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Arpeggio Communication

Privacy Policy Arpeggio SPRL



1. Introduction


Arpeggio SPRL, Avenue des Rossignols, 5, 21310 La Hulpe, BCE 0 0457.568.794 (hereinafter referred to as “ Arpeggio “ and/or "we" and/or "us") is located in Belgium, a Member State of the European Union (EU). Therefore, the basic principles established through this Policy are based on the requirements of the European Data Protection and Privacy Legislation, Regulation (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46 / EC (General Data Protection Regulation, after "RGPD"). If, on an ad hoc basis, applicable local law sets out more stringent data protection and privacy requirements than this Policy, personal data must be treated in accordance with these more stringent laws.

Questions about the applicable law may be addressed to the Data Protection Officer ("DPO").



2. Who is responsible for data processing operations?


As defined by the basic EU data protection regulations, Arpeggio is responsible for the processing of your personal data. The headquarters of Arpeggio are in La Hulpe.

The contact data for Arpeggio Customer Care can be viewed here.



3. When does Arpeggio acquire and process personal data?


  • Arpeggio acquires and processes your personal data in the following cases, including:
  • when you contact us directly, for example via our website and you are interested for example in our products or services or have any other concerns. Please help us to keep your details up to date by notifying us regarding changes to your personal data – in particular your contact data.


4. Which data about you can be collected?


The following categories of personal data can be collected via the numerous services and contact channels described in this data protection information:

  • Contact data: Name, telephone number, e-mail address.
  • Other personal data: IP-address, browser language version, browser version.
  • Use of websites and communication: Information on how you use the website, including data gathered via cookies and other tracking technologies. More information on his can be obtained here in our Arpeggio cookie policy.


5. What is the purpose of processing your data?


The data acquired in the context of concluding contracts or the providing services are processed for the purposes stated below. An explanation of the area of application of the available legal basis can be found here.

A. Customer care (Article 6 Paragraph 1 b, g, f) of basic EU data protection regulations) Arpeggio uses your personal data to handle any request you have. Regarding all aspects of dealing with a concern, we will contact you without separate consent, for example in writing, by telephone, per messenger service or per e-mail, depending on which contact data you have specified. Arpeggio also processes your personal data on this basis to optimize your experience with us. to identify you correctly if you make contact with us.

B. Compliance with legal obligations to which Arpeggio is subject (Article 6, Paragraph 1 c, f) of basic EU data protection regulations) Arpeggio will also process personal data if there is a legal obligation to do so. Collected data are also processed within the framework of ensuring the operation of IT systems. Ensuring operation involves the following activities:

  • Backup and restoring of data processed in IT systems
  • Detection and defense against unauthorised access to personal data
  • Incident and problem management to remedy malfunctions in IT systems. Arpeggio is subject to a large number of other legal obligations. In order to fulfill these obligations, we process your data to the required extent and, if necessary, pass them on to the authorities responsible within the framework of legal obligations of notification. We also process your data in the event of legal conflicts if the legal conflict makes processing the data necessary.


C. Data transfer to selected third parties Data are forwarded to the following companies, among others, if and to the extent that the requirements in compliance with data protection legislation necessary for this are met:

  • to carefully selected and verified service providers and business partners with whom we cooperate to be able to offer you products and services.
  • to other third parties (for example public authorities) to the extent that we are legally obliged to do so.


6. How do we protect your personal data?


We employ various security measures such as encryption and authentication tools in line with the current state of the art to protect and maintain the security, integrity, and availability of your data.

