Privacy Policy

Last updated: 6 March 2024

1. Parties and Purpose

BUREAU D’ÉTUDES PIRNAY SA (the “Company”)

Company Registration Number / VAT Number: BE 0460.645.179
Legal Form: Public Limited Company (SA)
Email: info@bepirnay.be
Telephone: +32 71 33 04 49
Registered Office: Rue du Parc 47, B-6000 Charleroi, Belgium
Place of Business: Rue du Parc 47, B-6000 Charleroi, Belgium

Mr Jean-Sébastien Pirnay hereby establishes this Privacy Policy to inform users, in a transparent manner, of the way in which personal data is collected and processed by BUREAU D’ÉTUDES PIRNAY SA through the website hosted at the following address: lesnuitsducirque.be (the “Website”).

The term “User” refers to any user, whether a natural or legal person, who visits or interacts with the Website in any way.

In this regard, BUREAU D’ÉTUDES PIRNAY SA determines the technical, legal and organisational means and purposes of the processing of Users’ personal data. BUREAU D’ÉTUDES PIRNAY SA undertakes to take all necessary measures to ensure that personal data is processed in accordance with the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data (hereinafter referred to as the “Act”) and Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the General Data Protection Regulation, hereinafter referred to as the “GDPR”).

BUREAU D’ÉTUDES PIRNAY SA is free to appoint any natural or legal person to process Users’ personal data on its behalf and in accordance with its instructions (hereinafter referred to as the “Processor”). Where applicable, BUREAU D’ÉTUDES PIRNAY SA undertakes to select a Processor that provides sufficient guarantees regarding the technical and organisational security measures implemented for the processing of personal data, in accordance with the Act and the GDPR.

2. Processing of Personal Data

Users’ use of the Website may result in the communication of personal data. The processing of such data by Mr Jean-Sébastien Pirnay, in his capacity as Data Controller, or by service providers acting on behalf of and for the account of BUREAU D’ÉTUDES PIRNAY SA, shall comply with the Act and the GDPR.

BUREAU D’ÉTUDES PIRNAY SA shall process personal data in accordance with the purposes set out below.

3. Purposes of Personal Data Processing

In accordance with Article 13 of the GDPR, Users are informed that their personal data may be processed for the following purposes:

      • To call or email you with information that we believe may be of legitimate interest to you or that you have requested.

      • To respond to your enquiries or process the orders you have placed.

      • For commercial purposes, such as data analysis, audits, monitoring and fraud prevention, identifying usage trends, and strengthening, improving or modifying our services.

    • Where we consider it necessary or appropriate: (1) to comply with applicable laws and regulations; (2) to comply with legal proceedings; (3) to respond to requests from public and governmental authorities; (4) to enforce our terms and conditions; (5) to protect our business operations; (6) to protect our rights, privacy, safety or property, and/or those of others; and (7) to pursue available legal remedies or limit any damages we may suffer.


4. Categories of Personal Data That May Be Processed

By visiting and using the Website, the User acknowledges that BUREAU D’ÉTUDES PIRNAY SA may collect and process the following personal data in accordance with the procedures and principles set out in this Privacy Policy:

      • Any personal data you voluntarily provide to us or provide in connection with a contractual relationship, such as your name, billing and delivery addresses, telephone number, email address and payment details.

      • Personal data that may help us contact you in the future, such as your name, company name, address, telephone number and email address, where we consider that there is a legitimate interest for both parties.

      • Personal data contained in contact forms and online surveys that you complete, records of our correspondence and telephone calls, and any other information exchanged when you send, receive or otherwise communicate messages relating to our services.

      • Non-personally identifiable information. This may include the browsers, operating systems and devices used to access our content; information about the countries, cities and languages from which our services are accessed; and information about how and when our services are accessed. The purpose of DiscoVR collecting this non-personal information is to better understand how visitors to DiscoVR use the Website.

    • We and our third-party service providers may also collect information about your visit to our Website. This may include your geographical location, browser and device type, the pages you viewed, the duration of your visit and the search terms you used.


