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1. Introduction

This privacy policy explains how JORI deals with the personal data of its customers, suppliers, employees and all other natural persons who are in contact with JORI (hereafter referred to as ´you´).

By ‘personal data’ is understood every form of information that permits you to identify yourself directly or indirectly as a natural person.

JORI attaches great importance to protecting your personal data and fully respecting your privacy. JORI thus handles and protects your personal data in a lawful, proper and transparent manner.

When processing your personal data, JORI naturally complies with the law, currently the Belgian Act of 8 December 1992 and as of 25 May 2018 the European Regulation no. 2016/679 of 27 April 2016 on data protection (better known as the ´GDPR´) or any other legislative act amending these.

You can obtain more information about the protection of personal data from the Belgian Commission for the Protection of Privacy, which as of 25 May 2018 has been called the ´Data Protection Authority´.

We invite you to read this policy carefully so that you know and understand JORI´s policy in this area.

This policy is regularly updated. The most recent version of the policy is available on our website. We will inform you via the usual channels of communication if any important changes are made to it.

2. Who is the controller?

JORI is the controller of your data. Its details are: JORI nv, Hoogweg 52 8940 Wervik, jori@jori.com, +32 56 31 35 01

JORI is the party that must provide justification to the Data Protection Authority concerning the processing of your personal data. JORI defines the purposes for which your personal data are processed as well as the methods used and the processing characteristics.

3. What are the purposes for which JORI processes your personal data?

JORI collects and processes your personal data solely for the purposes described below. JORI ensures that only the data which are necessary and relevant for a specific purpose are processed.

JORI processes your data in the situations authorised by law, more specifically:

  • In order to fulfil the legal obligations resting upon JORI.
  • In order to execute a contract with you, or in order to take certain measures at your request prior to the conclusion of this contract.
  • For the promotion of JORI´s legitimate interests, whereby these interests are weighed against your fundamental rights and freedoms.
  • In specific cases, with your consent, as a result of a specific and unambiguous request, preceded by clear and understandable information; you can withdraw this consent at any time in accordance with the law. 

3.1   Legal obligations

JORI must comply with legislation that obliges it in specific circumstances to process your personal data within the framework of its activities. These obligations can entail that JORI must work together with the competent authorities and/or third parties, and possibly transfer certain pieces of your personal data to them.

Amongst others this includes the following:

  • The obligation to contribute to the prevention of money laundering and terrorist financing.
  • The obligation that is imposed on a building manager relating to the management of co-properties.
  • The obligation to respond to a formal request of the Belgian tax and judicial authorities.

This list of legal obligations for which JORI must process your data is not exhaustive and is subject to changes.

3.2 Contractual relations between JORI and you as a customer

Before concluding contracts, JORI must sometimes obtain and process certain data, in particular in order to, amongst other things:

  • To respond to your request.
  • To assist you with furnishing information and concluding the contract
  • To follow up a request, evaluate the suitability and assess the risks relating to a possible contract.
  • To fulfil your mediation assignment

Within the framework of ongoing contracts or the management of contracts, JORI must process certain data, in particular in order to fulfil administrative and accounting obligations.

Within this framework, your data can be sent internally within JORI to various departments, including to those which are not directly responsible for the relationship with you or the execution of a certain contract.

JORI can process your personal data for additional purposes within the framework of the relationship with you and the execution of contracts.

3.3 Legitimate interests of JORI 

JORI also processes your data for the fulfilment of its legitimate interests. Hereby JORI strives to strike a fair balance between the necessity of processing data and respect for your rights and freedoms, including the protection of your privacy. 

Personal data are processed for, amongst other things:

  • Personalising JORI´s services
  • Improving the quality of the service provided to you by:
  • Evaluating and improving processes, including campaigns, simulations and sales, by means of various methods such as statistical analysis, satisfaction studies and a range of other search methods
  • Improving JORI products that already exist or are under development, on the basis of surveys amongst JORI customers, statistics, tests and feedback from customers via social networks (Twitter, Facebook) linked to JORI.
  • Using cookies in order to improve the user-friendliness of its website for visitors. You will find more information about the functioning of cookies and the possibilities for limiting their use and removing them in our Cookies Policy.
  • The preservation of evidence (archives)
  • The establishment, exercise, defence and safeguarding of JORI’s rights or all persons who represent it, for example for collection procedures or disputes.

