1. Who are we?

1.1 Behind The Buttons as data controller.

With this statement (hereinafter the "Statement"), we wish to inform you why and how your personal data are collected and processed by Behind The Buttons Belgium, consisting of the Belgian Behind The Buttons entities (hereinafter "we", or "Behind The Buttons"). Your personal data is collected and stored centrally within Behind The Buttons. The Belgian Behind The Buttons entities, which are not considered third parties in relation to each other, all process your personal data in line with this Statement.

Our contact information can be found under Item 10 of this Statement.

We are responsible for the processing of personal data requested and used by us. As the controller, we take the measures that ensure that you:

  • remain informed about our processing of your personal data and about your rights;
  • retains control over the personal data we process;
  • can exercise your rights with respect to your personal data. More information about your rights can be found in section 9 of this Statement.

As part of its services to its customers, Behind The Buttons is also a processor of personal data of its customers. This is addressed in the processor agreement between Behind The Buttons and its customers, and is not part of this Statement.

1.2 Data Protection Officer

We have also appointed a data protection officer. This is a data protection expert who provides an additional safeguard to ensure that we process your personal data correctly.

You may contact the officer through the channels mentioned in paragraph 10 of this Statement.

2. What information do we collect about you?

2.1. Personal data

By "personal data" we mean any information that refers to a particular living natural person. It includes, where applicable, data of you and/or your representatives, staff, independent employees and/or directors (hereinafter together also referred to as "you" or "your").

If we receive personal data from you from your representatives, staff, independent workers and/or directors, you must inform them of the existence and content of this Statement including our obligations, their rights and how they can exercise these rights. In particular, we collect:

  • of our existing customers: identification and contact data (surname, first name, gender, e-mail address, telephone number, copy of identity card, etc.), declared areas of interest, and certain financial data (bank account number, etc.);
  • From prospects: identification and contact data (name, first name, gender, e-mail address, phone number, ...), areas of interest indicated, ....
    We need and use this data for the purposes mentioned in point 3 of this Statement.

Our websites also use "cookies". These are small pieces of information that are stored by the browser on Your computer and allow us to register certain information about the users of our website (e.g. choice of language, duration of Your visit on the page, ...). They help to adapt the website to your needs, preferences and ease of use. More information about this can be found in our cookie statement.

As a data controller, we do not collect and process personal data of minors or so-called sensitive data, namely:

  • personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership;
  • genetic or biometric data (e.g., facial images and fingerprints);
  • health data;
  • data relating to sexual behavior or sexual orientation.

Should such sensitive personal data be provided to us, we will not use it and will delete it.

3. What do we need your data for?

3.1. In order to accept you as a customer and properly execute the contract.

We need personal data in order to:

  • Be able to register and manage you as a prospect or customer in our customer management system (CRM);
  • Be able to accept you as a client in our "client acceptance" process;
  • Be able to contact and coordinate with you as a customer in connection with the performance of the services you have requested;
  • be able to bill our services or to make settlements regarding the services provided.

3.2. To engage in direct marketing

We wish to be able to inform you about our services, events or relevant news items. This may be at your express request, or if we suspect that you are interested in or would benefit from a service.

This information can reach you in many ways: through the Behind The Buttons offices, the Internet and apps, by email, by mail, by phone and at events. In addition, there are new technologies emerging every day that we wish to use if it helps to convey information clearly in the way that causes you as little disruption as possible.

You will receive our direct marketing communications if you have given express consent to do so. In particular, we will seek your express consent if you are not a customer of Behind The Buttons.

However, even if you do not give your consent, you may still receive offers or advertising from Behind The Buttons, especially if you already have an existing customer relationship with Behind The Buttons. We base this on our legitimate interest.

If you do not want advertising at all, please exercise your right to oppose direct marketing as stated in Section 9.2 of this Statement.

3.3. Because it is necessary to function as a business

This purpose amounts to what is called a "legitimate interest." Indeed, we still have a number of legitimate interests that form the basis for processing personal data. This is done only after we have weighed up that in each case the balance between our legitimate interests and their possible impact on your privacy will not be disturbed.

If you do object to these processing operations, you may exercise your right to object, as stated in section 9.3 of this Statement.

