Personal data protection policy

27 Apr

The confidentiality and security of your personal data (“Data”) is extremely important to us.

The present data protection policy (“Policy”) describes how we process your Data and provides information about your rights.
It contains information about the following:

THE DATA CONTROLLER
THE SCOPE OF APPLICATION
THE PURPOSE OF PROCESSING
THE LEGAL BASIS FOR PROCESSING
a. The execution of our public interest missions
b. The execution of a contract with you
c. Our legitimate interest d. Your consent
TYPES OF DATA PROCESSED
DATA TRANSMISSION AND GUARANTEES
DATA RETENTION PERIODS
SECURITY MEASURES REGULATING DATA PROCESSING
YOUR RIGHTS WITH RESPECT TO YOUR DATA
a. Right of access
b. Right of rectification
c. Right to erasure
d. Right to restrict processing
e. Right to object
f. Right to lodge a complaint with the Data Protection Authority
DISPUTE RESOLUTION

1. Data Controller

Your Data Controller is the public limited company with a social purpose Brussels Agency for Business Support, whose registered office is located at Chaussée de Charleroi 110, 1060 Saint-Gilles, registered with the Banque-Carrefour des Entreprises under number 0678.485.603, operating under the trade name “hub.brussels” (“hub.brussels” or “we”). hub.brussels hosts the 1819 department. hub.brussels is a Brussels-Capital Region public interest organisation..
For any questions about the processing of your personal data, please contact our Data Protection Officer at the following email address: compliance@hub.brussels.

2. Scope of Application

This Policy explains how we collect, record, process, use and transfer your Data. It also describes where and how we collect your Data, as well as your rights related to all of the Data we have about you.

The Policy was last updated on the above date. It is subject to change and we recommend that you review its contents on a regular basis. Any substantial changes to the Policy will be expressly mentioned on the website homepage.

This Policy can be completed by contracts and specific clauses intended to cover particular aspects of our relationship with you, and when we have to provide you with more extensive information about how we collect and use your Data.

Concepts such as “processing”, “data controller”, “processor”, “person concerned”, “personal data”, etc. have the meaning assigned to them by the General Data Protection Regulation (GDPR) (Regulation no. 2016/679 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).

The GDPR can be viewed at: https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=CELEX:32016R0679.

3. The purpose of processing

Your Data are processed for specific purposes which will differ depending on the type of relationship you have with hub.brussels. hub.brussels primarily processes your Data to execute its public interest missions based on the Order of 18 May 2017 on the creation of the Brussels Business Support Agency, and to offer you its services on this basis.

The public interest missions are as follows:

All individual and collective public service advisory and support activities, both those aimed at Brussels-based companies and businesses with a view to aiding their development, and those aimed at foreign companies and businesses with a view to promoting investment in the Region. hub.brussels may also undertake operations which contribute directly or indirectly to the fulfilment of this purpose.
hub.brussels is responsible for the following public sector missions:
- Advising, equipping and supporting economic projects in Brussels and their leaders to ensure their success in the Region and in other countries;
- Identifying, generating, initiating and attracting new economic, technological and investment opportunities, both in the Region and in other countries;
- Assisting the public authorities in creating and implementing a proactive economic policy and in fostering a stimulating entrepreneurial ecosystem, in particular through marketing initiatives in the Region and in other countries.
In addition to these missions, hub.brussels:
- Provides the “one-stop” information and guidance service (known as “1819”) with an operational framework which enables it to fulfil its purpose of educating, informing and guiding entrepreneurs in the Region;
- Coordinates the Region’s network of Economic and Commercial Attachés;
- Provides the secretariat for the Economic Coordination Council and coordinates its working groups, as provided for in the Brussels-Capital Region Government decree of 28 November 2002 on the creation of the Economic Coordination Council.
On a reasoned proposal by the Minister, the following public service missions are also entrusted exclusively to hub.brussels:
1° completion of exploratory studies to identify new programmes and projects, within the context of the economic and business policy;
2° provision of expertise and assessment of programmes and projects, within an economic and business policy context.
In addition to the public service missions assigned to it, hub.brussels may take any actions, or engage in any activity entrusted to it by any international institution or legal entity under Belgian or foreign law that contributes directly or indirectly to its corporate purpose, provided that they are compatible with its assigned missions and comply with competition regulations.
hub.brussels may undertake missions on behalf of third parties, provided that they fulfil the following three conditions:
- the missions must be compatible with the public service missions of hub.brussels, as set forth above;
- the missions must not compromise the high quality standards required of hub.brussels missions;
- the missions must be part of a Government-approved regional or sector-specific strategy.

In order to enable us to complete our public interest missions, we process your Data for the following purposes:

To answer any inquiries you make by email, post, telephone or during a conversation with one of our agents;
To send you emails with information regarding the public services we offer, which may be of interest to you;
To send you emails inviting you to events promoting both the development of Brussels-based businesses and companies and the development of foreign business and companies with a view to encouraging them to invest in the Region;
To send you awareness-raising emails as part of our public interest mission;
To manage your participation in competitions organised by hub.brussels and to contact you if you win. It is also in our legitimate interest to process these Data in order to combat fraudulent competition entries. For competitions held on Facebook, you are free to choose which data you wish to share via the hub.brussels Facebook page;
To conduct satisfaction surveys;
To use cookies on our websites;
To use social networks (Facebook, Twitter, etc.) to provide you with information. The general terms and conditions of the social network operators apply. By using the services, you accept these terms and conditions.

hub.brussels also processes your Data in order to execute any contracts that it may have entered into with you, or for legitimate purposes such as producing statistics or combating fraud.

