Last updated on 25 May 2023
This cookie policy explains what cookies are and how they are used (hereafter the “Cookie Policy”). It is addressed to the public accessing the Website (hereinafter the “Visitor(s)”, “Users” or “you”).
Hardy.Digital Sprl (hereinafter “Avroy Tech”, “we”, “us”) is a Belgian-incorporated company having its registered seat at Rue Charles Martel 8, 1000 Brussels, Belgium (Commercial registry number: 0695.438.035).
We advise you to read both the Privacy Policy and the Cookie Policy as both are important for the protection of personal data.
This Cookie Policy applies to all websites operated by Avroy Tech and notably avroy.tech (hereinafter the “Website”).
As you first access our Website a Cookie Banner appears requesting that you accept the use of our cookies..
By accessing the Website and clicking the “accept” button, you accept the use of cookies in accordance with the terms of this Cookie Policy. Should the Visitor choose not to consent to our Cookie Policy, they are kindly requested to leave the Website.
We reserve the right to amend both our Cookie and Privacy Policies. The Visitor is asked to regularly consult these Policies to stay informed.
If you have any questions about how we collect, store and use your personal information, please read our Privacy Policy which is accessible below. If you have any questions about how we use cookies, please contact us at hello@avroy.tech
A cookie is a small text file that we store on your device (desktop pc or mobile device) when you visit the Website. We do so to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, to spare you the burden of re-entering them upon your next visit or as you browse through the Website's pages.
Cookies are also used to collect data on how the Website is accessed to improve their overall performance in terms of speed and functionality/ease of use.
Cookies do not operate independently from the Website. They can be read only by the Website operator.
These cookies are necessary to enable web browsing and different functions attached thereto. The cookies allow you to navigate from one webpage to the next and store information necessary for filling in forms. Should You refuse these cookies, then different Website functions will be hindered (either completely or partially).
These cookies facilitate and improve your overall browsing experience by enabling you to personalise the settings. From our end, these allow us to count visits and traffic sources in order to measure and improve our site performance. They also inform us on which pages are the most and least popular, as well as give us visibility on how visitors move around the site. Note that the information collected by these cookies is aggregated and therefore anonymous. If you do not enable these cookies, we will not see when you have visited our site, and will not be able to monitor its performance.
These cookies allow the website to offer enhanced functionality and personalisation. These may be set by us or by third party providers whose services we have added to our pages. The purpose is to give you a more personalised experience on our site based on your visit history and selections. If you do not enable these cookies, then some or all of these services may not function properly.
These cookies may be put on our site by our advertising business partners with a view to using and sharing by those companies to build a profile of your interests and show you relevant adverts on other sites. This is carried out by uniquely identifying your browser and internet device. If you do not enable these cookies, you will receive less targeted advertising.
These cookies are used to analyse and identify the behaviour of our web visitors. Among others, your IP address on the device will be tracked to identify you when you visit our site. If possible, we may combine your online web behaviour data with your previously submitted personal data. This will be used to analyse behaviour on our site and to personalise your experience with us.
The data collected from the cookies will be used in line with our Privacy Policy. In this respect, we only share your data with third party acting on our behalf and in line with our policies.
First and foremost, any personal data collected through the cookies is used to improve your browsing experience and to improve our Website. We further use such personal data to study purchasing behaviour and preferences for our general market research.
Information on cookie duration can be found here.
In order to ensure access to, rectification of, and the ability to withdraw consent at any time concerning your personal data you can always manage the use of cookies through your personal web browser’s settings. The web browser can be configured to either block all, accept/block some or accept all cookies.
Should you choose to erase or block certain cookies, you will probably experience difficulties operating the Website. Blocking cookies impacts the ease and functionality of web browsing. For example, refusing all cookies will impede web transactions.
Every web browser has its own configuration, please refer to your browser’s user manual for more information.
This Website privacy policy provides you with details about the personal information (hereinafter the “data”) Hardy.Digital Sprl, a Belgian-incorporated company having its registered seat at Rue Charles Martel 8, 1000 Brussels, Belgium (Commercial registry number: 0695.438.035) (hereinafter “Avroy Tech”, “we”, or “us”) collects from persons visiting its website (hereinafter the "Visitor(s)", the “Users” or “you”), how and why we use your data and your rights to control personal information We hold about you.