5. Consent

By accessing and using the Website, the User declares that they have read this Privacy Policy and have freely, specifically, knowingly and unambiguously consented to the processing of their personal data. This consent relates to the contents of this Privacy Policy.

Consent is given through a positive action by which the User ticks the checkbox referring to the Privacy Policy via a hyperlink. Such consent is a prerequisite for carrying out certain operations on the Website or for enabling the User to enter into a contractual relationship with BUREAU D’ÉTUDES PIRNAY SA. Any contract between BUREAU D’ÉTUDES PIRNAY SA and a User concerning the services and goods offered on the Website is subject to the User’s acceptance of the Privacy Policy.

The User consents to the Data Controller collecting and processing their personal data, which they provide through the Website or in connection with the services offered by BUREAU D’ÉTUDES PIRNAY SA, in accordance with the procedures and principles set out in this Privacy Policy and for the purposes described above.

The User has the right to withdraw their consent at any time. Withdrawal of consent shall not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

6. Retention Period for Users’ Personal Data

In accordance with Article 13(2) of the GDPR and the Act, the Data Controller shall retain personal data only for as long as is reasonably necessary to fulfil the purposes for which it is processed.

In all cases, the retention period shall be less than three months.

7. Recipients of Data and Disclosure to Third Parties

Personal data may be disclosed to the officers, employees, collaborators, processors or service providers of BUREAU D’ÉTUDES PIRNAY SA who provide appropriate data security guarantees and collaborate with BUREAU D’ÉTUDES PIRNAY SA in connection with the marketing of products or the provision of services. They act under the direct authority of BUREAU D’ÉTUDES PIRNAY SA and may be responsible for collecting, processing or further processing such data.

In all cases, recipients of the data and any parties to whom the data are disclosed must comply with this Privacy Policy. BUREAU D’ÉTUDES PIRNAY SA shall ensure that they process the data solely for the specified purposes and in a confidential and secure manner.

If personal data is to be disclosed to third parties for direct marketing or promotional purposes, the User shall be informed in advance so that they can give their consent to the use of their personal data.

8. Data Protection Officer (DPO)

The following person is appointed as the Data Protection Officer (hereinafter referred to as the “DPO”): Mr Jean-Sébastien Pirnay.

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

The DPO can be contacted at: info@bepirnay.be/en

9. Users’ Rights

Users may exercise their rights at any time by sending an email to info@bepirnay.be/en or by sending a letter by post, together with a copy of their identity card, to the following address:

Rue du Parc 47, B-6000 Charleroi, Belgium

9.1. Right of Access

In accordance with Article 15 of the GDPR, BUREAU D’ÉTUDES PIRNAY SA guarantees Users the right to access their personal data. Users have the right to obtain access to their personal data and to 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, particularly recipients in third countries or international organisations.

      • Where possible, the envisaged retention period for the personal data or, where this is not possible, the criteria used to determine that period.

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


The Data Controller may charge a reasonable fee based on administrative costs for any additional copies requested by the User.

Where the User submits a request electronically, for example by email, the information shall be provided in a commonly used electronic format unless the User requests otherwise.

A copy of the User’s personal data shall be provided no later than one month after receipt of the request.

9.2. Right to Rectification

BUREAU D’ÉTUDES PIRNAY SA guarantees Users the right to have their personal data rectified and erased.

In accordance with Article 16 of the GDPR, incorrect, inaccurate or irrelevant data may be corrected or erased at any time. Users should first make the necessary changes themselves through their user account or the relevant interface, unless this cannot be done independently. In that case, a request may be submitted to info@bepirnay.be/en.

In accordance with Article 19 of the GDPR, the Data Controller shall communicate any rectification of personal data to each recipient to whom the data have been disclosed, unless doing so proves impossible or requires disproportionate effort. Upon request, the Data Controller shall inform the data subject of those recipients.

9.3. Right to Erasure

Users have the right to obtain the erasure of their personal data without undue delay in the circumstances listed in Article 17 of the GDPR.

Where the Data Controller has made personal data public and is required to erase them under the preceding paragraph, the Data Controller shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested the erasure of any links to, copies of or reproductions of those personal data.

