POLITICO Privacy Policy
Effective since: 14 May 2018
Last update : 18 December 2019
We make it a matter of pride to respect the privacy of our users and to treat their personal data in the strictest confidentiality and in accordance with the legislation in force.
The privacy policy is intended to inform you, in a transparent manner, about the data we collect, the purpose for collecting it, the way we use it and the rights you have regarding the processing of such data.
On this page, we provide you with a simplified version of our privacy policy in the form of questions and answers. We invite you to also read the detailed version available below.
We draw your attention to the need to read this privacy policy carefully. If you have any other questions, do not hesitate to contact us at the following address: [email protected]
- WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?
POLITICO is the controller of your personal data.
Here is our complete contact information:
SOCIETE A RESPONSABILITE LIMITEE, POLITICO
RUE DE LA LOI 62, 1040 BRUSSELS, BELGIUM
Belgian business registry (BCE) number: BE 0526 900 436
- WHAT DATA DO WE COLLECT?
We collect your data – personal or otherwise – for various reasons which are defined in the following point (see point 3). It includes the following data:
- your identifying information (surname, first name, e-mail address, delivery address and country);
- the type of domain with which you connect to the Internet;
- the IP address assigned to you;
- the date and time of your access to our website;
- the pages you viewed on our website;
- the type of browser, platform and/or operating system you are using;
- the search engine and the keywords used to find the website;
- your browsing preferences.
- WHY DO WE COLLECT YOUR DATA?
We collect your data mainly to provide our services, send you our newsletter, improve our service and, more generally, to easily communicate with each other. Finally, your data also allows us to improve and facilitate your navigation on our website. The legal bases for processing your data are listed in the full version of the Privacy Policy.
- HOW DO WE COLLECT YOUR DATA?
Most of your data is communicated to us by your active intervention. Other data, such as the date and time of your access to our website, the pages you have viewed, or your location data, are collected automatically through servers consulted and “cookies” placed on our website. For more information on what a cookie is, how it is used and the exact data it collects, visit our page concerning our cookie policy.
- ARE YOUR DATA PROTECTED?
We take pride in respecting the privacy of our users. We maintain a strict privacy policy and take all appropriate measures to ensure that our servers prevent, to the extent possible, any unauthorized leak, destruction, loss, disclosure, use, access or modification of your data.
- HOW LONG DO WE STORE YOUR DATA?
We keep your data for the time necessary to accomplish the objectives pursued (see point 3). Once this goal is achieved, we either delete or anonymize them.
- WHAT ARE YOUR RIGHTS AND HOW CAN THEY BE EXERCISED?
You may, at any time, request to verify, access, rectify, delete, transfer and object to the use of your data, as well as request the limitation of such use of your data. To do so, simply send us an email at the following address: [email protected]. We will then make every effort to take the necessary action as soon as possible.
- WHO HAS ACCESS TO YOUR DATA AND TO WHOM ARE THEY COMMUNICATED?
Our employees have access to it only to the extent necessary for processing your request and/or for fulfilling the objectives pursued (see point 3). Each of them is subject to a strict obligation of confidentiality.
- DO WE TRANSFER YOUR DATA ABROAD?
We only transfer your data to a non-EU country if it provides a level of protection equivalent to what you can find in your country of residence. (for more information, please consult the following link).
- HOW TO RECEIVE OUR PRODUCTS?
We only use your email address to offer you articles and products similar to those you have already ordered.
With your consent or based on our legitimate interest based in particular on our relationship, we will subscribe you to our newsletter and offer you other similar articles that may interest you. You can unsubscribe and withdraw your consent to these communications at any time by sending an email to the following address: [email protected]
- WHAT IS OUR POLICY ON DATA CONCERNING MINORS?
Our website are not targeted to children under the age of 13. If you learn that your minor child has provided us with their personal data without your consent, contact us at the following address: [email protected].
- WHAT HAPPENS IN THE EVENT OF A CHANGE TO THE PRIVACY POLICY?
If we had to make any changes to this privacy policy, you would be notified through our website or email.
- WHAT TO DO IN THE EVENT OF A DISPUTE?
Lengthy trials do not benefit anyone. In the event of a dispute between us, we commit to give priority to dialogue and openness in search of an amicable solution. You can also contact the Data Protection Authority.
