Project BV, with its registered office at Boskouter 26, 3010 Kessel-Lo, registered in the Crossroads Bank for Enterprises (KBO) under number 0767.806.171.is responsible for the processing of personal data as shown in this privacy statement.
Introduction:
Project BV respects your privacy and ensures that you can trust us with your personal data.
Personal data is processed by us in accordance with the Belgian Data Protection Act and the provisions of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter, "GDPR Regulation"). We want to inform, respect and give you as much control as possible over what happens to your personal data. Below you will find information about what data we collect, why we do it, how long we keep it, what your privacy rights are and how you can exercise them.
1. Scope of this privacy policy:
This privacy policy applies only to the personal data that we process as a data controller.
It applies to the processing of personal data of our customers in relation to our products and services, as well as to personal data of third parties that we need to process for the execution of our agreement.
This privacy statement applies when you visit our offices, our website, our newsletter, or in any other way when you use, our products or services.
We also try to process and secure the personal data of our former customers or prospects as well and as carefully as possible, in accordance with this privacy statement.
2. What does 'processing of data' mean and who is responsible for it?
a. Definition
By 'processing of personal data' we mean any processing of data that can identify you as a natural person. The concept of 'processing' is broad and covers, among other things, the collection, recording, organization, storage, updating, amendment, retrieval, consultation, use, dissemination or making available in any way, compilation, combination, archiving, erasure or eventual destruction of such data.
For the avoidance of doubt, a processing of personal data of business customers only applies if the business customer is a natural person, or - if the business customer is a legal person - then the privacy policy only applies to the personal data of the natural persons that we process in the context of their relationship with the business customer.
b. Processor
BV Project, with its registered office at Boskouter 26, 3010 Kessel-Lo and registered with the KBO under no. 0767.806.171 is the data controller of your data. This means that BV Project determines the purpose and means of processing your personal data.
3. Collection of personal data
a. How do we collect your personal data?
We process the personal data that you give us yourself.
You may choose to provide us with your personal data at different times and in response to different situations. For example, you can provide us with data when you want to communicate with us, request information from us, call us, when a document, a contract, etc. needs to be drawn up. When you want to come and work for us, you may give us access to your personal data.
In short, whenever you come into contact with us.
Very often we will ask your permission to process these data, but not always. Sometimes we need to process personal data purely out of necessity for the execution of the agreement we have with each other, or we need to process personal data from a legal obligation (e.g. anti-money laundering legislation)
b. What data do we process from you?
We distinguish different types of personal data, which may be combined with each other:
- Identification data, such as, among others: name, address, nationality, gender, e-mail, telephone number ...
- Financial data, such as, among others: account number(s), payment history, benefits, insurance, subsidies ..;
- Electronic data, such as, among others: IP address, location, .....
- Social, community and work related data, such as but not limited to: position, job history, licenses, diplomas.
4. For what purpose and on what basis we process personal data:
a. Proportionate and necessary nature of the processing.
We process w personal data for various purposes, but in each case we only process the data necessary to achieve the purpose.
For example, the processing of your personal data is necessary for the following purposes:
- In the context of the preparation, execution or termination of our contract;
- within the framework of the obligations of the office with regard to the Belgian government or foreign governments, in execution of legal or regulatory obligations, in execution of a court decision, within the framework of the protection of a legitimate interest, ...(e.g. in the context of the application of the Law of 18 September 2017 on the prevention of money laundering and the financing of terrorism and on limiting the use of cash);
- implementing marketing strategies (e.g. sending newsletters).
Without the provision and processing of this data, we cannot properly carry out our mission.
If the processing of your personal data is not necessary for any of these reasons, we will always ask for your consent to process your data.
b. Purpose of processing personal data
Your personal data will be processed by us for the conclusion and execution of contracts with our partners and in order to provide you with substantive advice, to carry out the tasks entrusted to it by you or by law and to manage our relationship with you, including any communication to keep you informed of new developments (including carrying out activities aimed at increasing the customer base and marketing purposes).
