Privacy charter of COMPAGNIE FIDUCIAIRE ET DE GESTION SPRL
(updated: 16/10/2018)

1. Scope of application

The private limited liability company COMPAGNIE FIDUCIAIRE ET DE GESTION (whose registered office is located at 6032 Charleroi, avenue Paul Pastur 359, registered with the CBE under number 0759.412.703), with a place of business located at 88 rue Gachard, 1050 Brussels, hereinafter referred to as “CFG”, in its capacity as controller, attaches great importance to the protection of your personal data. This Privacy Charter (hereinafter referred to as “the Charter”) is intended to inform you of how CFG uses and protects the personal data that you need to send when you entrust the company with a task and/or when you contact the company, in particular through its website accessible from the following URL: https://www.cfg.be.

Any personal data collected by CFG will be transferred, stored and processed in accordance with 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 and the Law of 8 December 1992 on the protection of privacy with regard to the processing of personal data.

CFG reserves the right to modify this Charter at any time, in particular in order to comply with any legislative or technological developments. The date of its update will always be indicated at the top of this Charter. The changes made are binding on you as soon as the new version of the Charter is posted on the CFG website. You are therefore advised to consult this Charter regularly in order to be aware of any changes.

Terms such as “processing”, “controller”, “processor”, “data subject”, “personal data”, etc. have the meaning given 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).

2. Controller

In connection with your personal data, CFG is the controller.

If you have any questions about the processing of your personal data, please contact us by e-mail at info@cfg.be.

3. Category of personal data processed by CFG

When you entrust CFG with an accounting, tax or legal task, you must fill out a customer record and provide a copy of your identity card. The customer record contains a certain amount of information about you, including your first name, surname, national number, address, phone number, mobile phone number, fax number, e-mail address and VAT number.

During the performance of its task, CFG may be required to process other data strictly necessary for the processing of your file, including what are known as “sensitive” data, or data relating to any offences you may have committed and any criminal convictions against you.
In addition, when you contact CFG through its website, you will also be asked to fill in your contact details and therefore to provide the above-mentioned personal data.

In addition, when you contact CFG through its website, you will also be asked to fill in your contact details and therefore to provide the above-mentioned personal data.

4. Purpose of the processing and legal basis

CFG uses your personal data for the following purposes:

PURPOSESUSER DATALEGAL BASIS
1. CommunicationCFG uses your data in order to provide you with information in relation to the task you have entrusted to it.Address, e-mail address, phone number, mobile phone number or fax numberThis processing is based on the consent provided by you in the customer record or on the website or on performance of the contract between you and CFG.
2. Execution of the taskCFG uses your data in order to carry out the task you have entrusted to it correctly.All the data required to process your file (see above)This processing is based on the consent provided by you in the customer record or on the website or on performance of the contract between you and CFG.
3. PaymentCFG uses your data in order to send you invoices for the services performed within the framework of the task you have entrusted to it.Address, surname, first name and VAT number.This processing is necessary for the proper performance of the contract and for fulfilment of its statutory obligation to respect the formalities of an invoice.
4. Provision of informationCFG uses your data in order to send you by e-mail any legal information it deems useful with regard to the task previously entrusted to it.E-mail address.This processing is based on the consent provided by you in the customer record or on the website, or on the legitimate interest that CFG has in the light of the task previously entrusted to it.

You can ask to stop receiving this type of information at any time.

5. Compliance with the anti-money laundering lawCFG keeps your data in order to comply with its obligations under the anti-money laundering law of 18 September 2017.Surname, first name, place and date of birth, address.This processing is based on a statutory obligation.

CFG keeps your personal data for the duration of the processing of your file. Once your file has been closed, your data are kept for a maximum of 10 years, starting from the end of CFG’s services, in order to enable CFG in particular to meet its obligations in terms of liability.

5. Means of protection put in place

CFG undertakes to protect your data against unauthorised access and against unlawful use, accidental loss, destruction and damage. To this end, CFG has implemented the following measures in particular:

  • Use of antivirus software;
  • Installation of firewalls;
  • Encryption of saved data;
  • Physical data protection by securing the premises with cameras, an alarm system and a security patrol.

6. Recipients of personal data and guarantee in case of transfer to a third country

CFG undertakes not to transfer your personal data outside the European Union.

If the processing of your file so requires, CFG may be required to share certain data from your file, including your personal data, with other persons subject to the same obligations of professional secrecy. If this is the case, CFG undertakes to transfer these data through a secure electronic information exchange system.

7. Your rights concerning your personal data

a. Right of access

You have the right to access your personal data. To exercise your right of access, you can send an e-mail to info@cfg.be. The data that CFG has collected about you will be sent to you in hard copy format to the address that you have given in the above-mentioned e-mail or, failing that, in the customer record or on the website.

b. Right to rectification

You may, at any time, ask CFG to add to or change your personal data if you find that they are incomplete, incorrect or out of date.

c. Right to object

You are entitled to object to CFG processing your personal data. Exercise of this right to object is only possible in one of the following two situations: :
–      where exercise of this right is based on legitimate grounds; or
–      where exercise of this right is intended to prevent the data collected from being used for direct marketing purposes.

When your Personal Data are processed for direct marketing purposes, you have the right to object to their processing in all circumstances.

d. Right to erasure

You have the right to request the deletion of your Personal Data when there is no longer any reason to process them.

Please note, however, that even if you exercise your right to erasure, CFG is likely to retain certain information about you where it is required to do so by law (such as tax or accounting legislation) or where it has a legitimate reason to do so.

e. Right to restriction of processing

You have the right to request restriction of the processing of your Personal Data, in which case we may only retain such Personal Data to the exclusion of any other form of processing.

f. Right to withdraw your consent

You have the right to request restriction of the processing of your Personal Data, in which case we may only retain such Personal Data to the exclusion of any other form of processing.

g. Right to data portability

You also have the right to receive the data that you have provided to a controller in a structured, commonly used and machine-readable format and have the right to transmit (or request the transmission of) these data to a data controller other than CFG where:

–  the processing of your data is based on your consent or on the performance of the contract;
–  the processing is carried out by automated means.

To exercise these rights, you can contact CFG by e-mail at info@cfg.be.

CFG undertakes to respond within a reasonable period of time to any request relating to the exercise of the aforementioned rights. This period may not exceed one month from receipt of your request, unless CFG decides to exercise its right to extend this period by a maximum of two months.

h. Right to request information or to lodge a complaint with the Data Protection Authority

You are also entitled to request additional information or to lodge a complaint with the Data Protection Authority, whose contact details are as follows:

Adresse : Rue de la Presse, 35, 1000 Bruxelles
Téléphone : +32 (0)2 274 48 00
Fax : +32 (0)2 274 48 35
Email : contact@apd-gba.be