1.1 Positive Thinking Company S.A. is legally registered in accordance with Belgian law with registered offices in Charleroisesteenweg 112 Chaussée de Charleroi, 1060 Brussels / Bruxelles and registered under the BCE/KBO number 0895.492.518 (hereafter referred to as “ Positive Thinking Company S.A. ”)
2.1 Given the importance of protecting personal data, Positive Thinking Company S.A. is committed to adhere to regulations concerning the privacy, especially to the Law of 30th of July 2018 relating to the protection of privacy and its executive orders (« Law of 30 July 2018”) as well as the General Data Protection Regulation of 27 April 2016 (“GDPR”), and take all reasonable measures to ensure that personal data provided to us will remain properly handled, confidential where appropriate and safely protected.
2.3 More specifically, undertakes to respect the following principles:
2.4 Finally, Positive Thinking Company S.A. undertakes to comply with all other principles required under the applicable regulations on the protection of personal data.
2.5 However, Positive Thinking Company S.A. does not accept unauthorized idea submissions outside of established business relationships. To protect the interests of our current clients and ourselves, we must treat the issue of such submissions with great care. Importantly, without a clear business relationship, Positive Thinking Company S.A. cannot and does not treat any such submissions in confidence. Accordingly, please do not communicate unauthorized idea submissions to Steep through this website. Any ideas disclosed to Positive Thinking Company S.A. outside a pre-existing and documented confidential business relationship are not confidential and Steep may therefore develop, use and freely disclose or publish similar ideas without compensating you or accounting to you. Positive Thinking Company S.A. will make every reasonable effort to return or destroy any unauthorized idea submissions without detailed review of them. However, if a review is necessary in Positive Thinking Company S.A.’s sole discretion, it will be with the understanding that Steep assumes no obligation to protect the confidentiality of your idea or compensate you for its disclosure or use. By submitting an idea or other detailed submission to Steep through this website, you agree to be bound by the terms of this stated policy.
2.6 By visiting our website, the data subject declares that he or she is familiar with the information below and authorizes Positive Thinking Company S.A. in line with what is outlined below, to process data of a personal nature which is transmitted via the services (including via online forms, applications, e-mails sent to Positive Thinking Company S.A. e-mail addresses, cookies, etc.).
3.1 When using Positive Thinking Company S.A.’s services or contacting and interacting with us, you may provide us with your personal information voluntarily which is collected on an individual basis. This includes:
3.2 « Cookies » are used in some parts of Positive Thinking Company S.A.’s website and applications in order to provide the internet user with a better service.
3.2.1 A cookie is a text file containing information about the behavior of someone visiting a website. It is created by software on the website server but stored on the computer hard drive of the user. During a subsequent visit to the website, the contents of the cookie can be retrieved by the website’s server.
3.2.2 Cookies generated by the website or application enable services to be personalized according to the areas of interest of each user, who can be identified by means of these cookies.
5.1 To perform our contractual obligations and enable an appropriate level of service
5.2 For customer care purposes
5.3 To communicate with you
5.4 For direct marketing purposes
6.1 Positive Thinking Company S.A. processes your personal data (i) on the basis of your explicit consent, (ii) to perform the contract or in order to take steps at the request of the data subject prior to entering into a contract, (iii) to comply with legal obligations Positive Thinking Company S.A. is subject to or (iv) to perform Positive Thinking Company S.A.’s legitimate interests.
6.2 Your consent may always be withdrawn at any time in accordance with Article 10. In such case, be aware that the withdrawal of consent shall not affect the lawfulness of processing based on your consent before the withdrawal.
6.3 Furthermore, if you refuse to provide Positive Thinking Company S.A. with some personal data or if you provide Steep with incomplete or inaccurate information required for the performance of the contract or for compliance with a legal obligation, be aware that we may not be able to provide or deliver your all or parts of the services, which you may have requested from us in full quality.
6.4 When we process your personal data for our legitimate interests or the interests of a third party, Positive Thinking Company S.A. ensures that a balance of these interests against your legitimate interests has been done. When necessary we have taken appropriate measures to limit implications and prevent unwarranted harm to you.
7.1 Positive Thinking Company S.A. may disclose certain personal information to third parties, such as authorized Steep’s employees, undertakings of Positive Thinking Company S.A. ’s group (i.e. undertakings of the Positive Thinking Company S.A.), and strategic partners that work with Steep to provide products and services.
7.1.2 However, Personal Data will not be shared with third parties for their marketing purposes.
7.1.3 Positive Thinking Company S.A. may be required by law, legal process, litigation and/or requests from public and governmental authorities within or outside your country of residence to disclose your personal information.
7.1.4 Positive Thinking Company S.A. may disclose personal information, on a legitimate basis, if Positive Thinking Company S.A. determines that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.
7.1.5 Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
7.2 Transfers of Personal Data to third countries
7.2.1 You are informed that Positive Thinking Company S.A. may transfer your Personal Data to third parties located outside the European Union in order to be processed and stored.
7.2.2 In that context and if applicable, Positive Thinking Company S.A. undertakes to guarantee the processing of your Personal Data in accordance with Article 46 of the GDPR.
10.2 If you choose to request information from Steep you may need to communicate personal information of a general nature. In addition to, if you choose to correspond further with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protection for these electronic communications that we employ in the maintenance of information received by mail or telephone.
10.3 Your rights, resulting from the Law of 20 June 2018 and the GDPR nevertheless remain guaranteed for as much and insofar as this technology allows it.
10.4 The right of access:
10.5 The right of rectification:
10.6 The right to be forgotten:
10.7 The right to restriction of processing:
10.8 The right to data portability:
10.9 The right to object:
10.10 The right to withdraw consent:
10.11 The right to lodge a complaint:
11.1 We will communicate immediately, when your personal data are breached, to you and the Data Protection Authority every time it is required by the GDPR. This communication about your personal data breach will describe in clear and plain language the nature of the personal data breach and contain at least the following information and measures:
11.2 This communication shall not be required if any of the following conditions are met:
12.1 The Data Controller is Positive Thinking Company S.A., with registered offices in 112 Chaussée de Charleroi, 1060 Brussels / Bruxelles, Belgium and registered under the BCE/KBO number 0895.492.518 (email: firstname.lastname@example.org).
12.2 In order to ensure the security of your personal information and to protect your rights and freedoms, Steep has appointed a Data Protection Officer:
Mr. Cédric Neef de Sainval
Address: Positive Thinking Company S.A., 112 Chaussée de Charleroi, 1060 Brussels / Bruxelles, Belgium