Privacy Policy

1. Data controller

The data controller for personal data processed through this website (spoxen.com) is AJCF, operating under the brand Spoxen, with registered office at Place du Tomberg 18, 1200 Brussels, Belgium, registered under BCE/VAT number BE0738877209. Contact: a.ferreira [at] spoxen [dot] com.

2. Applicable law

This policy is issued in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR") and the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.

3. Data we collect

When you submit the contact form, we collect:

• Full name
• Email address
• Company name
• The content of your message
• A verification token issued by hCaptcha

We do not use analytics, advertising, or profiling cookies. Our hosting provider may log standard technical data (IP address, user agent, timestamps) for security and abuse prevention.

4. Purposes and legal bases

• Responding to your inquiry — legal basis: consent (Art. 6(1)(a) GDPR), given by submitting the form.
• Spam and abuse prevention (hCaptcha) — legal basis: legitimate interest (Art. 6(1)(f) GDPR) in keeping the contact channel usable.
• Compliance with legal obligations — where applicable (Art. 6(1)(c) GDPR).

5. Recipients and processors

Personal data is only accessible to AJCF. We rely on the following processors:

• hCaptcha (Intuition Machines, Inc., USA) — bot protection. See hCaptcha privacy policy.
• Lovable Cloud / hosting infrastructure — website hosting and delivery within the EU where possible.

6. International transfers

Where a processor is located outside the European Economic Area (notably hCaptcha in the United States), the transfer is protected by Standard Contractual Clauses adopted by the European Commission, together with any additional safeguards required under GDPR.

7. Retention

Contact form submissions are kept for up to 24 months from the date of the last exchange, then deleted. Data required to comply with a legal obligation is retained for the period imposed by that obligation.

8. Your rights

Under the GDPR you have the right to:

• Access your personal data and obtain a copy;
• Request rectification of inaccurate data;
• Request erasure ("right to be forgotten");
• Request restriction of processing;
• Object to processing based on legitimate interest;
• Data portability;
• Withdraw consent at any time, without affecting past processing.

To exercise these rights, contact us at a.ferreira [at] spoxen [dot] com. We respond within one month.

9. Complaints

You have the right to lodge a complaint with the Belgian Data Protection Authority:

Autorité de protection des données / Gegevensbeschermingsautoriteit
Rue de la Presse 35 / Drukpersstraat 35, 1000 Brussels
autoriteprotectiondonnees.be

10. Changes

This policy may be updated to reflect changes in our practices or in applicable law. The "Last updated" date at the top indicates the current version.