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Privacy & Cookie Policy

Benthe & Aaron

Version 1.0

last update: 05 March 2021

This is the Privacy and Cookie Policy of Benthe & Aaron, with registered offices

in Egelantierstraat 32/1, 3600 Genk, Belgium and registered at the Crossroads Bank for

Enterprises, or cbe (Banque-Carrefour des Entreprises (bce) / Kruispuntbank van

Ondernemingen (kbo)), with number BE0730.450.481 (hereinafter ‘Benthe & Aaron’’, ’the agency’, ‘we’, ‘us’ or ‘our’).


This Privacy Policy contains essential information about how we process personal data

and which cookies are used. We reserve the right to periodically alter and update this

Privacy Policy.

We may process your personal data in the following situations:

— by visiting our website

— by meeting us at events and fairs

— by inquiring by e-mail, phone or via online platforms

— by subscribing to our newsletter

— by delivering goods or services

— by purchasing from us

Some processing activities require your consent in accordance with our Privacy Policy

whereas the legal basis for others pertains to activities such as the execution of contracts,

legitimate interests, or compliance with legal or regulatory obligations.


Article 1 — General terms

1.1. Benthe & Aaron, as a Belgian company, is compliant with the European Regulation

2016/679 of 27 April 2016 on the protection of personal data (hereinafter ‘gdpr’).

1.2. Benthe & Aaron takes responsibility for the processing of your personal data.


Article 2 — Processing activities

Benthe & Aaron processes your data for specific, well-intentioned and bona fide

purposes. Retention times are limited to those purposes. Each processing activity is

justified by one or more legal grounds. This Privacy Policy provides comprehensive

information about the various processing activities.


2.1. Visiting our website

When visiting our website, your personal data are processed through cookies.

For further information on these cookies and the data processed, please refer

to Article 8 of this Privacy Policy.


2.2. Meeting us

If you provide us with your personal details during a meeting, we will store

these details in our database. Personal data processed include your name and

contact details, such as phone number, e-mail address or physical address, as

well as your artistic preferences and collections, your marketing and communication

preferences or any other information disclosed. Your data are

processed so we may invite you to and inform you about our events.
The legal ground is our legitimate interest (Art. 6.1f) gdpr).
In the context of our research and the maintenance

of records pertaining to the ownership of artworks (to assist with checks on

Egelantierstraat 32/1, 3600 Genk, Belgium - Luc Balcer, authenticity,
provenance and title), we will keep this data for as long as the

record is relevant to our legitimate business interest and the public interest.

Your data will be removed as soon as you express your desire to opt out from

or object to the further processing of your data.


2.3. Contacting us

Whenever you contact us via e-mail or telephone, or when submitting an inquiry

through an online platform, you are providing us with your name(s),

contact details and the content of your request. This information can be

processed and stored, together with our response. Your data are processed for

the purpose of responding to your request. The legal ground is the performance

of services (Art. 6.1 b) gdpr). Unless the data are necessary for other

activities, it will be removed as soon as your request has been handled.


2.4. Our newsletter

You may subscribe to our newsletter. We only process your e-mail address

and your name(s) in order to send you a personalised newsletter. The legal

ground for this processing is your explicit consent (Art. 6.1 a) gdpr). Your

data will be removed as soon as you decide to opt out. You may inform us of

your decision to withdraw your consent. You may also unsubscribe via a link

at the bottom of each newsletter.


2.5. Suppliers

If you are a service provider or a deliverer of goods, we process certain

personal data for the execution of the agreement. These data typically include

your name(s), legal entity, address(es), contact details, bank details, your

general terms and conditions, vat number, invoices, goods and services

delivered, e-mail correspondence and all other data you have provided. We

need to process your personal data in order for us to execute our contract

and for accountancy purposes. The legal grounds for this processing are the

performance of the agreement (Art. 6.1 b) gdpr) and our legal accountancy

obligations (Art. 6.1 c) gdpr). Your data will be removed after the legal retention

time of seven (7) years. After the initial retention time of seven years, we

keep records of your professional details for further reference and for up to

ten years after the last services rendered.


2.6. Visiting the agency

When you have an appointment with the author, your name is stored in our

agenda and our e-mail correspondence, if any, is kept in our digital mailbox.

You may be filmed by surveillance cameras when entering the premises.

Processing your personal data is required for organisational purposes. Images

taken by our surveillance cameras are made for security purposes. The legal

ground for this processing is the performance of an agreement (Art. 6.1 b)

gdpr). As for the surveillance cameras (and in part for the agenda), the legal

grounds are both our legal obligation to take appropriate technical security

measures in order to comply with gdpr (Art. 6.1 c) gdpr), as well as our legitimate

interest to have security in place for the safety of our staff, our visitors

and the artworks that we sell (Art. 6.1 f) gdpr). The retention

time for the agenda is five (5) years. The retention time of the surveillance

footage is one (1) week, in accordance with the timed loop of the surveillance



Article 3 — Direct marketing

Certain processing activities may serve marketing purposes, such as those

related to our newsletter. Your personal data will only be used for these

purposes if you have given your explicit and preliminary consent (‘opt-in’). If

you consent to be added to the agency’s mailing list, your personal data will

be used to send you information relating to the agency’s activities and those

Egelantierstraat 32/1, 3600 Genk, Belgium, Luc Balcer, +32(0)456 14 63 08

of its co-workers. This consent can be revoked at any time, at no cost and without

motivation by clicking the unsubscribe button below every newsletter.


