Legal Notice

The information available on the blog WORLD TRADE CONTROLS is intended for public discussion and educational purposes only. Although all publications have been compiled with great care, the authors cannot accept any liability for the consequences of making use of them without their cooperation. The information provided is intended as general information and cannot be regarded as advice. The use of this blog and any information contained in it does not create any attorney-client relationship. The opinions and content shared via this blog are those of the individual contributor and do not reflect those of ICC Belgium, the Federation of Enterprises in Belgium, Bryan Cave Leighton Paisner LLP, Loyens & Loeff, or any of these organizations’ clients and stakeholders.

Copyright

WORLD TRADE CONTROLS © 2016-2018 ICC Belgium (BE0892.722.969), a Brussels-based non profit organization and a member organization of the International Chamber of Commerce (ICC) network of independent national committees affiliated with ICC, The World Business Organization, a French entity. All Rights Reserved. No part of WORLD TRADE CONTROLS may be reprinted or re-used in any form except with the express written consent of the copyright holders.

Privacy

1. About worldtradecontrols.com, ICC Belgium and ICC, The World Business Organization

The blog WORLD TRADE CONTROLS accessible on: worldtradecontrols.com is an initiative of ICC Belgium.

The International Chamber of Commerce in Belgium (ICC Belgium) is the Brussels-based committee of the world business organization, the only representative body that speaks with authority on behalf of enterprises from all sectors in every part of the world. ICC Belgium was founded in 1920, one year after Belgium was one of the five founding countries of the International Chamber of Commerce (ICC). Today ICC groups millions of member companies and associations from over 130 countries.

ICC Belgium is the controller of your personal data.

ICC Belgium is located at Stuiversstraat 8 rue des Sols, 1000 Brussels, Belgium. We can be reached by phone at +32 2 515 09 33.

If you want to know more about ICC Belgium, please visit the Who We Are gateway of the ICC Belgium website at www.iccwbo.be.

2. ICC Belgium’s Privacy Statement

The purpose of this Privacy Policy is to inform you of the procedures regarding the collection, use and disclosure of information on ICC Belgium’s website: worldtradecontrols.com, including any mobile versions or related mobile applications, accessible on: worldtradecontrols.com. ICC Belgium encourages you to carefully read this Privacy Policy.

By visiting www.worldtradecontrols.com and providing information to ICC Belgium, you acknowledge that you have been informed and you consent to the Privacy Policy, including with regard to ICC Belgium’s collection, use and disclosure of personal information which may be collected when you subscribe to ICC Belgium’s email alerts and newsletters on worldtradecontrols.com, when you register for events and trainings on worldtradecontrols.com, or when you ask for any other products and services provided on worldtradecontrols.com. If you do not wish your personal information to be used by ICC Belgium in the manner set out in this Privacy Policy, please do not provide us this information.

3. What Information is Collected and How It Is Used

Nature of information collected

In order to receive newsletters or information about worldtradecontrols.com, to contact worldtradecontrols.com for any questions or comments, or to register for events and trainings on worldtradecontrols.com, you may choose to provide some personal information. The categories of personal information that ICC Belgium may collect for the processing purposes described hereto are: family name, first name, organization, position, activity, main centre of interest, address, postal code, country, phone, website, and email.

Purposes

ICC Belgium, or third parties on its behalf, may use the personal information that you provide:

      • to process and respond to your questions and/or inquiries, and
      • to deliver you newsletters, emails, or other communications relating to products and services that you may be interested in;
      • to provide you with any services and products on worldtradecontrols.com.

ICC Belgium, or third parties on its behalf, may also use certain information you provide in an aggregate and anonymous form for internal business and planning purposes, such as statistics.

Security

Protecting your privacy and your information is a priority at ICC Belgium. ICC Belgium has taken reasonable measures to protect your personal information from loss, misuse and alteration. However, please be aware that no data transmission over the internet or storage technology can be guaranteed to be 100% secure. ICC Belgium can only take steps to help reduce the risks of unauthorized access. Each individual using the internet can take steps to help protect his/ her personal information and further minimize the likelihood that a security incident may occur.

