BrightChoice BV

Rue de l'Université 26, 4000 Liège 1020 098 322

info@toward.be

VAT number: BE 1020.098.322  

Each visit to this Toward Insurance website is subject to these Terms and Conditions. By his or her visit to the website, the user tacitly agrees to the applicability of the General Terms and Conditions, whether it is a free visit to the website or a visit for which payment is made to Toward in some way.

Toward Insurance strives to ensure that the information on its website is up-to-date, reliable and complete. Consultation and use of the website is at the visitor's risk. Toward provides no guarantee as to the correctness, completeness and accuracy of the information on its website, whether gathered by Toward itself or provided by third parties. Consequently, Toward is not liable for damages of any kind, direct or indirect, suffered by the visitor when visiting this website. Nor is it liable for telecommunications costs higher than expected or usual, and this regardless of the medium used by the visitor. Toward is not liable for any network failures, interruptions or errors. It reserves the right, at any time and without any prior notice, to optimize or modify the construction, content of its services and/or website. A temporary delay or unavailability cannot give rise to any damages or other financial compensation.

The information provided on this website regarding prices, investments, trends, forecasts corresponds to the highest professional standards. It is provided solely for information purposes and can under no circumstances be regarded as investment advice. Consequently, we can never be held liable for any damage which you might suffer as a result of a decision which you might (partly) take on the basis of this information.

Toward is not responsible for any decision or action allegedly taken by the user on the basis of the information or data provided; nor is it responsible for errors or mistakes; nor is it responsible v.a. the user or third parties for any direct, indirect, incidental damage, loss of profit, loss of opportunity or for any damage caused by its negligence or omission in providing, compiling, assembling, writing, interpreting, reporting and distributing information or data by means of this service, even if it has been warned of such damage. 

The websites contain multiple links to third-party websites. This does not necessarily mean that Toward recommends, endorses or cooperates in any way with these websites. Nor does Toward make any warranty as to the suitability, accuracy or completeness of these websites. Toward can never be held responsible for damages in the context of visiting these websites.

Toward Insurance grants the user a temporary, non-exclusive and non-transferable license with respect to the content of this site. This also applies if the User obtains access to paid portions or services of the website through a login provided by a third party, such as his/her employer. In the latter case, the user also undertakes to comply with the terms of use agreed with this third party.

This license to the content and the assigned login may not be shared with other persons or exercised simultaneously on different equipment. The license is not transferable to third parties except with Toward's prior and written consent.

You have the right to use our website for private purposes. Commercial use (such as the use of (parts of) the website to obtain advertising revenue, the (partial) copying of content) is prohibited. You may not obstruct the normal operation of our website, and undertake to observe the following rules of conduct on our website:

(1) Not infringe upon the intellectual property rights of Toward or the authors, broadly defined, who post works on our website;

(2) Not engage in any acts that interfere with other visitors' use of this website;

(3) Not spread spam or other inappropriate messages or information through our website;

(4) Not spread viruses or other malware;

(5) Not use or install adblockers, or otherwise exclude advertising or content from our website. You agree that Toward has the right to install a script that detects adblockers.

(6) Do not circumvent or interfere with the security of this website;

(7) Do not use means for searching or indexing (parts of) this website, such as robots or spiders, among others (except if the visitor is a search engine);

In case of non-compliance with one or more of these rules of conduct, we reserve the right to deny you access to our website.

The information and services provided on the website, as well as any software useful for its use are protected by (intellectual) property rights, which belong exclusively to Toward. Full or partial reproduction, distribution, sale, publication, adaptation, translation, editing or use for commercial purposes in any manner is expressly prohibited. Exceptions may only be granted with Toward's prior written consent.

Storing information from the website in a database is expressly prohibited, with the exception of automatic 'caching' of the information by the browser. You may, however, use or reproduce our articles as a private individual for strictly personal use without our permission.

For more information about this, please visit http://www.license2publish.be/

All disputes arising from your visit to the website and the use you make of our services shall be submitted exclusively to the Courts of Liège for resolution.

This privacy policy (the Privacy Policy) has been drawn up by BrightChoice BV, with registered office at Rue de l'Université 26, 4000 Liège, registered in the Crossroads Bank for Enterprises under number 1020 098 322 (hereinafter referred to as the “Controller”).

In this document, we explain how we collect, process and use your personal data. It constitutes the office's general policy on data processing in accordance with applicable legislation, including the General Data Protection Regulation (GDPR).

