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Privacy Policy

Last updated: 13 September 2026

 

1. Introduction

Procomma BV (“Procomma”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how Procomma processes personal data when you:

  • visit our website www.procomma.be;

  • contact us through our website;

  • request information about our services;

  • book a meeting with us through our meeting-booking service;

  • communicate with us by email or telephone; or

  • otherwise interact with us in the context of our professional activities.

Procomma provides procurement and purchasing consultancy services exclusively to businesses and professional clients.

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Belgian data-protection legislation.

 

2. Who is responsible for your personal data?

The controller responsible for the processing of your personal data is:

Procomma BV
Doofmeer 15
1840 Londerzeel
Belgium

Enterprise number / VAT number: BE 0675.834.533
Email: bert@procomma.be
Telephone: +32 495 23 17 62
Website: www.procomma.be

For questions regarding this Privacy Policy or the processing of your personal data, you can contact us at bert@procomma.be.

Based on the current nature and scale of our activities, we have not appointed a Data Protection Officer (“DPO”). If this changes, this Privacy Policy will be updated accordingly.

 

3. What personal data do we collect?

Depending on how you interact with Procomma, we may process the following categories of personal data.

 

3.1 Information you provide through our contact form

When you contact us through the Website, we may collect:

  • your name;

  • your email address;

  • the content of your message;

  • any other information you voluntarily include in your message.

Please do not provide sensitive or unnecessary personal information through the contact form.

 

3.2 Information provided when booking a meeting

When you book a meeting with Procomma, we use Calendly as a meeting-scheduling service.

Depending on the information requested through the booking interface, this may include:

  • your name;

  • your professional email address;

  • meeting date and time;

  • organisation or company information;

  • information you voluntarily provide in connection with the meeting;

  • technical information required to operate the scheduling service.

Calendly may process information in accordance with its own privacy documentation and terms.

 

3.3 Technical information

When you visit our Website, certain technical information may be processed automatically as part of operating, securing and maintaining the Website.

This may include information such as:

  • IP address;

  • browser and device information;

  • operating system;

  • date and time of access;

  • pages or resources requested;

  • technical logs and security information.

The exact information collected may depend on our hosting provider, website platform and security configuration.

 

3.4 reCAPTCHA

Our Website uses reCAPTCHA as a security and anti-abuse measure.

reCAPTCHA may process technical information about your interaction with the Website in order to distinguish legitimate users from automated or abusive traffic.

The information processed by reCAPTCHA is subject to the applicable terms and privacy documentation of the provider.

 

4. Why do we process your personal data?

We process personal data only where there is a valid legal basis under applicable data-protection law.

Depending on the circumstances, we may process your personal data for the following purposes.

 

4.1 Responding to enquiries

When you contact Procomma, we use your information to:

  • respond to your enquiry;

  • understand your requirements;

  • communicate with you;

  • provide information about our services;

  • determine whether we may be able to assist your organisation.

The legal basis is generally Article 6(1)(f) GDPR – legitimate interests, namely our legitimate interest in responding to professional enquiries and developing potential business relationships.

Where appropriate, processing may also be necessary to take steps at your request before entering into a contract under Article 6(1)(b) GDPR.

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4.2 Scheduling meetings

When you use our meeting-booking functionality, we process the information necessary to arrange and manage the meeting.

The legal basis may be:

  • taking steps at your request before entering into a contract; and/or

  • our legitimate interest in efficiently managing professional communications and meetings.

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4.3 Providing professional services

If you become a client of Procomma, we may process relevant professional and contact information to:

  • perform our contractual obligations;

  • communicate with you;

  • manage projects;

  • deliver consultancy services;

  • coordinate meetings and activities;

  • administer the client relationship;

  • manage invoicing and payments;

  • comply with legal and accounting obligations.

The relevant legal bases may include Article 6(1)(b) GDPR (contractual necessity), Article 6(1)(c) GDPR (legal obligations) and, where appropriate, Article 6(1)(f) GDPR (legitimate interests).

 

5. We do not operate a marketing or newsletter database

Procomma does not currently operate a newsletter or marketing mailing list through the Website.

We do not use the information submitted through the contact form to automatically subscribe you to a newsletter or marketing campaign.

If this changes in the future, Procomma will update its privacy practices and, where required, obtain the appropriate consent before sending electronic direct marketing.

 

6. Cookies and similar technologies

The Website may use cookies and similar technologies.

Some cookies or similar technologies may be strictly necessary for the Website to function, maintain security or provide a service requested by the visitor.

Other cookies or tracking technologies may require prior consent under applicable Belgian rules.

Procomma does not currently use Google Analytics or Google Tag Manager.

The Website does use reCAPTCHA and may use technologies associated with third-party services such as Calendly.

Further information about cookies, their purposes, providers and retention periods is provided in our separate Cookie Policy.

Where consent is required, non-essential cookies and similar technologies will only be used after the required consent has been obtained.

The Belgian Data Protection Authority confirms that non-essential cookies generally require prior, informed, specific and freely given consent, while strictly necessary cookies may fall within an exemption.

 

7. Who may receive your personal data?

We do not sell your personal data.

We may share personal data with trusted third parties where this is necessary to operate our Website, provide our services, manage communications or comply with legal obligations.

These parties may include:

  • website hosting and infrastructure providers;

  • IT and cybersecurity service providers;

  • website maintenance providers;

  • email and communication service providers;

  • meeting-scheduling providers, including Calendly;

  • security and anti-abuse service providers, including reCAPTCHA;

  • professional advisers, such as accountants, lawyers or auditors, where necessary;

  • public authorities where disclosure is required by law.

