Confidentiality policy

1. Responsible for the treatment

This Privacy Policy describes how COBRIA SRL (hereinafter “COBRIA” or “we”) collects, uses and protects your personal data in connection with the use of its application and services.

COBRIA is registered with the Crossroads Bank for Enterprises and has its head office established at 1070 Anderlecht, Boulevard Industriel 65, Belgium.

2. Data collected

As part of the use of our application, we may collect the following data:

• Identity: name, first name, company, email address, telephone number, postal code.
  
• Data related to the use of the application: connections, preferences, functionalities used.
  
• Billing and payment data (via secure service providers).
  
• Information provided voluntarily by the user as part of the configuration of his account or the use of certain functionalities.
  

COBRIA does not collect or process the personal data of its users' end customers (e.g. individuals, consumers). The user remains solely responsible for complying with the RGPD for this data.

3. Purposes of the treatment

The data collected is used to:

• To provide and perform COBRIA services.
  
• Manage user accounts and subscriptions.
  
• Improve and personalize the user experience.
  
• Provide customer support.
  
• Conduct statistical analyses for internal purposes.
  
• Send communications related to the service and, where appropriate, promotional offers (with the possibility of opposition).
  

4. Legal basis for processing

The treatments carried out by COBRIA are based on:

• The execution of the contract between COBRIA and the user (article 6.1.b RGPD).
• Compliance with legal obligations (article 6.1.c RGPD).
• COBRIA's legitimate interest in improving its services and commercial prospecting (article 6.1.f RGPD).
• The explicit consent of the user, when required (article 6.1.a RGPD).

5. Data recipients

Data is not sold to third parties under any circumstances. They can be shared with:

• COBRIA employees and subcontractors, only to the extent necessary for the execution of the service.
• Technical and hosting providers. - Public authorities, if required by law.

6. Shelf life

The data is kept for the duration of the contractual relationship plus the applicable legal deadlines (e.g. accounting obligations). Data related to marketing is kept until the user's consent is withdrawn or opposed.

7. security

COBRIA implements all appropriate technical and organizational measures to protect personal data against unauthorized access, loss, modification, or disclosure.

8. User rights

In accordance with the GDPR, you have the following rights over your data:

• Right of access and correction.
• Right to erasure (“right to be forgotten”).
• Right to limitation of treatment.
• Right to data portability.
• Right to object, in particular to the use of data for prospecting purposes.
• Right to withdraw your consent at any time.

These rights can be exercised by sending a request to: privacy@cobria.be. You also have the right to file a complaint with the Data Protection Authority (www.autoriteprotectiondonnees.be).

9. Transfers outside the EU

In some cases, data may be transferred to countries outside the European Union. COBRIA then ensures that appropriate guarantees are put in place (standard contractual clauses, certified service providers).

10. Confidentiality

COBRIA undertakes never to communicate confidential information relating to the user to third parties, except with the express agreement of the user or legal obligation.

11. Changes

This Privacy Policy may be updated to reflect changes in our practices or the legal framework. The user will be informed of any substantial changes.