Cookies and session cookies

Subject to your prior explicit consent where such consent is required by the applicable law in your jurisdiction, ICC Belgium Sites like worldtradecontrols.com use “cookies” (i.e., small text files which are downloaded to a user’s device when visiting the ICC Belgium Sites) in order to make easier for users to navigate around the worldtradecontrols.com website and improve the quality. Cookies are essential in order to enable you to move around the worldtradecontrols.com webite and use their features, such as accessing secure areas of the worldtradecontrols.com website or making pages load properly. You can disable cookies by changing your web browser settings.

General information on cookies

On 26 May 2011 a new EU originated law came into effect that requires website owners to be more transparent regarding their usage of cookies on websites. ICC Belgium uses cookies to save your logged in status and track that you have visited the site. This is useful for you and means that you do not have to login to access your preferences each time you visit worldtradecontrols.com. This is also useful for us as it helps us gauge how many users have visited our site. By using worldtradecontrols.com you the consent that you allow us to use cookies in this way, if you do not consent to this, you may disable these cookies through your browser.

4. Disclosure of Information

ICC Belgium does not disclose your personal data to third parties, except to the ICC Belgium global network, business partners and service providers, or except as may be required by any applicable law, regulation, or governmental request or to protect the rights of ICC Belgium. Access to your information may be granted to such third parties as needed to perform their assistance or services. Yet ICC Belgium does not authorize third parties to use or to transfer your information for any other purposes.

Transfer of personal data outside the European Union

As an international organization with a global network, ICC Belgium may need to transfer and process your information (personal and non-personal) internationally for the above mentioned purposes as described in the article 3 of this Privacy Policy.

Your consent to this Privacy Policy followed by your submission of your personal information through the ICC Belgium Sites represents an express consent to such transfer and processing.

5. Rights to Unsubscribe of to Access the Information

How to unsubscribe from the worldtradecontrols.com newsletter

If you no longer wish to receive any kind of communications from worldtradecontrols.com (e.g. newsletters), you may opt out by cancelling your subscription on worldtradecontrols.com through the link sent in each email you receive from worldtradecontrols.com, or by sending an email to we@iccwbo.be.

How to access and update your information

The collected information is necessary for your registration and, more generally, for the purposes described in the article 3 of this Privacy Policy. They are subject to data processing at ICC Belgium. Pursuant to the European Directive 95/46/EC, you will benefit from the right to access and the right to rectify data regarding your personal information. If you wish to exercise these rights and obtain all relevant information, please contact us at we@iccwbo.be.

6. Links to Other Sites

worldtradecontrols.com may contain links to or from a number of third party websites (hereinafter referred to as “Third Party Sites”). ICC Belgium doest not, in any way, control or operate the Third Party Sites. ICC Belgium is not responsible for the privacy practices, content, policies or actions of the Third Party Sites. This Privacy Policy is only applicable to general information processed by the ICC Belgium Sites, pursuant to information collected on ICC Belgium Sites. The use of any information you may provide to third parties on Third Party Sites, or which such parties may otherwise collect on other websites, is not governed by this Privacy Policy.

7. Social Networks

Social media plug-ins of social networks such as Facebook, Twitter and Google plus or services with user-generated content features are integrated on worldtradecontrols.com. Where the worldtradecontrols.com website contains a plug-in to a social network site, these are clearly marked (e.g. with a Facebook button). If you choose to click on one of these buttons or links, your browser connects directly to the servers of the relevant social network. The other website’s privacy policy applies to any personal information you provide to that website. If you do not want the social network to collect the information about you, please review the privacy policy of the relevant social network and/or log out of the relevant social network before you visit worldtradecontrols.com.

8. Intellectual Property (IP) / Content

All content displayed on worldtradecontrols.com, including but not limited to, text, graphics, logos, buttons, icons, images, sounds, audio clips, digital downloads, data compilations and software, is the property of ICC Belgium or ICC or its content suppliers and is protected by the Belgian and/or foreign applicable laws.

Registered trademarks of ICC Belgium are marks indicated on worldtradecontrols.com and include licensors, in Belgium and other countries. All other trademarks that appear on worldtradecontrols.com are the property of their respective owners.

