1. General This privacy policy (“Privacy Policy”) governs the processing of your personal data as part of your use of our website (the “Website”) and the services associated with it (collectively, the “Services”). This processing is carried out by Bossenstein as controller, with its registered office at Oelegemsesteenweg 37E, 2520 Broechem (“we”, “us”),BE 0431.549.733, in accordance with applicable legislation on the protection of personal data. By using our Website and/or our Services, you acknowledge that you have carefully read this Privacy Policy and that you agree to it without reservation. We reserve the right to modify the Privacy Policy from time to time in our sole discretion. Any such changes will be communicated through the Website. By clicking on the privacy opt-in checkbox on forms on the Website, you acknowledge that you have indeed read and agree to this Privacy Policy. You declare that you understand the purposes for which your personal data is processed. You also agree that your continued use shall be construed as continued consent. You may withdraw your consent at any time by sending a request to golf@bossenstein.be. Please note that we may use so-called “cookies” or similar technology as part of the Website and/or the Services. Cookies are small text files placed on a device’s hard drive containing certain information, sometimes including personal data. For more information regarding our use of cookies, please read our Cookie Policy (https://stefc65.sg-host.com/cookie-policy/). This Privacy Policy was last updated on 01/06/2022. 2. What & why we process data When you use the Website and/or Services, we process personal data relating to you. Such personal data includes:

When	What	Why (purpose)	Legal Basis
Use of Website	Personal identification	data Customer management Application procedures	Justified interest
Use of Services		Direct marketing	Consent (if any)
Applying for a job
Applying for a job
Contacting us

In principle, we obtain the personal data mentioned above directly from you. We do not forward any of the personal data you provide through the Website to social media providers unless you consent. In addition to the above purposes, we may also process your personal data: To provide you with the information on products and services you request in a personalised and efficient manner, whether through the Website, email, telephone or social media channels. To process your personal data so that we can provide the Services. For direct marketing purposes, i.e. to provide you with targeted communications, promotions, offers and other advertisements from us or our selected partners. For this, we will ask your prior consent. To perform statistical analysis to improve our Website and/or Services, or to develop new products or services. To provide to a financial institution or payment service provider, to enable your financial institution and the payment service provider to fulfil their legal obligations. To transfer to the police or judicial authorities as evidence of possible crimes or if there is reasonable suspicion of an unlawful act or crime committed by you through your registration with or use of the Website or the Services. In the context of a possible merger with, acquisition of/by or demerger by a third party, even if that third party is located outside the EEA (European Economic Area). If and when your registration on the Website or use of the Website or Services may be considered (a) a violation of the terms or conditions or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Services, (c) a threat to the Website or Services or our or our subcontractors’ systems from viruses, Trojan horses, spyware, malware, or any other form of malicious code, or (d) in any way illegal or unlawful, discriminatory or offensive, we may process your data in the interests of ourselves, our partners or third parties. With whom we share data We do not transfer your personal data in an identifiable manner to third parties if this is not required to provide the Services, without your express consent. We may use third party processors to provide you with the Website and/or Services. We ensure that third party processors may only process your personal data on our behalf, and upon written instructions from us. We guarantee that all third party processors are selected with due care to ensure the security and integrity of your personal data. We may transfer anonymised and/or aggregated data to other organisations that can use this data to improve products and services and to organise the marketing, presentation and sale of products and services in a tailored way.

Which	Country outside EER	Legal transmission mechanism
HubSpot	USA	EU – US Privacy Shield
Facebook	USA	EU – US Privacy Shield
Google	USA	EU – US Privacy Shield

How we process data We will use our best efforts to only process personal data that is necessary to achieve the purposes set out in this Privacy Policy. We will process your personal data in a lawful, fair and transparent manner. We will do our utmost to keep the personal data accurate and up to date. Your personal data will only be processed as long as necessary to fulfil the purposes set out in this Privacy Policy or until you withdraw your consent to its processing. Please note that withdrawal of consent may imply that you are no longer able to use all or part of the Website and/or Services. If you have registered with our Website, we will delete your personal data when you delete your profile, unless a legal or regulatory obligation or a court or administrative order would prevent us from doing so. We will take appropriate technical and organisational measures to keep your personal data secure against unauthorised access or theft and against accidental loss, manipulation or destruction. Access by our staff or staff of our external processors is only possible on a need-to-know basis and is subject to strict confidentiality obligations. You understand, however, that the care for safety and security are only best efforts obligations that can never be guaranteed. Your Rights You have the right to request access to all personal data that we process about you. However, requests for access which are manifestly made for the purpose of causing inconvenience or damage to us will not be entertained. You have the right to request that any personal data about you that is incorrect or inaccurate be corrected free of charge. If you have registered on our Website, you can correct many of these details yourself via your profile. If such a request is made, you must also include with it evidence that the personal data for which correction is requested is incorrect. You have the right to withdraw your previously given consent to the processing of your personal data. You can withdraw your consent at any time by sending an email to [email] or by deleting your profile (if applicable). You have the right to request that personal data relating to you be deleted if it is no longer necessary in view of the purposes set out in this Privacy Policy or if you withdraw your consent to its processing. However, you should note that a request for deletion will be assessed by us in the If you wish to make a request to exercise one or more of the rights mentioned above, please send an e-mail to golf@bossenstein.be. This request must clearly state which right you wish to exercise and why. It must also be dated and signed, and be accompanied by a digitally scanned copy of your valid identity card proving your identity. We will immediately inform you of the receipt of such a request. If the request proves to be justified, we will comply with it as soon as reasonably possible and no later than thirty (30) days after receipt of the request. If you have a complaint about the processing of your personal data by us, you can always contact us at the e-mail address golf@bossenstein.be. If you remain dissatisfied with our response, you are free to submit a complaint to the competent data protection authority, the Commission for the Protection of Privacy (CBPL). For more information, please visit http://www.privacycommission.be.