_____________________________________________________
- GENERAL WARNING
1.1 The SOCIETE A RESPONSABILITE LIMITEE, POLITICO (hereinafter, « POLITICO ») respects the privacy of its users (hereinafter, the “Users“).
1.2 POLITICO processes the personal data transmitted to it in accordance with the legislation in force, and, in particular, Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, applicable from 25 May 2018 and the Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data (hereinafter the “Data Protection Legislation“).
1.3 Access to the website www.politico.eu (hereinafter, the “Website”) implies the User’s full and unreserved understanding of this Privacy Policy (hereinafter the “Policy”), as well as the acceptance with the general terms of service (hereinafter the “Terms”) and the cookie policy (hereinafter, the “Cookie Policy”).
1.4 The User acknowledges having read the information below and understand that POLITICO can process, in accordance with the provisions of the Policy, the personal data that he/she communicates on the Website.
1.5 The Policy is valid for all pages hosted on the Website and for the registrations of this Website, as well as all company pages managed by POLITICO who is jointly responsible with the social networks (Facebook, Twitter, etc) for the processing of personal data from visitors of the page. The Policy is not valid for the pages hosted by third parties to which POLITICO may refer and whose privacy policies may differ. POLITICO cannot therefore be held responsible for any data processed on these websites or by them.
- DATA CONTROLLER
2.1 Simply visiting the Website shall take place without having to provide any personal data, such as first name, surname, postal address, e-mail address, etc.
2.2 As part of the Service, the User may be required to provide certain personal data. In this case, the data controller is:
SOCIETE A RESPONSABILITE LIMITEE, POLITICO
RUE DE LA LOI 62
1040 BRUSSELS
BELGIUM
Belgian business registry (BCE) number: BE 0526 900 436
2.3 Any question regarding the processing of this data may be sent to the following address: [email protected]
- DATA COLLECTED
3.1 By completing the order form on the Website and using the Service, the User allows, in particular, POLITICO to record and store, for the purposes mentioned in point 4, the following information:
- identifying data, such as the first name and surname, e-mail address and company delivery address, country;
- invoicing information;
- communications between the User and POLITICO;
- any other personal data required to provide the Service you requested.
3.2 The User is also aware that POLITICO may record and store the following data for the purposes mentioned in point 4:
- information voluntarily provided by the User for a purpose specified in the Policy, the general terms and conditions of sale (hereinafter the “GTC“), the Terms, the Cookie Policy, on the Website or on any other medium of communication used by POLITICO;
- additional information requested by POLITICO to the User in order to identify him or to prevent him from violating any of the provisions of the Policy;
3.3 In order to facilitate browsing the Website as well as to optimize technical management, the Website may use “cookies”. These “cookies” record, in particular:
- the User’s browsing preferences;
- the date and time of access to the Website and other data related to traffic;
- the pages visited;
All information relating to “cookies” is included in POLITICO’s Cookie Policy.
3.4 When the User accesses the Website, the servers consulted automatically record certain data, such as:
- the type of domain with which the User connects to the Internet;
- the IP address assigned to the User (when connected);
- the date and time of access to the Website and other data related to traffic;
- the pages visited;
- the type of browser used;
- the platform and/or operating system used;
- the search engine as well as the keywords used to find the Website.
3.5 No nominative data identifying the User is collected through the cookies and servers consulted. This information is kept for statistical purposes only and to improve the Website.
- PURPOSES OF PROCESSING THE DATA
4.1 We process your data for various purposes. For each purpose, only the data relevant to the
pursuit of the purpose in question are processed. The processing consists of any operation
(manual or automated) on a personal data. The Website collects, stores and uses its Users’ data for the following purposes, in particular:
- to establish, carry out and conduct the contractual relationship with the User;
- to analyse, adapt and improve the content of the Website;
- to provide the Service;
- to allow the User to receive messages (for example for renewal notifications);
- to facilitate the availability and use of the Website;
- to personalize the User’s experience on the Website;
- for any marketing activities and promotions proposed by POLITICO or its affiliates to Users who have given their consent;
- to inform them about any changes on the Website and its features;
- to respond to requests for information;
- for any other purpose to which the User has expressly consented.
4.2 The legal basis of the processing of your personal data is:
(i) the User’s consent; or
(ii) the execution of any request from the User or the necessity for the performance of a contract
with the User; or
POLITICO does need to collect some of the User’s data to answer any of their requests. If the User
chooses not to share this data with POLITICO, it may render the performance of the contract
impossible.