100% protection against unauthorized access in the case of data transfers across the Internet or a website cannot be guaranteed, but we and our service providers and business partners do our utmost to protect your personal data in line with the prevailing data protection regulations by means of physical, electronic, and process-oriented security precautions in line with the current state of the art. Among other things, we use the following measures:

  • Strict criteria for authorization to access your data according to the "need-to-know principle" (restriction to as few people as possible) and exclusively for the specified purpose
  • Transfer of acquired data exclusively in encrypted form
  • Storage of confidential data, exclusively in encrypted form
  • Firewall safeguarding of IT systems to provide protection against unauthorized access, for example by hackers
  • Permanent monitoring of accesses to IT systems to detect and prevent the misuse of personal data


7. How long do we keep your data?


In line with article 17 of the basic EU data protection regulations, we will keep your data only as long as necessary for the respective purposes for which we process your data. If we process data for a number of purposes, they are automatically deleted or stored in a format that does not permit conclusions to be drawn directly as regards your person as soon as the last specific task has been performed. To ensure that all of your data are deleted in line with the principle of data minimisation and article 17 of the basic EU data protection regulations, Arpeggio has created an internal deletion concept. The fundamental principles by which this deletion concept envisages the deletion of your personal data are described below.

  • Use for compliance with a contract To comply with contractual obligations, data acquired from you can be kept for as long as the contract is in force and - depending on the nature and scope of the contract - for 6 or 10 years beyond this point in order to comply with legal requirements for record keeping and to ensure clarification of any queries or claims after the end of the contract.
  • Use for the assessment of claims Data that in our opinion will be necessary to assess and avert claims against us or to initiate criminal proceedings or assert claims against you, us or third parties can be kept by us for as long as corresponding proceedings could be initiated.
  • Use for customer care For customer care, the data acquired from you can be kept for 3 to 10 years, unless you wish to have these data deleted and there are no contractual or legal requirements for preservation that prevent this request for deletion.


8. To whom do we grant international access to your data and how
do we ensure protection?

Personal data are processed by Arpeggio employees, and by service providers we have commissioned, preferably within the EU.
If data are processed in countries outside of the EU, Arpeggio uses EU standard contracts, including suitable technical and organisational measures in order to ensure that your personal data are processed according to the same standards as European data protection.



9. Contact with us, your data privacy protection rights, and your
right to file complaints

with data privacy protection authorities If you have any questions regarding the use of your personal data by us, it is best to use the contact form. As the person affected by the processing of your data, the basic EU data protection regulations and other relevant data privacy protection regulations enable you to assert certain rights in relation to us. The following section contains explanations of your rights as defined by the basic EU data protection regulations. Depending on the type and scope of your inquiry, we ask you to put the inquiry in writing.