The concept of “data” encompasses all the personal data relating to yourself and more specifically any information that allows us to directly or indirectly identify you as a natural person.
We recommend you to read this privacy policy carefully in order to understand our practice in the processing of your data and to be informed of the last version of this privacy policy.
The protection of your data and your privacy is of the utmost importance to us and we therefore ensure to comply with data protection laws including EU Regulation 2016/679 of 27 April 2016 on the protection of personal data (the "GDPR")”and any other implementing act or regulations.
The data controller responsible for the processing of Your data is Avroy Tech. As a data controller we solely and autonomously determine the purposes of the processing of Your data as well as all corresponding criteria. For any further information on our data protection practices or concerning your personal data as a Visitor, please contact us at hello@avroy.tech.
First, we may collect the information that you submit to us voluntarily when entering into a business relationship with us or registering with one of our services or events, such as your email address, first and last name, company, country, phone number .
In addition thereto, we may collect supplemental information about your device, our your use of our services (e.g. device network connections (Wifi) and Internet protocol (IP) address, geolocation information (e.g. GPS), address book, and biometric data etc), in ways that we describe in the relevant privacy policy or enrolment form, or otherwise with your explicit consent (e.g. for newsletters).
Further to that, we may process your personal data as necessary for the performance of an agreement we have with you, or as required by law, or in accordance with your explicit consent for such processing, or in a matter commensurate to our legitimate interest and provided that your fundamental rights and freedoms are safeguarded. Our legitimate interest may include the need to personalise our content or website or other general information, to collect information about your experience with our services in order to improve the latter, or the need to better understand your concerns and needs in order to develop innovative service offerings and further develop our activities (including for troubleshooting, data analysis, testing, research, statistical and survey purposes or to administer a contest, promotion, survey or other site feature).
We will not disclose, sell or rent your personal data to any third party, except as described in this privacy policy. We may share personal data with affiliates or third parties who perform data processing activities on our behalf, and only insofar as this is necessary. As far as these service providers are acting as data processors, on our behalf, we do not authorise them to use or disclose the data in any way except as specified in this privacy policy. We require that these data processors appropriately safeguard the privacy and security of the personal data they process on our behalf. We may disclose your personal information where we are required to do so
(i) by applicable law
(ii) by a governmental body
(iii) by a law enforcement agency or
(iv) in connection with an investigation of suspected or actual fraudulent or illegal activity.
We keep your data in the EEA whenever possible.
We may have to transfer your data to a country outside the EEA, including to countries that would not offer a sufficient level of protection pursuant to the criteria set by the EEA (e.g. a transfer to a subsidiary located outside the EEA. In such an eventuality, we will guarantee an appropriate level of protection for your data by resorting to standard EU contractual clauses or any other means so as to guarantee that your data will be transferred in a secure environment.
For all the purposes defined here above, and within the limits provided by applicable data protection laws, you have rights as a data subject. Avroy Tech wants you to be aware of these rights, namely:
− the right to ask us to provide you with copies of personal information that we hold about you at any time,
which include the right to ask us: whether we process your personal data, for what purposes; the
categories of data; the recipients to whom the data are shared;
− the right to ask us to update and correct any out-of-date or incorrect personal information that we hold
about you free of charge;
− the right to withdraw your consent where such consent has been given;
− the right to erasure within the limits afforded by data protection legislation;
− the right to data portability within the limits afforded by data protection legislation.
Where we process your data for our legitimate interests, you have the right to object to the processing of your data. However, according to our legitimate interests, we may continue to process your data after a careful balancing of your interests with the ones of Avroy Tech.
When Avroy Tech processes your data for direct marketing purposes, you always have the right to opt-out, at first request and free of charge, of any direct marketing communications.
You can exercise your objection right from the emails we send you or by sending us an email explaining what you would like to object to at hello@avroy.tech.
You may at any time exercise the abovementioned rights in accordance with data protection regulations, by sending us a written request to hello@avroy.tech, and subject to complying with our reasonable requests to verify your identity.
In the event of a conflict concerning the processing of your personal data, you can contact our Data Protection Officer by email at hello@avroy.tech.
You can also lodge a complaint to the Belgian Data Protection Authority by completing the form on their website at https://www.dataprotectionauthority.be/citizen/actions/lodge-a-complaint.