(iii) a legal obligation imposed on POLITICO; or
POLITICO does need to collect and store some of the User’s data to meet various legal requirements, including tax and accounting.
(iv) POLITICO’s legitimate interest, provided that it is in accordance with the User’s interests,
freedoms and fundamental rights.
POLITICO has a legitimate interest in providing its Users with this information and interacting with
them, especially to respond to their requests or improve the Services, prevent abuse and fraud,
control the regularity of the operations, exercise, defend and preserve POLITICO’s rights, for example in litigation, as well as evidence of a possible violation of its rights, manage and improve its relations with their Users, continually improve the Website and the Services, unless such interests are supplanted by the User’s interests or their fundamental rights and freedoms requiring the protection of their personal data. POLITICO takes care in any case to maintain a proportionate balance between its legitimate interest and respect for the privacy of their Users.
If the legal basis of our processing is the User’s consent, the User has the right to withdraw it at
any time without prejudice to the lawfulness of the processing performed prior to withdrawal.
In the context of direct marketing, this means that Users can unsubscribe at any time from
newsletters and other commercial communications from POLITICO. Such Users will be put in “optout”. Users can unsubscribe by sending an email to the following address: [email protected] or by clicking on the unsubscribe link at the bottom of each email.
- RIGHTS OF THE PERSON CONCERNED
5.1 According to the regulations on the processing of personal data, the User has the following rights:
- Right to be informed about the purposes of the processing (see above) and the identity of the data controller.
- Right of access and verification of data: the User may, at any time, have access to the data that POLITICO has on him or check if he is included in the database of POLITICO. POLITICO asks the User to make this request by mail in order to be able to identify him with certainty (Please provide POLITICO your first name, surname, complete address and a valid proof of your identity). POLITICO will thus be ensured that only the User accesses his data.
- Right to rectification: we take all reasonable steps to ensure that the data we keep is up to date. We encourage Users from time to time to consult their profile/account to check that their data is still up to date. If data is inaccurate or incomplete, Users have the right to ask us to correct it.
- Right of objection: the User may, at any time, object to the use of his/her data by POLITICO and by its active partners by sending his/her request to POLITICO by mail.
- Right of erasure: the User may, where appropriate, request the deletion of his/her personal data, except those which POLITICO must keep on record (legal obligation, fundamental right/freedom of the press, etc).
- Right of limitation of processing: the User may, in particular, obtain a limitation of processing when (s)he has objected to the processing, when (s)he disputes the accuracy of the data, or when (s)he considers that the processing is illegal.
- Right of portability: The User has the right to receive the personal data that he has communicated to POLITICO and may also ask to send this data to another data controller.
5.2 The User may, at any time, request access to his personal data, verify them, transfer them, and, in some cases, as aforementioned, limit their processing and rectify them, by writing to POLITICO accompanied by a valid proof of identity to the following email address: [email protected] or to the postal address: RUE DE LA LOI 62, 1040 BRUSSELS, BELGIUM.
5.3 POLITICO will then take the necessary steps to satisfy this request as soon as possible and in any case within one month of receipt of the application. If necessary, this period can be extended by two months, given the complexity and the number of requests.
- DURATION OF STORING THE DATA
6.1 POLITICO will keep the personal data of its Users for the duration necessary to achieve the objectives pursued (see point 4).
6.2 POLITICO may also continue to keep personal data concerning the de-registered User or after the conclusion of the Service, including all correspondence or request for assistance sent to POLITICO in order to be in a position to reply to all questions or complaints that may be sent to it after the Service, and in order to comply with all applicable laws, namely in tax matters or as part of other legal requirements.
- COMPLAINT WITH THE SUPERVISORY AUTHORITY
The User is informed that he has the right to lodge a complaint with the Data Protection Authority.
Rue de la Presse, 35, 1000 Bruxelles
- SECURITY
8.1 In order to guarantee optimal payment security, POLITICO uses the online payment service STRIPE, which meets high security standards.
8.2 In addition, POLITICO has taken the appropriate organizational and technical measures to ensure a level of security adapted to the risk and that, to the extent possible, the servers hosting the personal data processed prevent:
- unauthorized access to or modification of this data;
- improper use or disclosure of such data;
- unlawful destruction or accidental loss of such data.
8.3 In this respect, employees of POLITICO who have access to this data are subject to a strict confidentiality obligation. Nevertheless, POLITICO may in no way be held liable in the event that this data is stolen or hijacked by a third party despite the security measures adopted.