Your personal data may also possibly be used for processing in publications, taking into account the circumstances and on an anonymous basis.
For the same purposes, your data may be transmitted to employees working on an independent basis within our company (BV Project), as well as to our carefully selected correspondents who may be involved in the processing of your file and who are subject to the same obligation of professional secrecy and confidentiality.
5. How do we secure your personal data?
a. Principle
We want to protect your personal data and maintain its accuracy. Therefore, we reasonably implement all physical, administrative and technical security measures to protect your personal data from unauthorized access, unauthorized use and unauthorized disclosure.
We also require our suppliers to protect such data from unauthorized access, unauthorized use and unauthorized disclosure.
b. Organizational measures.
Our staff and employees are trained to handle confidential data correctly. In the context of any project involving the processing of personal data, an assessment is first made in terms of security and the protection of personal data, whereby your interests take precedence.
Our staff and employees are granted access to your personal data only to the extent that they need that information to properly perform their duties.
c. Technical measures
We use a variety of technical measures to protect your personal data from unauthorized access, unauthorized use, and loss or theft of your data, such as: password protection, firewalls, antivirus....
Should a data leak occur with negative consequences for your personal data, then you as a customer will be personally notified in the circumstances provided by law.
6. Transfer of Personal Data
Data Transfers.
We do not sell personal data to third parties without your consent and we do not transfer it to third parties unless:
- There is a legal obligation.
- We may transfer the personal data at the request of any legally competent authority, or on our own initiative if we believe in good faith that the transfer of such information is necessary to comply with the law and regulations, or to defend and/or protect the rights or property of our firm, of you or of our website.
- To our legal successors and other companies in our group for the same purposes as those mentioned in this privacy policy, for example to inform you of the products and services of the entire group. In the event of non-payment, we may also transfer your payment habit in order to protect the legitimate interests of our group. In this context, the companies within the group qualify as joint processors.
- Which is necessary for our services. We make some of our databases accessible to third parties who work on our behalf and who assist us in providing our products and services. Think for example of our independent employees, IT company that maintains our network. Your data will only be passed on for the purposes for which Project BV processes your data itself and will be limited to the data they need to carry out their tasks.
necessary for the performance of their duties on our behalf. We ensure that they, like us, manage your data safely, respectfully and with due care and we provide adequate contractual safeguards for this; - You give us permission to do so.
- If in other situations we should transfer personal data to third parties, we will do so with an explicit notice explaining the third party and the purposes of the transfer and processing. Where required by law, we will obtain your explicit consent.
7. Your Privacy Rights and How to Exercise them
A. Summary of your rights
a. Right of inspection
You have the right at any time to learn from BV Project whether or not we are processing your personal data, and if we are processing it to inspect that data and receive additional information about:
- the processing purposes;
- the categories of personal data involved;
- the recipients or categories of recipients (in particular, recipients in third countries);
- if possible, the retention period or, if that is not possible, the criteria for determining that period;
- the existence of your privacy rights;
- the right to lodge a complaint with the supervisory authority;
- the information available to us about the source of the data if we obtain personal data through a third party; and
- the existence of automated decision-making.
You also have the right to obtain a free copy of the processed data, in intelligible form. BV Project may charge a reasonable fee to cover its administrative costs for each additional copy you request.
b. Right to correct personal data
You have the right to have incomplete, incorrect, inappropriate or outdated personal data corrected without delay.
In any case, in order to keep your data up-to-date, we ask you to notify us of any change, such as a move, the change of your e-mail address or a renewal of your identity card.
c. Right to erasure of you personal data
You have the right to have your personal data deleted in the following cases, and without unreasonable delay:
- your personal data is no longer needed for the purposes for which it was collected or otherwise processed by BV Project;
- you withdraw your previous consent for the processing and there is no other legal ground on which BV Project can rely for the (further) processing;
- you object to the processing of your personal data and there are no more weighty, legitimate grounds for the (further) processing by BV Project;
- your personal data are processed unlawfully;
- your personal data must be deleted to comply with a legal obligation;
- your personal data was collected when you were still a minor.
