Date:

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CONTENT

2. COLLECTION OF PERSONAL DATA.. 2

3. LEGAL BASES AND PURPOSES OF PROCESSING.. 2

4. QUALITY AND BALANCING OF INTERESTS. 4

5. RETENTION PERIOD FOR PERSONAL DATA.. 4

6. TRANSMISSION OF PERSONAL DATA.. 4

7. DATA SECURITY. 5

8. RIGHTS OF THE DATA SUBJECT. 5

1. INTRODUCTION

1.1. Preliminary

LOCINOX NV, located at Mannebeekstraat 21, 8970 Waregem, and registered under company number BE 0433.541.104 (hereinafter referred to as "Locinox," "we", or "us"), believes it's essential to provide clear explanations of the terms used by the legislator in understandable language. Therefore, in this Privacy Policy, various terms are further explained.

Words with an initial capital letter that are not defined in this Privacy Policy (“Privacy Policy”) have the same definition as provided in Article 1 of the Terms and Conditions Locinox Mobile Application (“T&C”).

In this Privacy Policy information about the protection of your personal data as described in article 2 of this Privacy Policy (“Personal Data”) and privacy is mentioned regarding the use of the Application in accordance with the T&C. The protection of the personal privacy of the Locinox Mobile Application (“Application”) users will be addressed in this privacy policy.

It is important to Locinox that the terms that are applied by the legislator are correct and explained in an understandable fashion, therefore the different terms used in this Privacy Policy are explained more elaborately.

We provide you with a free copy or access to, as applicable, the most recent version of this Privacy Policy for the use of the Application. By using the Application, you confirm that you have read the provisions and appropriate organizational measures in this Privacy Policy and that you had the opportunity to ask any questions you may have had about this Privacy Policy.

Locinox reserves the right to amend this Privacy Policy at any time (due to changes in applicable laws, changes in internal data governance, etc.), provided that it informs the data subjects via its website, the Application, or by email. Upon publication of the new Privacy Policy, the changes automatically take effect on the date specified at the top of this Privacy Policy.

1.2. The data controller

The data controller is the person or institution responsible for collecting Personal Data. It is of utmost importance that we, as the data controller, are always available for any questions and comments regarding this Privacy Policy.

CONTACT INFORMATION
Data Controller	LOCINOX NV
Address	Mannebeekstraat 21
City	8790 Waregem
KBO	0433.541.104
E-mail	info@locinox.com
Telephone	+32 (0)56 77 27 66

1.3. Applicable law

The processing of Personal Data within the European Economic Area is subject to:

· The European Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("GDPR").

· The Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.

· Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector ("E-privacy Directive").

· The Belgian Act of 13 June 2005 on electronic communications.

· All other laws and regulations applicable to or related to privacy and the protection of personal data.

These laws collectively constitute the applicable legislation ("Applicable Legislation").

2. COLLECTION OF PERSONAL DATA

2.1. Definition of Personal Data

The term "Personal Data" encompasses all data or information (e.g., first name, phone number, email address, company registration number, etc.) related to an identified or identifiable natural person.

Due to its broad wording, many types of data can be considered as Personal Data.

2.2. The Personal Data shared by you

If you wish to register on the Application, although it is not necessary for using the Application, we request the following Personal Data from you:

Type of data	Description of data
Contact information	Name, first name, and email address.

2.3. Automatic collection of Personal Data

Additionally, Personal Data can be collected automatically through the use of the Application.

Type of data	Description of data
Electronic localization data	The location of the user of the Application when using/opening the Application.

3. LEGAL BASES AND PURPOSES OF PROCESSING

3.1 Definition of data processing

The processing of Personal Data includes all possible operations or a set of operations, whether automated or not, such as collecting, structuring, storing, consulting, updating, using, combining, deleting, or destroying Personal Data.

Locinox will process Personal Data in accordance with the fundamental principles of the Applicable Legislation and will never process more Personal Data than strictly necessary.

For some of these processing activities, Locinox may engage processors. These are natural or legal persons, services, or other entities that process Personal Data under the supervision of Locinox.

3.2 Performance of the Contract

a) Registration

Locinox provides an additional guarantee with regards to the Product insofar you have chosen to register on the Application. In order to provide aforementioned guarantee, Locinox requires Personal Data in order to link your registration with the acquired Product.

When providing incorrect Personal Data, we reserve the right to claim damages if applicable.

The table below illustrates the processing processes based on the legal basis "performance of the contract" and indicates which types of Personal Data are processed for which purpose.

