Cyclop ("Cyclop", "we", "us") is committed to protecting the personal data of visitors to this website and users of its services. This Privacy Policy explains what data we collect, why we collect it, how we use it, and what rights you have under the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Belgian data protection law.
1. Data Controller
The data controller responsible for your personal data is:
Cyclop
Brussels, Belgium
Email: info@cyclop.com
If you have questions about how we handle your data, contact us at the address above.
2. Data We Collect
We collect only the data that is necessary for the purposes described below:
2.1 Data you provide directly
- Contact and enquiry data: name, professional email address, company name, and any message you send when requesting a demo or contacting us.
- Beta access requests: email address and company context submitted via our CineRights beta access form.
2.2 Data collected automatically
- Technical data: IP address (anonymised where possible), browser type and version, operating system, referring URL, pages visited, and time of visit — collected via server logs and, where applicable, analytics tools.
- Cookies: see Section 8 below.
We do not collect special-category data (Article 9 GDPR) and we do not knowingly collect data from persons under 16 years of age.
3. Legal Bases for Processing
We process your personal data only where we have a valid legal basis under Article 6 GDPR:
- Contract performance (Art. 6(1)(b)): where processing is necessary to respond to your request for our services or to provide access to CineRights.
- Legitimate interests (Art. 6(1)(f)): to operate and improve our website, prevent fraud, and respond to unsolicited enquiries. We have assessed that our legitimate interests do not override your rights and freedoms.
- Consent (Art. 6(1)(a)): where you have freely given explicit consent, in particular for the placement of non-essential cookies or for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.
- Legal obligation (Art. 6(1)(c)): where we are required to retain or disclose data by applicable law.
4. Purposes of Processing
- Responding to demo requests and service enquiries
- Managing CineRights beta access
- Operating and securing our website
- Analysing aggregate usage to improve our services
- Complying with legal and regulatory obligations
- Sending service-related communications (not marketing without consent)
5. Data Retention
We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by law:
- Enquiry and contact data: up to 36 months from last contact, unless a contractual relationship is established.
- Contract-related data: 7 years from contract end, in accordance with Belgian accounting and commercial law obligations.
- Server logs: up to 12 months, then deleted or anonymised.
- Cookie data: per the retention periods set out in Section 8.
6. Sharing of Data
We do not sell, rent, or trade personal data. We may share data with:
- Service providers (data processors): hosting providers, email delivery services, and analytics tools acting strictly under our instructions and bound by data processing agreements (DPAs) compliant with Article 28 GDPR.
- Legal authorities: where we are legally required to disclose data by court order or applicable law.
- Professional advisers: lawyers, auditors, or insurers under confidentiality obligations.
Any processor located outside the European Economic Area (EEA) is subject to appropriate safeguards under Chapter V GDPR (e.g. Standard Contractual Clauses).
7. Your Rights
Under GDPR you have the following rights, exercisable free of charge by contacting info@cyclop.com:
- Right of access (Art. 15): obtain confirmation of whether we process your data and receive a copy.
- Right to rectification (Art. 16): request correction of inaccurate or incomplete data.
- Right to erasure (Art. 17): request deletion of your data where there is no longer a legal basis for processing.
- Right to restriction (Art. 18): request that we limit processing in certain circumstances.
- Right to data portability (Art. 20): receive your data in a structured, machine-readable format where processing is based on consent or contract.
- Right to object (Art. 21): object to processing based on legitimate interests, including profiling.
- Right to withdraw consent: where processing is consent-based, you may withdraw at any time.
We will respond to your request within one month (extendable by two further months for complex requests). If we cannot satisfy your request we will explain why.
You also have the right to lodge a complaint with the Belgian supervisory authority:
Autorité de protection des données (APD) / Gegevensbeschermingsautoriteit (GBA)
Rue de la Presse 35 / Drukpersstraat 35, 1000 Brussels
www.autoriteprotectiondonnees.be
8. Cookies
Our website may use the following categories of cookies:
- Strictly necessary cookies: required for the website to function. No consent is required.
- Analytics cookies: used to measure visits and improve the site. These are only placed with your consent and are anonymised where possible.
We do not use advertising or tracking cookies. You can manage cookie preferences through your browser settings or any consent banner presented on the site.
9. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or destruction, in accordance with Article 32 GDPR. These include encrypted data transmission (HTTPS), access controls, and regular security reviews.
10. Changes to This Policy
We may update this Privacy Policy from time to time. The effective date at the top of this page will reflect the most recent version. Material changes will be communicated via a prominent notice on our website or, where appropriate, by email.
11. Contact
For any privacy-related enquiries:
info@cyclop.com
Cyclop, Brussels, Belgium