Privacy Policy

Who does this Privacy Notice apply to?

This website is owned and operated by Pro-Pay NV, with registered office address at Belgium, 1831 Diegem, Culliganlaan 1A (referred to as ‘Pro-Pay’).

We are a Belgian payroll provider, acting with integrity and respecting your privacy. We are committed to protect the personal data that are trusted to us and that you share with us and handling your information in an open and transparent manner, in particular with respect of the General Data Protection Regulation 2016/679 of 27 April 2016 (‘GDPR’).

With this Privacy Notice we would like to inform you more about why and how we use your personal data when we perform any activities that form part of the operation of our business as described below or when you use our website, who we give these data to, what your rights are and who you can contact for more information or queries.

How we obtain data

We may collect personal data from you when in connection with the performance of any activities that form part of the operation of our business as described below or 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), because other people give that data to us (for example your employer or third party service providers that we use to help operate our business) or because it is publicly available.

Where we are provided with personal data about you by other parties, we use reasonable efforts to include clauses into the contract with this party that will require them to comply with the privacy laws and regulations relevant to that information; this may include, for example, that this party has provided you with a proper information notice and has obtained any necessary consent for us to process that information as described in this Privacy Notice.

We may also collect or obtain personal data from you because we observe or infer that data about you from the way you interact with us or others.

Data we collect and why we process it

The personal data that we collect or obtain may include: identification data (such as name, address (private/work), phone number (private/work), e-mail address (private/work), country of residence, electronic identification data (cookies, logged data, IP addresses, your browser type and language, your access times,...); personal characteristics (such as age, gender, date of birth, place of birth, civil status, nationality); your financial specifics (such as your bank account number); lifestyle and social circumstances; 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); your postings on any blogs, forums, wikis and any other social media applications and services that we provide; 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 that we collect will vary depending on the nature of the services that we provide or how you use our website, such as:

Commercial relationship performance - We have commercial relationships with companies - customers and suppliers - in the context of which your personal data may be shared with us. For example, we might use your personal data for contact, accounting, invoicing, or delivery purposes, or to provide you with technical-commercial information and information regarding our products and services.

Contact us – if you contact us through the website (via social media, the contact form or other contact means), we ask you for information such as your name, address and email address so we can manage and respond to your questions and comments submitted through our website.

Newsletter – if you would like to receive updates and announcements regarding our products and services, we ask for your name and email address so we can send you the newsletter. You can unsubscribe at any time if you are no longer interested to receive a newsletter.

Information we automatically collect from you – if you make use of our website we automatically collect or obtain personal data from you because we observe or infer that data about you from the way you interact with us or others. We don’t use this data to personally identify you. We use this aggregated data to improve your experience when you use our website (for example to provide you with a more personalized experience and draw your attention to information about our services that may be of interest to you) and ensure that it is functioning effectively. For example, we (or our service providers) may use cookies (small text files stored in a user’s browser) which may collect personal data.

Marketing purposes – with your (if necessary free, informed, specific and unambiguous) consent, we use your data for marketing purposes, such as analyzing and maintaining our activities, internal management, improve our website, products and services and improve our customer service.

The legal grounds for processing your data

We are required by law to set out in this Privacy Notice the legal grounds on which we rely in order to process your personal data.

We use your personal data for the purposes outlined above because:

• the information is required for contract performance with our customers and suppliers;
• of our legitimate interests, namely in assuring the effective operation of our business, delivery of our services, and performance of our contracts with customers and suppliers, in so far as your interests do not override our interests;
• we have to comply with obligations imposed by laws and regulations.

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.

Disclosures

In connection with one or more of the purposes outlined in the “Data we collect and why we use it” section above, we may disclose details about you to third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “Data we collect and why we use it” section above. If our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.

Please note that some of the recipients of your personal data referenced above may be based in countries outside of the European Union whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal data that comply with our legal obligations. The adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal data to third countries.

Further details of the transfers described above and the adequate safeguards used by Pro-Pay in respect of such transfers are also available from us by contacting David Alen, Data Security Officer of Pro-Pay on the following address: Belgium, 1831 Diegem, Culliganlaan 1A.

In general, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or in the framework of a judicial proceeding, court order, or request from a regulator.

Security of your data and data retention

We employ strict technical and organizational (security) measures to protect your data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage both online and offline.

These measures include:

• training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
• administrative and technical controls to limit the access to personal data to the competent staff;
• technological security measures, including fire walls, encryption and anti-virus software;
• physical security measures, such as staff security badges 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.

We will retain your information for a reasonable period, i.e. 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.

Your rights

You have several rights concerning the information we held about you. We would like to inform you that you have the 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 if you believe that there is no (longer a) lawful ground for us to process it;
• 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 for which we use legitimate interest as a legal basis, in which case we will cease the processing unless we have compelling legitimate grounds for the processing.

In order to exercise any of your rights, you can send us a request, indicating the right you wish to exercise to the following email address: David Alen, Data Security Officer of Pro-Pay, Belgium, 1831 Diegem, Culliganlaan 1A.

You may also use these contact details if you wish to make a complaint to us relating to your privacy.

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 competent Data Protection Authority (“DPA”).

How to contact us?

If you have any questions about this website or our Privacy Notice, you can e-mail us at info@propay.be.

Changes to this Privacy Notice

We may modify or amend this Privacy Notice from time to time. Any changes we may make to our Privacy Notice in the future will be posted on this page. To let you know when we make changes to this Privacy Notice, we will amend the revision date at the bottom of this page. The new modified or amended Privacy Notice will apply from that revision date. Please check back periodically to see changes and additions.

Notification date

Last update of this notification is May 24, 2018.