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Privacy Policy

Privacy Policy

Version 17 december 2020

Please check this page regularly for the most recent version.

The protection of your personal data is important to us.

We attach great importance to the protection of privacy and will process your personal data with due care. The personal data you provide us with is processed by POM West-Flanders, Koning Leopold III-laan 66 in 8200 Sint-Andries and enterprise number 0881.702.779, as the controller of your personal data. In doing so, we work in accordance with the provisions of the European General Data Protection Regulation (GDPR) of 27 April 2016 and the Belgian Act of 30 July 2018 on the protection of natural persons in relation to the processing of personal data and subsequent amendments and implementing decrees.

If you would like more information on how we process your personal data through cookies, social plug-ins or other types of tracking technology, please refer to our Cookie Policy.

What personal data do we process and why?

When you use our website or social media channels, or communicate with us by telephone, e-mail, the online contact form or another digital communication channel, we process the following personal data:

  • Basic identity data that you provide us with such as title, surname, first name, address, telephone and mobile number, e-mail, company for which you work;
  • the content of your communication and the technical details of the communication itself (with whom you correspond, date and time, etc.);
  • technical information related to the device you are using, such as IP addresses, browser type, geographic location and operating system;
  • Information about your surfing behaviour, such as how long you surf, which links you click on, which pages you visit and how often you visit a page;
  • publicly available information about your profile on social media;
  • any other personal data you provide to us.

We collect and use this personal data to:

  • Enable communication between you and us, for which we rely our legitimate interest to respond to requests, questions or comments or to contact you proactively for questions of any kind;
  • Improve the content and overall experience of website and social media pages, including on the basis of statistical analysis, for which we invoke our legitimate interest in providing visitors with an interesting online experience;
  • Provide targeted communications, promotions, offers and other advertisements to you. We will only send you targeted communications, promotions, offers and other advertisements via email and other electronic communication channels between individuals if you have expressly consented to receive such information, promotions, offers and other advertisements.
  • detect and prevent malware, illegal content and conduct and other forms of abuse, for which we invoke our legitimate interest in keeping our online presence safe

When you subscribe to the online newsletters, we process the following personal data:

  • basic identity information that you provide to us such as your organisation/company, surname, first name, position, email address;
  • your preference as regards the newsletters you wish to receive.

We collect and use this personal information to keep you informed about news and activities related to our operation by sending you our newsletters.

We will always ask you for your explicit consent before sending you our newsletter, unless you are an existing relation whom we would like to keep informed about our services. You always have the possibility to unsubscribe from the online newsletter via http://www.pomwvl.be/uitschrijven.

When you give us your business card, we will process the following personal data:

  • the personal details listed on your business card.

We process these personal data as part of our normal relationship management, relying on our legitimate interest in building up a network of contacts.

When we handle your file as a public authority with legal obligations and tasks in the public interest or public authority, we process the following personal data:

  • basic identity information that you provide to us such as title, surname, first name, address, telephone and mobile number, e-mail, company for which you work;
  • national registry number and identity card number;
  • financial and transaction data such as bank account numbers, payments, supplier data;
  • any other personal data you provide to us;

We collect and use these personal data in order to fulfil our legal obligations and carry out our tasks, invoking the necessity of processing for the fulfilment of the tasks of general interest assigned to us;

When you enter into a contract with us, either as a supplier or as a partner in a subsidised project, or as a X, we process the following personal data

  • basic identity information that you provide to us such as title, surname, first name, address, telephone and mobile number, e-mail, company for which you work;
  • financial and transaction data such as bank account numbers, payments, supplier data;
  • any other personal data you provide to us;

We collect and use this personal data to:

  • comply with our contractual obligations, for which we invoke the necessity of processing your personal data for the conclusion and performance of the contract we have with you. However, if you are acting on behalf of a company or other legal entity, we rely on our legitimate interest in contracting with that company or entity;
  • carry out our normal business administration (e.g. billing and customer relationship management), for which we rely on our legitimate interests to manage business in a responsible and professional manner;

When you apply for one of our vacancies, we process the following personal data:

  • basic identity information that you provide to us such as title, surname, first name, address, telephone and mobile number, e-mail, company for which you work;
  • the other personal data mentioned in your CV and accompanying letter;
  • information that you have made public on social media;
  • any other personal data you have chosen to include in your request.