You are prohibited from using, without permission, any of the marks, trademarks, trade names, service names, logos or other propriety graphic appearing throughout worldtradecontrols.com. For more information, please ask us.

9. Updates to Privacy Policy

To the extent permitted by applicable law in your jurisdiction, ICC Belgium may from time to time revise or update this Privacy Policy. You agree to be bound by such modifications or updates. If we make material revisions to the way we collect or use your personal information such that we are using it for purposes that you have not consented to, we will notify you of the changes and, as the case may be, ask for your explicit consent.

Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy on the internet, accessible through worldtradecontrols.com. By continuing to use the worldtradecontrols.com website following such changes, you will be deemed to have agreed to such changes.


Effective since: 14 May 2018

  1. GENERAL WARNING

1.1          The ASSOCIATION SANS BUT LUCRATIF, ICC BELGIQUE (hereinafter, « ICC Belgium ») respects the privacy of its users (hereinafter, the “Users“).

1.2          ICC Belgium processes the personal data transmitted to it in accordance with the legislation in force, and, in particular, Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, applicable from 25 May 2018 (hereinafter the “General Data Protection Regulation“).

1.3          Access to the website worldtradecontrols.com (hereinafter, the “Website”) implies the User’s full and unreserved acceptance of this Privacy Policy (hereinafter the “Policy”), as well as its general terms of service (hereinafter the “Terms”) and the cookie policy (hereinafter, the “Cookie Policy”).

1.4          The User acknowledges having read the information below and authorizes ICC Belgium to process, in accordance with the provisions of the Policy, the personal data that he/she communicates on the Website.

1.5          The Policy is valid for all pages hosted on the Website and for the registrations of this Website. It is not valid for the pages hosted by third parties to which ICC Belgium may refer and whose privacy policies may differ. ICC Belgium cannot therefore be held responsible for any data processed on these websites or by them.

  1. DATA CONTROLLER

2.1          Simply visiting the Website shall take place without having to provide any personal data, such as first name, surname, postal address, e-mail address, etc.

2.2          As part of the Service, the User may be required to provide certain personal data. In this case, the data controller is:

ASSOCIATION SANS BUT LUCRATIF, ICC BELGIQUE

RUE DES SOLS 8 STUIVERSSTRAAT
1000 BRUSSELS
BELGIUM

Belgian business registry (BCE) number: BE 0892.722.969

2.3          Any question regarding the processing of this data may be sent to the following address: we@iccwbo.be.

  1. DATA COLLECTED

3.1          By completing the order form on the Website and using the Service, the User allows, in particular, ICC Belgium to record and store, for the purposes mentioned in point 4, the following information:

  • identifying data, such as the first name and surname, e-mail address and company delivery address, country;
  • invoicing information;
  • communications between the User and ICC Belgium;
  • The User also authorizes ICC Belgium to record and store the following data for the purposes mentioned in point 4:
  • information voluntarily provided by the User for a purpose specified in the Policy, the general terms and conditions of sale (hereinafter the “GTC“), the Terms, the Cookie Policy, on the Website or on any other medium of communication used by ICC Belgium;
  • additional information requested by ICC Belgium to the User in order to identify him or to prevent him from violating any of the provisions of the Policy;

3.3          In order to facilitate browsing the Website as well as to optimize technical management, the Website may use “cookies”. These “cookies” record, in particular:

  • the User’s browsing preferences;
  • the date and time of access to the Website and other data related to traffic;
  • the pages visited;

All information relating to “cookies” is included in ICC Belgium’s Cookie Policy.

3.4          When the User accesses the Website, the servers consulted automatically record certain data, such as:

  • the type of domain with which the User connects to the Internet;
  • the IP address assigned to the User (when connected);
  • the date and time of access to the Website and other data related to traffic;
  • the pages visited;
  • the type of browser used;
  • the platform and/or operating system used;
  • the search engine as well as the keywords used to find the Website.

3.5          No nominative data identifying the User is collected through the cookies and servers consulted. This information is kept for statistical purposes only and to improve the Website.

