a complaint concerning the processing of his/her personal data by Antidote with the Belgian Data Protection Authority. 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
Tel. + 32 2 274 48 00
Fax. + 32 2 274 48 35
E-mail: contact@apd-gba.be
The User may also lodge a complaint with the court of first instance in his place of residence.
9. Cookies
The Site uses cookies to distinguish between Users of the Site. This makes it possible to provide Users with a better browsing experience and to improve the Site and its content. The purposes and conditions of cookies are set out in this article.
a. General principles
A “Cookie” is a file deposited temporarily or permanently on the User’s hard disk when consulting the Website, with a view to subsequent connection. Cookies enable the server to recognize the User’s computer.
Cookies may also be set by third parties with whom Antidote collaborates.
Some of the cookies used by Antidote are necessary for the proper operation of the Site, while others are used to improve the User’s experience.
The User can personalize or deactivate cookies by configuring his browser.
By using the Website, the User expressly agrees to the management of cookies as described in the present article.
b. Type of cookies and purpose
Different types of cookies are used by Antidote on the Site:
Technical cookies: these are necessary for the operation of the Website, enable the communication of data entered and are intended to facilitate the User’s browsing experience;
Statistical and audience measurement cookies: these cookies enable 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 behavior, they are an effective means of improving the User’s browsing experience, by displaying proposals and offers likely to be of interest. They also enable Antidote to identify and correct any bugs on the website.
Functional cookies: these make it easier to use the website by remembering certain choices you have made (e.g. user name or language).
c. Cookie retention period
Cookies are retained for the time necessary to achieve the intended purpose. The cookies likely to be stored on the User’s hard disk and their retention period are as follows: 1 year maximum.
d. Cookie management
If the User does not want the Website to place cookies on his hard disk, he can easily manage or delete them by modifying his browser settings. Browser programming also enables the User to receive a notice or notification as soon as a Website uses cookies, and thus decide whether to accept or reject them.
If the User deactivates certain cookies, he accepts that the Website may not function optimally. Certain parts of the Website may not be usable, or may only be partially usable.
If the User wishes to manage and/or delete certain cookies, he may do so by using the following link(s):
For Users with :
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
10. Limitation of the data controller’s liability
The website may contain links to other websites owned by third parties unrelated to Antidote. Antidote is not responsible for the content of these sites or their compliance with the Law and Regulations.
We pay particular attention to the importance of protecting children’s privacy, especially in the context of their online interactions. This Site is not designed for persons under the age of 18 and does not intentionally target or solicit them. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he or she is under 16 years of age.
The Data Controller cannot be held liable 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.
Antidote is not responsible for the loss, corruption or theft of personal data caused by viruses or computer attacks.
11. Security
The Data Controller implements organizational and technical measures to guarantee a level of security appropriate to the processing and collection of data. These security measures depend on the cost of implementation in relation to the nature, context and purposes of the personal data processing.
The Data Controller uses industry-standard encryption technologies when transferring or collecting data on the Site.
12. Modification of the Privacy Policy
Antidote reserves the right to modify this Privacy Policy in order to comply with legal requirements.
The user is therefore invited to consult the Privacy Policy on a regular basis in order to take note of any modifications and adaptations. Any such modification will be posted on the Site or sent by e-mail for enforceability purposes.
13. Applicable law and jurisdiction
This Privacy Policy is governed exclusively by Belgian law. Any dispute shall be brought before the courts of the judicial district of Antidote’s registered office.
14. Contact
For any questions or complaints relating to this Privacy Policy, the User may contact the Data Controller at the following address: Tarik Hennen: th(AT)lecercle.ai)