  • Rights of persons affected In line with the basic EU data protection regulations, as the person affected you have the following rights in particular vis-à-vis of Arpeggio:
  • Right to information (Article 15 of basic EU data protection regulations): You can ask us for information regarding any data of yours that we keep at any time. This information concerns, among other things, the data categories we process, for which purposes we process them, the origin of the data if we did not acquire them directly from you and, if applicable, the recipients to whom we have sent your data. You can obtain a copy of your data from us free of charge. If you are interested in additional copies, we reserve the right to charge for the additional copies.
  • Right to correction (Article 16 of basic EU data protection regulations): You can request that we correct your data. We will initiate appropriate measures to keep the data of yours that we continuously process correct, complete, and up to date, based the latest information available to us.
  • Right to deletion (Article 17 of basic EU data protection regulations): You can request that we delete your data provided the legal requirements have been met. In accordance with Article 17 of basic EU data protection regulations, this can be the case if
  • the data are no longer required for the purposes for which they were acquired or otherwise processed
  • you revoke your consent, which is the basis of the data processing, and there is no other legal basis for the processing
  • you object to the processing of your data and there are no legitimate reasons for the processing or you object to data processing for the purposes of direct advertising
  • the data have been processed illegally Wherever the processing is not necessary
  • to ensure adherence to a legal obligation that requires us to process your data
  • In particular with regard to legal retention periods
  • to assert, exercise or defend against legal claims
  • Right to restriction of processing (Article 18 of basic EU data protection regulations): You can request that we restrict the processing of your data if
  • you dispute the correctness of the data - for the period of time we need to check the correctness of the data
  • the processing is illegal but you do not wish to have your data deleted and request a restriction of use instead
  • we no longer need your data, but you need them to assert, exercise or defend against legal claims
  • you have filed an objection to the processing, though it has not yet been decided whether our legitimate grounds outweigh yours.
  • Right to data transferability (Article 20 of basic EU data protection regulations): At your request, we will transfer your data – where technically possible – to another responsible entity. However, this right only applies if the data processing is based on your consent or is required to fulfill a contract. Instead of receiving a copy of your data, you can ask us to send the data directly to another responsible entity that you specify.
  • Right to objection (Article 21 of basic EU data protection regulations): You can object to the processing of your data at any time for reasons that arise from your special situation provided the data processing is based on your consent or our legitimate interest or that of a third party. In this case, we will no longer process your data. The latter does not apply if we are able to prove there are compelling, defensible reasons for the processing that outweigh your interests or we require your data to assert, exercise or defend against legal claims.
  • Time limits for compliance with the rights the persons affected As a general principle, we make every effort to comply with all requests within 30 days. This time limit, however, can be extended for reasons related to the specific rights of persons affected or the complexity of your request.
  • Restriction in the provision of information regarding the rights of persons affected In certain situations, legal specifications might require us not to provide information regarding all of your data. If we have to refuse your request for information in such a case, we will inform you of the reasons for refusal at the same time.
  • Complaints to supervisory authorities Arpeggio takes your reservations and rights very seriously. However, if you are of the opinion that we have not dealt with your complaints or reservations adequately, you have the right to submit a complaint to the data privacy protection authorities responsible.

10. Contact Data

If you have any questions regarding the use of your personal data, it is best to use the contact form or use the following contact data:

Arpeggio Communication
Chaussée de Bruxelles 135 A B3
1310 La Hulpe
02 653 71 09
privacy@arpeggio.be
Data Protection Officer: Maxime Paquet

11. Legal basis for the processing of personal data

  • We only process your data if this is permitted by an applicable legal regulation. We will process your data in particular on the basis of Article 6 and Article 9 of the basic EU data protection regulations as well as on the basis of consent in line with Article 7 of the basic EU data protection regulations. Here, we will base the processing of your data on, among others, the following legal principles. Please bear in mind that this is not a complete or conclusive list of the legal principles, rather only examples intended to make the legal principles more transparent.
  • Consent (Article 6 Paragraph 1 Page 1 a), Article 7 of the basic EU data protection regulation, or Article 9 Paragraph 2 a), Article 7 of the basic EU data protection regulations): We will process certain data only on the basis of the consent you have given expressly and voluntarily. You have the right to revoke your consent at any time with effect for the future.
  • Fulfillment of a contract / pre-contractual measures (Article 6 Paragraph. 1 Page 1 b) of the basic EU data protection regulations): For initiation and/or execution of your contract with Arpeggio, we require access to certain data.
  • Fulfillment of a legal obligation (Article 6 Paragraph 1 Page 1 c) of the basic EU data protection regulations): Arpeggio is subject to a number of legal specifications. We must process certain data to comply with these specifications.

    Protection of legitimate interests (Article 6 Paragraph 1 Page 1 f) of the basic EU data protection regulations): Arpeggio will process certain data in order to protect their legitimate interests or the interests of third parties. However, this only applies if your interests do not outweigh ours in individual cases.


12. Warranty, liability


The information on this website is provided "as is" and without warranty of any kind, expressed or implied, including (but not limited to) any implied warranties of merchantability, fitness for any particular purpose, or non-infringement of third party rights. While the information provided is believed to be accurate, it may include errors or inaccuracies. In no event shall Arpeggio be liable to any person for any special, indirect or consequential damages relating to this material, unless caused by gross negligence or intentional misconduct. Arpeggio is not responsible for the contents of websites that are maintained by third parties and therefore waives its liability for any links from this website to other websites.