We will collect and use this personal data to:

  • assess your application, for which we rely on the necessity of processing your personal data in order to reach a potential agreement with you;
  • keep you in our recruitment reserve, for which we will ask for your consent;

When you participate in an event (e.g. consultations, study days, information sessions, networking events and fairs) organised by us, we process the following personal data:

  • basic identity information that you provide to us such as title, surname, first name, address, telephone and mobile number, e-mail, company for which you work;
  • photo and/or image material of your presence at the event;

We process these personal data in order to

  • register your presence at the event correctly and organise it in a practical way, for which we invoke our legitimate interest to receive only registered persons at our event venues;
  • communicate your presence at the event to the other participants;
  • be able to send you additional information relating to the event;
  • promoting future events and provincial promotion to local authorities and partners;

We will always ask you for your explicit consent before using your personal data for these last three purposes.

We believe that the above purposes for processing your personal data are within everyone's reasonable expectations. However, for all personal data collected in the above circumstances, we would like to make it clear that we will also process your personal data in order to:

  • comply with a legal obligation or reasonable request from authorised agents or representatives of law enforcement, judicial authorities, public authorities or bodies, including competent data protection authorities, or from a financial institution or payment service provider to enable them to comply with their legal obligation, for which we rely on our legal obligations.
  • defend us in legal proceedings, when it is in our legitimate interest to use your personal data in those proceedings.

How do we process your personal data?

We take technical and organisational measures to ensure the secure processing of your data and we require third parties who handle or process your personal data for us to do the same. Access to your personal data is restricted to prevent unauthorised access, alteration or misuse and is only permitted for those employees who need your data to perform their job. These employees are obliged to handle the data discreetly and comply with all technical regulations in order to process the data securely.

Your personal data will only be processed for as long as necessary to achieve the purposes described above or, where we have asked you for your consent, until such time as you withdraw your consent.

As a general rule, we will de-identify your personal data when it is no longer needed for the purposes described above or when the retention period, as explained in this article, has expired. However, we cannot delete your personal data if there is a legal or regulatory obligation or a court or administrative order preventing us from doing so.

  • All personal data that we collect through our interactions with you through the website, social media, telephone, fax, email and other digital communication channels will be retained for as long as necessary to communicate with you, but also to maintain a historical record of our communications. This allows us to return to previous communications when you return to us with new questions, requests, comments or other input.
  • We will retain all personal data collected to send you our newsletter for as long as you remain subscribed to our mailing list.
  • All personal data that we collect when you give us your business card will be stored as long as you do not ask us to delete your personal data.
  • All personal data that we collect as part of the handling of your file will be retained for the duration of the handling of your file and for at least 10 years thereafter.
  • Any personal data we collect in the context of a contractual relationship with you or the organisation you represent will be retained by us for the duration of the contractual relationship and for at least 10 years thereafter.
  • All personal data collected from us in the context of your application will be retained by us for the duration of the application procedure and, if we choose to use your services, for the entire duration of your contract with us and for up to 10 years after termination of the contract. If we do not choose to use your services, but have invited you for an interview, we will retain your personal data for 1 month after the assessment process is completed. If you consent to the inclusion of your personal data in our recruitment reserve, we will retain your personal data for 2 years following receipt of your personal data.
  • We will retain all personal data collected in connection with your participation in an event for as long as you do not withdraw your consent.

Do we pass on your personal data to third parties?

