This Privacy Statement regulates the processing of personal data by Square Circle BV (hereafter referred to as “Square Circle”), with registered office at 1200 Brussels, Calabriëlaan 10, box 30, recorded in the Crossroads Bank for Enterprises and the VAT Register under the number BE0477.290.082, e-mail: firstname.lastname@example.org, URL https://www.squarecircle.be/.
Unless mentioned otherwise, Square Circle is the controller for the personal data that we collect and to which this Privacy Statement applies. However, for some of the tasks that we perform, we act only as external processor. If necessary, a processing agreement is always provided for.
This Privacy Statement forms part of the compliance with the General Data Protection Regulation of 24 May 2016 with regard to the protection of privacy in the processing of personal data and the Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data. It explains what personal data we collect and how we use it. Please read this Privacy Statement with care, because it contains essential information on how your personal data are processed and which cookies are used.
We hereby respect your privacy and your rights to control your personal data.
1. PERSONAL DATA
As controller, we process data that you have provided to us voluntarily when making an appointment or during a networking event, within the framework of a collaboration that we enter into, or data that are necessary for the execution of the assignment you entrusted to us.
More specifically we can thus process (amongst other things) the following personal data: name, e-mail address, address, telephone number, company data, invoicing data.
In addition, we also automatically collect data on the use of, access to or interaction with our website by means of cookies (Google Analytics) and comparable technologies, e.g. in order to be able to monitor the functioning of the website, or with a view to the detection of fraud and/or security breaches, by means of IP addresses and browser data.
Finally, we can receive information on you from other sources, including third parties, such as partners with whom we jointly offer services or perform marketing activities. We can also receive information on you from social media platforms (LinkedIn), for example when you communicate with us on such platforms. We protect data that we receive from third parties in the same way as that described in this Privacy Statement.
2. SECURITY AND STORAGE
We take the processing of your personal data extremely seriously and strive to provide for the necessary technical and organizational measures in order to protect your personal data and to help prevent theft, misuse and unauthorized access, provision, modification and destruction of your information from taking place.
We therefore audit our systems regularly for potential security risks and attacks. However, we cannot guarantee the security of data sent by you. If there should be a breach, one will respond quickly to it and the parties involved will be informed. However, Square Circle cannot be held liable for direct, indirect, or consequential loss caused by erroneous or wrongful use of the personal data by a third party.
The personal data collected are stored and processed in Belgium, at our registered office, or at external service providers that are also established in Belgium or Europe. The collected data only concern a secure connection from the website to the server.
Some collected personal data are stored and processed by tools that have their server outside of the European Union (e.g. Dropbox, Office365). If the personal data are collected and kept outside of the European Union, the processing will take place in accordance with the EU-US Privacy Shield. For more information about this, we refer to the privacy statement of these tools.
3. ACCESS AND TRANSFER TO THIRD PARTIES
In order to be able to process your personal data, we grant access to our staffers, employees and agents. Nevertheless, we guarantee a similar level of protection by making contractual obligations that are opposable to these staffers, employees and agents which are similar to this Privacy Statement.
The personal data provided by you are not sold to or shared with third parties, except within the framework of the execution of the contract, the assignment entrusted to us and/or with regard to external suppliers, including practical tools that perform services for us such as processing of invoicing data, time registration, e-mail communication and administration.
However, even then we share your personal data only if it is necessary, such as to deliver the services that you authorized, and only with partners who work on our behalf for the purposes that are described in this Privacy Statement. In that case, your personal data are shared with these partners, but only for the performance of services on behalf and by the order of Square Circle.
In addition, and only in so far as this is legally required or strictly necessary for the performance of the services or for the protection of our rights, or the rights of third parties affiliated with us or our customers, we provide your personal data to law enforcement agencies, investigatory bodies, to companies affiliated with us or in judicial proceedings, including (judicial) reorganisation, bankruptcy or transfer. In such a case we will always attempt, in so far as possible, to inform you in advance of any transfer.
Finally, Square Circle makes use of marketing or advertising plug-ins such as e.g. LinkedIn and Google Analytics. By installing these plug-ins, your personal data can be collected and passed on to these third parties. In accordance with article 26 of the General Data Protection Regulation of 24 May 2016 with regard to the protection of privacy in the processing of personal data, Square Circle is the controller together with these third parties. For the rights and obligations of each controller, reference is made to the respective privacy statements of LinkedIn and Google Analytics.
5. PROCESSING PURPOSES
The personal data collected in our capacity of controller are used for the benefit of our services, the management and handling of your request or within the framework of a collaboration (performance, invoicing, etc.).
Other personal data are processed for our customer relations management and supplier management or with a view to giving training courses.
In addition, they are also used in order to guarantee you access to the website and to assure the proper functionality of the website by being able to inform you about updates, new functionalities, etc. We can also use the data in order to inform and contact you about marketing and advertisements.
Finally, we want to offer the necessary protection and security, and the data can also be used within the framework of resolving disputes.
