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Privacy Policy

Privacy Policy Cluma Engineering NV 2020

At Cluma Engineering NV (Cluma), accessible from www.cluma.com, one of our main
priorities is the privacy of our visitors. This Privacy Policy document informs about types of
information that is collected and recorded by Cluma and explains how Cluma uses it.

If you have additional questions or require more information about our Privacy Policy, do not
hesitate to contact us at: info@cluma.com

This Privacy Policy applies only to our online activities and is valid for visitors of our website
with regards to the information that they shared with us. This policy is not applicable to any
information collected offline or via channels other than this website.

Consent

By using our website, you hereby consent to our Privacy Policy and agree to its terms.

What data do we collect?

When you register an account on our website you may have to fill in some personal details that
we will collect. This information might include:

• First name and last name
• Company Name
• Company legal form
• Address
• Phone number
• Email address
• Registration number
• Date of birth
• Gender
• Bank details
• VAT number

We might also collect any other information that you provide to us, including any uploaded
attachments and content of your messages.

The collected information is used to optimize your experience on our website.

We also collect some technical information that allows us to perform internal analytics. This
information includes:

  • Internet Protocol (IP) address
  • Browser type
  • Operating system type
  • Computer location
  • Time spent on the Cluma website
  • Actions performed on the Cluma website

We use the information we collect in various ways, including to:

• Provide, operate, and maintain our website
• Improve, personalize, and expand our website
• Understand and analyze how you use our website
• Develop new products, services, features, and functionalities
• Communicate with you, either directly or through one of our partners, including for
  customer service use, to provide you with updates and other information relating to
  the website, and for marketing and promotional purposes
• Send you emails
• Find and prevent fraud

How do we collect your data?

We collect and process the data directly when you:

• Visit our website
• Register, login and use our web application
• Subscribe to one of our mailing lists

Cluma may also receive your data indirectly from the following sources: Google Analytics,
Google ads, Facebook, Facebook ads, Social Media login.

How will we use your data?

We collect the stated above data only to make your experience on our Platform more pleasant
and easy. This data makes it possible for you to navigate our website and application and make
use of all the available features.

If you face any difficulties on our website or application we use the activity history to provide
the needed support; this will help you to get back on track. We analyze the usage of our website
to constantly improve your experience and to design new features.

Where do we store your data?

Cluma securely stores your personal details and the content that you uploaded partly on
Combell hosted and Cluma owned servers.

For analytic and performance purposes the technical data is stored partly on Combell hosted
and Cluma owned servers.

For how long do we keep your data?

As long as you have an account on the Cluma website we store the data you shared with us.

When you delete your account, all the data will be removed within 30 days from your request.

Marketing

We would like to send you information about products and services that we think you might
like. If you have agreed to receive marketing emails you can always opt-out at a later date.

You have the right to ask Cluma stop contacting you for marketing purposes at any time and
we will respect that decision. Simply click “unsubscribe” in one of the emails we sent to you
and we will not disturb you anymore.

Do we share your personal data with third parties?

We process your data only for internal business purposes. Some of our internal processes are
done with the help of third parties. This includes:

● Companies that we collaborate with for software integration and hosting, such as
   Combell
● Companies that we collaborate with for analytical purposes, such as Combell and
   Google Analytics
● Companies that we collaborate with for payment purposes, such as Paypal, Mollie

With all the stated above partners we work on a contractual basis, which guarantees the secure
protection of your personal data. We make sure that our partners treat your data only on our
behalf and not for their own purposes.

Your personal data will never be sold or transferred to other parties without your permission.
The only exceptions to disclosing your personal information are if we get a request from the
competent authority or when we are being taken over by another company.

Advertising Partners Privacy Policies

You may consult us to find the Privacy Policy for each of the advertising partners of Cluma.
Third-party ad servers or ad networks use technologies like cookies, JavaScript, or Web
Beacons that are used in their respective advertisements and links that appear on Cluma, which
are sent directly to users' browser. They automatically receive your IP address when this occurs.
These technologies are used to measure the effectiveness of their advertising campaigns and/or
to personalize the advertising content that you see on websites that you visit.

Note that Cluma has no access to or control over these cookies that are used by third-party
advertisers.

Third Party Privacy Policies

Cluma's Privacy Policy does not apply to other advertisers or websites. Thus, we are advising
you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

You can choose to disable cookies through your individual browser options. To know more
detailed information about cookie management with specific web browsers, it can be found at
the browsers' respective websites.

What are your data production rights?

We would like to make sure that you are fully aware of all of your data protection rights. Every
user is entitled to the following:

The right to access – You have the right to request copies of your personal data. We may charge
you a small fee for this service.

The right to rectification – You have the right to request that we correct any information you
believe is inaccurate. You also have the right to request that we complete the information you
believe is incomplete.

The right of erasure – You have the right to request that we erase your personal data, under
certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing
of your personal data, under certain conditions.

The right to object to processing – You have the right to object to our processing of your
personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we
have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any
of these rights, please contact us at: info@cluma.com

What are cookies?

A cookie is a piece of information in the form of a very small text that is placed on your hard
drive. This piece of information is generated by our server and it might be used when you visit
our website. A cookie can be described as your internet identification card, which can tell us
that you returned to the website.

You can find more information about cookies and a great edible cookie recipe on
https://www.aboutcookies.org/

How do we use cookies?

We use cookies to improve your experience on our website. Cookies keep you signed in, so you
do not lose your data. They also help us to understand how you use our website, so we can
improve usability and make your experience even more pleasant.

What types of cookies do we use?

Our website uses different types of cookies:

Essential cookies - These cookies are necessary for you to be able to use our platform.
These cookies include, but are not limited to: Login / register / account-related info /
previous actions / payment processing, etc.

Performance cookies - These cookies help us to improve the performance of our
website, as well as to record your preferences. These cookies include, but are not limited
to: Remembering preferences/analytics/load balancing/testing/ error management, etc.

Marketing cookies - These cookies are used to collect information about your visit to
our website, the content you view, the links you followed, the information about your
browser, device and your IP address. These cookies help us to recommend content you
might be interested in. These cookies include but are not limited to newsletters/
remarketing, etc.

Third-party cookies - For the functionality of our website, Cluma is connecting to
third-party websites. These platforms may contain cookies that Cluma does not control.
Please consult these platforms for more information about the cookies they are using.

How to manage your cookies?

You can always reject cookies in the pop-up menu on our platform. You can also set your
browser not to accept cookies, however, in a few cases, some of our website features may not
function as a result.

Depending on which browser you use, please consult the following websites for more
information:

● Cookie settings in Internet Explorer
● Cookie settings in Microsoft Edge
● Cookie settings in Firefox
● Cookie settings in Chrome
● Cookie settings in Safari
● Cookie settings in Opera
● Cookie settings in Brave

Changes to our Privacy policy

We review our Privacy Policy regularly and update it when something changes in the way we
treat your personal data. We recommend you to consult our Privacy Policy once in a while to
see if there are any changes made. Our Privacy Policy was last updated on 25 May 2020.

How to contact us

If you have any questions about Cluma’s Privacy Policy, the data we hold on you, or you would
like to exercise one of your data protection rights, please do not hesitate to contact our Data
Protection Officer Steven Deweirt.

Email us at: info@cluma.com

Mail us at:
Cluma Engineering nv
Kachtemsestraat 161
8800 Roeselare

How to contact the appropriate authorities?

If you are not satisfied with our response or would like to report a complaint you can contact
the Data Protection Authority: www.dataprotectionauthority.be/

call us

+32 51 24 45 00

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