As an insurance broker, the office may fulfill a dual role in the field of data processing. In that case, we are  both controller and processor. We assume the role of controller when we process data in our own name and for our own account. In addition,  we also fulfill the role of processor on behalf of  the companies. This means that we also collect and process personal data for the insurance companies with whom we work and whose products we present and offer to you. In this statement, we will only discuss the processing of your data in more detail as the data controller.

The Privacy Policy is an expression of the intention of the Data Controller to act in a fully transparent manner, in accordance with the Act of December 8, 1992, on the protection of privacy with regard to the processing of personal data and in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter referred to as the “General Data Protection Regulation”).

The Controller pays particular attention to protecting the privacy of its users and therefore undertakes to take all necessary and reasonable measures to protect the personal data of these persons against loss, theft, distribution or unauthorized use.

“Personal data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly.

If the user wishes to respond to one of the provisions listed below, they can contact the Controller at the postal address or email address shown in the “contact details” section of the Privacy Policy. 

The Controller collects and processes the following personal data in accordance with the modalities and principles described below:

• the user's domain (automatically picked up by the server of the Controller), including the dynamic IP address;
  
• the user's e-mail address if the user has entered it beforehand, for example by posting messages or asking questions on the Website, by communicating with the Controller via e-mail, by participating in discussion forums, by identifying oneself in order to gain access to a limited part of the Website, etc.;
  
• all information relating to the pages visited by the user on the Website;
  
• all information that the user has voluntarily provided, for example in the context of surveys and/or registration on the Website, or by identifying themselves to gain access to a limited part of the Website.
• All data that you provide to us as a result of contacting the office, such as your name, address, e-mail address and professional data, such as company name and VAT number. This also includes all data necessary to enable us to assess your insurance needs. This includes information about your home (in the context of fire insurance), your financial information (for investment insurance) and medical information (for health insurance).

The Controller may also collect data that is not of a personal nature. This data is qualified as non-personal data and does not allow a particular person to be directly or indirectly identified. This data can therefore be used for any purpose, for example to improve the Website, to improve the products and services offered or to improve publications of the Processing Manager.

In the event that personal data is combined with data of a non-personal nature, making it possible to identify the persons involved, this data will be processed as personal data until the persons involved can no longer be identified based on the data in question, because the link between the personal data and non-personal data has been severed.

The firm collects and processes data about you when you contact us for advice on insurance contracts, the offering or proposing of insurance contracts, the carrying out of preparatory work with a view to  concluding insurance contracts and the conclusion of insurance contracts themselves.

In addition, you can also call on us or contact us for assistance in the management and execution of the insurance contracts you have taken out. For example, in the event of a claim.

Even if you contact us in any other way, we will (have to) process your data.

When filling in documents and forms, both manually and electronically.

When you visit our website, via one or more cookie(s),  along data found on the web.

Finally, it is also possible that we obtain information about you via third parties and use this information to contact you to conclude an agreement through our mediation. 

Personal data is collected and processed for the following purposes:

• to guarantee management and control with regard to the execution of the services offered. This includes: the management and conclusion of insurance contracts and the promotion of other products and services from our office, as well as the management of claims;
  
• to send promotional material;
  
• answering questions from users;
• generating statistics;
• improving the quality of the website and the products and/or services;
• forwarding information regarding new products and/or services or changes in products or legislation;
• commercial prospecting, based on our legitimate interest in entrepreneurship;
  
• to allow the user's interests to be better identified;
• to maintain operations with our suppliers based on the contractual relationship we have or will have with them;
• to manage our personnel and payroll.
  

The Controller may be required to carry out processing operations that are not yet included in this Privacy Policy. In such cases, the Controller will contact the user before using their personal data in order to inform them of the changes and, where appropriate, to give them the opportunity to refuse such use.

Certain processing operations by the Controller are based on the legal basis of his legitimate interest. These legitimate interests are proportional to the respect of the user's rights and freedoms.  During prospecting, you will be given the opportunity to unsubscribe and thus not be contacted in the future, or you can contact us so that we can take the necessary action or provide you with the necessary information (see “contact details” in this Privacy Policy). 

In principle, we collect and process your data based on the contractual relationship we have with you as a result of your application or request in connection with an insurance need and the resulting agreement(s), as well as as a result of the request to assist you in the management and follow-up of the insurance agreements you have concluded.

Where the processing is not necessary to execute the contractual relationship, it is based on our legitimate interests as a company, in particular the freedom of enterprise and information. In doing so, we always ensure that there is a balance between our interests and yours, for example by granting you the right to object.

