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Privacy Statement


Last updated 16 November 2018

Kratos Law, a Belgian CVBA/SCRL (hereinafter “K law”) and KPMG Tax Advisers CVBA/SCRL (hereinafter “KPMG”) as joint controllers are dedicated to protecting the confidentiality and privacy of information entrusted to them. K law and KPMG are collectively referred to as “we," "our," and "us” in this privacy statement ("Privacy Statement").

As part of this fundamental obligation, K law and KPMG are committed to the appropriate protection and use of personal data.

Generally, our intent is to collect only the personal data that is provided to us so that we can offer information and/or services. Please review this Privacy Statement to learn more about how we collect, use, share, protect and process the personal data that we have obtained.

  1. Collection and use of personal data
    1.1 What type of data do we collect
    1.2 The legal grounds we have to use your personal data
            1.3 The purposes for which your personal data will be processed
            1.4 Automatic collection of personal data
                     1.4.1 IP addresses
                     1.4.2 Web beacons
                     1.4.3 Location-based tools
             1.5 Social media widgets and applications
             1.6 Children
  2. Sharing and transfer of personal data
  3. Choices
  4. Your rights
  5. Data security and integrity
  6. Links to other sites
  7. Changes to this statement
  8. Who is responsible for the processing of your personal data
  9. Who to contact in case of questions
  10. Statement questions and enforcement

 

1. Collection and use of personal data

1.1  What type of data do we collect

We obtain personal data about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you may have previously provided your personal data to K law and/or KPMG (if, for example, you are a former employee). If you choose to register or login to this website using a third party single sign-on service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with us, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect may depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.

By registering and/or submitting personal data to us you are giving your explicit consent to us so that we may use this data in accordance with this Privacy Statement. Your personal data is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to our website and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other of our sites you visit. If you subscribe to receive direct marketing (i.e. newsletters, insights, events, etc.) we may use your personal data in order to send you such messaging.

In some cases where you have registered for certain services we may store your email address until we receive confirmation within 48 hours of the information you provided (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).

1.2 The legal grounds we have to use your personal data

We generally collect only the personal data necessary to fulfill your request. Where additional data is sought, you will be notified of this at the point of collection.

The applicable legislation allows us to process personal data, so long as we have a processing ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal data, we will rely on one of the following legal grounds for processing:   

  • Performance of a contract: this is when the processing of your personal data is necessary in order to perform our obligations under a contract or the intention to enter into a contract;
  • Legal obligation: this is when we are required to process your personal data in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency; 
  • Legitimate interests: we may process data about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
  • Your consent: we may occasionally ask you for specific permission to process some of your personal data, and we will only process your personal data in this way if you agree to us doing so. You may withdraw your consent at any time by contacting us at info@companylawcode.be.

We only collect special categories of personal data when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Special categories of personal data include personal data revealing a person's race, ethnicity, political opinions, trade union membership, religious or philosophical beliefs, data concerning health, genetic data, biometric data, sexual life or orientation, or criminal record. Please use your discretion when providing special categories of personal data to us, and under any circumstances, do not provide special categories of personal data to us, unless you thereby explicitly consent to our use of that information for its legitimate business purposes.

1.3 The purposes for which your personal data will be processed

We will only process your personal data for specified, explicit and legitimate purposes and we will not process your personal data further in a way that is incompatible with those purposes.

This purpose can be the execution of an engagement, the improvement of your visit on our website or portals, the improvement of our products and services more generally, the offering of services or applications, marketing communications and actions, web personalization, direct marketing, web analytics, etc.

The purpose of each processing of your personal data will be clearly defined in the privacy notice. This privacy notice will be accessible, for example, on a website or portal, on an application, in an electronic newsletter, etc.

1.4 Automatic collection of personal data

In some instances, we and our service providers use cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of our online presence, and to measure the effectiveness of our marketing activities.

1.4.1 IP addresses

An IP address is a number assigned to your computer or internet enabled device whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct website trend and performance analysis.

1.4.2 Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. We only use web beacons in accordance with applicable laws.

We or our service providers may use web beacons to track the effectiveness of third party websites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

1.4.3 Location-based tools

We may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

1.5 Social media widgets and applications

Our website may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of our website. Any personal data that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, our website may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal data that you provide on any of our social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

1.6 Children

We understands the importance of protecting children’s privacy, especially in an online environment. In particular, our site are not intentionally designed for or directed at children.

2. Sharing and transfer of personal data

We do not share personal data with unaffiliated third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. This would include:

In some instances, we may also share personal data about you with various outside companies or service providers or vendors working on our behalf.

