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Promo Sapiens – Privacy notice
Please read this Privacy Notice carefully. It explains why and how we collect your personal data, how we protect it and for how long we retain it. We keep your data as secure as reasonably possible and protect it from loss and unauthorized disclosure or access and we handle your personal data in strict compliance with applicable data protection laws, in particular the General Data Protection Regulation 2016/679 of 27 April 2016 (“GDPR”).
This Privacy Notice has been prepared as a Q&A (“Questions & Answers”) list.
- Who will process my personal data?
In the course of your activity on the https://www.promosapiens.be/ website, we collect and use personal data relating to you, an individual (hereinafter “Data Subject”).
The controller of your personal data is the following legal entity:
Tollaan 95 – 1932 Sint-Stevens-Woluwe
Company number: BE 0437.062.895
Hereinafter referred to as the company.
- What are the purpose and legal basis for processing my personal data?
We collect your Personal Data for specific purposes and on different legal grounds.
In the context of the execution of the contract or pre-contractual measures, your Data is processed for the following purposes:
- Contract management.
- Management of your client account.
- Complaints and after-sales service management.
- Management of jobs’ applications sent from the online forms on our website.
On the basis of your consent, your Data is processed for the following purposes:
- Carrying out commercial and marketing prospecting operations.
- Transmission of your Data to our commercial partners.
- Management of the newsletter.
- Management of cookies requiring your consent.
In the framework of the legitimate interest of PROMO SAPIENS, your Data are processed for the following purposes:
- Establishment of statistics for the improvement of products and services.
- Carrying out satisfaction surveys.
- Management of pre-litigation and litigation.
- What categories of personal data will be processed?
Personal data includes any information relating to you or allowing you to be identified. Anonymous data without the possibility of identifying you are therefore not considered personal data.
By using our website, you provide us with a certain amount of information about yourself, some of which may identify you (“Personal Information”). This is the case when you browse our site or when you fill in online forms.
The nature and quality of the Personal Data collected about you will vary depending on the relationship you have with our company. For the purposes set out above, the processing of personal data includes:
- Identification data: This includes all information that would allow us to identify you, such as your name, first name, telephone number. We may also collect your e-mail address, as well as your postal address (in case of payment, the postal address will be necessary to generate an invoice).
- Authentication data: This is all the information we need to access your personal account, such as password, and other information necessary to authenticate and access an account. We also collect your IP address for maintenance and statistical purposes.
- Financial data: this corresponds to banking data such as bank details
- Documents of different kinds (PDF, Microsoft Office, Image) with titles, contents, folder names, or information related to a document, such as comments written in the documents, alert and reminder dates.
- Browsing information: by browsing our website, you interact with it. As a result, some information about your browsing is collected.
- Data collected from Third Parties: Personal Data that you have agreed to share with us or on publicly available social networks and/or that we may collect from other publicly available databases.
- Who will have access to my personal data?
Your Data are intended for the authorized employees of our company in charge of the management and the execution of the contracts and legal obligations, according to the purposes of the collection and within the limits of their respective attributions.
It may be transmitted for certain tasks related to the purposes, and within the limits of their respective missions and authorizations, to the following recipients:
- PROMO SAPIENS services such as Human Resources Department, Commercial Department, Marketing Department etc.
- Service providers and subcontractors that we use to carry out a range of operations and tasks on our behalf, including data hosting, commercial prospecting etc.
- Duly authorized public authorities (judicial, control…), in the framework of our legal and regulatory obligations.
- Regulated professions (lawyers, bailiffs, etc…) who may intervene in the context of the implementation of guarantees, collection or litigation.
The employees, managers and/or representatives of the above-mentioned service providers or institutes and the specialised service providers appointed by them must respect the confidential nature of this data and may only use this data in line with the instructions of the company.
- Will my personal data be transferred outside my country of residence?
Our company strives to keep the Personal Data in Belgium, or at least within the European Economic Area (EEA).
However, it is possible that the Data we collect when you use our platform or services may be transferred to other countries. This is for example the case if some of our service providers are located outside the European Economic Area
In the event of such a transfer, we guarantee that it will be carried out:
- To a country ensuring an adequate level of protection, i.e. a level of protection equivalent to what the European Regulations require.
- Within the framework of standard contractual clauses.
- Within the framework of internal company rules.
- Will the company use automated decision-making?
Automated decision making is defined as decisions about individuals which are based solely on the automated processing of data and which produce legal effects concerning them or significantly affect them.
The company’s guiding principle is not to use automated decision-making as described above.
- How long will my personal data be kept?
Your personal data will not be kept longer than necessary for the purposes stated above and/or to meet your needs and/or our legal obligations.
Retention times vary depending on several factors, such as:
- PROMO SAPIENS business needs.
- Contractual requirements.
- Legal requirements.
- Recommendations from regulatory authorities.
- What rights can I invoke in connection with the processing of my personal data by the company?
The GDPR provides Data Subjects with rights that they can exercise. Thus, are provided:
- Right to information: the right to have clear, precise, and complete information on the use of Personal Data by PROMO SAPIENS.
- Right of access: the right to obtain a copy of the Personal Data that the Data Controller holds on the applicant.
- Right to rectification: the right to have Personal Data rectified if they are inaccurate or obsolete and/or to complete them if they are incomplete.
- Right to erasure / right to be forgotten: the right, under certain conditions, to have the Data erased or deleted, unless PROMO SAPIENS has a legitimate interest in keeping it.
- Right to object: the right to object to the Processing of Personal Data by PROMO SAPIENS for reasons related to the particular situation of the applicant (under conditions).
- Right to Withdraw Consent: the right at any time to withdraw Consent where Processing is based on Consent.
- Right to restriction of processing: the right, under certain conditions, to request that the Processing of Personal Data be temporarily suspended.
- Right to Data Portability: the right to request that Personal Data be transmitted in a reusable format that allows it to be used in another database.
- Right to Avoid Automated Decision-Making: the right of the applicant to refuse fully authorized decision-making and/or to exercise the additional safeguards offered in this regard
To exercise your rights, you may contact the Data Protection Officer (DPO): email@example.com
When you send us a request to exercise a right, you are asked to specify as far as possible the scope of the request, the type of right being exercised, the Personal Data Processing concerned, and any other useful information, in order to facilitate the examination of your request. In addition, in case of reasonable doubt, you may be asked to prove your identity.
- How do we ensure the security of your Personal Information?
Our company is committed to protecting the Personal Data we collect, or that we process, from loss, destruction, alteration, unauthorized access, or disclosure.
Thus, we implement all appropriate technical and organizational measures, depending on the nature of the Data and the risks that their Processing entails. These measures must preserve the security and confidentiality of your Personal Data. They may include practices such as limited access to Personal Data by persons authorized by their functions, pseudonymization or encryption.
In addition, our practices, and policies and/or physical and/or logical security measures (secure access, authentication process, backup, software, etc.) are regularly reviewed and updated as necessary.
We reserve the right to modify this Privacy Notice from time to time, subject to applicable privacy and data protection regulations.