Effective since: 01 January 2022
We take our obligation to protect your privacy seriously!
That’s why we provide you with this 2 minute-read summary, including the necessary information on how we process your Personal Data.
What you should know:
First of all : you always remain the sole owner of your data.
What information do we collect about you?
When you contact us as a (future) customer, make use of our website, products and/or services, solutions or portal(s), we may collect your (professional) contact details, such as your (Employer/company) name, email address, phone number, tax identification number, payment details, address, social media, or other means of communications.
By contacting us through any medium, we collect information about your/our communication, including its content and technical details.
Upon receipt of information about you from third parties, such as our partners, including but not limited to our customers, vendors, banks, payment processors, we may collect the information contained in their message or communication.
By applying for a job or if you wish to have a supplier relationship with us, we collect the information you provide us with, such as identity details, resume and cover letter, containing but not limited to your name, address, phone number, email address, matricula, national identification card or passport and payment details.
By registering and/or creating an account on one of our portals, we collect your identification data and information to maintain your account and to provide you access to our portal(s) and the customized services available thereon in execution of the agreement we entered into.
Why do we collect this information?
To respond to your requests
To establish and/or maintain our contractual relationship
To provide you with the requested products, services and information
To provide you access to, customize and improve our services, portal(s), (technical) solutions
To maintain your account and to provide you with support services
To comply with third party requests
To keep you informed of any updates with regard to our products, services, solutions and/or portal(s).
For operational and legal reasons related to a (potential) supplier relationship
If you applied for a job opportunity, to evaluate your application.
Who has access to your data?
Only (a specific part of )Lock Step Consulting‘s trustworthy team has access to the information you provide us with.
Furthermore, we use some suppliers and service providers, such as but not limited to computer security, digital solutions and web hosting services. These parties are legally obliged to ensure your privacy at all times, and will only process data in accordance with our purposes.
Finally, it may happen that a third party is commissioned to process data. However, they can only do this for aforementioned purposes and upon our instructions and signature of a data processing agreement.
What do you control?
Also, you can always request a copy of all the information we collected about you by sending an email to the same address.
What do we do to protect your data?
We adopted the required safety measures on a technical and an organizational level.
Effective since: 1 January 2022
This policy applies specifically to our customers, applicants, suppliers, business partners, visitors of our Website, www.lockstepinvesting.com, and/or persons who contact us (e.g., via contact form) regarding the provision of our Products and Services as described on our Website.
You are not obliged to provide us with your Personal Data, however understand that we are not able to provide you with our Services in case you refuse to provide us with certain Personal Data.
If you have any other questions, do not hesitate to contact us at the following address: [email protected]
Article 1 – GENERAL
Lockstep Investment Consulting, (hereinafter, “we”, “us”, “our”, “LIC”), with registered office in Belgium, 8000 Bruges, Zonnekemeers 1, and with company number 0775.823.321, takes responsibility for the processing of your Personal Data as a (1)“data processor”, when it processes Personal Data for the purpose of providing its Services to its clients and customers (hereinafter, “User”,“Users”), pursuant to the applicable data processing terms with those customers and as a (2)“data controller”, when or if it processes data for other purposes.
LIC processes Personal Data 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 (hereinafter the “GDPR”).
Article 2 – WHAT PERSONAL DATA DOES LIC COLLECT
2.1 Hereby, the visitor and User allow, in particular, LIC to process, for the purposes mentioned in article 3, the following categories of Personal Data:
Category 1: By completing the order form available on our Website, ordering and/or using products and/or our Services (e.g. when you enter into a contract with us as a (future) client or supplier, communicating with us (e.g. via social media, E-mail, phone or any other means), handing us your business card and/or by collaborating with us (e.g. suppliers)
Your (professional) identity data
Your first name, name, phone number, email address, address and country;
Information concerning your employer or company, such as company name, company address, invoice details and VAT-number;
Social media information, such as your (company’s) username(s) on your social media.
Information about our/your communication, including content and technical details.
Category 2: Applicant data (by applying for a job at LIC)
Your (professional) identity data
Your first name, name, phone number, email address, address, (optional) photo and country, matricula, national identification card or passport and payment details.
Your resume and cover letter.
