General Data Protection Regulation (GDPR) - Web Policy for Data Protection
ThinkingMinds nv (SEW nv), VIP Call SARL, dedicated to the processing and management of your Personal Data (as defined in point 1 below) with due diligence, confidentiality and in accordance with the requirements of the General Regulations on Data protection.

1. Data Protection - Key Definitions and Principles

GDPR: the General Data Protection Regulation (EU) 2016/679 is an EU regulation on the protection of personal data and privacy. GDPR achieves uniformity in the data protection rules applicable to all individuals within the European Union.

Personal data: any information related to a person identified or that can identify a person directly or indirectly (eg name, phone number, job title). Personal data does not include information or data relating to legal persons (eg investment funds, issuers of securities ...).

Processing: any transaction or set of transactions carried out on Personal Data or sets of Personal Data, whether by automated means (eg collection, registration, organization, storage, consultation).

Data controller: the person or entity that determines the purpose and means of the processing of personal data.

2. Scope of the policy

This Data Protection Web Policy (the "Policy") does not apply to the processing of your Personal Data by ThinkingMinds sa (SEWs), VIP Call Ltd., when you are a customer, a business counterparty, a supplier or supplier, an employee or any person with whom ThinkingMinds SA (SEWs) has established or is in the process of establishing a contractual, legal or commercial relationship.

The policy only explains how and why ThinkingMinds sa (SEWs), VIP Call LLC, collects and uses your personal data when:
-You use the website of ThinkingMinds sa (SEW nv), VIP Call SARL, (the "Website") or any feature or application form available on the Site; you request the submission of communications or invitations from ThinkingMinds SA (SEWs).
In both cases, ThinkingMinds sa (SEWs), VIP Call Ltd., acts as a data controller.

3. Processing your personal data

3.1 Use of the website
When you use the Site or any feature thereof, ThinkingMinds sa (SEWs), VIP Call sarl, collects and processes your Personal Data as follows:

-Collection of your personal data: Your personal data are collected through cookies (text files stored on your computer by your browser), via information received from your browser, and / or when you connect to dedicated or personalized pages of your browser. Site.
   
Personal data collected by ThinkingMinds sa (SEWs), VIP Call sarl, will collect your IP address, the pages of the Website you visit, the duration and time of your visit and in some cases your name, address, telephone number and / or e-mail address.
Processing of your personal data: ThinkingMinds sa (SEWs), VIP Call sarl, will treat your personal data for:
Obtaining statistical data on the use and access volume of the Site in order to improve the quality and efficiency of the services of ThinkingMinds sa (SEWs), VIP Call sarl, and to create a better experience by improving the functionalities and by achieving a better level of usability, manage and operate the website, facilitate and accelerate your access to dedicated web pages

Any subsequent use of your personal data outside of this context will require other specific consent.

3.2 External Communications and Invitations
When you request the sending of communications and / or invitations by Exodium Ltd, ThinkingMinds sa (SEW nv), VIP Call sarl, collects and processes your personal data as follows:
Collection of your personal data: ThinkingMinds sa (SEWs), VIP Call sarl, will collect your personal data when you fill out the registration / application form to receive communications and / or invitations from ThinkingMinds nv (SEW ), VIP Call sarl, (according to your preferences).
Personal data collected by ThinkingMinds nv (SEW nv), VIP Call sarl, will only collect the data you provide by completing the registration / application form, ie your surname, first name, job title, email address, the name of your company and in some cases your phone number (s). You have no obligation to provide all of the information above and may decide, at your discretion, to disclose only part of the information requested.
Processing of your personal data: ThinkingMinds sa (SEWs), VIP Call sarl, will process your personal data for the sole purpose of sending you communications and / or invitations (according to your preferences).
Any subsequent use of your personal data outside of this context will require other specific consent.

