Politique de confidentialité

Latest update: 29/12/2020


The purpose of this privacy policy is to inform our customers and prospects (referred to as “individuals” or “data subjects” how we collect, use, disclose, store and transfer personal information we are provided by them.

Personal data ("data") is all information on the basis of which you can be identified or on the basis of which you are identifiable, such as your name, your identification number, your location data, an identifier, one or more elements that may be characteristic of your physical, physiological, genetic, psychic, economic, cultural or social identity.

A "processing" is any operation or set of operations using or not using automated processes (manual) and applied to personal data, from its collection to its erasure.

This privacy and cookies policy may be extended or adapted in the future. This is the case if new developments occur in terms of processing performed or in terms of services offered. For this reason, Manalys SA recommends that visitors / users regularly consult this privacy and cookie policy.

Latest update of this policy can be found at any time on our websites (www.manalys.com and www.holemans.com)

1. The controller

The data controller is MANALYS SA with its corporate situated at Boulevard de Waterloo 11, 1000 Brussels and registered at the so-called Belgian Crossroad Bank for companies under number: 0811.901.381. (Hereafter “Manalys”)

Manalys (operating under Manalys and Holemans trade names) is devoting all the attention required to the protection of privacy with regard to the processing of your personal data in accordance with the European Regulation 2016/679 of 27 April 2016 better known as GDPR as well as the Belgian law of July 31, 2018 related to the protection of individuals with regard to the processing of their personal data.

2. Data processed by Manalys (including through cookies)

We are collecting personal data through different manners when you look for information or buy online, remotely or in-store:

Contact forms on our websites or dedicated platforms (such as contest platforms managed by Manalys SA)

  • Interactions via email
  • Interactions via social media
  • Visits in our boutiques
  • Referrals from friends and acquaintances
  • Newsletters

Type of information collected typically covers:

Name, gender, date of birth

  • Mail and e-mail addresses
  • Phone number
  • Passport number (in specific cases)
  • Finger measure (in specific cases)

Functional “Cookies” are used on Manalys’ websites solely to retain language settings, compile statistics on the consultation and to allow us to optimize its use. No information identifying the visitor is collected.

You can disable the use of cookies in your browser.

3. Legal basis and purpose of the processing

Personal data is being collected and processed for the following purposes:

  • Fulfil any of our legal, contractual, or pre-contractual obligations
  • Manage the full lifecycle of the order (from information collection to invoicing and after-sales)
  • Seek views and comments on the services we provide
  • Send promotional information on our products and services
  • Deal with individuals’ inquiries and requests
  • Perform analyses and improve quality of service we provide to our customers
  • Notify users of changes related to our offerings

We may contact individuals through phone, email or postal mail.

We will not sell, rent or release personal data to third parties for them to use for their own direct marketing purposes, unless requested by individuals or required by law (e.g., court order or for the purpose of prevention of fraud or other crime).

4. Data storage and protection

Personal data is kept for as long as:

  • Necessary for the purposes for which they are collected and processed
  • They are relevant to meeting our legal and contractual obligations, and to satisfying our commercial and operational activities

These retention periods will therefore vary according to the type of service provided.

5. Transfer of personal data

Manalys may give access to your personal data to its employees who are contractually bound by a confidentiality obligation.

Manalys may also in certain cases call on subcontractors (processors) whom are bound by an obligation of confidentiality as well as to provide sufficient security guarantees for the processing and who only process your data in accordance with this policy.

If your data is communicated or stored with a subcontractor established in a country which is not a Member State of the European Union, the communication or transfer will only take place if a so-called adequacy decision applies to the country concerned. Manalys also verifies that sufficient contractual guarantees are provided by the subcontractor as to the security of processing.

In the event of reorganization or the total or partial sale of Manalys's activities, or in the event of bankruptcy, one may transfer the personal data it processes to new entities or new third parties carrying out all or part of the professional activities of Manalys.