Category 3: Information about your visitation and use of our Website
By accessing our Website, or creating an account on one of our portals The servers consulted automatically record certain data, by placing cookies
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;
location data or other data relating to the communication;
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.
Category 4: Information about you, received from third parties
Upon receipt of information about you from third parties, such as our partners, including but not limited to our customers, vendors, banks, payment processors
We may collect the information contained in their message or communication to resolve the request of the third-party.
Article 3 – THE PURPOSES OF DATA PROCESSING
We process your data in order to offer you our best possible services while handling your needs. 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 Personal Data LIC collects, stores and uses its visitor’s and/or Users’ data for the following purposes, in particular:
3.1 General purposes
to establish, carry out and conduct the contractual relationship with the User(s);
to provide and optimize the Service;
to allow the User to receive messages;
to respond to requests for information, products and/or services;
for any marketing activities and promotions proposed by LIC to Users who have given their consent;
to inform Users about changes on the Website and its features.
the necessity for the performance of the agreement we have entered into or execution of any request from you.
Applicant data will be processed by LIC to evaluate your application and allow us to pursue a recruitment policy
to facilitate the availability and use of the Website;
to analyse, adapt and improve the content of the Website;
to personalize the User’s experience on the Website;
to maintain and improve the security of the Application and/or Services;
to create statistics
our legitimate interest to improve our Website and our Services
With regard to the eventual use of non-essential cookies, we shall only process your data based upon your consent given through our cookie banner.
to establish, carry out and conduct the contractual relationship with these third parties;
to comply with a legal obligation
where the processing is necessary for the purposes of the legitimate interests pursued by these third parties.
3.2 Direct Marketing
Your Personal Data will only be used for direct marketing purposes, based on your consent or based upon our legitimate interest if we have concluded an agreement with you.
Your Personal Data will not be used for direct marketing purposes for any services that would not be identical or similar to those to which you have already subscribed, unless you have previously explicitly consented to such use by ticking the boxes provided for this purpose (“opt-in”).
When you give us your consent to use your Personal Data for direct marketing purposes, you also retain the right to revoke such consent at any time, upon request and free of charge. You may simply communicate your request by clicking the unsubscribe button below every promotional E-mail or by writing to us via the following E- mail address: [email protected]
3.3 Transfer to third parties
LIC may communicate its your personal information to third parties to the extent that such information is necessary for the performance, execution and management of a contract with you, including but not limited to reporting, support, marketing, computer security or offering specific other services. In such case, these third parties will not communicate this information to other third parties, except in the following situations:
the communication of this information by such third parties to their suppliers or subcontractors is necessary for the performance of the contract;
such third parties are obliged by the regulations in force to communicate certain information or documents to the competent authorities.
The communication of this information to the aforementioned third parties shall, in all circumstances, be limited to what is strictly necessary or required by the applicable regulations.
3.4 Legal requirements
In extraordinary circumstances it may occur that LIC is obliged to transfer your Personal Data following a court order, or in order to comply with imperative laws and/or regulations. LIC will, if reasonably possible, try to inform you on beforehand, unless revealing this information is subject to legal constraints.
Article 4 – THE STORAGE PERIOD
LIC will store your Personal data for the duration necessary to achieve the objectives pursued (see article 3.1), or for as long as this is essential for the contractual relationship.
LIC may also store your Personal data after the termination of the contract, in order to comply with all applicable laws or as part of legal requirements.
As long as necessary for us to communicate with you, with a maximum of five (5) years after the first request or contact. In case of a contractual relationship, we will keep your identity data for maximum ten (10) years after the end of the contractual relationship.
For maximum five (5) years after the last qualitative contact.
With regards to cookies the retention period may vary depending on the specific cookie, ranging from end of the session to 2 years.
For as long as necessary to comply with our obligations and only as long as legally permitted.
Article 5 – YOUR RIGHTS
As a Data Controller, LIC User(s) is/are responsible for disclosing the rights of individuals (“Data Subjects”) with respect to their Personal Data and other information regarding the collection and use of that Personal Data, in accordance with the GDPR and other laws requiring such disclosures.
According to the regulations on the processing of Personal Data, you have the rights described hereunder.
5.1 Right of access and right to obtain a copy
The right to freely obtain access to Personal Data, as well as to be informed about the purpose of the processing, at any moment.
