Privacy Policy

This privacy policy sets out the privacy practices of PHPro NV in relation to the Website (hereinafter the 'Privacy Policy'). As we are committed to protecting your personal data to the fullest extent possible, we will explain in this Privacy Policy how we will treat your personal data and this in accordance with the Belgian Law of 8 December 1992 on the protection of privacy in relation to the processing of personal data, as amended and updated from time to time and in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC once it enters into force (hereinafter the "Privacy Act"). This Privacy Policy allows us to be open and transparent so that you can make meaningful choices regarding the use of your personal data.
By using our Website and/or our Services, you acknowledge that you have read this Privacy Policy carefully and agree to it without reservation. We reserve the right to change the Privacy Policy from time to time according to our sole discretion. Such change will be communicated through the Website.
Please note that we may use so-called 'cookies' or similar technology as part of the Website and/or the Services. Cookies are small text files placed on the hard disk of a device, which contain certain information, sometimes including personal data. For more information regarding our use of cookies, please read our cookie policy.
Your personal data will be collected and processed by PHPro NV, a Belgian company with its registered office at B-2550 Kontich, Veldkant 33 B and registered in the Crossroads Bank for Enterprises under number 0694.507.231.
This Privacy Policy was last updated on 08/10/2018.

This Privacy Policy should be read together with our General Terms and Conditions and our Cookie Policy. We reserve the right to make changes to our Privacy Policy. The most recent version of our Privacy Policy will always be available on our Website.

By using our Website, you consent to us collecting your personal data for the purposes specified in this Privacy Policy.

Our Privacy Policy clarifies:

- What personal data is collected
- How we use your personal data and with whom it may be shared
- Your rights in relation to the information collected

What personal data do we collect?

We collect various personal data:

Personal data that you give us: For example, your name, address, e-mail address, telephone number when you enter these details in the contact form and any additional information following the purchase of services.
Personal data we receive through your use of our Website or services:
- Log information: we store some data in server logs such as, but not limited to:
  - Internet Protocol address;
  - Browser information;
  - The external website you redirected;
  - The pages you visited on our Website;
  - The time and date of each page you visited;
  - Details about how you use our services.
- Device information: we may collect device-specific data e.g. serial number, hardware type, version etc.
- Local storage: using browser web storage, application data caches and other mechanisms on your device, we may collect and store data (including personal data)
- Cookies: we use cookies to identify our visitors, remember customised preference settings (e.g. language), ... (for more information on what cookies are and their use, please refer to our Cookies Policy.
We use your personal data to provide, maintain, protect, promote and improve our services and develop new ones. Your personal data will not be kept for longer than necessary to fulfil the purposes for which it was collected.
We may use your personal data to communicate with you, in particular by providing feedback on questions you asked via the contact form, to respond to your job applications and to promote the use of our services to you on the Website.

What and why we process data

When you use the Website and/or Services, we process personal data relating to you. Such personal data include:

When? Using Services, contacting us, requesting a quote, using Website
Which? Identifying information
Why (purpose)? Processing request
Legal basis? Legitimate interest
When? Subscribing to newsletter, downloading whitepapers, requesting leaflets or information
Which? Identification data
Why (purpose)? Posting related information and supplements
Legal basis? Consent
When? Use of live chat on website
Which? Identification data
Why (purpose)? Sending related information and supplements
Legal basis? Consent

In principle, we obtain the personal data mentioned above directly from you. In addition to the above purposes, we may also process your personal data
- To provide you with the information on products and services you request in a personalised and efficient manner, either through the Website, email, telephone or social media channels.
- To process your personal data so that we can provide the Services.
- For direct marketing purposes, i.e. to provide you with targeted communications, promotions, offers and other advertisements from us or our selected partners. For this, we will seek your prior consent.
- To perform statistical analysis to improve our Website and/or Services, or to develop new products or services.
- To provide to a financial institution or payment service provider, to enable your financial institution and the payment service provider to fulfil their legal obligations.
- To transfer to the police or judicial authorities as evidence of possible crimes or if there are reasonable suspicions of an unlawful act or crime committed by you through your registration with or use of the Website or the Services.
- In the context of a possible merger with, acquisition of/by or demerger by a third party, even if that third party is located outside the EEA.
If and when your registration on the Website or use of the Website or Services may be considered (a) a violation of the terms or intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Services, (c) a threat to the Website or Services or systems of us or our subcontractors as a result of viruses, Trojans, spyware, malware, or any other form of malicious code, or (d) in any way illegal or unlawful, discriminatory or offensive, we may process your data in the interests of ourselves, our partners or third parties.

With whom we share data

With your consent: We will share your personal data with other companies only with your consent - to be distinguished from PHPro NV - Please note that the social media provider may collect your personal data, if you hit a social media button. In that case, that provider's privacy policy will apply.

