01Data controller
The controller of your personal data is:
// Italique SRL is a company under Belgian law, subject to GDPR and the Belgian Data Protection Act of 30 July 2018.
02Who this policy covers
This policy covers all personal data processed by Italique SRL as part of Ancalagon's activities:
- Visitors of
ancalagon.be(including the contact form); - Users of the Ancalagon Manager (
manager.ancalagon.be); - Clients and their operational contacts (billing, contracts, support);
- Job applicants who send us their CV.
03Data we collect
Website visitors
Manager users
- Full name, email, phone (optional), password (bcrypt-hashed)
- Account verification status, access logs
- Company, address, city, postal code, country, VAT no.
Contract & billing data
- Signatory identity, signed contracts, project email threads
- Invoices, payments, banking references
Job applicants
- Résumé, cover letter, recruitment correspondence
04Why we collect this data
- Deliver and maintain our infrastructure services and the Manager;
- Notify you of incidents, changes, or maintenance windows;
- Provide 24/7 technical support;
- Ensure platform security (abuse detection, fail2ban, audit);
- Meet legal obligations (accounting, tax, judicial requisitions);
- Manage the commercial and contractual relationship.
05Legal basis
Per GDPR Article 6, each processing activity rests on one of the following bases:
- Contractual necessity — service delivery and invoicing;
- Legal obligation — accounting, tax retention, compliance;
- Legitimate interest — platform security, fraud prevention;
- Consent — where required (e.g. submitting the contact form).
06Retention period
Past these terms, data is irreversibly deleted or anonymised. Soft-deleted records remain accessible to a restricted set of administrators for audit purposes only.
07Hosting & sub-processors
Ancalagon is itself a hosting provider. All data is stored on our own infrastructure, in Belgium and Luxembourg, within Tier III or equivalent datacenters. We do not delegate storage, compute, or backups to US hyperscalers.
- Application hosting: Ancalagon infrastructure (BE / LU)
- Databases: self-hosted, replicated in Belgium
- Backups: self-hosted, encrypted at rest
- Transactional email: Ancalagon-internal SMTP servers
- No transfer outside the EU/EEA.
08Security
We apply reasonable technical and organisational measures to protect your data:
- TLS 1.3 encryption on all external connections;
- Passwords stored as bcrypt with per-record salt;
- Backups encrypted at rest (AES-256);
- Multi-factor authentication on all administrator access;
- Network segmentation, firewalls, intrusion detection (IDS);
- Centralised logging and 24/7 alerting;
- Security patches within 7 days for high-severity CVEs;
- Least-privilege access: data accessible only to staff who need it.
09Cookies & tracking
The site ancalagon.be uses no analytics, no advertising pixels, no third-party cookies. We don't track your browsing. We don't know who you are until you write to us.
The only local storage we perform is:
anca.lang— your language choice (FR / EN), stored in browserlocalStorage. This value never leaves your machine.
The Manager (manager.ancalagon.be) uses a strictly-necessary session cookie to keep you signed in. No analytics or marketing cookies are set.
10Your rights under GDPR
GDPR grants you the following rights. You can exercise them free of charge by writing to privacy@ancalagon.be. We reply within one month at most.
Right of access
Get a copy of the data we hold about you.
Rectification
Correct inaccurate or incomplete information.
Erasure («right to be forgotten»)
Request deletion of your data, subject to legal obligations.
Restriction
Freeze processing while a dispute is resolved.
Portability
Retrieve your data in a structured, readable format.
Objection
Object to processing based on legitimate interest.
Automated decisions
We make no automated decisions about you.
Withdrawal of consent
When processing relies on consent, you can withdraw it anytime.
// we may ask for reasonable proof of identity before responding, to avoid a third party exercising your rights on your behalf.
11Data breach
In case of a breach likely to result in a risk to your rights and freedoms, we will notify the Belgian Data Protection Authority (APD/GBA) within 72 hours of becoming aware, per GDPR Article 33. If the risk is high, you will be notified directly by email.
12Changes to this policy
This policy may evolve: new services, legal changes, contractual requirements. Any material change will be flagged by email to affected users and published on this page with a new updated stamp.
13Contact & complaints
For any question on your data or this policy, write to us. A real person will reply — not an automated ticket.
privacy@ancalagon.be
Reply within one month max (GDPR art. 12.3) — usually within days.
If you feel your rights are not respected, you may lodge a complaint with the competent supervisory authority: