Privacy policy

In general

This privacy statement applies to the processing of your personal data by Circlair in all interactions with us, for example when you visit our website, use our services, subscribe to our newsletters, contact our employees, and so on.

Circlair takes your privacy seriously. It processes the personal data obtained in accordance with the principles relating to data processing and the obligations imposed by the European Regulation (EU) 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, and repealing Directive 95/46/EC, also referred to as the General Data Protection Regulation (“GDPR”).

Circlair processes the personal data obtained in accordance with the principles that apply to all data processing, namely:

a) Personal data are processed lawfully, fairly, and transparently in relation to the data subject (“lawfulness, fairness, and transparency”);

b) Personal data are collected for specified, explicit, and legitimate purposes only, and are not further processed in a manner incompatible with those purposes (“purpose limitation”);

c) Personal data are adequate, relevant, and limited to what is necessary for the purposes for which they are processed (“data minimisation”);

d) Personal data are accurate and, where necessary, kept up to date; Circlair takes every reasonable step to ensure that inaccurate personal data, having regard to the purposes for which they are processed, are erased or rectified without delay (“accuracy”).

What personal data are stored?

Personal data refers to information relating to an identifiable individual. This data is provided to us when you, for example, fill out a form on the website, use our products and services, or use an application on this website. All data we collect may be combined in order to better tailor our offers and services to your personal needs.

Our website collects the following personal data:

When filling out the contact form:

  • name
  • company name
  • email address
  • telephone number


During other interactions involving the exchange of information (consultations via telephone, email, at the office, etc.), we only collect personal data that is necessary for the execution of the agreement with Circlair.

Who is responsible for these data?

Circlair BV, with registered office at Galileilaan 15, 2845 Niel, and registered with the Crossroads Bank for Enterprises under number 1017.358.665 (hereinafter “Circlair”), is responsible for the processing of your personal data. The following person has been appointed within our organisation to ensure data protection:

Lander Hollevoet
+32 35 50 00 48
info@circlair.be

How are these data protected?

We do everything possible to protect your personal data and privacy, both in our offices, on our network, and while on the move. Our employees are trained to handle confidential information with great care. Additional measures are also taken for highly sensitive data.

  • Secure passwords that are only used in one or a limited number of specific applications
  • Submission of form data via HTTPS
  • Proper, up-to-date firewalls at both our offices and hosting providers
  • Proper, up-to-date servers at both our offices and hosting providers
  • Intrusion detection software on firewalls
  • Only a limited number of employees have access to your personal information, and only those who need it to perform their duties
  • Recent hardware with updated firmware
  • Physically secured office with alarm system
  • No third-party access without the presence of management

What if personal data are breached?

In the event of a data breach with adverse consequences for your personal data, you will be personally notified — no later than 72 hours after it has come to our attention — in the circumstances required by law.

How are these data stored?

This data is stored on:

Internal systems

Circlair takes the protection of personal data very seriously and applies appropriate technical and organisational measures to secure this data against loss, misuse, unauthorised access, disclosure, alteration, or destruction. Our internal systems comply with applicable security standards and are regularly monitored and updated to ensure data security and integrity.

Access to personal data is strictly limited to authorised employees of Circlair who need this information to perform their duties. These employees are bound by confidentiality and act in accordance with our internal security and privacy procedures.

Servers of the website provider

  • The data centres are physically located in Brussels.
  • The hosting provider is, as the only one in Belgium, certified under ISO 27001:2013, a standard derived from the British “Code of Practice for Information Security Management (BS7799)”. It refers to a management system specifically for information security (Information Security Management System, ISMS) and specifies how security risks can be demonstrably controlled. As part of an ISMS, the ISO 27001:2013 standard requires defining a scope and policy, performing a risk analysis, selecting and implementing controls for identified risks, allocating resources, and continuously monitoring and reviewing these measures in a cyclical process.

Where are these data stored?

The data centers are physically located in Brussels. Our internal systems are hosted at our head office in Niel.

How long are these data stored?

This data will be retained indefinitely.

For what purposes are these data used?

These data are currently not used for long-term purposes and are only processed to contact you regarding your request. We do not add your data to a mailing list unless you explicitly give your consent.

The personal data processed by Circlair are in principle not accessible to third parties and are used solely internally. However, Circlair does engage third parties for certain (technical) services, such as web hosting, email campaign management, specific software usage, cloud computing, and ICT support, in which context these third parties may have access to your personal data. Circlair has concluded separate data processing agreements with each of these service providers who process data on its behalf.

Are cookies stored as well?

Identification cookies are used to identify visitors in order to access the administration application used to edit the website.

Functional cookies are used to ensure the proper functioning of that administration application (e.g. where you are, what you are doing), but they are only usable by administrators.

Analytical cookies allow us to analyse our website. This helps us understand how many visitors come to our site, how long they stay, what they click on, which sections are popular, and so on. It also helps us identify issues visitors may encounter, enabling us to improve the website. For this purpose, we also use third-party cookies such as Google Analytics. The generated information about your browsing behaviour on our websites is collected and transmitted to Google, where it is stored on servers in the United States.

If your website uses optional cookies, and therefore certain non-functional cookies can be disabled, a pop-up may be displayed allowing you to refuse them upon visiting the site. You can also disable or delete all installed cookies at any time via your browser settings (usually under “Help” or “Internet Options”). Each browser has its own method for managing cookies; instructions can be found on the website of the browser you are using. Please note that changing these settings may cause the website to function improperly.

How can I access, edit or delete my data?

If you wish to contact us to modify your personal data, you can do so at our office, in writing, by telephone, or via social media. All general contact information can be found here: http(s)://www.circlair.be/contact. You can also contact our DPO.