Version: June 2025

1. Introduction and Scope.

This Privacy Policy applies to processing of personal data on our websites, social media channels and in the context of the services offered by e-Bo Enterprises NV, with registered office in Belgium at Stoppelweg, 44 , B-8978, Poperinge, with company number 0470.174.242, RPR. Ghent – Ypres Branch.

e-Bo Enterprises NV and affiliates together form “e-BO Enterprises Group of companies”, abbreviated as “e-BO Group” with headquarters located at 8900 Ypres, Ter Waarde 60, (hereinafter referred to as “we” or “us” or “e-BO Group”). e-BO Enterprises NV may also share personal data with another member of the e-BO Group or affiliates.

This Privacy Policy may be amended or updated from time to time.

We therefore kindly ask you to regularly consult this Privacy Policy on our websites to ensure that you always have the most recent version.

Questions regarding applicable law and this Privacy Policy may be directed to our Data Protection Officer (“DPO”) at .privacy@ebo-enterprises.com

2. Processing responsible and data protection.

We ensure the confidential processing of your personal data in accordance with the General Data Protection Regulation, in short “AVG” or “GDPR”.

Within e-BO Group, your data will only be shared with authorized personnel (internal recipients) or a verified/authorized third party.

Our employees or internal contractors may have access to your personal data on a strictly necessary basis, which is usually determined and limited by the function, role and department of the respective employee.

e-BO Group guarantees a quality and high level of data and data security, and this by taking all necessary & reasonable contractual, technical and organizational measures.

We strive to evaluate these measures at regular intervals and adjust them if necessary. e-BO GROUP is ISO 27001 certified.

3. Purposes of data processing

e-BO Group processes personal data in its capacity as Processor, only for clearly defined, justified and legitimate purposes, in accordance with Article 5, paragraph 1, b) and c) of the General Data Protection Regulation (AVG or GDPR).

The processing is done in the regular operation of e-BO Group and is limited to the internal purposes listed below:

(a) Human Resources (HR).

• Management of personnel files (e.g. employment contracts, payroll, evaluations);
• Recruitment and selection (including screening and contact with applicants);
• Absence management and well-being at work;
• Access control and timekeeping (if applicable).

(b) Marketing and communications.

• Sending newsletters, product information, event invitations and other commercial communications to existing customers and contacts based on legitimate interest or consent;
• Management of contacts in CRM systems;
• Analysis of marketing effectiveness (e.g. click rates, open rates).

(c) Legal and contractual purposes.

• Compliance with legal obligations (such as tax and social legislation);
• Management of contracts and supplier relationships;
• Handling of disputes, complaints or legal proceedings.

d) Security and IT purposes.

• Management of access rights to digital platforms or buildings;
• Monitoring IT systems for security and audit purposes;
• Logging of usage (e.g., login activity, access logs) to ensure data integrity and availability.

4. Minimal data processing.

e-BO Group processes only those personal data that are adequate, relevant and limited to what is necessary for the purposes for which they are collected and processed, in accordance with Article 5(1)(c) GDPR.

For most purposes, this concerns only:

• Basic identification data: name, first name, position, company;
• Contact data: professional email address, phone number;
• Communication data: content of emails, responses to communications;
• Other data (such as identification numbers, evaluation data, etc.) only if functionally required.

5. Usage for other purposes

If e-BO Group intends to process personal data for a purpose other than that originally envisaged, the involved party will be transparently informed in advance, in accordance with Articles 13(3) and 14(4) GDPR.

In cases where required, prior explicit consent will be requested in advance.

6. Use of cookies

Cookies are small text files that can be stored on your computer or mobile devices when visiting websites.

A text file stores information, such as your language preference for a website. When you visit the website again later, this cookie is sent to the website again. That way, the website recognizes your browser and can remember, for example, your language preference.

Below is a list of the types of cookies and their purposes.

Essential or strictly necessary cookies
These cookies enable users to navigate the Website and use its essential functions. These cookies also ensure that a service or functionality expressly requested by the user can be provided. These cookies may be set without your consent. We additionally recommend that you do not disable these cookies given you may thereby lose basic Website functionality or access to certain areas of the Website.

Functional cookies
These cookies allow the Website to function properly and ensure faster and more efficient use. These cookies can be set without your consent.

Analysis or statistical cookies
These cookies collect data about the use of the Website such as the number of visitors, the time visitors spend on a web page and error messages, give us information about user traffic on our Website, e.g. how users get to the Website and whether there are navigation problems. We ask for your permission before setting these cookies.

Advertising or Targeting cookies.
First-party Advertising cookies placed by e-BO Enterprises on the Website, allow the Website to send personalized advertising messages. We ask for your permission before setting these cookies.

Please be aware that 3rd-party advertisers and tech giants (such as Google, Amazon, Adobe) seek your consent for transfers of your personal data outside the EU via their own privacy policies.

Social media cookies

Social media, with “tracking cookies,” tracks users’ browsing behavior across sites. Social media places a cookie while you visit site A and can read the cookie again when you visit site B. This allows Social media to profile and send you targeted advertising.

Please be aware that most Social media providers are US-based companies, which, through their own privacy policies, seek your consent for transfers of your personal data outside the EU.

These third parties may have access to specific cookie information (such as your userID, name, first name, email address, pages visited, banners clicked, etc.), e.g. in order to provide you with personalized ads or to collect your feedback.