Processing of personal data	Type of personal data	Purposes of processing
Registration	Contact information	To provide the extended warranty as provided in article 4 of the terms and conditions regarding the use of the Application and the Service.

b) Location sharing

To execute the Service through the Application, location data processing may be required, depending on the operating software of the Device on which the Application is installed.

Processing of personal data	Type of personal data	Purposes of processing
The collection electronic location data.	Electronic location data	To execute the Service (i.e. the remote configuration of the Product).

3.3 Legitimate interests

a) Informative mailings

Like any other commercial company, Locinox has a vested interest in promoting its products and services, brand, image, and potential offers to existing customers. To achieve these goals, Locinox will process your Personal Data to spread awareness around these offers and promotions by contacting them per e-mail.

Locinox only sends informational emails to the registered users of the Application and this on the basis of its legitimate interest, in accordance with recital 47 of the GDPR, article XV.110 and 113 of the Belgian Code of Economic Law and article 1 of the Belgian Royal Decree of 1 April 2003. Registered users always have the option to unsubscribe from the informational emails by unlinking their account or by contacting Locinox.

Processing of personal data	Type of personal data	Purposes of processing
Sending digital informative mailings to registered users of the Application.	Contact information, including all Personal Data you would provide to us.	Informing registered users via mailings about Locinox’s products and services.

b) Location sharing

In using the Application, the user can choose whether or not to share their location with Locinox. Locinox uses this location data for statistical, diagnostical and analytical purposes.

Processing of personal data	Type of personal data	Purposes of processing
The collection and aggregation of electronic location data.	Electronic location data	Statistical, diagnostical and analytical purposes.

c) Dispute Resolution

In the context of a dispute Locinox will process the Personal Data linked to your account, in order to uniquely identify you and to contact you regarding the dispute. Depending on the nature of the dispute, Locinox might share your Personal Data with other partners.

Processing of personal data	Type of personal data	Purposes of processing
Identification	Contact information	Dispute management and resolution and to protect the rights of Locinox and/or third parties.

4. QUALITY AND BALANCING OF INTERESTS

As the data controller, we ensure the quality and legality of the Personal Data we collect and process. We take all appropriate and organizational measures to delete or correct data that is inaccurate or incomplete.

In the collection and processing of the available Personal Data, we commit to collecting and processing only the Personal Data that is necessary to achieve our processing purposes.

5. RETENTION PERIOD FOR PERSONAL DATA

Personal Data is retained for the entire duration necessary to achieve our processing purposes. Longer retention or further processing beyond what is necessary to achieve the purposes is not carried out.

To provide a clearer understanding of these timeframes for you, the same subdivision between our activities should also be applied here:

Process	Retention period	Commencement date
Registration	Up to 5 years after you have unlinked the account.	The day on which the user has successfully completed the registration on the Application.
Direct marketing	Up to 5 years after the end of your contractual relationship with Locinox.	The day on which the user has successfully completed the registration on the Application.
Localization	Up to 5 years.	The day on which the user has opened the Application, unless the user has chosen not to share location data through the Application and the location data is not necessary for the performance of the Service.
Dispute Resolution	Up to 10 years after the dispute has come to an end.	The day on which the dispute has commenced.

The Personal Data are collected according to the term as described above, to be deleted or at least anonymized afterwards, after which identification of the data subject is no longer possible, unless this is necessary for the execution of an ongoing agreement or in the context of a legal obligation, judicial or police investigation.

6. TRANSMISSION OF PERSONAL DATA

Locinox, as the data controller, may disclose your Personal Data to others. A distinction should be made between (sub-)processors and other third parties (non-processors, such as recipients).

a) Subcontractors

Locinox can enlist the services of subcontractors located outside the European Economic Area. Locinox only works with subcontractors bound by the standard provisions endorsed by the European Commission, or with subcontractors from nations deemed by the European Commission to ensure an adequate level of protection.

Locinox may transfer your Personal Data to third countries outside the European Economic Area ("EEA"), including if you are located outside the EEA and download our Application from outside the EEA. It is also possible that Locinox, through its (sub-)processors, transfers your Personal Data to countries outside the EEA. In this case, Locinox will only transfer your Personal Data outside the EEA in accordance with the Applicable Law and with the implementation of appropriate technical and organizational measures.

An overview of (sub-)processors and international transfers can be obtained upon request.

b) Governmental entities

Locinox has a legal obligation to share your Personal Data with certain governmental entities in the context of legal obligations. These governmental entities are listed below:

· Belgian Data Protection Authority

· Judicial authorities

c) Other third parties

Only if you have given your consent, Locinox may transfer your Personal Data to other third parties who decide for themselves their own purposes for processing your data.