For legal reasons: We may share your personal data to comply with any applicable law or regulation or to comply with an order of an authorised supervisory body.

With entities that process personal data for us: These entities may only process the personal data on our instruction and for the purposes necessary to fulfil the purpose of the processing. These entities are equally bound by the Privacy Act.
We may use third-party processors to provide you with the Website and/or Services. We ensure that third party processors may only process your personal data on our behalf, and upon written instructions from us. We ensure that all third-party processors are selected with due care so that we can rely on the security and integrity of your personal data.
We may transfer anonymised and/or aggregated data to other organisations that may use this data to improve products and services and to organise the marketing, presentation and sale of customised products and services.

Where we process data

We ourselves and our third-party processors will only process your identifiable personal data in the EEA.
We may transfer your anonymised and/or aggregated data to organisations outside the EEA. If such a transfer takes place, we will ensure that appropriate safeguards are in place to ensure the security and integrity of your personal data, and that any rights in relation to personal data that you might enjoy under applicable mandatory law are guaranteed.
If a transfer of your personal data and/or anonymised and/or aggregated data takes place, the following legal protection mechanism will be put in place:

Which? HubSpot
Country outside the EEA? USA
Legal pass-through mechanism? US - EU Privacy Shield
Which one? MAILCHIMP
Country outside the EEA? USA
Legal pass-through mechanism? US - EU Privacy Shield
Which? WHOISVISITING
Country outside the EEA? USA
Legal pass-through mechanism? US - EU Privacy Shield

How we process data

We will make every effort to process only the personal data necessary to fulfil the purposes set out in this Privacy Policy. We will process your personal data in a lawful, fair and transparent manner. We will make every effort to keep personal data accurate and up-to-date.
Your personal data will only be processed for as long as is necessary to achieve the purposes set out in this Privacy Policy or until such time as you withdraw your consent to its processing. Please note that withdrawal of consent may imply that you are no longer able to use all or part of the Website and/or Services. If you have registered with our Website, we will delete your personal data when you delete your profile, unless a legal or regulatory obligation or a court or administrative order would prevent us from doing so.
We will take appropriate technical and organisational measures to keep your personal data safe from unauthorised access or theft and from accidental loss, manipulation or destruction. Access by our staff or staff of our third-party processors is only possible on a need-to-know basis and is subject to strict confidentiality obligations. However, you understand that care for safety and security are only best-efforts obligations, which can never be guaranteed.

Your rights

You have the right to request access to any personal data we process about you. However, access requests that are made with the apparent intention of causing inconvenience or harm to us will not be processed.
You have the right to request that any personal data about you that is incorrect or inaccurate be corrected free of charge. If you have registered on our Website, you can correct many of these details yourself via your profile. If such a request is made, you must also enclose with this request proof that the personal data for which correction is requested is inaccurate.
You have the right to withdraw your previously given consent to the processing of your personal data. You may withdraw your consent at any time by sending an e-mail to info@phpro.be, or by deleting your profile (if applicable).
You have the right to request that personal data relating to you be deleted if it is no longer necessary in light of the purposes set out in this Privacy Policy or if you withdraw your consent to its processing. However, you should note that a deletion request will be assessed by us in light of legal or regulatory obligations or administrative or court orders that may prevent us from deleting the personal data in question.
In lieu of deletion, you may also request that we restrict the processing of your personal data if (a) you contest the accuracy of such data, (b) the processing is unlawful or (c) the data are no longer necessary for the stated purposes, but you need them to defend yourself in legal proceedings.
You have the right to object to the processing of personal data if you can demonstrate that there are serious and legitimate reasons related to special circumstances that justify such an objection. However, if the intended processing is classified as direct marketing, you have the right to oppose such processing, free of charge and without justification.
Where your personal data are processed on the basis of consent or on the basis of a contract and the processing is carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and, if technically feasible, you have the right to transmit such data directly to another service provider. The technical feasibility of this will be assessed solely by us.
We will in no case process personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, or personal data relating to health or a person's sexual life.
If you wish to make a request to exercise one or more of the rights listed above, please send an e-mail to info@phpro.be. This request should clearly state which right you wish to exercise and why. It must also be dated, signed and accompanied by a digitally scanned copy of your valid ID card proving your identity. We will immediately inform you of the receipt of such request. If the request proves to be justified, we will comply with it as soon as reasonably possible and no later than thirty (30) days after receipt of the request.
If you have a complaint or queries regarding our processing of your personal data, you can always contact us at the e-mail address info@phpro.be. If you remain dissatisfied with our response, you are free to lodge a complaint with the competent data protection authority, the Belgian Privacy Commission. For more information, please visit http://www.privacycommission.be.