  1. PURPOSES OF PROCESSING THE DATA

4.1          The Website collects, stores and uses its Users’ data for the following purposes, in particular:

  • to establish, carry out and conduct the contractual relationship with the User;
  • to analyse, adapt and improve the content of the Website;
  • to provide the Service;
  • to allow the User to receive messages (for example for renewal notifications)
  • to facilitate the availability and use of the Website;
  • to personalize the User’s experience on the Website;
  • for any marketing activities and promotions proposed by ICC Belgium or sister organizations or partners to Users who have given their consent;
  • to inform them about any changes on the Website and its features;
  • for any other purpose to which the User has expressly consented.
  1. RIGHTS OF THE PERSON CONCERNED

5.1          According to the regulations on the processing of personal data, the User has the following rights:

  • Right to be informed about the purposes of the processing (see above) and the identity of the data controller.
  • Right of access and verification of data: the User may, at any time, have access to the data that ICC Belgium has on him/her or check if he/she is included in the database of ICC Belgium. ICC Belgium asks the User to make this request by mail in order to be able to identify him with certainty (Please provide ICC Belgium your first name, surname, complete address and a copy of your identity card). ICC Belgium will thus be ensured that only the User accesses his data.
  • Right of objection: the User may, at any time, object to the use of his data by ICC Belgium and by its active partners (…) by sending his request to ICC Belgium by mail.
  • Right of cancellation and/or modification: the user may, at any time, notify ICC Belgium of corrections to the data concerning him and, where appropriate, request the deletion of his personal data.
  • Right of limitation of processing: the User may, in particular, obtain a limitation of processing when he has objected to the processing, when he disputes the accuracy of the data, or when he considers that the processing is illegal.
  • Right of transferability: The User has the right to receive the personal data that he has communicated to ICC Belgium and may also ask said company to send this data to another data controller.

5.2          The User may, at any time, request access to his personal data, verify them, transfer them, and, in some cases, as aforementioned, limit their processing and rectify them, by writing to ICC Belgium accompanied by a copy of his identity card or passport to the following email address: we@iccwbo.be or to the postal address: RUE DES SOLS 8 STUIVERSSTRAAT, 1000 BRUSSELS, BELGIUM.

5.3          The User may also request rectification free of charge and, where applicable, request the deletion of all his personal data from ICC Belgium’s database – except those which ICC Belgium has a legal obligation to keep on record – and object to the use and, where appropriate, request the limitation thereof by sending a written request, accompanied by a copy of his identity card or passport, to ICC Belgium:

  • by e-mail: we@iccwbo.be
  • by mail: RUE DES SOLS 8 STUIVERSSTRAAT, 1000 BRUSSELS, BELGIUM

5.4          ICC Belgium will then take the necessary steps to satisfy this request as soon as possible.

  1. DURATION OF STORING THE DATA

6.1          ICC Belgium will keep the personal data of its Users for the duration necessary to achieve the objectives pursued (see point 4).

6.2          ICC Belgium may also continue to keep personal data concerning the de-registered User, including all correspondence or request for assistance sent to ICC Belgium in order to be in a position to reply to all questions or complaints that may be sent to it after the order, and in order to comply with all applicable laws, namely with regard to taxes.

  1. COMPLAINT WITH THE SUPERVISORY AUTHORITY

The User is informed that he has the right to lodge a complaint with the Commission for the Protection of Privacy.

Rue de la Presse, 35
1000 Bruxelles

commission@privacycommission.be

  1. SECURITY

8.1          In order to guarantee optimal payment security, ICC Belgium may use online payment services, which meets high security standards.

8.2          In addition, ICC Belgium takes the appropriate organizational and technical measures to ensure a level of security adapted to the risk and that, to the extent possible, the servers hosting the personal data processed prevent:

  • unauthorized access to or modification of this data;
  • improper use or disclosure of such data;
  • unlawful destruction or accidental loss of such data.

8.3          In this respect, employees of ICC Belgium who have access to this data are subject to a strict confidentiality obligation. Nevertheless, ICC Belgium may in no way be held liable in the event that this data is stolen or hijacked by a third party despite the security measures adopted.