8.4 Users undertake not to commit acts that may be contrary to this Policy, the Terms of Service, the Cookie Policy or, in general, the law. Violations of confidentiality, integrity and availability of information systems and data which are stored, processed or transmitted by these systems, or the attempt to commit one of these violations, shall be punishable by imprisonment of between three months and five years and a fine of between twenty-six euros and two hundred thousand euros, or one of these penalties only.
- COMMUNICATION TO THIRD PARTIES
9.1 POLITICO treats personal data as confidential information. It will not communicate them to third parties under any condition other than those specified in the Policy, such as to achieve the objectives set out and defined in point 4, or under the conditions in which the law requires it to do so.
9.2 POLITICO may communicate its Users’ personal information to third parties to the extent that such information is necessary for the performance of a contract with its Users or that it has obtained the consent from the Users or that it serves POLITICO’s legitimate interest while meeting the reasonable expectations of Users. In such case, these third parties will not communicate this information to other third parties, except in one of the two following situations:
- the communication of this information by such third parties to their suppliers or subcontractors to the extent necessary for the performance of the contract;
- where such third parties are obliged by the regulations in force to communicate certain information or documents to the competent authorities in the field of combating money laundering, as well as, in general, to any competent public authority.
9.3 The communication of this information to the aforementioned persons shall, in all circumstances, be limited to what is strictly necessary or required by the applicable regulations.
- TRANSFER TO A NON-EU COUNTRY OR COMPANY
POLITICO transfers data to a non-EU country only when that country provides an adequate level of protection within the meaning of the Data Protection Legislation or within the limits permitted by it, for example by ensuring the protection of data by appropriate standard contractual clauses.
If you wish, you can obtain a copy of the adapted contractual clauses by contacting us at:
- PAYMENT SERVICE
11.1 The payment service integrated into the Website is provided by STRIPE at www.stripe.com
11.2 The relationship between the User and STRIPE is governed by the Privacy Policy available at the following address: https://stripe.com/be/privacy which also includes provisions relating to the processing of personal data sent to STRIPE as part of its service, and for which STRIPE is the data controller.
11.3 When making a payment through POLITICO, the User declares that he/she has read and understood STRIPE’s privacy policy.
- DIRECT MARKETING
12.1 The personal data may be used by POLITICO or its affiliates for direct marketing purposes for similar services than those to which the User has already subscribed.
12.2 The User retains the right to object to such use at any time, upon request and free of charge. The User may simply communicate his/her request by writing to the following address: [email protected]
- NOTE CONCERNING MINORS
Persons under the age of 13 and persons who do not have full legal capacity are not permitted to use the Website. POLITICO asks them not to provide their personal data.
- UPDATES AND CHANGES TO THE POLICY
By informing Users through the Website or emails, POLITICO may modify and adapt the Policy, in particular to comply with any new legislation and/or regulations applicable (such as the General Data Protection Regulation applicable from 25 May 2018), the recommendations of the Belgian Data Protection Authority, the guidelines, recommendations and best practices of the European Data Protection Board and the decisions of the courts and tribunals on this topic.
- VALIDITY OF THE CONTRACTUAL CLAUSES
15.1 Failure by POLITICO to invoke – at any given time – a provision of this Policy, may not be interpreted as a waiver to subsequently make use of its rights under the said provision.
15.2 The invalidity, expiration or the unenforceable nature of all or part of one of the above or below mentioned provisions shall not give rise to the invalidity of all the Policy. Any fully or partially invalid, lapsed or unenforceable provision shall be deemed not to have been written. POLITICO undertakes to substitute this provision with another which, to the extent possible, fulfils the same objective.
- APPLICABLE LAW AND COMPETENT COURT
16.1 The validity, interpretation and/or implementation of the Policy are subject to Belgian law, to the extent permitted by the provisions of applicable private international law.
16.2 Before taking any step towards the judicial resolution of a dispute, the User and POLITICO undertake to attempt to resolve it amicably. To this end, they shall first contact each other before resorting, where appropriate, to mediation, arbitration, or any other alternative method of dispute resolution.
16.3 In the event of a dispute relating to the validity, interpretation or implementation of the Policy, the courts and tribunals of Brussels have exclusive jurisdiction, to the extent permitted by the provisions of applicable private international law.
_____________________________________________________