The preceding provisions shall not apply to the extent that processing is necessary:

      • For exercising the right to freedom of expression and information.

      • For compliance with a legal obligation requiring processing under Union law or the law of 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 defence of legal claims.


In accordance with Article 19 of the GDPR, the Data Controller shall communicate any erasure of personal data or restriction of processing to each recipient to whom the data have been disclosed, unless doing so proves impossible or requires disproportionate effort. Upon request, the Data Controller shall inform the data subject of those recipients.

9.4. Right to Restriction of Processing

Users have the right to obtain restriction of the processing of their personal data in the circumstances set out in Article 18 of the GDPR.

In accordance with Article 19 of the GDPR, the Data Controller shall communicate any restriction of processing to each recipient to whom the personal data have been disclosed, unless doing so proves impossible or requires disproportionate effort. Upon request, the Data Controller shall inform the data subject of those recipients.

9.5. Right to Data Portability

In accordance with Article 20 of the GDPR, Users have the right to receive the personal data concerning them that they have provided to BUREAU D’ÉTUDES PIRNAY SA in a structured, commonly used and machine-readable format. Users also have the right to transmit those data to another data controller without hindrance from BUREAU D’ÉTUDES PIRNAY SA, where the conditions laid down in the GDPR are met.

When exercising their right to data portability under the preceding paragraph, Users have the right to request that their personal data be 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 shall not adversely affect the rights and freedoms of others.

9.6. Right to Object and Rights Relating to Automated Individual Decision-Making

Users have the right, at any time, to object to the processing of their personal data on grounds relating to their particular situation, including automated processing carried out by BUREAU D’ÉTUDES PIRNAY SA.

In accordance with Article 21 of the GDPR, BUREAU D’ÉTUDES PIRNAY SA shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the User, or where the processing is necessary for the establishment, exercise or defence of legal claims.

Where personal data are processed for direct marketing purposes, Users have the right to object at any time to the processing of their personal data for such purposes, including profiling to the extent that it is related to direct marketing.

Where a data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for those purposes.

10. Right to Lodge a Complaint

Users have the right to lodge a complaint regarding the processing of their personal data by BUREAU D’ÉTUDES PIRNAY SA with the Belgian Data Protection Authority, which is the competent supervisory authority in Belgium.

Further information is available on its website: https://www.autoriteprotectiondonnees.be

Complaints may be submitted to the following address:

Data Protection Authority
Rue de la Presse 35
1000 Brussels, Belgium
Telephone: +32 2 274 48 00
Fax: +32 2 274 48 35
Email: contact@apd-gba.be

Users may also lodge a complaint with the court of first instance having jurisdiction over their place of residence.

11. Limitation of the Data Controller’s Liability

The Website may contain links to other websites owned by third parties that are not affiliated with BUREAU D’ÉTUDES PIRNAY SA. BUREAU D’ÉTUDES PIRNAY SA shall not be responsible for the content of such websites or for their compliance with the Act and the GDPR.

The holder of parental responsibility must give their explicit consent before a minor under the age of 16 may disclose personal information or personal data on the Website. BUREAU D’ÉTUDES PIRNAY SA strongly encourages persons exercising parental responsibility over minors to promote responsible and safe use of the Internet.

The Data Controller cannot be held responsible for collecting and processing personal information or personal data relating to minors under the age of 16 where the necessary consent has not been duly provided by their legal guardians, or for inaccurate information entered by minors, particularly information concerning their age. Under no circumstances shall the Data Controller process personal data where the User indicates that they are under the age of 16.

BUREAU D’ÉTUDES PIRNAY SA shall not be liable for the loss, corruption or theft of personal data, particularly where caused by viruses or cyberattacks.

12. Applicable Law and Jurisdiction

This Privacy Policy shall be governed exclusively by Belgian law. Any dispute shall be brought before the courts of the judicial district in which the registered office in Mons is located.

13. Contact

For any questions or complaints relating to this Privacy Policy, Users may contact the Data Controller at the following email address:

info@bepirnay.be/en

14. Complaints and Data Protection Officer

If Users have any questions or concerns regarding this Privacy Policy, they may email our complaints contact at:

info@bepirnay.be