We will not store your personal data beyond the time necessary for the performance of the purposes for which the data is processed. Specifically, we distinguish between a retention period and an archiving period:
We take appropriate technical and organisational measures to safeguard and protect your personal data, against unauthorised or unlawful processing and against accidental destruction, loss, access, misuses, damage and any other unlawful forms of processing of the personal data in our possession.
Changes to our Privacy Policy
We may revise our Privacy Policy from time to time to reflect changes to our business, services or relevant laws. Any changes we make to our Privacy Policy in the future will be posted on this page with immediate effect from the date of publication and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.
If you have any questions or comments about this privacy policy, if you would like to exercise your rights, or to update the information we have about you or your preferences, please contact us by email at hello@avroy.tech.
Welcome to the website https://www.avroy.tech/ (hereinafter the “Website” ), brought to you by Hardy.Digital Sprl, a Belgian-incorporated company having its registered seat at Rue Charles Martel 8, 1000 Brussels, Belgium (Commercial registry number: 0695.438.035 (hereinafter “Avroy Tech”, “we” or “us”).
These Terms of Service (hereinafter the “Terms”) are directed at all public users of the Website (hereinafter the “Visitor(s)”, “Users” or “you”), and govern your use of and access to the Website.
By accessing the Website, you acknowledge having been informed of and explicitly agree to these Terms as well as the Privacy and Cookies Policies. Should you disagree with these Terms or Policies you are kindly requested to leave the Website and clear your cookies..
The Website is provided exclusively as an informational resource to describe our consultancy services. More concretely, the consultancy services advertise on our Website include but are not limited to our regulatory expertise in Fintech, payments, and digital assets space, particularly in the EU and broader European region (e.g. UK, Switzerland). By visiting the Website, you accept that such use is for informational purposes only and that the information might not be up-to-date.
Avroy Tech will use all reasonable efforts to keep the content up-to-date and correct. However, not all information may be current or complete. Avroy Tech does not guarantee the accuracy of the content and none of it should be considered to be, or relied upon as, legal, financial or tech advice.
The text, layout, illustrations on the Website or any other content are protected by Avroy Tech’s or its affiliates’ copyright, trademark, or other rights (intellectual property and other). Thus, all content remains Avroy Tech’s property even once downloaded.
Unless otherwise specified, information (textual or numeric) may be used freely so long as it is correctly referenced (i.e. Avroy Tech is mentioned as the source) and only for non-commercial and non-advertising purposes (i.e. scientific, educational, or purely private ends). However, any use of other aspects of content, such as the images, sound or layout, is strictly prohibited without Avroy Tech’s prior written approval.
The site contains no advertisement for any digital currencies nor legal, tax, or financial advice. To the extent that virtual currencies or assets are mentionned, we do so to explain the technology or make a larger point as part of a larger thesis. The site does not distribute virtual currencies and no compensation is received by us when a virtual asset is mentioned on the website.
As noted by the Belgian Financial Services and Markets Authority: 'Virtual currencies, real risks. The only guarantee in crypto is risk.'
Before dealing with digital assets, you should be aware of the different considerably high risks associated with them such as transaction confirmation times, the irreversible and immutable nature of transactions, possible inherent technical defects and regulatory uncertainties. In particular, risks inherent to digital assets include, but are not limited to, the following:
In light of the foregoing, you understand and agree that your use of this Website and the information it displays is conducted at your own risk. This section is not exhaustive and does not disclose all the risks associated with digital assets and the use of our Website. Should you wish to purchase digital or virtual assets, you should, therefore carefully consider whether such use is suitable for you in light of your particular circumstances and financial resources. Nothing we publish should be used as basis of that consideration.
To the extent permitted by law, Avroy Tech will not be held liable for any damage that may result directly or indirectly from using the Website.
The use of any information obtained from or through the Website is done at the Visitor’s own risk.
To the extent permitted by law, Avroy Tech’s declines any liability relative to decisions made on the basis of information obtained from or through the Website.
Avroy Tech does not guarantee the Website’s effective operation and functional performance. To the extent permitted by law, Avroy Tech declines all liability in the case of any defect or unavailability, or in the case of any other direct or indirect damage that may arise in connection to accessing or using the Website. Avroy Tech is not liable for any damage owing to any service interruptions, technical errors, viruses or any other factors beyond Avroy Tech’s control.
