Privacy Policy


Operated in Belgium by : 
Positive Thinking Company S.A. 
Chaussée de Charleroi, 112
1060 Brussels

BCE/KBO : 0895.492.518
TVA/VAT : BE 0895.492.518

Operated in France by : 
Otofacto S.A.S
10, rue jean marcuit
69009 Lyon

SIREN : 851.732.412
RCS Lyon
TVA : FR65851732412

1. General information regarding Positive Thinking Company

1.1 Positive Thinking Company S.A. is legally registered in accordance with Belgian law with registered offices in Charleroisesteenweg 112 Chaussée de Charleroi, 1060 Brussel / Bruxelles and registered under the Company number 0895.492.518 (hereafter referred to as “PTC”).

2. PTC’s commitments regarding the protection of personal data

2.1 Given the importance of protecting personal data, PTC is committed to adhere to regulations concerning the privacy, especially to the Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data, as well as the General Data Protection Regulation of 27 April 2016 (“GDPR”), and take all reasonable measures to ensure that personal data provided to us will remain properly handled, confidential where appropriate and safely protected.

2.2 This Privacy Policy published on our website explains why and how we collect, record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose, align or combine, restrict, erase or destroy your personal data when you use our services, visit our website, use our mobile application or interact with us. This Privacy Policy also instructs you how to exercise your rights relating to your personal data.

2.3 More specifically, PTC undertakes to respect the following principles:

  • your personal data are processed lawfully, fairly, and transparently, in accordance with article 5.1 a) of the GDPR;
  • your personal data are collected for specific, explicit and legitimate purposes and are not further processed in way incompatible with these purposes, in accordance with article 5.1 b) of the GDPR;
  • your personal data are stored in an appropriate and relevant manner and are limited to what is necessary for the purposes for which they are processed, in accordance with article 5.1 c) of the GDPR;
  • your personal data are accurate, kept up to date and all reasonable steps are taken to ensure that inaccurate data, having regard to the purposes for which they are processed, are erased or rectified without delay, in accordance with article 5.1 d) of the GDPR;
  • your personal data are kept in a form which permits identification of data subjects for no longer than necessary for the purposes for which the personal data are processed, in accordance with article 5.1 e) of the GDPR;
  • in accordance with article 5.1 f) of the GDPR, PTC implements appropriate technical and organizational measures to ensure appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage.

2.4 Finally, PTC undertakes to comply with all other principles required under the applicable regulations on the protection of personal data.

2.5 However, PTC does not accept unauthorized idea submissions outside of established business relationships. To protect the interests of our current clients and ourselves, we must treat the issue of such submissions with great care. Importantly, without a clear business relationship, PTC cannot and does not treat any such submissions in confidence. Accordingly, please do not communicate unauthorized idea submissions to PTC through this website. Any ideas disclosed to PTC outside a pre-existing and documented confidential business relationship are not confidential and PTC may therefore develop, use and freely disclose or publish similar ideas without compensating you or accounting to you. PTC will make every reasonable effort to return or destroy any unauthorized idea submissions without detailed review of them. However, if a review is necessary in PTC’s sole discretion, it will be with the understanding that PTC assumes no obligation to protect the confidentiality of your idea or compensate you for its disclosure or use. By submitting an idea or other detailed submission to PTC through this website, you agree to be bound by the terms of this stated policy.

2.6 By accepting this Privacy Policy, the data subject declares that he or she is familiar with the information below and authorizes PTC in line with what is outlined below, to process data of a personal nature which is transmitted via the services (including via online forms, applications, e-mails sent to PTC e-mail addresses, cookies, etc.).

2.7 If you have any questions regarding this Privacy Policy, please contact PTC:

3. Items of personal information which may be collected and processed by PTC

3.1 When using PTC’s services or contacting and interacting with us, you may provide us with your personal information voluntarily which is collected on an individual basis. This includes:

  • your name and email address;
  • if applicable, all information included in your curriculum vitae;
  • If applicable, the VAT-number used for your commercial activities with PTC.

4. Methods of personal data collection

4.1 PTC may collect the personal information or data set forth in Article 3 of the Privacy Policy when you use our services, website or applications.

5. Purposes for which the information is collected and processed

The main purposes for which PYTC collects and processes your personal information are as follows:

5.1 To perform our contractual obligations and enable an appropriate level of service

5.2 For customer care purposes

5.3 To communicate with you

5.4 For direct marketing purposes

6. Legal basis of the processing of your personal data

6.1 PTC processes your personal data (i) on the basis of your explicit consent, (ii) to perform the contract or in order to take steps at the request of the data subject prior to entering into a contract, (iii) to comply with legal obligations PTC is subject to or (iv) to perform PTC’s legitimate interests.

6.2 Your consent may always be withdrawn at any time in accordance with Article 10. In such case, be aware that the withdrawal of consent shall not affect the lawfulness of processing based on your consent before the withdrawal.

6.3 Furthermore, if you refuse to provide PTC with some personal data or if you provide PTC with incomplete or inaccurate information required for the performance of the contract or for compliance with a legal obligation, be aware that we may not be able to provide or deliver your all or parts of the services, which you may have requested from us in full quality.

6.4 When we process your personal data for our legitimate interests or the interests of a third party, PTC ensures that a balance of these interests against your legitimate interests has been done. When necessary we have taken appropriate measures to limit implications and prevent unwarranted harm to you.