3.3 Sending requests to ThinkingMinds sa (SEWs), VIP Call sarl, using the contact form
Collection of your personal data: ThinkingMinds sa (SEWs), VIP Call sarl, will collect your personal data when you fill out the contact form.
Personal data collected by Exodium Ltd: ThinkingMinds sa (SEWs), VIP Call sarl, will collect the data you provide by filling out the contact form ie your name, surname, job title, email address, the name of your company, your telephone number and the contact You do not have to provide all the information above and you can decide, at your discretion, to divulge only part of the requested information .
Processing of your personal data: ThinkingMinds sa (SEWs), VIP Call sarl, will process your personal data for the sole purpose of processing your request and providing you with an appropriate response. This response may be, where appropriate, an offer or solicitation of subscription to services provided by ThinkingMinds nv (SEW nv), VIP Call sarl ,. Any other use of your personal data outside of this context will require other specific consent.

4. Storage of your Personal Data
ThinkingMinds SA (SEWs), VIP Call, Personnel takes reasonable and appropriate technical and organizational security measures to: Store your Personal Data in secure databases or restricted access systems, Protect your Personal Data against loss, accidental or intentional misuse, alteration, destruction and unauthorized access.
ThinkingMinds SA (SEWs), VIP Call, will notify you as soon as possible if ThinkingMinds SA (SEWs), VIP Call, becomes aware of unauthorized or inappropriate use, access or disclosure of the Data. Personal, likely to pose a high risk for your rights and freedoms.
Please note that some of the databases or systems used by ThinkingMinds SA (SEWs), VIP Call, for messaging services and storage systems may be hosted and / or managed by third-party service providers located at inside or outside the European Union. Your personal data will only be disclosed to these service providers if ThinkingMinds SA (SEWs), VIP Call, has determined, in its reasonable judgment, that these service providers offer appropriate privacy, security and privacy safeguards. of your personal data.
ThinkingMinds SA (SEWs), VIP Call, also reserves the right to disclose personal data to any judicial, judicial or administrative authority if necessary or legally obliged to do so.
5. Period of conservation
ThinkingMinds SA (SEWs), VIP Call, will keep your Personal Data in accordance with the statutory retention periods applicable in Luxembourg or when required by ThinkingMinds SA (SEWs), VIP Call, to assert or defend against legal claims up to the end of the relevant retention period or until the claims in question have been settled. Your Personal Data will be deleted when: It is no longer reasonably necessary for the purpose for which the personal data was initially collected, you withdraw your consent (if any); or ThinkingMinds SA (SEWs), VIP Call, is not legally required or otherwise permitted to continue storing your personal data.
6. Your right to access, rectify and delete your Personal Data
You have a right to access, modify, rectify and / or delete Personal Data at any time, as well as to restrict or oppose the use of your Personal Data for the purposes mentioned above, including: For communications and invitations sent by ThinkingMinds SA (SEWs), VIP Call,: You may withdraw your consent to receive communications or invitations at any time by sending an email to contact@thinkinkminds.eu. In this case, ThinkingMinds SA (SEWs), VIP Call, will immediately stop sending you communications and invitations. For the use of the website: you can, at any time, the option to accept or refuse cookies on the website by changing the settings of your browser. However, if you choose to decline cookies, you may not be able to access and use certain parts of the website. You may also encounter difficulties or restrictions when accessing all or part of the Site for which ThinkingMinds SA (SEWs), VIP Call, disclaims any liability or liability of any kind whatsoever.If any of the Data Personal that you have provided to ThinkingMinds SA (SEWs), VIP Call, changes or is out of date, you should send an email to contact@thinkinkminds.eu. ThinkingMinds SA (SEWs), VIP Call, will not be liable for losses resulting from inaccurate, unauthentic, insufficient or incomplete personal data that you have provided.

7. Modification of the Policy
The Policy may be amended, superseded or supplemented at any time without notice or notice by ThinkingMinds SA (SEWs), VIP Call,. It is therefore advisable to examine it from time to time for any possible change.