4. Legal basis for processing

The processing of your Data by hub.brussels is founded on the following legal bases:

1. The fulfilment of our public interest missions

In the majority of cases, we process your Data in order to communicate with you or provide you with information on our activities as part of our public interest missions, as set forth by the Order of 18 May 2017, concerning the creation of the Brussels Business Support Agency. This also includes “non-commercial direct marketing”, that is, the use of your email address or telephone number to send you information about our activities. You can opt out of receiving this type of information at any time.

2. Fulfilment of a contract with you

We may also process your Data to the extent necessary to fulfil a contract between you and hub.brussels, or to execute pre-contractual measures at your request. This essentially applies to cases when you receive support from hub.brussels. We only collect the Data needed to fulfil the contract, that is, the Data that will enable us to communicate with you and provide you with the requested service.

3. Our legitimate interest

Under certain circumstances, it is necessary to process Data in pursuit of hub.brussels’ legitimate interests. In these cases, we will check that your fundamental interests, rights and freedoms do not take precedence over hub.brussels’ interests.

4. Your consent

hub.brussels will ask for your consent to use your Data in specific cases, such as the use of sensitive Data. If you have given your consent, you may withdraw it at any time.

5. Types of data processed

hub.brussels ensures that your Data are processed in accordance with the applicable legislation, in an appropriate manner, and only as necessary for the intended purpose. hub.brussels may collect the following personal Data:

Identity details: including your last name, first name, date of birth, place of birth, gender, age, etc.
Contact details: postal address, email address, telephone number, etc.
Data about your online behaviour: such as the links you click on and the pages you visit;
Data related to complaints, questions and comments.

We do not collect and process special types of Data, unless we receive your explicit consent for this purpose, or are required to do so.

You will normally provide us with your personal data yourself (for example, when you contact us by email or telephone, or when you create an account on the hub.brussels websites).

We may also use personal data which are available on public databases or provided by partners who have obtained your permission to share these Data with us.

6. Data transmission and guarantees

For the purposes described in Article 3, we may transmit your Data to external service providers, in particular providers of IT and hosting services and/or to our partners in public, public-private, private sectors and non-profit organisations that support businesses in Brussels or to Belgian companies applying for export.

We guarantee that these suppliers, partners and companies only have access to the Data they need to perform their tasks. We also guarantee that they are bound by a confidentiality obligation and may only process the Data in accordance with our instructions.

We are sometimes required to transmit your personal Data. This is the case when a law, a regulation or legal proceedings (such as a court ruling) requires us to do so: at the request of the authorities and the police within the context of law enforcement actions. We may also consider it necessary or desirable to transfer your Data in order to prevent physical or financial harm, or in the case of investigations into suspected or proven fraud or illicit activity.

We also reserve the right to transmit all Data we hold about you in the case of full or partial transfer of our activity or assets. Under these circumstances, we undertake to do everything within our power to ensure that the assignee uses your Data in accordance with this Policy. If such a transfer occurs, you may contact the assignee with any questions regarding the processing of your Data.

7. Data retention periods

We will retain your Data for a period not exceeding that necessary to achieve the purposes for which they were collected and defined in point 3.

In addition to fulfilling these purposes, hub.brussels may store certain Data for a maximum of 10 years, in order to be in a position to defend its interests in a court of law and comply with its obligations, particularly in terms of taxation.

8. Security measures regulating data processing

hub.brussels has taken appropriate measures to ensure that, insofar as is possible, the servers hosting the Data processed prevent:

Unauthorised processing or modification of, or access to, the Data;
Inappropriate use or disclosure of the Data;
Illegal destruction or accidental loss of the Data.

To this end, hub.brussels employees who have access to the Data are bound by strict confidentiality requirements. However, hub.brussels cannot be held liable for the misappropriation of these Data by third parties, in spite of the security measures taken.

9. Your rights with respect to your data

You have the following rights with regards to your personal Data which we process. In order to exercise the rights in points a) to d), please email compliance@hub.brussels compliance@hub.brussels.

1. Right of access

You have the right to know whether or not hub.brussels is processing your personal Data and, if they are, to access and obtain information on how they are processed.

2. Right of rectification

You have the right to rectify your personal Data if they are inaccurate, or to complete them if they are incomplete.

3. Right to erasure

You have the right to request erasure of your personal Data if there is no longer any reason to process them.

4. Right to restrict processing

You have the right to request that the processing of your personal Data be limited, in which case we may only store said Data, without processing them in any other way.

5. Right to object

At any time, you have the right to object, on grounds relating to your particular situation, to the processing of your personal data which is based on the completion of the public interest missions of hub.brussels or our legitimate interests, including profiling founded on this lawful basis. We will no longer process your Data, unless we prove that there are legitimate and overriding reasons to do so, which take precedence over your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

6. Right to lodge a complaint with the Data Protection Authority

You have the right to submit a complaint to the Data Protection Authority, under the conditions and within the time limits established by the GDPR and any other legislation applicable to the processing of personal data. It can be contacted at the following:

Data Protection Authority:
Rue de la Presse, 35, 1000 Brussels
Tel: +32 (0)2 274 48 00
Fax : +32 (0)2 274 48 35
Email: contact@apd-gba.be.

10. Dispute resolution

This Policy is governed exclusively by the GDPR and the laws by which it is implemented in Belgium, in particular the law of 30 July 2018 on the protection of natural persons with regard to the processing of their personal data, in addition to other Belgian regulations, to the exclusion of its rules on conflict of laws.

All litigation concerning the validity, application, interpretation or implementation of this Policy that cannot be settled amicably, shall fall under the sole jurisdiction of the Brussels courts.

Personal data protection policy