Privacy Policy
1. WHO WE ARE.
“We”, ‘us’ or ‘our’ means Crowe Spark, with registered office at Sneeuwbeslaan 14, 2610 Wilrijk and with company number BE0780588890. We will be considered a data controller with respect to the personal data we collect in connection with your use of our website. The sole purpose of this privacy policy is to provide you with information regarding the processing of personal data in the context of our website. For the processing of personal data in the context of our services, we refer you to the existing agreements or contracts.
Your privacy is important to us. Hence, we have developed this privacy policy to provide you with more information regarding the collection, communication, transfer and use (“processing”) of the personal data you share with us, as well as to provide you with more information regarding your rights. We therefore request that you review this Privacy Policy.
If you have any questions, comments or complaints regarding this Privacy Policy or the processing of your personal data or wish to make a request in accordance with Article 4, please contact us by any of the following means:
By email: to contact@crowespark.be,
By mail: to Crowe Spark, Sneeuwbeslaan 14, 2610 Wilrijk.
This privacy policy was last updated on 01/08/2024.
2. HOW WE USE AND COLLECT YOUR PERSONAL DATA
Personal data is defined as any information about an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.) that can be used to directly or indirectly identify a natural person. The personal data we collect is collected for the following purposes:
If you use the contact form on our website, we use your personal data to respond to your request, either via e-mail, or by phone.
We process your data to manage our customer database. We process your data for the purpose of recruitment and processing job applications.
If you subscribe to our newsletter, your e-mail address will be used to send you our newsletters, which may include invitations to events, seminars, etc. organized by us.
We process your personal data for the purpose of supporting the website and improving your user experience. This purpose extends to monitoring the security, availability, (performance), capability, and health of our website.
3. RETENTION OF YOUR PERSONAL DATA AND DELETION
Your personal data will not be kept longer than necessary to fulfil the purposes for which it was collected.If you use the contact form on our website, your personal data will be kept for 3 years after the last contact;
Data for the management of our customer database are kept for 7 years after the end of the agreement or 3 years if no agreement was concluded;
Data for the purpose of recruitment and processing job applications are kept for 3 to 5 years;
Personal data processed for the purpose of supporting the website and improving your user experience on the website are kept in accordance with the retention periods that can be found in our Cookie Policy; However, we are entitled to keep your personal data if necessary to comply with our legal obligations, to bring a legal claim or defend ourselves against such claim or for evidentiary reasons.
Accounting data may possibly justify a longer retention period according to the relevant legal provisions. Other data that may be necessary for an efficient after-sales service or future services are kept anonymised to the extent possible so that they are not traceable to identifiable individuals.
4. YOUR RIGHTS AS AN INDIVIDUAL
This article contains an overview of your most important rights in accordance with applicable data protection legislation. We have tried to summarise them for you in a clear and readable way.
If you wish to exercise any of your rights, please send us a written request in accordance with Article 1 of this privacy policy. We will endeavour to respond to your request without unreasonable delay, but in any event within a period of one month from receipt of your request. If we are unable to respond within the aforementioned one-month period and wish to extend the period, or in case we will not respond to your request, we will notify you accordingly.
Right of access
In the event that we process your personal data, you have the right to access your personal data as well as certain additional information as described in this privacy policy. You have the right to receive from us a copy of your personal data that we hold, provided that this does not adversely affect the rights and freedoms of others. The first copy will be provided to you free of charge, but we reserve the right to charge a reasonable fee if you request multiple copies.
Right of rectification
If the personal data we hold about you is inaccurate or incomplete, you have the right to ask us to correct this information, or to ask us – taking into account the purposes of the processing – to complete it.
Right to data erasure / oblivion
When one of the following cases applies, you have the right to obtain – without unreasonable delay – erasure of your personal data:
• The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
• You withdraw your consent on which the processing is based, and there is no other legal basis for processing your personal data;
• Your personal data have been processed unlawfully;
• Erasure of your personal data is necessary to comply with EU or Belgian law;
• There are certain exclusions to the right to data erasure. These exclusions include where processing is necessary, To exercise the right to freedom of expression and information;
• For reasons of public interest in the field of public health;
• For the purpose of archiving in the public interest, or statistical purposes;
• For compliance with a legal obligation; or,
• For the establishment, exercise or substantiation of a legal claim.