7. Disclosure to Third Parties

7.1 Potential recipient of your Personal Data

7.1.1 PTC may disclose certain personal information to third parties, such as authorized PTC’s employees, undertakings of PTC’s group (i.e. undertakings of the Positive Thinking Company), and strategic partners that work with PTC to provide products and services.

7.1.2 However, Personal Data will not be shared with third parties for their marketing purposes.

7.1.3 PTC may be required by law, legal process, litigation and/or requests from public and governmental authorities within or outside your country of residence to disclose your personal information.

7.1.4 PTC may disclose personal information, on a legitimate basis, if PTC determines that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.

7.1.5 Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

7.1.6 PTC will use its best endeavors to ensure that its employees and strategic partners who are involved in the collection, processing and disclosure of personal information will observe and adhere this privacy policy.

7.2 Transfers of Personal Data to third countries

7.2.1 You are informed that PTC may transfer your Personal Data to third parties located outside the European Union in order to be processed and stored.

7.2.2 In that context and if applicable, PTC undertakes to guarantee the processing of your Personal Data in accordance with Article 46 of the GDPR.

8. Technical measures for protecting personal Information

8.1 To secure the safety of personal information from a loss, theft, leak, falsification, or damage, PTC implements the following technical, managerial and physical devises:

− prevent personal information from leakage or damage by hacking or computer virus;
− implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including the pseudonymization;
− ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
− restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
− ensure a process for regular testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing;
− minimize the number of employees for managing personal information.

9. Period for Personal Data retention

9.1 PTC will retain your personal information collected for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law or until the information are required to be deleted by you.

10. Your rights to the personal data collected

10.1 As the possessor of personal data, you have the following rights which can be exercised at the following email address:

10.2 If you choose to request information from PTC you may need to communicate personal information of a general nature. In addition to, if you choose to correspond further with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protection for these electronic communications that we employ in the maintenance of information received by mail or telephone.

10.3 Your rights, resulting from the Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data, and the GDPR nevertheless remain guaranteed for as much and insofar as this technology allows it.

10.4 The right of access:

10.4.1 Any individual concerned may access the data concerning him, processed by PTC and, if necessary, request that incorrect data be corrected or deleted.

10.5 The right of rectification:

10.5.1 PTC makes it easy for you to keep your personal information accurate, complete and up to date. You have the right to obtain from PTC the rectification of inaccurate or incomplete personal data concerning you.

10.6 The right to be forgotten:

10.6.1 You have the right to obtain the erasure of your personal data stored by PTC in the situations provided by the GDPR such as in situations where your personal data are no longer necessary in relation to the initial purposes for which they were processed as well as situations where they were processed unlawfully.

10.7 The right to restriction of processing:

10.7.1 You have the right to obtain from PTC a limitation of the processing of your personal data without deleting the personal data concerned on the conditions stated in the GDPR.

10.8 The right to data portability:

10.8.1 You have the right to recover some of your data for your own use or to transmit them to another company in the conditions provided by the GDPR.

10.9 The right to object:

10.9.1 You have the right to object at any time to the processing of your data for prospecting and marketing purposes, including profiling and direct marketing.

10.10 The right to withdraw consent:

10.10.1 When the processing of your personal data is subject to your prior consent, you have the right to withdraw your consent at any time.

10.10.2 You shall be aware that the withdrawal of consent shall not affect the lawfulness of processing based on your consent before the withdrawal. In case of withdrawal, it may mean that we will not be able to provide or deliver you all or parts of the service.

10.11 The right to lodge a complaint:

10.11.1 You have the right to lodge a complaint with the Data Protection Authority (DPA) if you consider that the processing of your personal data constitutes a violation of the GDPR.

11. Communication with you and notification to the Data Protection Authority in case of a breach of your personal data

11.1 We will communicate immediately, when your personal data are breached, to you and the Data Protection Authority every time it is required by the GDPR. This communication about your personal data breach will describe in clear and plain language the nature of the personal data breach and contain at least the following information and measures:

  • communicate the name and contact details of the Data Protection Officer or other contact point where more information can be obtained;
  • describe the likely consequences of the personal data breach;
  • describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, when appropriate, measures to mitigate its possible adverse effects.

11.2  This communication shall not be required if any of the following conditions are met:

  • PTC has implemented appropriate technical and organizational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person which is not authorized to access it, such as encryption;
  • PTC has taken subsequent measures which ensure that the high risk to your rights and freedoms referred to in the first paragraph is no longer likely to materialize;
  • It would involve disproportionate effort for PTC. In such a case, there shall instead be a public communication or similar measure whereby you are informed in an equally effective manner.

12. The Data Controller and the Data Protection Officer:

12.1 The Data Controller is Positive Thinking Company S.A., with registered offices in Charleroisesteenweg 112 Chaussée de Charleroi, 1060 Brussel / Bruxelles and registered under the Company number 0895.492.518 (email:

12.2  In order to ensure the security of your personal information and to protect your rights and freedoms, PTC has appointed a Data Protection Officer:

Mr. Cédric Neef de Sainval

Address:  Positive Thinking Company S.A., Charleroisesteenweg 112 Chaussée de Charleroi, 1060 Brussel / Bruxelles.