Certain cookies are placed on the Website of e-BO Enterprises by social networking services such as Facebook, Twitter and LinkedIn. This is done through the buttons of these social networks that may be offered on the Website of e-BO Enterprises. If you use these, these third parties may receive certain cookie information, but they will only be activated if you accept those cookies.

Cookies may be stored on your computer or mobile device for varying lengths of time. Depending on the type of cookie, they (and the information they collect) are automatically deleted when you close your browser (these are the so-called “session cookies”), in other cases these cookies are stored for a longer period of time and can also be used during a subsequent visit to this Website (these are the so-called “persistent cookies”).

Performance cookies

These cookies allow us to count visitors and their origins so that we can analyze and improve the performance of our Website. They help us understand which pages are most and least popular and how visitors move throughout the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site.

Targeted cookies

These cookies may be set by our advertisers on our website. They may be used by those companies to compile a profile of your interests and show you relevant ads on other websites. They do not store personal information directly, but they are based on unique identifiers from your browser and Internet device. If you do not allow these cookies, you will see fewer ads targeted to you.

Cookie Settings 

Through our cookie preference settings, you can set your preferences and determine whether to reject or accept certain cookies.

How you can do this varies from browser to browser: most browsers automatically accept cookies, but you can set your browser to warn you before a cookie is set or to refuse cookies. More information on how to set your browser can be found via the ‘Help’ button on your browser or via the following links: Through the links below you can find more explanation on how to do this.

Are you using a different browser? Check if the procedure for your browser is included on the website www.allaboutcookies.org/manage-cookies. This website exists only in English.

If you use different devices to visit our Website, please ensure that your cookie preference is set on each device’s browser. In addition, https://www.youronlinechoices.com allows you to choose which companies you no longer wish to receive cookies from.

7. Processing of your personal data via social media channels

For platforms such as Facebook, LinkedIn, Instagram, Twitter and YouTube, e-BO Group is a joint processing controller together with the platform operator (in accordance with Article 26 AVG).

For the respective processing purposes and data categories, please refer to the individual social media channels.

We exclusively use anonymized statistical data via Insights or Analytics services, without access to individual profiles.

Details are available in the joint controller agreements of each platform.

Unless explicitly stated otherwise, the legal basis for the processing is our legitimate interest (AVG Art 6 Par. 1 f).

8. Rights of involved party   

You have the right to access, correct, delete, restrict processing, transferability and object to the processing of your personal data.

If we request consent for processing, you may withdraw such consent at any time.

The withdrawal of consent does not affect the lawfulness of processing based on consent prior to the withdrawal.

If you wish to exercise any of the above rights, please contact us at any time at the following email address: privacy@ebo-enterprises.com

In order to process your request quickly and correctly, we ask that you be as specific as possible when addressing your request. If there is any doubt about the identity of the applicant, additional information will be requested to establish it.

e-BO Group has the right to refuse your requests if they are “manifestly unfounded or excessive” (in particular because of their repetitive nature) or to charge a reasonable fee of 60 Euro excl.

9. Transfer to third parties and processing of data outside the EU   

We use subcontractors to assist us in providing services that may process personal data on our behalf.

We ensure that the selection of our subcontractors and any processing of personal data by them complies with the AVG.

e-BO GROUP uses the following categories of subcontractors to provide services : hosting services, data center services, suppliers of standard software solutions (such as Microsoft, Google); providers of marketing and analytics software and operators, and other software services. We have processing agreements with these parties.

e-BO GROUP does not share your personal data with third parties, except to third parties in connection with the performance of its services, and only if this is necessary for technical support or if it is required to do so by a statutory provision or court order.

These third parties may only process your personal data on our behalf and with our express written consent and in accordance with the purposes outlined above. We ensure that all third parties acting as processors or sub-processors are carefully selected and required to maintain the security, confidentiality and integrity of your personal data.

We strive to have all cloud services and servers in the EU. However, some of our subcontractors or the aforementioned recipients of personal data may be located outside the EU or their servers may be located outside the EU. Any transfer of personal data outside the EU is done by us only under strict compliance with the AVG. We ensure that the external recipients in non-eligible countries have entered into the EU Model Contractual Clauses (EU SCC) with us or ensure equivalent safeguards.

10. Data retention and security

e-BO Group retains your personal data for a period necessary for the performance of the contract and in function of the purposes of processing, as described above.

Due to this legal obligation but also due to technical and financial aspects of data storage, we actively delete data where it is no longer needed.

Retention periods are either provided for in the respective laws, data processing agreements, instructions from data controllers, respectively customers or are set out by us in our internal policies.

If the processing of your personal data is based on consent and you decide to withdraw your consent, we will not further process your personal data for the specific purpose.

All retention periods regarding personal data we process on behalf of our clients are determined by our clients. We can only retain such personal data during the term of our data processing agreement, after which we must return or delete all personal data relating to customer data subjects. However, we may delete personal data even earlier if the customer instructs us to do so, for example, if the customer no longer considers the storage of such data necessary for the specified purpose.

11. Complaints and Monitoring 

If you have questions or complaints about the way we process your personal data, you can always contact us at the following e-mail address: privacy@ebo-enterprises.com

In addition, you always have the possibility to file a complaint with the Data Protection Authority: Rue du Printing Press 35, 1000 BRUSSELS, e-mail: contact@apd-gba.be