Article 4 — Transfer of your data

4.1. In the case of Benthe & Aaron complete or partial reorganisation, its liquidation

or cessation of its activities your personal data may be transferred to new

entities or third parties.


4.2. Benthe & Aaron might be obliged by rule of law, court or administrative order

to disclose personal data. Benthe & Aaron will make all reasonable efforts to

inform you beforehand of this transfer of your personal data.


4.3. Benthe & Aaron will not sell, lease or give away your personal data except in

the situations provided for in this policy or unless you have given explicit and

preliminary consent.


Article 5 — Your rights

5.1. Access right and right to obtain a copy

You have the right to freely obtain access to your personal data at any moment,

as well as to be informed about the purpose of the processing by Benthe & Aaron.


5.2. Right to correct, delete and limit

You have the choice to share your personal data with Benthe & Aaron as well

as to request their correction, deletion or completion. You acknowledge that

a refusal to share data or a deletion request will make the delivery of certain

services and/or products impossible. You can also request the processing of

your personal data to be limited.


5.3. Right to object

You have the right to object to the processing of your personal data when you

have serious and legitimate reasons to do so. You also have the right to object

to the use of your personal data for purposes of direct marketing without

providing a motivation.


5.4. Right of data portability

You have the right to obtain your personal data which are processed by

Benthe & Aaron in a structured and standard form, which is readable by machines,

and/or to transfer this data to another data controller of your choice.


5.5. Right to withdraw consent

Egelantierstraat 32/1, 3600 Genk, Belgium, Luc Balcer, +32(0)456 14 63 08.

When the processing is based on prior consent you have the right to withdraw

this consent.


5.6. Exercise of rights

Our Privacy Co-ordinator handles all requests from data subjects, authorities

and third parties. You can exercise your rights by contacting us via e-mail:; or by post: Egelantierstraat 32/1, 3600 Genk, Belgium, p.a. Luc Balcer,
+32(0)456 14 63 08


5.7. Automated decisions and profiling

The processing of your personal data does not include profiling, nor shall you

be subjected to automated decisions.

5.8. Right to file a complaint

If you think that your privacy rights have been violated, you have the right to

file a complaint with the Belgian Data Protection Authority, Drukpersstraat

35, 1000 Brussels, Belgium, Tel +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35,

e-mail: This does not affect your right to file a suit before

the civil court. If you have suffered damages caused by the processing of

your personal data you can file a claim for damages.


Article 6 — Safety and confidentiality

6.1. We have adopted safety measures which are suited on both a technical and an

organisational level to avoid the destruction, the loss, the forgery, the adjustment,

the non-authorised access or the accidental disclosure of the personal

data to a third party, as well as the non-authorised processing of these



6.2. Benthe-Aaron shall not be liable in any way for direct or indirect damages

caused by the wrongful or improper use of personal data by a third party.


Article 7 — Access by third parties

7.1. In order to process your personal data, we need to provide certain employees

with limited access to the records.


7.2. We guarantee a similar level of protection by imposing contractual obligations

upon our employees that are similar to this Privacy Policy.


Article 8 — Cookies

8.1. What is a cookie?

A ‘cookie’ is a small text file that is sent from the server used by Benthe-Aaron and

stored on your device’s hard drive. In this way, our systems can remember

your preferences when visiting our website. The information stored through

these cookies can only be read by Benthe-Aaron and only for the duration of

your visit to our website.


8.2. Why do we use cookies?

Our website uses cookies and similar technologies to distinguish your preferences

from those of the other users of our website. This allows us to offer you

Benthe & Aaron, - Egelantierstraat 32/1, 3600 Genk,
Belgium a better experience when you visit our website and to optimize our website

in the meantime. As a result of recent amendments of the law, all websites

focusing on certain parts of the European Union are obligated to ask for your

permission in order to use or save cookies and similar technologies on your

computer or mobile devices. This cookie policy provides clear and complete

information about the cookies we use and their purpose.


8.3. Your permission

You can block cookies by activating your browser settings to refuse them. The

rejection of these cookies may have the effect of not allowing you to use some

functionalities on the website. Should you have further questions or remarks

regarding the processing of personal data, please contact Benthe & Aaron, Egelantierstraat 32/1, 3600 Genk, Belgium. General information about cookies can

also be found via the following link: Further

information about online behavioural advertising and online privacy can be

found via this link:

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