We will never share your data with third parties, except in the following cases:

  • it is necessary to achieve the objectives mentioned above (see "What personal data do we process and why?")
  • you give us your written consent to do so
  • we are legally obliged to do so
  • it is requested as part of a judicial investigation

POM West-Flanders only shares your personal data with the following categories of recipients:

  • Other public authorities:
    As a regional government body, we will pass on your personal data to federal and Flemish government bodies or to local authorities where we are obliged to do so. Conversely, we will also request your personal data from other government bodies, in particular when using authentic data sources. This exchange of data is also regulated by law, or we are permitted do so on the basis of authorisations.
  • Partners in European projects:
    POM West Flanders is also a partner in numerous European projects. It is often necessary to communicate personal data to the project partners in order to carry out the projects. Given that they also belong to the EU, they will also apply the European General Data Protection Regulation (GDPR) of 24 May 2016.Participants in the events of POM West-Flanders:
    If you have given us your consent to do so when you register for an event, we can distribute your surname, first name and organisation to the other participants in the event, if this would contribute to the purpose and success of the event. We wish to do this, for example, at events specifically aimed at networking and establishing contacts.
  • The employees of POM West Flanders:
    Our employees have access to your personal data on a need-to-know basis and can process them in the context of their assignments. It goes without saying that anyone who has access to your personal data is always bound by strict obligations to treat your personal data securely and confidentially.
  • Local authorities and local partners:

If you have given us permission, your personal data, and more specifically your photo and image material,

may be disclosed to other local authorities and partners, but under strict conditions and only for purposes of

provincial promotion, i.e. to make our operations better known.

  • Subcontractors of POM West-Flanders, such as hosting and IT service providers:
    In order to process your data, we use a number of applications or programs. A number of these applications are with external service providers that specialise in this field. Some of those suppliers have also developed the application and are carrying out the management of the application for us. We have entered into commitments with these suppliers to ensure that they will also handle your personal data carefully and correctly.
  • Logistics and postal companies (such as Bpost):
    These companies enable POM West Flanders to deliver correspondence or parcels to you.
  • Financial institutions, payment service providers or payment initiation service providers:
    Your personal data will only be shared with these institutions when you have to make a payment to POM West-Flanders.

However, please note that if you use the social media of the POM West-Flanders, your personal data will also be processed by these social media providers.

We intend to process your personal data only within the European Economic Area (EEA). If a transfer of your personal data outside the EEA should nevertheless take place, we will put in place sufficient safeguards to protect your personal data in the event of a transfer (for example, by concluding an agreement based on model contractual clauses as drawn up by the European Commission).

What are your rights and how can you exercise them?

As a data subject, you have certain rights and, at POM West-Flanders, we want to ensure that you can easily exercise these rights. However, you must bear in mind that not all of these rights can be invoked at your sole discretion. As a government body, we have a number of legal obligations and fulfil tasks in the public interest as a public authority, as a result of which we cannot always respond to requests for access, rectification, erasure, restriction of processing, data portability or objection to processing. The European General Data Protection Regulation (GDPR) of 24 May 2016 provides for exceptions in this respect. We will always give the reasons for any refusal on our part.

RIGHT TO WITHDRAW CONSENT:
For certain processing operations that are based on your consent, you as a data subject always have the right to withdraw your consent free of charge. This is the case when we process your personal data for the sending of our newsletters, for promotional and advertising purposes, to include your personal data in our recruitment reserve and in the context of your participation in one of our events. Withdrawing your consent can be done either via a link in the newsletter you received or by sending an e-mail to dpo@pomwvl.be. Please note that withdrawing your consent does not affect the lawfulness of the processing on the basis of the consent prior to withdrawal.

RIGHT OF ACCESS:

You have the right to access your personal data, which means that you can ask us to provide you with information about the personal data we hold about you. You can even request a copy of your personal data. Please note, however, that you must indicate the processing activities for which you wish to have access to your personal data.

If you make the same request repeatedly and clearly cause inconvenience, we may refuse these successive requests or charge you an administrative fee to cover the costs. We can also refuse you the right of access to your personal data or only grant you partial access if such access could disproportionately harm the rights and freedoms of others, including those of POM West Flanders.