5.2 Right to rectification, erasure or restriction
The right to request the restriction of processing of your Personal Data, if you think your data is inaccurate and you subsequently notified us about it or its erasure.
5.3 Right to object:
The right to object to the processing of your Personal Data when you have serious and legitimate reasons to do so and the right to object to its use for direct marketing purposes.
5.4 Right to data portability:
The right to obtain your Personal Data, which is processed by LIC in a structured, commonly used format and/or to transfer this data to another data controller.
5.5 Right to withdraw consent:
When the processing is based on prior consent you have the right to withdraw this consent.
5.6 Automated decisions and profiling:
The right to request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
5.7 Exercising your rights:
You can exercise your rights by contacting us with a copy of the essential parts of your ID, such as name and date of birth, as attachment,
Either through E-mail to [email protected]
Or via ordinary mail to:
Lockstep Investment Consulting
5.8. Right to file a complaint:
The right to file a complaint with the supervising Data Protection Authority:
Tel: +32 (0)2 274 48 00
This does not affect a procedure before the civil court. Following hereto, if you have suffered damages caused by the processing of your Personal Data, you can file a claim for damages.
Artikel 6 – SAFETY AND CONFIDENTIALITY
LIC has adopted safety measures which are suited on a technical, organizational and physical level to avoid the destruction, the loss, the forgery, the adjustment, the non-authorised access or the notification of the Personal Data by accident to a third party, as well as the non-authorised processing of these data.
Nevertheless, if these events would occur and would affect your Personal Data, LIC will inform you of the breach without undue delay, including a summary description of the potential impact and a recommendation on measures to mitigate the possible adverse effects of the breach.
LIC shall not be liable in any way for direct or indirect damages caused by a wrongfully or improper use of the Personal Data by a third party.
At the same time, you also share responsibility for maintaining the privacy and security of the Services, for example: by not allowing any third party to have insight in your confidential communication(s).
Article 7 – APPLICABLE LAW AND JURISDICTION
Article 8 – COOKIES
8.1 What are cookies?
A “cookie” is a small file sent by LIC’s server and placed on your computer’s hard drive. The information stored on these cookies can only be read by LIC and only for the duration of the visit to the Website.
The cookies we use are safe. The information we collect using cookies helps us to identify any errors or to show you specific services that might be of your interest.
8.3. Types of cookies:
There are many different cookies that can be distinguished according to functionality, origin or storage period. Below you may find a general description of the most common types of cookies. Next, a detailed overview is given of the different cookies that are used on our Website.
These cookies are necessary for the Website to function and cannot be disabled in our systems. They are usually set in response to actions taken by you, such as setting your privacy preferences, logging in or filling out forms. They are necessary
for the good communication and facilitation of the page navigation (e.g. returning to a previous page, etc.).
These cookies increase the user-friendliness of the Website by reminding you of your choices (e.g. language preference) and offering improved visitor and User functionality and personalisation. For example, these cookies allow certain settings to be personalised at your request. Non-acceptance of these cookies may affect the Website performance and functionality and may restrict access to Website content. These cookies can be set by us or by third party providers whose services we have added to our pages.
These cookies collect information about the use of our Website such as the number of visitors, the time visitors spend on a Web page and any error messages. They help us improve the performance of the Website. These cookies will not identify you.
These cookies are used to deliver content that is more relevant to you. They can be used to deliver targeted ads or to limit the number of times you see an ad. These cookies can be used to remember websites that you have visited and share this information with other parties, including advertisers. These cookies may also be set by advertising partners through a website and used by those companies to build a profile of your interests and show you relevant ads on other sites
Social Sharing Cookies
We use some social sharing plugins, to allow you to share certain pages of our Website on social media. These plugins place cookies so that you can correctly view how many times a page has been shared.
Third party cookies
First party cookies are cookies that are sent from our servers or domains from which the requested service is offered. Third party cookies are cookies that are sent to your browser from a server or domain that is not managed by us, but by a cooperating organization. Only these third parties have access to those cookies and the information collected by the cookie. If you would like to know more about these cookies, please refer to the policies that these parties offer on their respective websites. Please note that we have no influence on the content of their policy or on the content of these third-party cookies.
8.4 Your consent
8.5 Managing your cookies
You can block cookies by altering your browser’s settings. The rejection of these cookies may inhibit some functionalities on the Website.