Please note, however, that we cannot always delete all the personal data requested, for example, if their processing is necessary for the establishment, exercise or substantiation of legal claims. We will inform you of this in more detail in our response to your request.
d. Right to restriction of processing
You have the right to obtain the restriction of the processing of your personal data if one of the following applies:
- you dispute the accuracy of that personal data: its use is restricted for a period that allows BV Project to verify the accuracy of the data;
- the processing of your personal data is unlawful: instead of deleting your data, you request the restriction of its use;
As long as a decision on the exercise of your right to object to the processing has not yet been made, you request that the use of your personal data be restricted;
e. Right to transferability of personal data ('data portability').
You have the right to 'recover' your personal data, for example to be able to change your service provider more easily. This is only possible for the personal data that you have provided to BV Project yourself, based on consent or after agreement. In all other cases, you can therefore not enjoy this right (for example, when the processing of your data is based on a legal obligation).
There are 2 aspects to this right:
- you can request BV Project to recover the personal data concerned in a structured, common and machine-readable form; and
- you can request BV Project to transfer the personal data concerned directly to another controller. In doing so, you are responsible for the accuracy and security of the (e-mail) address you provide for the transfer. BV Project has the right to refuse this if the transfer is technically not possible.
f. Right to object to the processing of your personal data
You have the right, based on your particular situation, to object to the processing of your personal data if the processing is in the legitimate interest of BV Project or in the public interest. BV Project will cease processing your personal data, unless BV Project can demonstrate compelling and legitimate grounds for processing which outweigh your interests or if the processing of the personal data is related to the establishment, exercise or substantiation of a legal claim (for example, the submission of a request to a court).
B. Practicalities: how to exercise them
a. To whom should you apply?
If you wish to exercise any of your rights, you may send a written request to that effect to BV Project, with registered office at Boskouter 26, 3010 Kessel-Lo and at the e-mail address
b. Are there any costs involved?
You can exercise your privacy rights free of charge, unless your request is manifestly unfounded or excessive, in particular due to its repetitive nature. In such a case, we have the right and choice - in accordance with privacy laws - to (i) charge you a reasonable fee (taking into account the administrative costs of providing the requested information or communication and the costs associated with taking the requested measures), or (ii) refuse to act on your request.
c. In what format will you receive a response?
If you submit your request electronically, the information will be provided electronically where possible, unless you request otherwise. In any event, we will provide you with a concise, transparent, understandable and easily accessible response.
d. When will you receive a response?
We will respond to your request as soon as possible, and in any event within one month of receiving your request. Depending on the complexity of the requests and the number of requests, this period may be extended by a further two months if necessary. If the deadline is extended, we will inform you of this within one month of receipt of the request.
8. Retention of your personal data?
We are not allowed to keep personal data longer than necessary to realize the purpose for which we collect them. The retention period may therefore differ for each purpose. Sometimes the period may also be longer, for example to meet our legal obligations (for example, to meet our accounting and tax obligations we are required to keep your billing information for up to 7 years)
After the end of the applicable retention period(s), personal data will be deleted or anonymized.
9. Change privacy policy
BV Project may amend this privacy policy from time to time, for example, in response to new market conditions or because we are carrying out new activities.
We will inform you in advance about the changes in content and request permission for our new processing activities when the legislator deems it necessary.
10. Data Protection Authority
We would also like to inform you that you have the option of submitting a complaint to the national supervisory authority in connection with the processing of your personal data. This can be done through the following contact details:
Commission for the Protection of Privacy
Drukpersstraat 35, 1000 Brussels
+32 (0)2 274 48 00 +32 (0)2 274 48 35
11. Dispute resolution
Our privacy declaration and policy is governed by Belgian law.
Any dispute relating to the interpretation or interpretation of this privacy statement shall be governed by Belgian law and falls within the exclusive jurisdiction of the courts of the jurisdiction in which Project BV has its registered office.