7. DATA SECURITY

Locinox takes all necessary measures to ensure the security of your Personal Data and makes every reasonable and appropriate effort to protect the confidentiality of your Personal Data. We have implemented appropriate technical and organizational measures, safeguards, and protections to process your Personal Data in accordance with Applicable Legislation, particularly to protect your Personal Data against loss, misuse, or unauthorized alteration or destruction.

Locinox has a team of specialized IT professionals, automated systems, and advanced technologies in place to safeguard the confidentiality of your Personal Data.

Despite the technical and organizational measures we have implemented, please be aware that there are always risks associated with sending Personal Data over the internet. The security and protection of your Personal Data can never be fully guaranteed, nor can we guarantee that unauthorized third parties will never be able to bypass such measures or use your Personal Data for improper purposes.

8. RIGHTS OF THE DATA SUBJECT

8.1. General

Locinox is responsible, as a data controller, to inform you with regard to the collection and processing of your Personal Data. This privacy policy hereby applies as a notification.

Depending on the selected legal basis for the processing, certain rights can be executed. In order to offer a clear overview, a schematic summary of your rights under the GDPR has been portrayed in the table below.

Legal basis	Rights of the data subject
Legitimate interests	Right to access
	Right to rectify
	Right to object
	Right to restriction of processing
	Right to be forgotten
	Right to data portability
	Right to file a complaint
Performance of the contract	Right to access
	Right to rectify
	Right to object
	Right to restriction of processing
	Right to be forgotten
	Right to data portability
	Right to file a complaint

You can refer to section 8.8 (‘Procedure for exercising rights’) for the procedure to exercise these rights.

8.2. Right to access

You have the right to obtain information from Locinox on whether or not your Personal Data will be processed. If your Personal Data is processed you can have access to your data in all our files with additional information about the processing purposes, the categories of Personal Data, possible receivers of your Personal Data, the retention period, complaints procedure, …

Furthermore, you can request a copy of your Personal Data, without additional administrative costs. Mind you, when you request multiple copies Locinox will charge you a fair compensation.

8.3. Right to rectify

As a data subject, you have the right to correct any incomplete or inaccurate Personal Data related to yourself.

Under the term "correct," you should understand that you can have incorrect Personal Data adjusted or even deleted at no cost.

The accuracy and quality of your Personal Data are crucial for achieving our purposes.

8.4. Right to restriction of processing

You have the right to restrict the processing of your data. This means that processing will be temporarily halted, for example, until there is certainty about its accuracy.

8.5. Right to object

You have the right to object. Legal provisions provide for a general right to object and an objection regarding direct marketing.

a) General right to object

You can object to the processing of your Personal Data when the data is incomplete or irrelevant for the processing purposes, or when the registration, communication, or storage of data is prohibited, or when the data has been stored for longer than the specified duration.

If your Personal Data is processed unlawfully, you can object to this processing under Applicable Legislation for compelling and legitimate reasons related to your particular situation. However, you must demonstrate significant and legitimate reasons to prevent further processing.

b) Right to Object to Informational Mailings:

You can object, without any justification, to the processing of your Personal Data for direct marketing purposes at no cost. You are provided with this option, for example, at the bottom of the relevant email.

8.6. Right to be forgotten

Without undue delay, you can have your Personal Data erased in your own name. The right to be forgotten is not an absolute right. It can be exercised if:

· The Personal Data is no longer necessary for the purposes for which it was collected or processed;

· You withdraw consent for specific purposes;

· The Personal Data has been unlawfully processed;

· The Personal Data needs to be erased to comply with a legal obligation.

8.7. Right to obtain personal data

Under Applicable Legislation, you, as a data subject, has the right to request from Locinox your Personal Data, which Locinox possesses, in a structured, commonly used, and machine-readable format.

This request can be made for personal use as well as for transferring the data to another data controller other than Locinox.

If technically feasible, you can also request the electronic transmission of your Personal Data to another company.

8.8. Procedure for exercising rights

If you wish to exercise the aforementioned rights, you should send your request by email to: info@locinox.com.

Upon receiving your request, we will respond as quickly as possible and, in any case, within one month.

Depending on the complexity of the request, this period may be extended by two months. You will be informed of such an extension.

8.9. Reporting and Competent Authority in Case of Violations

If you believe that your rights as mentioned above are not being respected by us and you wish to file a complaint, you can contact the Belgian Data Protection Authority:

Competent authority	Data Protection Authority of Belgium
Address	Drukpersstraat 35, 1000 Brussels
Telephone	+32 (0)2 274 48 00
E-mail	contact@apd-gba.be

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