Thus, personal data are processed in various situations:

  • Personal data can be used as evidence (archives);
  • Personal data may be used to record your participation and/or attendance at our events;
  • Personal data may be used to provide information requested by you;
  • Personal data may be used for the establishment, exercise, defense and indemnification of the rights of Behind The Buttons or the persons it may represent, such as in litigation;
  • Personal data may be used for governance, (risk) management and control of our organization, such as compliance (such as money laundering and fraud prevention and investigations, and privacy), risk management, risk functions and inspection, complaint management, internal and external audit;
  • Personal data held by the Belgian Behind The Buttons entities can be aggregated and used for centralized or efficient management of customers, for the creation of segments or sectors (e.g. Public Sector, Real Estate & Construction, Life Sciences, Retail, ...), and for the creation of more detailed customer or prospect profiles in order to communicate with you in a more targeted way;
  • Personal data may be used to support and facilitate the customer's purchase, use and termination of services, among other things to avoid having to re-enter information that you previously provided, or to avoid having to go through a complete identification process again if you want to become a customer at another Behind The Buttons entity. For example, identification information may be passed on to Behind The Buttons entities to make identification at those other entities smoother.

4. What is the legal basis for processing your personal data?

4.1. General

Your personal data can be lawfully used and processed by us only if one of the following conditions is met:

  • the use of your personal data is necessary for the performance of a contract you have concluded with us or in order to take, at your request, the necessary steps to reach a contract with us. The processing purposes stated in section 3.1 of this Statement are based on this basis.
  • we have your express and free consent to use your personal data for a specific purpose. For example, we will seek your consent to write to you from direct marketing purposes, as stated in section 3.2 of this Statement, if you do not already have a customer relationship with us.
  • the use of your personal data is necessary to pursue our legitimate interests, to the extent that it outweighs your interests and rights. We base the processing necessary to operate as a business on our legitimate interest, as stated in section 3.3 of this Statement, and to write to our existing customers for direct marketing considerations, as stated in section 3.2 of this Statement.
  • we may be legally obliged to process certain data, and in particular to pass it on to the relevant authorities. In the context of certain services (commissioner mandates, tax returns, accounting, etc.) Behind The Buttons is indeed subject to reporting obligations to authorities, or still, we must be able to respond correctly if you exercise your rights under privacy legislation, and we are also obliged to answer questions from the Data Protection Authority, for example in the case of complaints.

5. With what other individuals do we share your personal data?

Only our employees and independent workers who effectively need access for the performance of their duties are granted access to your data. These persons act under our supervision and responsibility.

In addition, we also engage the services of third-party suppliers who perform certain processing operations on our behalf in order to enable us to offer our products and activities to you, such as IT services (among others) and legal, financial, accounting and similar other services. Since these third parties have access to personal data in the context of the services requested by us, we have implemented technical, organizational and contractual measures to ensure that your personal data is only processed and used for the purposes mentioned in point 3 of this Statement.

Only when we are legally required to do so, your personal data may be provided to supervisory institutions, tax authorities and investigative services.

6. Where will data be stored and processed?

Your data will not be transported outside the EU and, in any case, we will ensure that minimum legal requirements and security standards are respected at all times. If we foresee that your data will be stored and processed outside the EU, we will explicitly state this and ensure that the same level of protection is applied as applicable within the EU.

Apart from these cases, your personal data will never be transferred or made available to third parties and will only be used for our benefit. Thus, other companies cannot use your data to send you e.g. advertising.

7. How long do we keep your personal data?

We keep your data only as long as necessary in view of the purposes for which the data are used as mentioned under point 3 of this Declaration (e.g. execution of an agreement, sending information requested by you...). Any derogations or clarifications to this principle are expressly stated under the different purposes mentioned under point 3 of this Statement.

Because the need to retain data may vary by data type as well as by the purpose of processing, the actual retention periods may vary significantly.

We can hereby inform you that our criteria for determining assertion periods include the following:

  • How long are personal data needed to provide the requested service?
  • Have we established and announced a certain specific retention period?
  • Have we received permission for a longer retention period?
  • Do we have a legal, contractual or similar obligation to retain the data?
  • Once your data is no longer needed and we also have no legal retention obligation, legitimate interest or contractual obligation we will permanently delete it or, if this is not possible, anonymize it in our systems.

However, your personal data will be retained and used for as long as necessary to comply with our legal obligations, resolve disputes or enforce our agreements.

8. How do we secure your personal data?

Your personal data is considered strictly confidential. We take appropriate technical and organizational measures to protect the personal data provided and collected from destruction, loss, inadvertent alteration, damage, accidental or unlawful access or any other unauthorized processing of personal data.

9. What are your rights?

9.1. Right of access, rectification, erasure, transferability of data and objection

  1. Recht op inzage van uw persoonsgegevens
    U heeft steeds recht op toegang tot en inzage van uw persoonsgegeven die door ons worden verwerkt. Wij zullen u in dit kader een kosteloze kopie van deze persoonsgegevens verstrekken.

  2. Right to rectify your personal data
    U heeft altijd het recht om foutieve, onvolledige, ongepaste of verouderde persoonsgegevens te laten verwijderen of recht te zetten.