RIGHT TO RECTIFICATION:
You have the right to request that we correct your personal data if you can demonstrate that the personal data we process about you is inaccurate, incomplete or out of date. Please indicate the context in which we use your personal data (e.g. to send you newsletters) so that we can review your request quickly and accurately.

RIGHT TO ERASURE:
You may request us to erase your personal data if it is no longer necessary for the purposes for which we collected it, if its collection was unlawful or if you have successfully exercised your right to withdraw your consent or your right to object to the processing of your personal data. Where either of these circumstances applies, we will delete your personal data immediately, unless legal obligations or administrative or judicial orders prohibit us from deleting your personal data.

RIGHT TO RESTRICTION OF PROCESSING:
You may ask us to restrict the processing of your personal data:

  • during the time that we review your request for rectification of your personal data;
  • during the time that we assess your objection to the processing of your personal data;
  • where such processing was unlawful, but you would prefer a restriction to erasure;
  • when we no longer need your personal data, but you need them for the purpose of establishing, exercising or defending a legal claim.

RIGHT TO OBJECT:
When we process your personal data on the basis of our own legitimate interests, i.e. you have not given us your consent and we do not need them for the performance of a contract or to comply with legal obligations, you have the right to object to the processing of your personal data by us. If our interest relates to direct marketing, we will comply with your request immediately. For other interests, for example our security interests, we ask you to describe your specific circumstances that give rise to the request. We will then have to weigh your circumstances against our interests. If this balancing exercise results in your circumstances outweighing our interests, we will cease processing your personal data. However, if the intended processing qualifies as direct marketing, you have the right to object to such processing free of charge and without justification.

RIGHT TO DATA PORTABILITY:
Where we have collected your personal data on the basis of your consent or because the processing was necessary for the performance of a contract with you, you have the right to obtain a copy of your personal data from us in a structured, commonly used and machine-readable format. However, this right only applies to personal data that you have provided to us.

To exercise your rights or for other questions:

  • By letter: send your question to POM West-Flanders, Koning Leopold III-laan 66, 8200 Bruges
  • By e-mail: send your question o dpo@pomwl.be

Please note: in order to be able to answer your question, your request must be dated and signed and we will need proof of your identity. This can be done by sending a copy or scan of your identity card. We will only use this copy or scan to determine whether you are actually the data subject whose personal data is being processed, or the parent or guardian in the case of people under 16yo. This way, we prevent a personal data breach from occurring, for example, because an unauthorised person is impersonating you and is exercising a right on your behalf. As soon as we are both satisfied with the answer to your question, we will destroy the copy or scan.

Furthermore, we ask you to clearly indicate and specify in your request which right you wish to exercise. Please always indicate the context in which we have obtained your personal data, so that we can process your request quickly and carefully.

We will inform you of the receipt of your request as soon as possible. If the request proves to be justified, we inform you as soon as possible and no later than thirty (30) days after receipt of the request.

Where can you go if you are not satisfied with the way we are handling your data?

We do our utmost to treat your personal data correctly. If you are nonetheless dissatisfied with our way of working, then please contact us in the first place using the contact details at the bottom of this page or contact our Data Protection Officer (DPO) at dpo@pomwvl.be.

If you are not satisfied with our response, you can always lodge a complaint with the Belgian Data Protection Authority, whose contact details are given below:

Data Protection Authority
Rue de la Presse 35, 1000 Brussels

tel: +32 (0)2 274 48 00
e-mail: contact@apd-gba.be
https://www.dataprotectionauthority.be/citizen

Alterations to this privacy policy

POM West-Flanders may alter or amend this privacy policy at any time. When changes have been made, POM West-Flanders will change the date at the top of this page. The new privacy policy will apply to you from this date, unless you notify POM West-Flanders of your objections within three (3) days of the publication of the altered privacy policy. We therefore advise you to consult this page regularly in order to stay informed about our privacy policy and how we protect your personal data.