1. The parties
In this Privacy Statement, the following terms are defined as stated below:
'First Class Projects BVBA’: the limited limited company under Belgian law, having its registered office at Romain Steppestraat 109, B-2890 SINT AMANDS AAN DE SCHELDE, Belgium, listed under enterprise number BE 0892.785.624.
'Purchaser': any private individual (B2C) or legal entity (B2B) that has or will be having a contractual relationship of whatever nature with First Class Projects.
'Products': the subject of one or more sales contracts.
‘Privacy Act’: Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
2. What are my details used for?
First Class Projects attaches great value to the protection of your privacy and your personal details. First Class Projects only uses your details in accordance with the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data, and other relevant prevailing statutory regulations.
We may use your personal details to provide you with informative news items about new promotions, ads, events related to the operations of First Class Projects, events of partners of First Class Projects, job-related information and vacancies, the operations and services of First Class Projects and/or its partners, recruitment of staff, important news, etc. Your details may be forwarded to third parties or partners for informative purposes. First Class Projects has taken all possible legal and technical precautions to prevent unauthorised use and access. It can therefore never be held liable for identity theft, data theft or IT crimes. In the event its IT systems are hacked, it will immediately take all possible measures to reduce damage, loss and/or theft to a minimum.
3. Which personal details are collected?
For the application of the Privacy Act, 'personal details' are taken to mean all information relating to an identifiable natural person. Identifiable is taken to mean any person who can be directly (or indirectly) identified by means of an ID number or an element that characterises his physical, physiological, psychic, economic, cultural or social identity.
Each person is entitled to protection of his fundamental rights and freedoms, particularly protection of his privacy. First Class Projects recognises this right and makes great efforts to convert this right practically and online. Privacy legislation applies only to (the full or partial) computerised processing of personal details, or manual processing when the personal details are written to a file.
Personal details must be processed fairly and lawfully, they must be obtained for a certain, explicitly described and justified purpose, they must be sufficient, relevant and not excessive, they must be accurate and come in a form that makes it possible to identify the person involved.
First Class Projects complies with the conditions set out above. Personal details are processed for informative and technical purposes. The purposes are explicitly described under item 2. We may also use our data for statistic purposes.
4. Does First Class Projects store location data?
First Class Projects’s analytical data (such as Google Analytics) does indeed contain location data. This data enables First Class Projects to find and show your (probable) location on a map (‘Map’). However, this kind of location indication (obtained through an IP address) is far from precise, because not enough location data is collected to be able to determine your exact location.
We do not use location data to identify you, only to guarantee the proper technical functioning of our website.
5. Who is responsible for data processing?
The "party responsible for processing" is taken to mean the natural person or legal entity that determines the purpose and resources for processing on his own or with others.
First Class Projects acts as the party responsible for processing. It defines the purpose (item 2) and the legal and technical resources for processing. It does not however process the details itself, that is done by the actual processor.
6. Who is the actual processor?
"Processor" is taken to mean the natural person or legal entity that processes personal details on the instructions of the party responsible for processing, with the exclusion of persons who, under the direct control of the party responsible for processing, are authorised to process the details.
The current actual processor is www.combell.com. The actual processor is responsible for the correct performance of the technical online portal of First Class Projects. The party responsible for processing does not accept any liability for lost or corrupted data, identity theft, data theft, viruses or Trojan horses, SQL injections or other attacks on IT systems or online cloud portals. The actual processor autonomously selects the technically most suitable application for data processing, and does this on the basis of its professional expertise. The party responsible for processing cannot be expected to have that same expertise and know-how.
This processor offers sufficient safeguards with regard to the technical and organisational security measures in connection with the processing to be carried out, and as such complies with the Privacy Act.
7. What are my rights?
The party responsible for processing and/or the actual processor must provide the User with at least the following information, no later than the moment at which the data is collected:
Name and address of the party responsible for processing: see items 1 and 5.
Name and address of the actual processor: see item 6.
Purposes of processing: see item 2.
The right to object, on request and free of charge, to the intended processing of his personal details, if the details are processed with the purpose of direct marketing:
First Class Projects collects or processes identity details with the primary goal of its portal performing well in technical terms. The collected details can be used for marketing purposes once the technical and practical sides have been completed, but the User can object to this at all times. Objection can be made by registered letter. First Class Projects therefore complies with the provision set out above.
Other, additional information, particularly: the right to access to and correction of his personal details:
You always have a legal right to fully or partially supplement, correct or remove your personal details. First Class Projects undertakes to follow up your request within 15 working days. To that end, you can correct your data via our website (see item 1) or by sending an e-mail to
When proving your identity, you are entitled to obtain the necessary information about the processing of your personal details when you ask for it.
8. Are my details shared with trusted third-party services?
We may share your information with certain trusted third-party services to help us provide, improve, promote, or protect First Class Projects's Services (like when we partner with payment processors, or use services that help us manage our activities). When we share data with third-party services that support our delivery of services, we require that they use your information only for the purposes we’ve authorized, and that they protect your personal information at least to the same standards we do. We may also share information that’s aggregated and anonymized in a way that it doesn’t directly identify you.
First Class Projects guarantees that it does not process details to or store them in countries that cannot offer the same guarantees, except:
when the person involved has given his explicit consent;
when the transfer is required for the execution of the agreement (between the User and First Class Projects,
when the transfer is required for the conclusion or execution of an agreement concluded or to be concluded between the party responsible for processing and a third party, in the interest of the User;
when the transfer is required or compulsory by law (major general interest or right);
when the transfer is made from a public register intended to inform the public.