(Latest Update: 5th of March 2019)
Article 1 - General
horsum also respects the anti-spam provisions of Book XII of the Belgian Code of Economic Law concerning the " Law of the electronic economy ".
The person responsible for the processing of your personal data can be reached at:
Dok Noord 4C Bus 205
+32 9 378 38 28
Article 2 - Who does this privacy statement apply to and what does it cover?
We are committed to protecting your privacy and handling your information in an open and transparent manner.
This privacy statement sets out how we will collect, handle, store and protect information about you when:
- providing services to you or our clients;
- you use “our website” or;
- performing any other activities that form part of the operation of our business, as described in further detail below.
When we refer to “our website” or “this website” in this policy we mean the specific website, starting with “horsum.be”.
This privacy statement also contains information about when we share your personal data with third parties (for example, our service providers).
We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.
Article 3 - Which personal data do we collect?
In the course of providing services to you or our clients and performing due diligence checks in connection with our services (or discussing possible services we might provide), we will collect or obtain personal data about you. We may also collect personal data from you when you use our website.
We may collect or obtain such data because you give it to us (for example in a form on our website), because other people give that data to us (for example your employer or adviser, or third party service providers that we use to help operate our business) or because it is publicly available.
The personal data that we collect or obtain may include: your name, age, date of birth, gender, email address, telephone number, home address, country of residence, employment (for example, the organization you work for, your job title) and education details, your postings on any blogs, forums and any other social media applications and services that we provide, your IP address, your browser type and language, your access times; complaint details, details of how you use our products and services, details of how you like to interact with us and other similar information.
The personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your dietary requirements (for example, where horsum would like to provide you with a lunch during a meeting or a training).
The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you or our client, or how you use our website. In some rare circumstances, we might also gather other special categories of personal data about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.
We understand the importance of protecting children's privacy. Our website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.
Article 4 - How do we process your personal data?
Use of personal data to provide services to our clients
We will use your personal data to provide you or our client with the requested services. As part of this, we may also use your personal data in the course of correspondence relating to the services. Such correspondence may be with you, our client, our service providers or competent authorities. We may also use your personal data to conduct due diligence checks relating to the services. Because we provide different types of services to our clients, the way we use personal data in relation to our services also varies.
Use of personal data for other activities forming part of the operation of our business
We may also use your personal data for the purposes of, or in connection with:
- applicable legal or regulatory requirements;
- requests and communications from competent authorities;
- administrative purposes;
- financial accounting, invoicing and risk analysis purposes;
- client relationship purposes, such as: (i) sending you details of our products and services that we think might be of interest to you; (ii) contacting you to receive feedback on services; and (iii) contacting you for other marketing or research purposes. In all above cases, we give you the opportunity to decline our offers and requests at any time. In specific cases if needed, for example in case you are not yet a client, we will make sure to obtain your prior consent before sending you communications’ materials or other marketing requests (see also below, “What legal grounds do we use for processing your personal data?”);
- recruitment and business development purposes (for example testimonials from a client’s employees may be used as part of our recruitment and business development materials with that employee’s permission);
- services we receive from our professional advisors, such as lawyers, accountants and consultants;
- protecting our rights and those of our clients.
Use of personal data collected via our website
In addition to the purposes connected to the operation of our business above, we may also use your personal data collected via our website:
- to manage and improve our website;
- to tailor the content of our website to provide you with a more personalized experience;
- to manage and respond to any request you submit through our website.
A "cookie" is a small file sent by horsum server and placed on the hard drive of your computer. The information stored on these cookies can only be read by us and only for the duration of the visit to the Website.
Although there are different types of cookies, distinguished in terms of functionality, origin or storage period, the legislation mainly distinguishes between functional or technically necessary cookies on the one hand and all other cookies on the other.