Where a third party processes personal data on behalf of Procomma, we seek to ensure that appropriate contractual and data-protection safeguards are in place where required by GDPR.

 

8. International transfers

Some third-party service providers used by Procomma may process personal data outside the European Economic Area (“EEA”).

Where personal data is transferred outside the EEA, Procomma will take appropriate measures to ensure that the transfer is carried out in accordance with applicable data-protection legislation.

Depending on the circumstances, this may include:

  • an adequacy decision adopted by the European Commission;

  • Standard Contractual Clauses approved by the European Commission;

  • other legally recognised transfer mechanisms or safeguards.

Because third-party providers may change their infrastructure and processing locations, the applicable provider documentation should be consulted for the most current information.

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9. How long do we keep your personal data?

We retain personal data only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

The retention period depends on the nature of the information and the purpose of the processing.

Contact enquiries

Information relating to general enquiries will normally be retained for as long as reasonably necessary to handle the enquiry and any resulting professional relationship.

Where an enquiry does not lead to a client relationship, Procomma will not retain the information indefinitely and will delete or anonymise it when it is no longer reasonably necessary.

Client information

Where you become a client, relevant information may be retained for the duration of the contractual relationship and subsequently for as long as necessary to comply with legal, accounting, tax, contractual or dispute-resolution requirements.

Technical and security information

Technical and security logs may be retained for periods appropriate to the security and operational purposes for which they are collected.

Third-party services

Retention periods applicable to information processed directly by third-party services such as Calendly or reCAPTCHA may also be determined by those providers' own policies.

 

10. Security of your personal data

Procomma takes reasonable technical and organisational measures to protect personal data against:

  • unauthorised access;

  • accidental loss;

  • destruction;

  • alteration;

  • disclosure; and

  • other unlawful or unauthorised processing.

However, no method of transmission over the internet or method of electronic storage can be guaranteed to be completely secure.

You should therefore avoid sending highly confidential or sensitive information through publicly accessible website forms.

 

11. Your rights under the GDPR

Subject to applicable legal conditions and limitations, you may have the following rights:

Right of access

You may request confirmation as to whether we process your personal data and, where applicable, obtain a copy of that data.

Right to rectification

You may request that inaccurate or incomplete personal data be corrected.

Right to erasure

In certain circumstances, you may request that your personal data be deleted.

Right to restriction of processing

In certain circumstances, you may request that we restrict the processing of your personal data.

Right to object

You may object to certain processing based on our legitimate interests.

Where we process personal data for direct marketing purposes, you have the right to object to such processing.

Right to data portability

Where the legal requirements are met, you may request to receive certain personal data in a structured, commonly used and machine-readable format or have it transmitted to another controller.

Right to withdraw consent

Where processing is based on your consent, you may withdraw your consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

The Belgian Data Protection Authority confirms these rights, including access, rectification, erasure, restriction, objection, portability and withdrawal of consent.

 

12. How to exercise your rights

To exercise your rights or ask a question about the processing of your personal data, please contact:

Procomma BV
Doofmeer 15
1840 Londerzeel
Belgium

Email: bert@procomma.be

To help us protect personal data, we may need to verify your identity before responding to certain requests.

We will normally respond to requests within the timeframe required by applicable data-protection legislation.

 

13. Right to lodge a complaint

If you believe that Procomma has processed your personal data unlawfully or has not respected your rights, you are encouraged to contact us first so that we can try to resolve the matter.

You also have the right to lodge a complaint with the Belgian Data Protection Authority:

Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données)
Drukpersstraat / Rue de la Presse 35
1000 Brussels
Belgium
Telephone: +32 (0)2 274 48 00
Email: contact@apd-gba.be

The Belgian Data Protection Authority confirms that individuals may lodge a complaint where they believe their personal data has been processed contrary to data-protection rules.

 

14. Automated decision-making and profiling

Procomma does not use personal data collected through this Website for automated decision-making that produces legal effects or similarly significant effects concerning individuals.

We do not currently use the Website to create individual behavioural profiles for advertising or marketing purposes.

 

15. Children's data

The Website and Procomma's services are intended for businesses and professional users and are not directed at children.

Procomma does not knowingly collect personal data from children through the Website.

If you believe that a child has provided personal data to Procomma, please contact us so that we can take appropriate action.

 

16. Links to third-party websites

The Website may contain links to websites or services operated by third parties.

This Privacy Policy applies only to Procomma's processing of personal data.

Procomma is not responsible for the privacy practices, security or content of third-party websites.

We recommend reviewing the privacy policies of third-party websites before providing them with personal information.

 

17. Changes to this Privacy Policy

Procomma may update this Privacy Policy from time to time to reflect:

  • changes to our services;

  • changes to the Website;

  • changes to the personal data we process;

  • changes to third-party providers;

  • changes in applicable legislation or regulatory guidance.

The latest version will always be made available on www.procomma.be.

The date at the top of this Privacy Policy indicates when it was last updated.

 

18. Contact

If you have questions about this Privacy Policy or the way Procomma processes personal data, please contact:

Procomma BV
Doofmeer 15
1840 Londerzeel
Belgium

Enterprise number / VAT: BE 0675.834.533
Email: bert@procomma.be
Telephone: +32 495 23 17 62
Website: www.procomma.be

End of Privacy Policy

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