6. LEGAL GROUNDS
The personal data collected are processed in our capacity as processor or on the basis of article 6.1.a (consent), article 6.1.b (necessary for the performance of a contract) and article 6.1.f (legitimate interests) of the General Data Protection Regulation and the EU-US Privacy Shield, for example in order to schedule an appointment, to perform our assignment, to invite you for our events, or for administrative, fraud detection or legal purposes.
This Privacy Statement and the opt-in system that is used ensure that you can give your consent freely, explicitly, unambiguously, actively and in an informed way.
7. RETENTION PERIOD
Depending on the purpose of the processing, the personal data that were processed in our capacity as controller will be retained as long as necessary, and at the most for a period of 10 years, so that we can (amongst other things) fulfil our legal and accounting obligations. After this period, we will irrevocably erase the data.
The data that are processed with a view to public relations are retained for a maximum of 10 years.
Data about the giving of training courses are kept for 1 year. They are irrevocably erased after this period.
8. RIGHTS AND COMPLAINTS OF THE USER
As data subject you have at all times the right to access the personal data processed by us as controller and you can have them corrected if they are incorrect or incomplete, have the data transferred, have the processing thereof restricted or have them deleted (under certain circumstances).
We do not use any data that were exclusively processed automatically (such as profiling), with the exception of marketing campaigns on social media (‘targeting’). You always have the right to withdraw from these.
Moreover, given that the processing of the personal data takes place in part on the basis of article 6.1.a (consent), you always have the right to withdraw the given consent. However, keep in mind that you will no longer receive relevant information if you do not give consent to the processing of certain personal data.
You can exercise these above-mentioned rights by informing us by e-mail to email@example.com. You can also reach us at this address if you have a question or complaint.
You can file an official complaint with the Data Protection Authority: Drukpersstraat 35, 1000 Brussels, Tel. +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35, e-mail: firstname.lastname@example.org.
9. CHANGES TO PRIVACY STATEMENT
If necessary, we can adapt or update this Privacy Statement in order to reflect changes on the website or in the way we work. If essential changes are made to the way we use or process your personal data, we will inform you thereof by posting a notification of the changes to take place before they enter into effect or by sending you a notification directly. We advise you to reread this statement regularly for more information on how we use and protect your information.
Brussels, November 2020
The website https://www.squarecircle.be/ is the property of Square Circle BV (hereafter referred to as: “Square Circle”), with registered office at 1200 Brussels Calabriëlaan 10, box 30, recorded in the Crossroads Bank for Enterprises and the VAT Register under the number BE0477.290.082, e-mail email@example.com
By accessing and using the website, you expressly accept the following general terms and conditions of use.
INTELLECTUAL PROPERTY RIGHTS
The contents of the website https://www.squarecircle.be/ – including the designs, concepts, logos, illustrations, images, (preliminary) drafts, descriptions, data, product or company names, texts, and so on – are protected by intellectual rights and belong to Square Circle or to right-holding third parties
LIMITATION OF LIABILITY
The information on the above-mentioned website is general in nature. The information is not adapted to personal or specific circumstances, and thus cannot be regarded as offering the user personal, professional or any other type of advice.
Square Circle makes great efforts to ensure that the information made available is complete, correct, accurate and up-to-date. Despite all such efforts, the information that is provided may still contain errors. If the provided information should contain inaccuracies or if specific information should be unavailable on or via the website, Square Circle will make every possible effort to rectify this as quickly as possible. However, Square Circle cannot be held liable for direct or indirect harm that arises from the use of the information on this website
If inaccuracies are found in the information that is made available via the website, the user can contact the administrator of the website about this, via firstname.lastname@example.org
The contents of the website (including links) may be changed or supplemented at any time without notice or announcement. Square Circle offers no guarantees for the proper functioning of the website and can under no circumstances be held liable for a poor functioning or temporary (un)availability of the website or for any form of harm, direct or indirect, that might derive from accessing or using the website.
Square Circle may under no circumstances be held liable vis-à-vis anyone – in a direct or indirect, special or any other manner – for harm attributable to the use of this website or some other website, especially as a result of links or hyperlinks, including, without limitation, for any losses, work interruptions, damage to programs or other data on the computer system, to hardware, software or other equipment of the user.
The website can contain hyperlinks to websites or pages of third parties, or refer to them indirectly. Providing links to these websites or pages does not, in any way, imply any implicit approval of their contents.
Square Circle expressly declares that it has no control over the content or other characteristics of these websites, and may under no circumstances be held liable for the content or the characteristics thereof or for any other form of harm caused by the use thereof.
Square Circle attaches importance to the privacy of the users of its website and, as controller, respects the General Data Protection Regulation of 24 May 2016 with regard to the protection of privacy in the processing of personal data and the Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.
Square Circle can collect anonymous or aggregated data of a non-personal nature, such as browser type or IP address, the operating system that you use or the domain name of the website from which you came to the website that is the property of Square Circle, or that of the website to which you go when you leave. This makes it possible for us to continuously optimize our website for our users.
The personal data communicated by the user will be processed in accordance with the Privacy Statement that you can find on this page.
APPLICABLE LAW AND COMPETENT COURTS
Belgian law applies to this website. In the event of a dispute, the tribunals of the judicial district of Brussels have exclusive jurisdiction.
Brussels, November 2020