In addition, we may transfer certain personal data across geographical borders to other member firms or outside companies working with us or on our behalf. We may also store personal data in a jurisdiction other than where you are based. Transfer of personal data by us takes place in accordance with the applicable Belgian data protection legislation.

  • We may also disclose personal data to our service providers: we work with reputable partners, service providers or agencies so they can process your personal data on our behalf. We will only transfer personal data to them when they meet our strict standards on the processing of data and security. We only share personal data that allows them to provide their services.             
  • If we are reorganized or sold to another organization: we may also disclose personal data in connection with the sale, assignment, or other transfer of the business of the site to which the data relates.             
  • Courts, tribunals, law enforcement or regulatory bodies: we may disclose personal data in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government regulations.            
  • Audits: disclosures of personal data may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.

In addition, we may transfer certain personal data outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. We may also store personal data outside of the EEA. If we do this your personal data will continue to be protected by means of contracts we have in place with those organisations outside the EEA, which are in a form approved by the European Commission. By providing personal data online, visitors are consenting to this transfer and/or storage of their personal data across borders.

We will not transfer the personal data you provide to any third parties for their own direct marketing use.

3. Choices

In general, you are not required to submit any personal data to us, but we may require you to provide certain personal data in order for you to receive additional information about our services and events. We may also ask for your permission for certain uses of your personal data, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

If you wish to prevent cookies from tracking you as you navigate our site, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our site may not work properly if you elect to refuse cookies.

4. Your rights

If you have submitted personal data to us, you have the following rights:                

  • Access and correction:you have the right to access your personal data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal data to you, we will provide it to you free of charge. Before providing personal data to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal data. If the information we hold about you is incorrect, you may ask us to correct any inaccuracies in the personal data.          
  • Object to processing:you have the right to object to us processing your personal data if we are not entitled to use it any more, to have your data deleted if we are keeping it too long or have its processing restricted in certain circumstances.      
  • Right to restriction of processing:you have the right to request a restriction on the processing of your personal data (for example, while the accuracy of your personal data is being checked).
  • Right to erasure:you have the right to the erasure of any data concerning you (except in some cases, for example, to prove a transaction or when required by law).   
  • Right to data portability:under certain conditions, you have the right to receive your personal data, which you have provided to us, in a commonly used, structured machine readable format and to transmit your personal data to any third party of your choice.

You can make a request or exercise these rights by contacting us at dpo@kpmg.be and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

5. Data security and integrity

We have reasonable security policies and procedures in place to protect personal data from unauthorized loss, misuse, alteration, or destruction. Despite our best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal data is limited to those who have a need to know. Those individuals who have access to the personal data are required to maintain the confidentiality of such information.

We also make reasonable efforts to retain personal data only for so long as the data is necessary to comply with an individual’s request or with the applicable legislation.

6. Links to other sites

Please be aware that our website may contain links to other sites, including sites maintained by other  member firms that are not governed by this Privacy Statement but by other privacy statements that may differ somewhat. We encourage users to review the privacy policy of each website visited before disclosing any personal data.

By registering on our website and then navigating to another website while still logged in, you agree to the use of your personal data in accordance with the privacy statement of the website you are visiting.

7. Changes to this statement

We may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how we are protecting your data.

If we make any significant changes in the way we treat your personal data we will make this clear via our website.

8. Who is responsible for the processing of your personal data?

K law and KPMG as joint controllers are responsible for the processing of your personal data.

  • Kratos Law Belgian CVBA/SCRL
    BE 0473.719.789
    Luchthaven Brussel Nationaal 1K
    1930 Zaventem
  • KPMG Tax Advisers CVBA/SPRL
    BE 0444.333.739
    Luchthaven Brussel Nationaal 1K
    1930 Zaventem
    (KPMG Tax Advisers CVBA/SPRL is a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity)
9. Who to contact in case of questions?

We have appointed a data protection officer who will handle your questions or requests relating to this Privacy Statement, any specific privacy notice or your personal data (and its processing).

For any questions or requests or complaints concerning the application of this Privacy Statement or to exercise your rights, as described in this this Privacy Statement, you may contact us at dpo@kpmg.be.

10. Statement questions and enforcement

We are committed to protecting the online privacy of your personal data. If you have questions or comments about our administration of your personal data, please contact us at dpo@kpmg.be.
You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

In any event, you always have the right to lodge a complaint with the Belgian regulator in charge of protecting personal data, i.e. the Belgian data protection authority.

Data Protection Authority
Drukpersstraat 35, 1000 Brussel

Tel: +32 (0)2 274 48 00

Fax: +32 (0)2 274 48 35

E-mail: contact@apd-gba.be