Privacy Statement for Minds&More Website and Services
Last revised: April 2018
Who this privacy statement applies to and what it covers?
This privacy statement applies to Minds&More C.V.B.A, with registered office address at Jan Emiel Mommaertslaan 16B, 1831 Diegem, Belgium (“MINDS&MORE”, “we”, “us” or “our”).
We are committed to protecting your privacy and handling your personal data in an open and transparent manner.
This privacy statement sets out how we will collect, handle, store and protect personal data about you.
When we refer to “our Website” or “this Website” in this privacy statement we mean the webpage with URL ‘https: //mindsandmore.biz/’.
In this privacy statement, any of your information that can identify you e.g. name, identification number, e-mail address, phone number, etc. is called “personal data”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as “processing” such personal data.
What personal data we collect?
We may collect or obtain your personal 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 our client, 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; e-mail address; telephone number; home address; country of residence; lifestyle and social circumstances (for example, your pastimes); family circumstances (for example, your marital status and dependents); employment and education details (for example, the organization you work for, your job title and your education details); financial and tax-related information (for example your income and tax residency); your postings on any blogs, forums, wikis 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 services; details of how you like to interact with us and other similar information.
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 personal data; 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 personal data 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 personal data about children.
How we use personal data about you?
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.
Use of personal data for other activities that form 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, which may involve: (i) sending you thought leadership or details of our services that we think might be of interest to you; (ii) contacting you to receive feedback on services; and (iii) contacting you for other market 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, “The legal grounds we use for processing personal data”);
- 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 personalised experience and draw your attention to information about our services that may be of interest to you
- to manage and respond to any request you submit through our Website.
The legal grounds we use for processing 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, such as keeping records for regulatory or tax purposes or providing information to a public body or law enforcement agency or (b) the personal data 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; (d) of our legitimate interests in the effective and lawful operation of our business so long as such interests are not outweighed by your interests;
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 each communication or e-mail.
Who we disclose your personal data to?
In connection with one or more of the purposes outlined in the “How we use personal data about you?” section above, we may disclose details about you to: other members of the MINDS&MORE network; third parties that provide services to us; competent authorities; your employer and/or their advisers; your advisers 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 personal data 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 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 personal data 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 data
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
- 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 personal data for?
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.
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
- 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.
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:
To the attention of the Office Manager
Jan Emiel Mommaertslaan 16B
You may also use these contact details if you wish to make a complaint to us relating to your privacy.
Right 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 EU Data Protection Authority (“DPA”) in your jurisdiction.
Changes 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 personal data.