Insofar as health data or so-called sensitive data are concerned, we can only process your personal data with your explicit consent. You will be asked for this consent when you become a customer. If this has not happened, we kindly request that you inform us so that we can take the necessary steps. 

Your data will be processed primarily internally. This does not alter the fact that they must be communicated to the insurance company with whom you ultimately conclude the agreement.

It is possible that we may call on third parties for certain specific services. In such cases, your data may be provided to these third parties, but only for the service in question and always under the control of our office.

In certain cases, there is a legal obligation to transfer certain data. This is particularly the case when we are legally obliged to do so or when government agencies have the right to request data from us.

In principle, your data will not be passed on to third countries or international organizations. 

In general, the Controller only stores personal data for the period that is reasonably necessary to achieve the stated objectives and in accordance with the legal and regulatory requirements.

A customer's personal data will be stored for a maximum of 10 years after termination of the contractual relationship that binds the customer to the Controller.

At the end of the retention period, the Controller will make every effort to ensure that the personal data has been made unavailable and inaccessible. 

With regard to all the rights mentioned below, the Controller reserves the right to verify the identity of the person concerned. This is to prevent your data from being communicated to someone who is not entitled to it.

This additional information will be requested by the person concerned within a period of one month after the request. 

The user can obtain his written correspondence or a copy of his personal data that was processed by the Controller free of charge.

The Controller can require the user to pay all reasonable costs, based on the administrative costs for each additional copy requested by the user.

As soon as the user submits this request electronically, the information will also be delivered electronically, unless the user requests otherwise.

Unless otherwise stipulated in the General Data Protection Regulation, the copy of his data will be communicated to the data subject no later than one month after receipt of his request. 

The user may request the correction of his or her personal data free of charge if they contain errors or are incomplete or irrelevant, and may also request that his or her data be supplemented if they prove to be incomplete.

Unless otherwise stipulated in the General Data Protection Regulation, the request will be processed within one month of its submission. 

The user can, at any time, for reasons relating to his or her personal situation, object to the processing of his or her personal data free of charge:

• when the processing is necessary for the fulfillment of a task of general interest or for a task in the context of the exercise of public authority;
  
• when the processing is necessary for the representation of the legitimate interests of the Controller, provided that the interests or the fundamental rights and freedoms of the data subject do not prevail over that interest (in particular when the data subject is a child).

The Controller may refuse to implement the user's objection if it establishes the existence of compelling and legitimate grounds justifying the processing that take precedence over the interests or the rights and freedoms of the user, or if it is used for legal challenges, to mount a legal defense or to exercise rights. In the event of a dispute, the user may appeal in accordance with the provisions of the “objections and complaints” section of the Privacy Policy.

The user may, at any time, without justification and free of charge, object to the processing of his or her personal data if this data was collected for the purpose of commercial prospecting (including profiling). You can report this via our contact details or by checking a box in the information provided to you on specific occasions.

If the personal data is used in the context of scientific or historical research or for statistical purposes in accordance with the General Data Protection Regulation, the user has the right to object to the processing of his or her personal data for reasons relating to his or her personal situation, unless the processing is necessary for the performance of a task carried out in the exercise of official authority.

Unless otherwise stipulated in the General Data Protection Regulation, the Controller is obliged to respond to the user's request within a reasonable period of time and no later than within one month, and must give reasons for his response if he does not intend to comply with the user's request. 

The user can obtain the restriction of the processing of his personal data in the following cases:

• when the user disputes the accuracy of a piece of data and only for the period that the Controller needs to verify this;
  
• when the use is unauthorized or when the user prefers the restriction of the operation over the erasure of the data;
• when the user needs this restriction for a dispute, exercise or defense in court, although this is no longer necessary for the continuation of the purposes of the
• during the period necessary to investigate the merits of an opposition request, in other words, the period that the Controller needs to weigh the legitimate interests of the Controller against those of the user.
  

The controller will inform the user as soon as the restriction is lifted. 

The user can obtain the deletion of his personal data if one of the following motives applies:

• the data is no longer necessary with regard to the purposes of the processing;
  
• the user has withdrawn his consent for the processing of his data and there is no legal basis for further processing;
• the user objects to the processing and there is no compelling legitimate reason for further processing and/or the user exercises his or her special right to object with regard to direct marketing purposes (including profiling);
• the personal data has been the subject of unauthorized use;
  
• the personal data must be erased in order to comply with a legal obligation (under European Union law or the law of a Member State) to which the Controller is subject;
• the personal data was collected in the context of an offer of services aimed at children.

