Updated May 1, 2023

1. Parties and Subject

Gemdax Corporation Limited (hereinafter “Gemdax” or the “Data Controller”)
Schupstraat 9-11, 2018 Antwerp
KBO/VAT: BE 0474.138.473
E-mail: info@Gemdax.com
Phone: +32 3 229 19 10
GEMDAX has established this Privacy Policy with the aim of transparently informing Users about the website hosted at the following

address: www.Gemdax.com (hereinafter the “Site”), and about how personal data is collected and processed by GEMDAX.

The term “User” refers to any user, whether a natural or legal person, who visits the Site or communicates with the Site in any way.

As the Data Controller, GEMDAX determines all technical, legal, and organizational means and the purposes of processing Users’

personal data. GEMDAX commits to taking all necessary measures to ensure that personal data is processed in accordance with the Law

of 30 July 2018 on the protection of natural persons with regard to the processing of personal data (hereinafter the “Law”), and

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27
April 2016 (the General Data Protection Regulation, or “GDPR”; hereinafter the “Regulation”).

GEMDAX is free to appoint a natural or legal person to process Users’ personal data on its behalf (hereinafter the “Processor” or

“Subcontractor”). In such a case, GEMDAX undertakes to select a Processor offering sufficient guarantees regarding the technical and

organizational measures for processing personal data, in compliance with the Law and the Regulation.

2. Processing of Personal Data

Use of the Site by Users may result in the collection of personal data. Processing of this data by

GEMDAX, either as Data Controller or through service providers acting on behalf of GEMDAX, is carried out in accordance with the Law

and the Regulation.

Personal data is processed by GEMDAX for the purposes described below, through the

following methods:

Registration to consult the online catalogue.

3. Purpose of Processing Personal Data

In accordance with Article 13 of the Regulation, the purposes of processing personal data are communicated to the User. These

purposes are:

Mailing and access only.

4. Personal Data That May Be Processed

The User agrees that, during the visit and use of the Site, GEMDAX may collect and process the following personal data:

First name, last name, email address.

This data is collected and processed in line with the conditions and principles described in this Privacy Policy.

5. Consent

By accessing and using the Site, the User declares that they have read and given their free, specific, informed, and unambiguous

consent to the processing of their personal data. This consent relates to the content of this Privacy Policy.

Consent is given by the User’s positive and active action of ticking the privacy policy checkbox in the hypertext link. This consent is

essential for performing certain actions on the Site or for enabling the User to enter into a contractual relationship with GEMDAX. Any

agreement between GEMDAX and a User concerning the services and goods offered on the Site is subject to the User’s acceptance of

this Privacy Policy.

The User consents to the Data Controller collecting and processing their personal data provided on the Site or in connection with

GEMDAX’s services, for the purposes set out above.

The User has the right to withdraw this consent at any time. Withdrawal does not affect the lawfulness of processing based on prior

consent.

6. Retention Period of Users Personal Data

In accordance with Article 13(2) of the Regulation, personal data is kept only as long as reasonably necessary to achieve the purposes

for which it is processed.

This period shall not exceed 5 years.

7. Data Recipients and Disclosure to Third Parties

Personal data may be disclosed to employees, collaborators, subcontractors, processors, or suppliers of GEMDAX, provided adequate

data security guarantees are in place and insofar as they collaborate with GEMDAX to market products or provide services. They act

under GEMDAX’s direct authority and are responsible for collecting, processing, or subcontracting such data.

In all cases, recipients of the data must comply with this Privacy Policy. GEMDAX ensures that they process the data only for the

intended purposes and in a discreet and secure manner.

If data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed in advance, and their prior

explicit consent will be required.

8. Data Protection Officer (DPO)

The following person has been appointed as Data Protection Officer (DPO):

Rafael Jamous

The DPO’s role is to ensure proper compliance with national and supranational provisions regarding the collection and processing of

personal data:

Contact details:

Terminalsession BV

Rijfstraat 3

2018 Antwerp

Rafaël.jamous@terminalsession.com

9. Users Rights

Users may exercise their rights at any time by sending an email to info@Gemdax.com, or by

mail (with a copy of their ID card) to:

Hoveniersstraat 2, 2018 Antwerp.

Rights include:

Right of access (Article 15 GDPR)
Right of rectification (Article 16 GDPR)
Right to erasure (Article 17 GDPR)
Right to restrict processing (Article 18 GDPR)
Right to data portability (Article 20 GDPR)
Right to object and automated decision-making (Articles 21 22 GDPR)
Right to lodge a complaint with the Belgian Data Protection Authority

(https://www.gegevensbeschermingsautoriteit.be/).

10. Cookies

The Site uses cookies to distinguish Users and improve browsing experience. Types include:

Technical cookies (site functionality),
Analytical/audience cookies (track usage, improve user experience, detect bugs),
Functional cookies (store preferences like username or language).

Users may manage or disable cookies via their browser settings. If cookies are disabled, some Site functions may not work optimally.

11. Limitation of the Data Controller s Liability

The Site may contain links to third-party websites not affiliated with GEMDAX. GEMDAX is not responsible for their content or compliance

with the GDPR.

Parental consent is required for minors under 16 before disclosing personal data on the Site. GEMDAX cannot be held liable for the

processing of minors’ data without parental consent.

GEMDAX is not responsible for loss, damage, or theft of personal data, particularly due to viruses or cyberattacks.

12. Security

The Data Controller implements technical and organizational measures to ensure an appropriate level of security in processing personal

data, including industry-standard encryption technologies.

13. Changes to the Privacy Policy

GEMDAX reserves the right to amend this Privacy Policy to comply with legal obligations. Users are encouraged to regularly review the

14. Governing Law and Jurisdiction

This Privacy Policy is governed exclusively by Belgian law. Any dispute will be brought before

the courts of the judicial district of GEMDAX’s registered office.

15. Contact

For any questions or complaints regarding this Privacy Policy, Users may contact the Data

Controller at: info@gemdax.com

Privacy Policy