The website only uses following cookies:
- Drupal.tableDrag.showWeight (Drupal): To store user interface preferences; Storage = 10 minutes
- _ga (Google Analytics): Improve website performance; Storage = 2 years
- _gat (Google Analytics): Improve website performance; Storage = 10 minutes
- _gid (Google Analytics): Improve website performance; Storage =1 day
For cookies placed by third parties (including Google Analytics) we refer you to the statements that these parties give on their respective websites. Please note: we do not exert any influence on the content of these statements, nor on the content of the cookies of these third parties: Google Analytics cookies.
You can refuse or block cookies by changing the configuration parameters of your navigation system. Disabling cookies may mean that you cannot use certain features of the Website.
If you have any further questions or comments regarding the processing of your personal data, please contact us, either by email to firstname.lastname@example.org or by using the contact form on the Website.
More information about cookies can also be found at: http://www.allaboutcookies.org/.
More information on online behavioral advertising and online privacy can be found here: http://www.youronlinechoices.eu/.
Article 5 – Legal grounds used for processing your personal data
We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal data.
As a result, we use your personal data for the purposes outlined above because: (a) of the legal and regulatory obligations that we are subject to; (b) the information is required in order to provide our services to you or our client; (c) of our legitimate interests in the effective delivery of our services to you or our client.
To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) we are required by law to process that data in order to ensure we meet our ‘know your client’ obligations (or other legal obligations imposed on us); (iii) the processing is necessary to carry out our obligations under employment, social security or social protection law; (iv) the processing is necessary for the establishment, exercise or defense of legal claims or (v) you have made the data publicly available.
Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you.
If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in any such communication.
Article 6 – To whom do we disclose your personal data?
In connection with one or more of the purposes outlined in article 4 above, we may disclose details about you to: third parties that provide services to us; competent authorities (including courts and authorities regulating us; your employer and/or their advisers; your advisers; organizations that help us reduce the incidence of fraud and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “How do we use information about you?” section above).
Our website hosts blogs and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Important: any personal data that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any Social Media Applications will be handled in accordance with this privacy statement.
Please note that some of the recipients of your personal data referenced above may be based in countries outside of the European Union whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal data, so that they comply with our legal obligations. The adequate safeguard for third parties might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal data to countries outside of the EU.
Further details of the transfers described above and the adequate safeguards used by horsum in respect of such transfers are also available, by contacting us at email@example.com.
We may also need to disclose your personal data if required to do so by law, a regulator or during legal proceedings.
Article 7 – We care about your personal data
We will hold your personal data on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or services; (ii) any retention period that is required by law; or (iii) the end of the period in which litigation or investigations might arise in respect of the services.
We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:
- education and training to our staff to ensure that they are aware of our privacy obligations when handling personal data;
- administrative and technical controls to restrict access to personal data;
- technological security measures;
- physical security measures, such as restricted access our premises.
Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by email) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us over the internet.
Article 8 – Data Subject Rights
You have various rights in relation to your personal data. In particular you have the right to:
- obtain confirmation that we are processing your personal data, and request a copy of the personal data we hold about you;
- ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
- ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data;
- withdraw consent to our processing of your personal data (to the extent such processing is based on consent);
- receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
- object to our processing of your personal data.
If you like to exercise any of your rights, or if you have any other questions about our use of your personal data, please email firstname.lastname@example.org or write to us at the address below:
Attn: Frederik Vervoort
Dok Noord 4C – Bus 205
B-9000 Gent, Belgium
You may also use these contact details if you wish to make a complaint to us relating to your privacy.
If you are not pleased with the way we have handled your personal data or any privacy query or request that you have raised with us, you can submit a right to complain to the EU Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us as indicated above.
Article 9 – Changes to the horsum privacy statement
We may modify or amend this privacy statement from time to time.
To let you know when we make changes to this privacy statement, we will amend the revision date at the top of this page. The new modified or amended privacy statement will apply from that revision date onwards. Therefore, we encourage you to periodically review this statement to stay informed about how we are protecting your personal data.