Avroy Tech bears no liability in connection to any third party websites and does not condone any content made available through them. The content of any third party websites or apps is the exclusive liability of those third party operators.
Avroy Tech may process your personal data as agreed and described in its Privacy Policy. Any data protection enquiries can be made to hello@avroy.tech.
The Website uses a certain number of Cookies, as agreed to and described in its Cookie Policy.
Avroy Tech reserves the right, at its sole discretion, to amend, complete or otherwise modify these Terms at any time and without notice. If you do not agree with these amendments, or any particular amendment, you may not be able to continue to use the Website.
The Website is made publicly and freely available to all Visitors. You agree to use the Website and the content solely for lawful purposes. The content may only be used for non-commercial and private purposes.
You may not, knowingly or unknowingly, use any harmful software or introduce any harmful programs or files (i.e. a virus) to access the Website, distort the content, or disrupt services. You will exercise reasonable care to avoid and prevent any of the foregoing. You may not distort, modify or otherwise manipulate the Website or content in any manner whatsoever.
Avroy Tech disclaims any and all warranties, expressed or implied, in connection with the use of this Website. The Website is provided “as is” and “as available” and at your own risk, and Avroy Tech does not warrant or represent any quality, fitness for purpose, non-infringement, completeness or accuracy of the Website. Regardless of our efforts to provide you with a Website of the highest quality, safety and security, we make no warranty that the Website will be uninterrupted, timely or error-free or that defects will be corrected.
Avroy Tech reserves the right, periodically and at any time, to modify or discontinue, temporarily or permanently, functions and features of the Website, and we will not be liable to you for any interruption, modification, or discontinuation of the Website or any function or feature thereof. Avroy Tech is not responsible for any difficulties in operating or using the Website that are caused by the web hosting service provider, internet service provider of the User or any other third party, unless prescribed otherwise by applicable law.
Avroy Tech does not provide any financial, legal, tax or investment advice or recommendations on its website. None of the information or analyses presented are intended to form the basis for any investment decision, and no specific recommendations are intended. Our Website is not, does not offer, and shall not be construed as advertisement, investment or financial products. You are solely responsible for determining whether any of the content on our Website is appropriate for you based on your personal objectives, financial circumstances and risk tolerance. You agree and understand that under no circumstances will the operations of Avroy Tech and your use of our Website be deemed to create a relationship that includes the provision of or tendering of any form of advice. You should consult your legal, investment, or tax professional regarding your specific situation.
You agree to indemnify, defend, and hold harmless us and our third party service providers from and against any claim, demand, loss, damage, cost, or liability (including reasonable attorneys' fees) arising out of, or relating to, your use or misuse of the Website, breach or alleged breach of any of these Terms and the violation of any rights (including intellectual property rights) of a third party.
Any activity or behaviour contrary to these Terms or Avroy Tech’s failure to enforce them can never be deemed a waiver of Avroy Tech’s rights under said Terms.
If any one or more of the provisions of these Terms is found to be void, invalid, illegal or unenforceable in any respect, the validity, legality and enforceability of the remaining provisions contained herein will not be affected or impaired. The invalidated provision will be replaced with a provision that adequately reflects the parties’ initial intention.
This agreement may not be assigned or transferred by you, without the prior written consent of Avroy Tech. We may assign our rights and transfer our obligations at any time provided we ensure that your rights are still adequately safeguarded after that transfer.
The User understands that we reserve ourselves the right without any prior notice to terminate this agreement, including but not exclusively, by restricting access to the Website or shutting down its operation entirely.
Moreover, upon any User’s infringement of any of these Terms or of the law, Avroy Tech has the sole right to terminate User’s access immediately without any prior notice.
These terms constitute the entire agreement between you and us in relation to the subject matter hereof. This Agreement supersedes any and all prior or contemporaneous written and oral agreements, communications and other understandings (if any) relating to the subject matter of the terms.
By accessing the Website, you agree to these Terms, and further accept the application of Belgian law.
Any dispute arising in connection to these Terms and/or the Website is the exclusive jurisdiction of the Brussels Courts, unless otherwise required by mandatory law.
If you have any questions or comments about these Terms, please contact us here hello@avroy.tech