Confidential Policy & Intellectual Property

1. Parties and Purpose

Navir SNC (hereinafter "Navir SNC" or the "Data Controller"), registered with VAT number BE.0797.962.679 and based at 430 Sint-Truidensesteenweg, 3300 Tienen. Navir SNC establishes this Privacy Policy to transparently inform users of the website hosted at the following address: https://navir.odoo.com (hereinafter the "Site") about how personal data is collected and processed by Navir SNC.

The term "User" refers to any user, either an individual or legal entity, who visits or interacts in any way with the Site.

In this regard, Navir SNC determines all technical, legal, and organizational means and purposes of processing the personal data of Users. Navir SNC commits to taking all necessary measures to ensure the processing of personal data in compliance with the Law of July 30, 2018, on the protection of individuals with regard to the processing of personal data (hereinafter, "the Law") and the European Regulation of April 26, 2016, on the protection of personal data of individuals with regard to the processing of personal data and the free movement of such data (hereinafter the "Regulation").

Navir SNC is free to choose any individual or legal entity to process the personal data of users at its request and on its behalf (hereinafter the "Sub-processor"). If applicable, Navir SNC undertakes to select a Sub-processor providing sufficient guarantees regarding the technical and organizational security measures of the processing of personal data, in accordance with the Law and the Regulation.

2. Processing of Personal Data

The use of the Site by Users may result in the communication of personal data. The processing of this data by Navir SNC, as the Data Controller, or by providers acting on behalf and for the account of Navir SNC, will comply with the Law and the Regulation.

Personal data will be processed by Navir SNC, in accordance with the purposes listed below, through:

- Use of cookies;

- Sending newsletters,

- Sending satisfaction questionnaires;

3. Purpose of Processing Personal Data

In accordance with Article 13 of the Regulation, the purposes of processing personal data are communicated to the User and are as follows:

- Improvement of the website, statistics concerning the use of the website, marketing actions, lead generation.

4. Personal Data that may be processed

The User consents, when visiting and using the Site, to Navir SNC collecting and processing, in accordance with the modalities and principles described in this Privacy Policy, the following personal data:

- Name, surname, email, phone, company name if applicable.

5. Consent

By accessing and using the Site, the User declares to have read and agreed freely, specifically, informed, and unequivocally to the processing of personal data concerning them. This agreement relates to the content of this Privacy Policy.

Consent is given by the positive act by which the User has checked the box proposing the Privacy Policy in the hyperlink. This consent is a necessary condition to perform certain operations on the Site or to allow the User to enter into a contractual relationship with Navir SNC. Any contract between Navir SNC and a User for the services and goods offered on the Site is subject to the User's acceptance of the Privacy Policy.

The User consents to the Data Controller processing and collecting, in accordance with the modalities and principles included in this Privacy Policy, their personal data communicated on the Site or on the occasion of the services offered by Navir SNC, for the purposes mentioned above.

The User has the right to withdraw their consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on the consent given prior to withdrawal.

6. Retention Period of User's Personal Data

In accordance with Article 13(2) of the Regulation and the Law, the Data Controller only retains personal data for the time reasonably necessary to achieve the purposes for which they are processed.

This duration is in any case less than: 1 year.

7. Recipients of Data and Disclosure to Third Parties

Personal data may be transmitted to Navir SNC's employees, collaborators, subcontractors, or suppliers who provide adequate data security guarantees and collaborate with Navir SNC in the marketing of products or the provision of services. They act under the direct authority of Navir SNC and are responsible for collecting, processing, or subcontracting this data.

In any case, the recipients of the data and those to whom this data has been disclosed comply with the content of this Privacy Policy. Navir SNC ensures that they will process this data for the sole purposes indicated, discreetly and securely.

In the event that the data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed in advance so that they can express their consent to the use of this personal data.

8. Data Protection Officer (DPO)

Navir SNC does not have a Data Protection Officer (DPO) assigned.

The role of the DPO is to ensure the proper implementation of national and supranational provisions regarding the collection and processing of personal data.