Right to restriction of processing
You have the right to obtain the restriction of the processing of your personal data (meaning that the personal data may be stored by us and used only for limited purposes), if any of the following applies:
• You dispute the accuracy of the personal data, for a period that allows us to verify the accuracy of the personal data;
• The processing is unlawful and you oppose the erasure of the personal data and request instead that its use be restricted;
• We no longer need your personal data for the processing purposes, but you need it for the establishment, exercise or defence of legal claims; or,
• You have objected to the processing, pending the answer to whether our legitimate grounds outweigh yours.
• In addition to our right to store your personal data, we may still process it, but only:
o With your consent; For the establishment, exercise or defence of legal claims;
o To protect the rights of another natural or legal person; or,
o For reasons of public interest.
Before we lift the restriction on processing your personal data, you will be informed.
Right to portability of your personal data / data portability
If the processing of your personal data is based on your consent, and the processing is carried out through automated processes, you have the right to receive your personal data in a structured, common and machine-readable form. However, this right does not apply insofar as it would prejudice the rights and freedoms of others.
You also have the right to have your personal data, if technically possible, transmitted directly by us to another company.
Right of objection
You have the right at any time – due to reasons related to your specific situation – to object to the processing of your personal data, but only to the extent that the legal basis for the processing is that the processing is necessary for:
Right to file a complaint with a supervisory authority
If you believe that the processing of your personal data carried out by us violates data protection legislation, you have the right to lodge a complaint with a supervisory authority responsible for data protection. You can do so in the EU Member State of your habitual residence, of the place where you work or of the place where the alleged breach took place. In Belgium, you can complain to the Data Protection Authority, Rue du Printing Press 35, 1000 Brussels (contact@apd-gba.be), https://www.gegevensbeschermingsautoriteit.be/burger/acties/klacht-indienen.
5. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
If you are a customer of ours, we may disclose your personal data to suppliers with whom we have contracted to provide services to you. If you are a supplier of ours, we may disclose your personal data to our customers to contact you.
We may disclose your personal data to our successors and affiliates, if any, such as subsidiaries and sister companies, for the same purposes as set out in this Privacy Notice. For some aspects of our products and services, we work with third parties or engage subcontractors. The transfer of your data is only for the same purposes as with Crowe Spark itself. We ensure that, like us, they manage your data securely and respectfully.
Providing access to your data may be necessary for legal purposes. In such a case, we will be obliged to comply. We may also provide your personal data if this is necessary to protect the vital interests of another natural person.
We do not provide personal data to third parties. However, our website uses social media plugins that allow you to link to our social media channels or enable you to share content on your social media channels. These social media channels are: Facebook, Instagram, LinkedIn. If you click on such links, the aforementioned social media partners may collect personal data, such as personal data relating to your profile.
We are not responsible for how these social media partners use your personal data. In such case, they will act as data controllers. For your information, we list the relevant links below (however, these may change from time to time):
a. Facebook: https://www.facebook.com/privacy/policy/;
b. Instagram: https://privacycenter.instagram.com/policy/;
c. LinkedIn: https://linkedin.com/legal/privacy-policy/
6. TRANSFER OF PERSONAL DATA
We endeavour to limit the transfer and processing of personal data to countries within the European Economic Area or to countries that ensure an adequate level of protection equivalent to that guaranteed under the AVG and this privacy policy. In the case of processing outside the borders of the European Economic Area, we will provide you with further clarification upon written request.
7. COOKIES
Our website makes use of cookies. For further information please refer to our cookie policy.
8. CHANGES TO THE PRIVACY POLICY
From time to time, we may make changes to this privacy policy. The most recent version of the privacy policy can always be consulted on the website.