Privacy
The simplest way to protect personal data is not to collect it.
Proper Tools is a small independent practice based in Brussels. This notice explains what personal data Proper Tools receives, why it is used, who may process it, how long it is kept, and the choices available to you.
Proper Tools SRL is the data controller for the processing described here.
Questions and requests can be sent to hello@propertools.be.
Proper Tools SRL ∷ Avenue Arnaud Fraiteur 15/23, 1050 Brussels, Belgium ∷ BCE/KBO 1033.362.180
What is collected, and why
Visiting the website
This is a static website. Proper Tools does not use visitor analytics, behavioural advertising, tracking pixels, or session recording.
Proper Tools does not intentionally use cookies for analytics, advertising, or visitor profiling. Ordinary browsing of this site does not depend on cookies set by Proper Tools.
Hosting infrastructure and websites reached through external links may use cookies or similar technical mechanisms under their own policies. If the way this site uses such technologies changes materially, this notice will be updated.
The site is currently hosted through GitHub Pages. GitHub records visitors’ IP addresses for security purposes. Proper Tools does not receive or use those logs for analytics, profiling, or marketing.
Subscribing to Field Notes
When you subscribe, Proper Tools receives your email address and the information needed to record and manage your subscription.
The address is used only to send Field Notes and essential subscription messages. Open and click tracking are disabled. Subscribers are not added to other lists.
The legal basis for this processing is your consent. You may withdraw that consent at any time by using the unsubscribe link in an email or writing to Proper Tools.
Writing to Proper Tools
When you send an email, make an enquiry, or begin a professional relationship, Proper Tools may receive your name, contact details, message, attachments, and any other information you choose to provide.
That information is used to respond, assess whether work is a fit, provide requested services, maintain the relationship, and meet contractual, accounting, or legal obligations.
Depending on the circumstances, the legal basis is taking steps at your request before entering a contract, performing a contract, complying with a legal obligation, or Proper Tools’ legitimate interest in conducting and documenting its work.
Please do not send highly sensitive, regulated, or confidential material through ordinary email unless the need and an appropriate channel have been agreed first.
Working in a shared document
When collaboration takes place through Google Docs or another shared workspace, the service may process your name, email address, comments, edits, and document activity according to its own terms.
Proper Tools uses shared documents only where they are useful to the work and limits access to the people involved.
What Proper Tools does not do
- Proper Tools does not sell, rent, or trade personal data.
- Proper Tools does not buy personal data or use data brokers.
- Proper Tools does not run behavioural advertising.
- Proper Tools does not profile website visitors.
- Proper Tools does not make decisions about people using automated scoring or automated decision-making.
- Proper Tools does not add correspondents or clients to the Field Notes list without their consent.
Services that may process personal data
Proper Tools uses a small number of providers where they are needed to operate the site, deliver email, communicate, or collaborate.
- GitHub Pages hosts the public website and records visitor IP addresses for security.
- Listmonk manages the Field Notes subscriber list on a Proper Tools instance at herald.propertools.be.
- Postmark delivers Field Notes and related subscription messages. It processes email addresses, delivery information, and message content needed to provide that service.
- Proton Mail provides email services and processes the message content and metadata involved in correspondence.
- Google Docs may be used for collaborative drafting or review where the participants agree to work there.
These providers process data under their own terms and privacy notices. Some operate or use infrastructure outside the European Economic Area.
Where personal data is transferred outside the EEA, the transfer is made using an applicable adequacy decision, standard contractual clauses, or another safeguard recognised under data protection law.
External services change. This list is reviewed when the way Proper Tools operates changes materially.
How long information is kept
Personal data is kept only while it remains needed for the purpose for which it was collected, or while a legal or contractual reason requires it to be retained.
- Field Notes subscriptions remain active until you unsubscribe. After unsubscribing, a minimal suppression record may be retained so that further messages are not sent by mistake.
- Ordinary enquiries are kept while needed to answer the question and maintain reasonable continuity, then reviewed and deleted when they no longer serve that purpose.
- Client and supplier records are kept for the duration of the relationship and for any further period required for contractual, accounting, tax, insurance, dispute-resolution, or other legal purposes.
- Working documents are retained while they remain useful to the work, the record of a decision, or an applicable professional obligation.
Service providers may retain operational records according to their own documented schedules. Postmark, for example, retains message content and delivery metadata for a limited delivery-history period and may keep suppression records needed to prevent unwanted mail.
Your rights
Depending on the processing and the circumstances, data protection law may give you the right to:
- ask what personal data Proper Tools holds about you;
- receive a copy of that data;
- correct inaccurate or incomplete data;
- ask for data to be erased;
- restrict how data is used;
- object to processing based on legitimate interests;
- receive portable data where that right applies; and
- withdraw consent without affecting earlier lawful processing.
Send a request to hello@propertools.be. Enough information may be requested to confirm your identity and locate the relevant records.
Proper Tools will respond without undue delay and ordinarily within one month. Where a request is particularly complex or numerous, the period may be extended as the GDPR permits; you will be told within the first month if that is necessary.
Requests are normally handled without charge. The GDPR permits a reasonable fee or refusal where a request is manifestly unfounded or excessive.
You also have the right to complain to the Belgian Data Protection Authority or, where applicable, another competent supervisory authority.
Security
Proper Tools uses access controls, encrypted connections, and service providers selected with the sensitivity of the information in mind.
Access to personal data is limited to what is needed to operate the practice and perform the relevant work.
No internet service or storage system is risk-free. If a personal data breach creates a material risk to people, Proper Tools will assess it and make the notifications required by law.
Changes to this notice
When this notice changes materially, the date and a brief description will be recorded here.
- — Substantially revised for clarity and to reflect the services and practices currently used by Proper Tools.
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