However, the erasure of the data does not apply in the following cases:

• as soon as the processing is necessary for the exercise of the right to freedom of expression and the right to information;
• as soon as the processing is necessary to comply with a legal provision that requires processing as provided for by European Union law or by the law of one of the Member States to which the Controller is subject, or when the processing is necessary for the fulfillment of a task of general interest or for a task in the context of the exercise of public authority;
• as soon as the processing is necessary for reasons of public interest in the field of public health;
  
• as soon as the processing is necessary for archiving purposes in the public interest, for scientific or historical research or for statistical purposes, and on condition that the right to erasure may render impossible the realization of the purposes of the processing or may seriously impair the behavior;
  
• as soon as the processing is necessary for the establishment, exercise or defense of legal claims.
  

Unless otherwise stipulated in the General Data Protection Regulation, the Controller is obliged to respond to the user's request for erasure within a reasonable period of time and at the latest within one month, and must state the reasons for his response if he does not intend to comply with the user's request. 

The user can at any time request to obtain his personal data free of charge in a structured and commonly used machine-readable format with a view to transferring it to another controller:

• if the data processing is carried out using automated processes; and
• if the processing is based on the user's consent or on an agreement concluded between the latter and the Controller.
  

Under the same conditions and following the same modalities, the user also has the right to demand from the controller that the personal data relating to him or her be transferred directly to another controller, insofar as this is technically feasible.

The right to data portability does not apply to processing that is necessary for a task in the public interest or that is part of the exercise of official authority that has been assigned to the Controller. 

The recipients of the collected and processed data are, in addition to the Controller itself, the staff members or other subcontractors, the carefully selected commercial partners, located in Belgium or the European Union, who collaborate with the Controller in the context of the commercialization of the products or the provision of services.

In the event that the data is disclosed to third parties for direct marketing or commercial canvassing purposes, the user shall be informed in advance to enable him or her to decide whether or not to consent to the processing of his or her data by third parties.

Given that this transfer is based on the user's consent, the latter may withdraw his or her consent at any time.

The controller complies with all applicable legal and regulatory provisions and shall in any event ensure that its partners, employees, subcontractors and other third parties with access to personal data comply with this Privacy Policy.

The Controller reserves the right to disclose the user's personal data if a law, legal proceedings or an order by a public authority requires such disclosure.

The Controller will not transfer any personal data outside the European Union. 

The Controller shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk represented by the processing and the nature of the personal data to be protected, in order to protect the personal data collected. The Controller shall take into account the state of the art, the costs of the implementation and the nature, scope, context and purpose of the processing, as well as the risk to the rights and freedoms of users.

When the Controller receives or sends data on the Website, it always uses encryption technology that is recognized within the IT sector as being the industrial standard.

The Controller has taken the necessary security measures to protect the information obtained via the Website and to prevent its loss, misuse or alteration.

In the event that the personal data processed by the Controller is breached, the Controller shall act swiftly to determine the cause and remedy the situation.

The Controller will inform the user of this when the law requires him to do so.

The user can submit an objection to the Belgian Data Protection Authority at the following address: Drukpersstraat, 35, 1000 Brussels. Tel. + 32 2 274 48 00. Fax. + 32 2 274 48 35, contact@apd-gba.be.

Users can also submit a complaint to the competent courts. 

For any questions and/or complaints, particularly with regard to the clarity and accessibility of the Privacy Policy, the user can contact the Controller:

By e-mail: info@towardinsurance.be

By post: BrightChoice BV, Rue de l'Université 26, 4000 Liège.

For questions that go beyond a simple request for information, we may ask you to identify yourself so that we can be sure that we provide the requested information and data to the right person. 

This privacy policy is subject to Belgian law.

In the event of a dispute regarding the validity, interpretation, implementation or termination of the privacy policy, the parties agree to initiate a mediation procedure before proceeding to any other form of dispute resolution.

Where appropriate, the parties shall consult with each other to appoint a recognized mediator from the Federal Mediation Commission (Simon Bolivarlaan 30 (WTC III), 1000 Brussels - https://www.fbc-cfm.be/nl) or have a third party appoint this recognized mediator.

Once a mediator has been appointed, the parties will establish the modalities of the mediation together with the mediator.

Each party may terminate the mediation procedure at any time, without prejudice to any other rights.

In the event that the mediation procedure fails, the courts of the following judicial district shall have jurisdiction: Liège. 

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