  3. Recht om uw toestemming in te trekken
    Wanneer de verwerking gebaseerd is op uw uitdrukkelijke toestemming, dan heeft u het recht om deze toestemming op elk ogenblik in te trekken. We wensen u er op te wijzen dat het intrekken van uw toestemming voor bepaalde verwerkingen van uw persoonsgegevens tot gevolg kan hebben dat u niet langer geïnformeerd zal worden of gebruik zal kunnen maken van door ons aangeboden activiteiten of diensten.

  4. Recht om tegen bepaalde verwerkingen bezwaar te maken
    Voor de verwerkingsactiviteiten gebaseerd op gerechtvaardigd belang, zoals vermeld onder punt 3.3, heeft u het recht om bezwaar te maken.

  5. Recht op wissing van uw persoonsgegevens
    U heeft een recht op wissing van uw persoonsgegevens. Op basis hiervan kan u ons vragen, wanneer u niet langer een relatie wenst met Behind The Buttons, om te stoppen met het gebruiken van uw persoonsgegevens. Wij kunnen echter wel persoonsgegevens bijhouden die voor bewijsdoeleinden vereist zijn. Onder dit verwijderingsrecht heeft u ook het recht om ons te allen tijde te vragen om te stoppen met het gebruik van uw persoonsgegevens die zijn verwerkt op basis van uw toestemming of ons gerechtvaardigde belang. Vanwege haar gerechtvaardigde belangen kunnen wij uw persoonsgegevens alsnog blijven verwerken na een afweging van uw belangen met die van ons, tenzij u besluit om de relatie met ons te beëindigen.

  6. Recht op overdracht van persoonsgegevens
    U heeft het recht om te vragen om persoonsgegevens die u zelf aan ons heeft verstrekt – in een gestructureerde, gangbare en digitale vorm – naar u door te sturen zodat u deze kan opslaan voor persoonlijk (her)gebruik, of om deze persoonsgegevens rechtstreeks door te sturen naar een andere gegevensverwerkingsverantwoordelijke, voor zover dit technisch mogelijk is voor ons. De privacywetgeving voorziet wel een aantal beperkingen op dit recht, waardoor het niet van toepassing is op alle gegevens.

  7. Right to restrict certain processing operations
    You may ask us to restrict the processing of your personal data in any of the following cases:

    • if you dispute the accuracy of the personal data, you may request a restriction of processing for a period that allows us to verify the accuracy of the personal data;
    • if the processing is unlawful and you oppose the erasure of the personal data and request instead that we restrict its use;
    • if we no longer need your personal data for the processing purposes mentioned under point 3, but you still need it for the establishment, exercise or substantiation of a legal claim;
    • if you have objected to any processing, we will stop such processing pending the answer to whether Behind The Buttons' legitimate grounds outweigh your own.

9.2. Right to object to direct marketing

As mentioned in section 3.2 of this Statement, we use your personal data to address commercial information, advertising or personalized proposals to you (via direct marketing actions or electronic newsletters). You have the right to object to the processing of your data for direct marketing purposes, if you do not or no longer wish to receive such communications from us, and this by using the options provided for this purpose in every mail you receive from us In this case, we will no longer process your data for direct marketing purposes. Your request will be fulfilled as soon as possible.

If you have exercised your right to object, you may, if you wish, reauthorize direct marketing activities through the same channels.

We draw your attention to the fact that your exercise of the right to object does not prevent us from contacting you, where appropriate, for any other purpose, including the performance of the contract, in accordance with this statement.

9.3. How to exercise?

To exercise the aforementioned rights, You may send a written request to Us in the following manner:

  • by email: data.protection@behindthebuttons.com
  • in writing to the following postal address: Behind The Buttons NV, attn. Data Protection Team, Foreestelaan 1, Ghent 9000

When exercising Your right, We ask that You clearly indicate which right You wish to invoke and what processing(s), if any, You oppose or what consent You wish to withdraw. Always be as specific as possible when exercising Your rights.

10. How to submit questions or complaints

If you have a question or complaint about our processing of personal data, about the exercise of your rights or about this Statement, you may contact us through the following channels:

  • by email: data.protection@behindthebuttons.com
  • in writing to the following postal address: Behind The Buttons NV, attn. Data Protection Team, Foreestelaan 1, Ghent 9000
  • by phone: +32 (0)9 395 0456

If you are not satisfied with our response, or if you have any comments concerning the exercise of your rights, or if you believe that our processing of your personal data is not in accordance with the law, you may lodge a complaint with the Belgian Data Protection Authority, formerly known as the Privacy Commission. All information in this regard can be found at https://www.privacycommission.be.

11. Amendments to this Statement

This Statement may be amended or supplemented by us as we deem necessary.

If significant changes are made to this Statement, the update date of the Statement will be updated and we will also notify you and provide you with a copy of the updated Statement.

We also encourage you to periodically review this Statement to learn how we process and protect your personal data.