3.4 Your consent for the processing and sending of electronic advertising (electronic direct marketing)

JORI can process your personal electronic contact details (e-mail address) in order to send you personal information, advertisements or proposals via direct marketing or newsletters. In this case, JORI must first ask you for your specific consent.

By accepting this privacy policy, you give your consent for the processing of your personal data for electronic direct marketing purposes and the sending of electronic advertising.

4. How long are your personal data preserved?

JORI will keep your personal data for no longer than is necessary in order to achieve the purposes for which the data are collected.

This period is linked to JORI´s legal and tax obligations, as well as the legal necessity of preserving your data beyond the retention period as evidence or in order to respond to requests for information by the competent body, for example:

  • 10 years within the framework of the anti-money laundering legislation
  • 10 years within the framework of JORI´s contractual liability

Beyond these periods your personal data are removed or anonymised.

5. How are your personal data protected? 

JORI applies strict standards in order to protect the personal data under its control against unauthorised or unlawful processing and against accidental loss, destruction or damage.

JORI thus takes measures of a technical and organisational nature - such as encryption, antivirus, firewalls, access controls, strict selection of employees and suppliers - in order to prevent and detect inappropriate access, loss or disclosure of your personal data

In the unlikely and unfortunate event that your personal data under JORI´s control should be compromised by an information security breach, JORI shall take immediate action to identify the cause of such breach and implement adequate remedial measures. If necessary, JORI shall inform you of this incident in accordance with the applicable legislation. 

6. What are your rights in connection with the processing of your personal data?

6.1 Rights of access, rectification, restriction, erasure, data portability and objection

For the above-mentioned purposes you have

  • A right to access your personal data at JORI. This means that you can ask JORI whether it is processing your personal data, for what purposes these data are being processed, what categories of data are being processed, and to whom they are communicated.
  • A right of rectification if you determine that your personal data are incorrect or incomplete.
  • A right of restriction if you e.g. dispute the correctness of your personal data, and this during a period that allows JORI to verify this
  • A right to erasure of your personal data. You can ask JORI to erase your personal data if they are no longer necessary for the purposes for which they were collected. You also have the possibility of requesting at any time erasure of personal data that are processed by JORI on the basis of your consent (unless JORI has some other legal ground for the processing) or on the basis of JORI´s legitimate interest (unless there are overriding legitimate grounds for the processing). In any event, JORI can keep these personal data if they should be required for evidentiary purposes within the framework of legal claims.
  • A right to the portability of data that you provided to JORI yourself if your personal data are being processed on the basis of an agreement or on the basis of your consent for the sending of electronic communication and these personal data are being processed with the aid of automated processes. Under this right you can ask JORI to pass on your personal data to yourself or send them directly to a different data controller, in so far as this is technically possible for JORI.

You have the right to object to the processing of your data for the purposes set forth in article IV.3 and IV.4. In the case of IV.3, however, JORI can continue to process the personal data if there are overriding legitimate grounds for the processing that outweigh your interests, rights and freedoms or there are grounds that relate to the filing, implementation or substantiation of a legal claim.

You can exercise your rights by sending a written request by post that is dated, signed and accompanied by a copy of your identity document to JORI nv, Hoogweg 52 8940 Wervik, Belgium or by e-mail to jori@jori.com.

6.2   Right to object to the sending of electronic advertising

In art. 3.4 your consent was requested to process your electronic contact details and to use them in order to send you commercial information, advertising or personal proposals (via direct marketing actions or electronic newsletters). This applies in particular for communication to your e-mail address.

You have the right to object to the processing of your personal data for electronic direct marketing and to demand that no such advertising be sent in the future. 

You can indicate this to us in the following ways: 

  • By sending an e-mail with a copy of your identity card to jori@jori.com
  • By sending a letter by post with a copy of your identity card to JORI nv, Hoogweg 52 8940 Wervik, Belgium
  • By clicking on the ‘unsubscribe’ link at the bottom of an e-mail or electronic newsletter sent out by JORI
  • By sending a request via the contact page on our website

However, exercising the right to object cannot prohibit JORI from contacting you for any other purpose, including a legal obligation or the execution of the contract, in accordance with this policy.

6.3   Right to file a complaint

If you have complaints relating to the processing of your personal data, you can contact us as follows:

  • By post: JORI nv, Hoogweg 52 8940 Wervik, Belgium
  • By e-mail: jori@jori.com

You can also file a complaint with the Commission for the Protection of Privacy, by post to Drukpersstraat 35, 1000 Brussels, or by e-mail to commission@privacycommission.be, or by telephone at +32 2 274 48 00.