9. User Rights

At any time, the User can exercise their rights by sending an email to the following address: info@navir.be, or a letter by postal mail, attaching a copy of their ID card to the following address: Sint-Truidensesteenweg 430 – 3300 Tienen.

a. Right of Access

In accordance with Article 15 of the Regulation, Navir SNC guarantees the User's right of access to their personal data. The User has the right to obtain access to such personal data as well as the following information:

- The purposes of the processing;

- The categories of personal data concerned;

- The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular, recipients established in third countries or international organizations;

- If possible, the envisaged duration of the personal data retention or, if not possible, the criteria used to determine that duration;

- The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation, and, at least in such cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

The Data Controller may require the payment of reasonable fees based on administrative costs for any additional copy requested by the User.

When the User makes this request electronically (via email, for example), the information is provided in a commonly used electronic format, unless the User requests otherwise. The copy of their data will be provided to the User no later than one month after receiving the request.

b. Right to Rectification

Navir SNC guarantees the right to rectification and erasure of personal data to the user.

In accordance with Article 16 of the Regulation, incorrect, inaccurate, or irrelevant data can be corrected or erased at any time. The User first makes the necessary modifications themselves from their user/other account unless these cannot be done independently, in which case the request can be made to Navir SNC.

In accordance with Article 19 of the Regulation, the Data Controller notifies each recipient to whom personal data has been communicated of any rectification of personal data unless such communication is impossible or requires disproportionate effort. The data controller provides information to the data subject about these recipients upon request.

c. Right

to Erasure

The User has the right to obtain the erasure of their personal data as soon as possible in the cases listed in Article 17 of the Regulation.

When the Data Controller has made the personal data public and is required to erase them pursuant to the previous paragraph, the Data Controller, taking into account available technologies and implementation costs, takes reasonable measures, including technical measures, to inform other data controllers processing this personal data that the data subject has requested the erasure by these data controllers of any link to this personal data or any copy or reproduction thereof.

The two previous paragraphs do not apply to the extent that such processing is necessary:

- To exercise the right to freedom of expression and information;

- To comply with a legal obligation that requires processing under the law of the Union or the Member State to which the data controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller;

- For the establishment, exercise, or defense of legal claims.

In accordance with Article 19 of the Regulation, the Data Controller notifies each recipient to whom personal data has been communicated of any erasure of personal data or restriction of processing, unless such communication is impossible or requires disproportionate effort. The data controller provides information to the data subject about these recipients upon request.

d. Right to Restriction of Processing

The User has the right to obtain the restriction of the processing of their personal data in the cases listed in Article 19 of the Regulation.

In accordance with Article 19 of the Regulation, the Data Controller notifies each recipient to whom personal data has been communicated of any restriction of processing unless such communication is impossible or requires disproportionate effort. The data controller provides information to the data subject about these recipients upon request.

e. Right to Data Portability

In accordance with Article 20 of the Regulation, Users have the right to receive their personal data from Navir SNC in a structured, commonly used, and machine-readable format. Users have the right to transmit this data to another data controller without hindrance from Navir SNC in cases provided for by the Regulation.

When the User exercises their right to data portability under the previous paragraph, they have the right to have their personal data transmitted directly from one data controller to another, where technically feasible.

The exercise of the right to data portability is without prejudice to the right to erasure. This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.

The right to data portability does not affect the rights and freedoms of others.

f. Right to Object and Automated Individual Decision-Making

The User has the right to object to the processing of their personal data at any time due to their particular situation, including data automation carried out by Navir SNC. In accordance with Article 21 of the Regulation, Navir SNC will no longer process personal data unless there are compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the User, or for the establishment, exercise, or defense of legal claims.

When personal data is processed for prospecting purposes, the User has the right to object at any time to the processing of personal data concerning them for such prospecting purposes, including profiling to the extent that it is related to such prospecting.

