Privacy Policy


We view protecting your privacy as a matter of the utmost importance. We would like to keep you informed as best as possible, respect you and give you control over what happens to your personal information. Set out below you will find information about what data we collect, why we do so, how long we keep it, what your privacy rights are and how you can exercise these rights.This privacy policy only applies in respect of the personal information, which we process as the data controller.‘Processing personal information’ is understood to mean any processing of information, which may identify you as a natural person.


Gumption a company incorporated under Belgian law having its registered office in 2550 KONTICH, Satenrozen 10 and with enterprise number BE0847610843.


We process personal information for a variety of purposes, and in each case we process the data, which is required to achieve the intended goal. In this way we can use personal information when this is necessary:

  • as part of the preparation, implementation or termination of our activities;
  • to meet the legal or regulatory provisions to which we are subject; and/or
  • for the furtherance of our legitimate interests.

If processing your personal information is not necessary for one of these three reasons, then we always ask for your consent to be permitted to process your personal information.

We collect personal information for the following specific purposes:

  • - For handling your demand, request or regitration. If you visit our web site to collect and/or request information then we may need your address details. All information, which we receive about you we only use to provide you with the requested information, in the way that you want;
  • - To improve our products and services;
  • - To monitor our performance;
  • - To meet our legal obligations


We process the personal information, which you yourself pass on to us. We may assign to you personal information for using our products and services. In addition, our systems may also record personal information, which is generated while you are using our products and services including use by end users.We may purchase personal information from specialist companies to better customize our service provision to your needs. The specialist companies that transfers your personal data are responsible for having the appropriate legal basis for processing personal data and for transferring it to us so that we can use it for our own purposes.

We distinguish in our systems between different types of personal information, which can be combined with one another:

  • - User data: we distinguish between the personal information, which can identify you as a user of our products and services, the personal information, which allows us to contact you, the personal information, which designates your personal characteristics or your lifestyle and consumer habits or relate to your invoicing and payment data and all other preferences, which you disclose to us;
  • Technical data: we need this to be able to ensure the smooth operation of our products and services;
  • - Traffic date: we need this special technical data to handle traffic over electronic communication networks;
  • - Location data: using this data we are able to determine the location of your devices which we use for network planning and management;
  • Data about your usage: the data, which we receive when you use our products and services;
  • Cookies: we may use cookies when you open our emails and/or when you visit our websites or mobile apps. Cookies are pieces of information that are stored on your own computer or mobile device and that are usually used to optimize the ease of use of websites and apps.


We do not transfer sell any personal information to third parties without your consent unless:

  • - it is to our legal successors and to affiliated companies;
  • - this is necessary to provide our service;
  • - there is a legal obligation;
  • - there is a legitimate interest for us or the third party involved;
  • - you give us consent to do so;


  • - Right of access: you are entitled to find out at any time whether or not we process your personal information;
  • - Right to update personal information: you are entitled to have incomplete, incorrect, inappropriate or out-of-date personal information corrected without delay.
  • - Right to erasure: you are entitled to have your personal information deleted without unreasonable delay;
  • - Right to restrict the processing of data: you are entitled without unreasonable delay to obtain a restriction on the processing of your personal information;
  • - Right to object against the processing of your personal information :you are entitled to lodge an objection against the processing of your personal information on grounds of your special situation;
  • - Opt-out for direct marketing: you are always entitled to oppose the use of your personal information for direct marketing purposes without having to specify a reason for this.


Send your request by email to [EMAILADDRESS] or to the registered office of the controler. To exercise your privacy rights, and to prevent any unauthorized disclosure of your personal information, we need to verify your identity. In case of doubt or unresolved issues we will first ask you for additional information (preferably a copy of the front of your identity card). If we cannot confirm your identity with certainty, we will not process your request.You can exercise your privacy rights free of charge unless your request is manifestly unfounded or disproportionate, in particular due to its repetitive nature.When you submit your request electronically, where possible the information is provided electronically, unless you request it otherwise. In any case we will provide you with a brief, transparent, intelligible and easy-to-access response.We will respond as quickly as possible to your request, and in any case within one month of receipt of your request. Depending on the complexity of the requests and the number of requests, this period may be extended for a further two months, if required. In case of an extension of the period, we will notify you of this within one month of receipt of the request.


We are not permitted to keep your personal information for longer than is necessary to achieve the purpose for which we are collecting it. The retention period varies for each purpose. Sometimes the period may also be longer, for example, to observe our legal obligations, e.g. to meet our accounting and tax obligations, for example, we are obliged to keep your invoicing data for a maximum of 7 years) or as a legal requirement to retain certain data (in particular your contract, invoices and correspondence in connection with complaints about this) as evidence in case of disputes, for up to a maximum of 10 years following termination of your contract. Archived data is only accessible to a limited extent. After expiry of the applicable retention period(s), personal information is deleted or anonymized.


We work hard to protect your personal information and privacy. Our staff are trained in how to correctly handle confidential data. As part of any project the aim of which is to process personal information, an assessment is first made in relation to security and the protection of personal information, in which case your interests take precedence. To protect your personal data we have employed skilled individuals who are also responsible for the security of networks, infrastructure and information systems. Furthermore, we use all kinds of technical measures to protect your personal information against unauthorized access, unauthorized use and loss or theft of your data. The software on our products is constantly kept up-to-date. The number of employees in our company that has access to your personal information is restricted. They are only granted access to your personal information insofar as they require this information to complete their duties properly.Insofar as personal information is processed outside of the European Union, through contractual or other measures we ensure that this data is granted an appropriate level of protection there comparable with the protection, which it would be granted within the European Union, in accordance with European regulations.


We may amend this privacy policy from time to time. We invite you to always check out the most recent version of this policy on our website.

The Data Protection Authority is an independent body that ensures that your personal data are processed in accordance with the law.

If you have a complaint regarding the processing of your personal data by us or if you wish to initiate proceedings for mediation, you can contact the authority via