If applicable, Manalys will make reasonable efforts to inform data subjects before transferring their data to a third party, but data subjects understand that this is not technically or commercially feasible in all situations.

In exceptional cases, Manalys may be compelled to disclose personal data by virtue of a court order or to comply with imperative regulations or legislation.

Manalys does not in any case sell the personal data it processes, nor does it rent databases or make them commercially available to third parties.

6. Technical and organizational security measures adopted by Manalys

Manalys has developed technical and organizational security measures to prevent destruction, loss, falsification, modification, unauthorized access or accidental notification to third parties of your personal data (as well as any other unauthorized processing). These measures include for example:

  • Raising staff awareness of level of confidentiality required
  • Securing physical access to data
  • Protecting against viruses and intrusions

Visitors are solely responsible for the use of the platform and access to their user account from their computer or on the basis of their IP address and their identification data.

Manalys can in no way be held liable for any direct or indirect damage arising from the improper or unlawful use of personal data by a third party.

7. Exercise of rights of data subjects

For all rights mentioned hereafter, Manalys can check the individual’s identity before granting the right. The following requests shall be completed by Manalys within one month after requests being made by the individuals.

In case the action cannot be completed within the month, Manalys must inform the concerned data subject and provide a reasonable deadline for completing the request. Any request should be addressed by email or regular mail (cf. contact details in last section).

Right of access

Individuals may obtain free of charge the written copy of the personal data concerning them that have been collected by Manalys SA. In the event of repeated requests, Manalys SA reserves the right to charge a reasonable fee based on the administrative costs.

Right of rectification

Individuals may obtain free of charge the rectification of their data in case they are inaccurate, incomplete or irrelevant.

Right to erasure

Individuals may obtain free of charge the deletion of personal data concerning them. This right is not an absolute right and does not apply where processing is necessary to comply with a legal or contractual obligation.

Right to limitation of processing

Individuals may obtain the limitation of the processing of their personal data when:

  • Individuals dispute the accuracy of data and Manalys SA needs time to verify the accuracy
  • The processing is unlawful, and the individuals prefer the processing to be limited to deletion
  • Needed by the individuals for establishment, exercise, or defense of their rights in court
  • Examining the validity of an opposition request submitted by individuals

Right to data portability

Individuals have the right to receive their personal data processed by Manalys SA in a structured, commonly used and machine-readable format.

This only concerns the data of which the processing is carried out using automated processes and where the processing is based on the consent or on a contract.

In all cases, the right to erase data shall remain applicable.

Right to object

Individuals have the right to object to certain types of processing of their personal data where this processing is carried out in connection with tasks in the public interest, under official authority, or in the legitimate interests of others.

Individuals have a stronger right to object to processing of their personal data where the processing relates to direct marketing. Where Manalys SA is using individuals’ personal data for the purpose of marketing something directly to them, or profiling them for direct marketing purposes, they can object at any time, and Manalys SA must stop processing as soon as they receive their objection.
In each email communication, a link will be provided in order for customers and prospects to unsubscribe from the distribution list.

Individuals may also object to processing of their personal data for research purposes, unless the processing is necessary for the performance of a task carried out in the public interest.

8. Contact information and complaints

Contact information

For any question and/or complaints, in particular as to the clear and accessible nature of the present Policy, individuals may contact Manalys SA:

  • By email: info@manalys.com
  • By mail: Boulevard de Waterloo, 1 – 1000 Brussels – Belgium


Individuals always have the right to file a complaint with the supervisory authority if they believe that the processing of their personal data by Manalys SA infringes the GDPR.

The Supervisory Authority is the Data Protection Authority, Drukpersstraat 35, 1000 Brussels, Tel +32 (0) 2 274 48 00, website: www.dataprotectionauthority.be

A complaint to the data protection authority does not prejudice the initiation (if any) of proceedings before a civil court (in the event of damage suffered as a result of a violation of the rights of the data subject).

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