When the data subject objects to processing for prospecting purposes, personal data is no longer processed for these purposes.

g. Right to Lodge a Complaint

The User has the right to lodge a complaint regarding the processing of their personal data by Navir SNC with the Data Protection Authority, competent for the Belgian territory. Further information can be found on the website: https://www.autoriteprotectiondonnees.be.

The User can also lodge a complaint with the court of first instance of their place of residence.

Although this Website may be linked to other websites, we are not, directly or indirectly, implying any approval, association, sponsorship, endorsement, or affiliation with any linked website, unless specifically stated herein.

You should carefully review the legal statements and other conditions of use of any website which you access through a link from this Website. Your linking to any other off-site pages or other websites is at your own risk.

10. Cookies

The website uses cookies to distinguish Users of the Site. This allows providing Users with a better browsing experience and improving the Site and its content. The purposes and methods of cookies are outlined in this article.

a. General Principles

A "Cookie" is a file deposited temporarily or permanently on the User's hard drive when consulting the website, with a view to subsequent connection. Thanks to cookies, the server recognizes the User's computer.

Cookies can also be installed by third parties with whom Navir SNC collaborates.

Some of the cookies used by Navir SNC are necessary for the proper functioning of the Site, while others improve the User's experience.

The User can customize or disable cookies by configuring their browser.

By using the website, the User expressly agrees to the management of cookies as described in this article.

b. Types of Cookies and Purposes

Different types of cookies are used by Navir SNC on the Site:

• Technical cookies: necessary for the operation of the website, allowing the communication of entered data and facilitating User navigation.
• Statistical and audience measurement cookies: used to recognize the User and count the number of Users on the website over a certain period. As they also indicate browsing behavior, they are an effective means to improve the User's navigation by displaying proposals and offers of interest. They also allow Navir SNC to identify possible bugs on the website and correct them.
• Functional cookies: facilitate the use of the website by remembering certain choices (e.g., username or language).
• Tracking cookies: Navir SNC uses tracking cookies via Plausible.io to measure User interaction with the content of the Site and produce anonymous statistics. These statistics allow Navir SNC to improve the website.

c. Cookie Storage Period

Cookies are kept for the time necessary to achieve the intended purpose. The cookies that may be stored on the User's hard drive and their storage period are as follows:

• "ga": 1 year

d. Cookie Management

If the User does not want the website to place cookies on their hard drive, they can easily manage or delete them by modifying their browser settings. Browser settings also allow the User to receive a notice or notification whenever a website uses cookies and decide to accept or reject it.

If the User disables certain cookies, they accept that the website may not function optimally. Some parts of the website may not be usable or may only be partially usable.

If the User wishes to manage and/or delete certain cookies, they can do so using the following link(s):

For Users using browsers:

• Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
• Microsoft Edge: http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq
• Chrome: https://support.google.com/accounts/answer/61416?hl=fr
• Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
• Safari: https://support.apple.com/kb/ph21411?locale=fr_CA

If the User does not want Google Analytics cookies to be used, they are invited to configure their browser accordingly on the following website: http://tools.google.com/dlpage/gaoptout.

11.  Limitation of the Data Controller's Liability

The website may contain links to other websites owned by third parties not affiliated with Navir SNC. The content of these sites and their compliance with the law and regulations are not the responsibility of Navir SNC.

The holder of parental authority must give express consent for minors under 16 to disclose information or personal data on the website. Navir SNC strongly advises individuals exercising parental authority over minors to promote responsible and secure use of the Internet. The Data Controller cannot be held responsible for collecting and processing information and personal data of minors under 16 whose consent is not effectively covered by that of their legal parents or for incorrect data - especially regarding age - entered by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that they are under 16.

Navir SNC is not responsible for the loss, corruption, or theft of personal data caused, in particular, by the presence of viruses or as a result of cyberattacks.

12. Applicable Law and Jurisdiction

This Privacy Policy is exclusively governed by Belgian law. Any dispute will be brought before the courts of the judicial district where the registered office of Navir SNC is located.

13. Contact

For any questions or complaints regarding this Privacy Policy, the User can contact the Data Controller at the following address: info@navir.be.