1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    This notice explains how we use data, where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.4    In this policy, “we”, “us” and “our” refer to Fipra International Limited.

2. How we use your personal data

2.1    In this Section 2 we have set out:

(a)    the categories of personal data that we may collect or process;

(b)    the purposes for which we may process personal data; and

(c)    the legal bases of the processing.

2.2    We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google analytics. This usage data may be stored (?) and processed. The purpose of use of personal data collected when visiting Company website:

– to provide customer service, customer relationship management  and  relationship development

– provision and development of Fipra services as informed on the website

– analysing of service usage, enabling the controller to offer tailored content to users

– opinion polls and market surveys

– fulfilling statutory obligations and any other official rules and regulations

– marketing, competitions and making recommendations

– risk management

2.3    We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include Name, Surname, Email address. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4    We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is performance of a contract.

2.5    We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is to take necessary steps at your request prior to entering into a contract.

2.6    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters, according to the laws on electronic marketing rules, “opt-in”.

2.7    We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is the  performance of a contract, proper administration of our website and business and communications with users.

2.8    Please do not supply any other person’s personal data to us, unless we prompt you to do so, and you can ensure you have the necessary rights from that person.

3. Providing your personal data to others

3.1    We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2    In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4. International transfers of your personal data

4.1    In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2    We and our other group companies have offices and facilities in Belgium and the UK.

4.3    The hosting facilities for our website are situated in the European Union.

4.4    You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1    This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3    Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments

6.1    We may update this policy from time to time by publishing a new version on our website.

6.2    We will notify you of any such changes to this policy that will impact your rights under current and applicable privacy laws and regulations.

7. Your rights

7.1    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)    the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor plus an original copy of a utility bill showing your current address).

7.2    We may withhold personal information that you request to the extent permitted by law.

7.3    You may instruct us at any time not to process your personal information for marketing purposes.

7.4    In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

8. About cookies

8.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2    Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies that we use

9.1    We use cookies for the following purposes:

(a)   necessary – we use cookies to ensure the correct functioning of our website in order to personalise the website for you. We also use these cookies to ensure website security is not compromised. Cookies used for this purpose are:

wfvt_{hash}: used by the WordPress Content Management System to remember a user’s submitted web form data when a comment is submitted in a blog post. The purpose is to auto-populate form fields for subsequent comments, in order to save time for the user.

gdpr: used to keep track of GDPR-related data consents as set by the user.

wordpress_test_cookie: used to test cookie functionality in the browser.

wordpress_{hash}: used to store settings from the current user’s browsing session (within our website only).

WordPress_logged_in_{hash}: used to identify whether the current user has administrative rights to the website CMS.

(b)   performance – we use cookies to help us to analyse the use and performance of our website and services. Cookies used for this purpose are:

_ga and _gid: used by Google Analytics to register a unique ID that is used to generate statistical data on how visitors use our website.

_gat: used by Google Analytics to throttle the request rate to their system.

collect: used to send data to Google Analytics about the visitor’s device and behavior.

10. Cookies used by our service providers

10.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/

11. Managing cookies

11.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2  Blocking all cookies will have a negative impact upon the usability of many websites.

11.3  If you block cookies, you will not be able to use all the features on our website.

12. Our details

12.1  This website is owned and operated by Fipra International Limited.

12.2  We are registered in England and Wales under registration number 3936157, and our registered office is at 6, Hay’s Lane – London SE1 2HB.

12.3  Our principal place of business is at 227, Rue de la Loi – 1040 Brussels – BELGIUM.

12.4  You can contact us:

(a)    by post, to 227, Rue de la Loi – 1040 Brussels;

(b)    by telephone, on +32.2.613.28.11; or

(c)    by email, using admin@fipra.com.

13. Data protection officer

13.1  Our data protection officer’s contact details are: John.Lion@fipra.com.