8.4          Users undertake not to commit acts that may be contrary to this Policy, the Terms of Service, the Cookie Policy or, in general, the law. Violations of confidentiality, integrity and availability of information systems and data which are stored, processed or transmitted by these systems, or the attempt to commit one of these violations, shall be punishable by imprisonment of between three months and five years and a fine of between twenty-six euros and two hundred thousand euros, or one of these penalties only.

  1. COMMUNICATION TO THIRD PARTIES

9.1          ICC Belgium treats personal data as confidential information. It will not communicate them to third parties under any condition other than those specified in the Policy, such as to achieve the objectives set out and defined in point 4, or under the conditions in which the law requires it to do so.

9.2          ICC Belgium may communicate its Users’ personal information to third parties to the extent that such information is necessary for the performance of a contract with its Users. In such case, these third parties will not communicate this information to other third parties, except in one of the two following situations:

  • the communication of this information by such third parties to their suppliers or subcontractors to the extent necessary for the performance of the contract;
  • where such third parties are obliged by the regulations in force to communicate certain information or documents to the competent authorities in the field of combating money laundering, as well as, in general, to any competent public authority.

9.3          The communication of this information to the aforementioned persons shall, in all circumstances, be limited to what is strictly necessary or required by the applicable regulations.

  1. TRANSFER TO A NON-EU COUNTRY OR COMPANY

ICC Belgium transfers data to a non-EU country only when that country provides an adequate level of protection within the meaning of the legislation in force, and, in particular, the Law of 8 December 1992 on protection of privacy and its executive orders, and Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, applicable from 25 May 2018 (hereinafter the “General Data Protection Regulation“), or within the limits permitted by the legislation in force, for example by ensuring the protection of data by appropriate contractual provisions.

  1. PAYMENT SERVICE

11.1       A payment service can be integrated into the Website.

11.2       The relationship between the User and this payment service is governed by the Privacy Policy available at service provider which should also include provisions relating to the processing of personal data sent to this service provider as part of its service, and for which it will be the data controller.

11.3       When making a payment through ICC Belgium, the User declares that he/she has read, understood and accepted the privacy policy of the payment service provider.

  1. DIRECT MARKETING

12.1        The personal data may be used by ICC Belgium or its partners for direct marketing purposes for similar services than those to which the User has already subscribed.

12.2        The User retains the right to object to such use at any time, upon request and free of charge. The User may simply communicate his request by writing to the following address: we@iccwbo.be

  1. NOTE CONCERNING MINORS

Persons under the age of 13 and persons who do not have full legal capacity are not permitted to use the Website. ICC Belgium asks them not to provide their personal data.

  1. UPDATES AND CHANGES TO THE POLICY

By informing Users through the Website, ICC Belgium may modify and adapt the Policy, in particular to comply with any new legislation and/or regulations applicable (such as the General Data Protection Regulation applicable from 25 May 2018), the recommendations of the Belgian Privacy Commission, the guidelines, recommendations and best practices of the European Data Protection Board and the decisions of the courts and tribunals on this issue.

  1. VALIDITY OF THE CONTRACTUAL CLAUSES

15.1        Failure by ICC Belgium to invoke – at any given time – a provision of this Policy, may not be interpreted as a waiver to subsequently make use of its rights under the said provision.

15.2        The invalidity, expiration or the unenforceable nature of all or part of one of the above or below mentioned provisions shall not give rise to the invalidity of all the Policy. Any fully or partially invalid, lapsed or unenforceable provision shall be deemed not to have been written. ICC Belgium undertakes to substitute this provision with another which, to the extent possible, fulfils the same objective.

  1. APPLICABLE LAW AND COMPETENT COURT

16.1        The validity, interpretation and/or implementation of the Policy are subject to Belgian law, to the extent permitted by the provisions of applicable private international law.

16.2        In the event of a dispute relating to the validity, interpretation or implementation of the Policy, the courts and tribunals of Brussels have exclusive jurisdiction, to the extent permitted by the provisions of applicable private international law.