PRIVACY STATEMENT
Summary
This privacy statement explains what information we gather about you, what we use that information for and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries. Click on the accordion labels below to take you to the more detailed sections of this statement.
Who this privacy statement applies to and what it covers
This privacy statement applies to Gate-16 Be and Gate-16 Lux, with registered office address at 36 ave des Azalées, B-1030 Brussels and 19 route de Bastogne, L-9638 Pommerloch .
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 webpages of Gate-16.com designated as Belgium in the upper right hand corner, and to specific webpages with a URL commencing ‘https://www.gate-16.com
This privacy statement also contains information about when we share your personal data with other third parties (for example, our service providers).
In this privacy statement, your information is sometimes called “personal data” or “personal information”. It means any information allowing you to be directly or indirectly identified. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.
What information we collect
In the course of (i) providing services to you or our clients, (ii) our marketing and recruiting campaigns/events and (iii) 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);
- 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);
- it is publicly available; or
- we observe or infer that data about you from the way you interact with us or others. For example, to improve your experience when you use our Website and ensure that it is functioning effectively, we (or our service providers) may use cookies (small text files stored in a user’s browser) and Web beacons which may collect personal data. Additional information on how we use cookies and other tracking technologies and how you can control these can be found in our Cookie notice.
The personal data that we collect or obtain may include:
- basic information: name; age; date of birth;
- contact information: e-mail address; telephone number; home address;
- country of residence;
- gender;
- lifestyle and social circumstances (e.g. your pastimes);
- family circumstances (e.g. your marital status and dependents);
- employment and education details (e.g. degree, expected graduation date, CV, former or current school, the organization you work for and your job title);
- financial and tax-related information (e.g. payment details, your income and tax residency);
- postings on any blogs, forums, wikis and any other social media applications and services that we provide;
- IP address;
- browser type and language;
- 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; and
- any other personal information which you may provide to us for the purpose of receiving our services.
The personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as:
- information on your dietary requirements (e.g. where Gate-16 would like to provide you with lunch during a meeting);
- your health details (e.g. allow us to make reasonable accommodations for you in our buildings, products and services);
- your sexual orientation (e.g. if you provide us with details of your spouse or partner); and
- a copy of your ID card (e.g. for anti-money laundering purposes).
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.
Where we are provided with personal data about you by our client, we use reasonable efforts to include clauses into the contract with the client that will require them to comply with the privacy laws and regulations relevant to that information; this may include, for example, that the client has provided you with notice of the collection (and other matters) and has obtained any necessary consent for us to process that information as described in this privacy statement.
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.
The legal grounds we use for processing personal information
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:
- we have received your consent to do so;
- of the legal and regulatory obligations that we are subject to (e.g. keeping records for regulatory or tax purposes, providing information to a public body or law enforcement agency);
- we perform a contract with you;
- we need to exercise, establish or defend legal claims;
- the information is required in order to provide our services to you or our client;
- of our legitimate interests in the effective delivery of our services to you or our client so long as such interests are not outweighed by your interests; and
- of our legitimate interests in the effective and lawful operation of our business (such as but not limited to prevent fraud, to make sure that complaints are investigated, to protect our business interests, to evaluate, develop or improve our services or products) so long as such interests are not outweighed by your interests.
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:
- you have given us your explicit consent to process that data;
- we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us);
- the processing is necessary to carry out our obligations under employment, social security or social protection law;
- the processing is necessary for the establishment, exercise or defense of legal claims; or
- you have made the data public.
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.
Who we disclose your information to
In connection with one or more of the purposes outlined in the “How we use information about you?” section above, we may disclose details about you to:
- other members of Gate-1l BeLux;
- third parties that provide services to us;
- competent authorities (including courts and authorities regulating us or our clients);
- 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 we use information about you?” section above.
Our Website hosts various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Importantly, any personal information 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.
We may also need to disclose your personal data if required to do so:
- by law;
- a regulator;
- or during legal proceedings.
We may share non-personal, de-identified and aggregated information with third parties for several purposes, including:
- data analytics;
- research;
- submissions;
- thought leadership; and
- promotional purposes.
Protection of your personal information
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 relevant staff to ensure they are aware of our privacy obligations when handling personal data;
- administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;
- technological security measures, including fire walls, encryption and anti-virus software; and
- physical security measures, such as staff security passes to 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 e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.
How long we keep your information for
We will hold your personal data on our systems for the longest of the following periods:
- as long as is necessary for the relevant activity or services;
- any retention period that is required by law; or
- the end of the period in which litigation or investigations might arise in respect of the services.
Your rights
You have various rights in relation to your personal data. In particular, you have a 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;
- consent to our processing of your personal data at any time (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); and
- object to our processing of your personal data.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please email hrm@gate-16.com .
You may also use these contact details if you wish to make a complaint to us relating to your privacy.
If you want to exercise your rights as referred to above, please note that in case of reasonable doubt as to your identity, we may need proof of who you are in order to answer your request.
Rights to complain
If you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us as indicated above.
Change to this 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. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.
