Crowe attaches great importance to the protection of your personal data and respects your privacy. This privacy statement is intended to inform you about how we collect, use, share, and protect your data in accordance with applicable legislation.
This Privacy Statement applies to all personal data collected and processed by Crowe Spark Belgium and its affiliated entities within the meaning of art. 1:20 of the Belgian Code of Companies and Associations (hereinafter "Crowe").
Crowe processes personal data of natural persons with whom we have, have had, or wish to have a direct or indirect relationship. This includes data from current and potential clients, suppliers, contractors, and employees, as well as potential clients and potential employees.
The use of your personal data is always dependent on various purposes:
· Client acceptance procedures: as a member of a professional organisation (ITAA/IBR), Crowe is subject to anti-money laundering legislation. Under this legislation, our clients must undergo a client acceptance procedure. For all services you wish to engage us for, we collect your identification data such as your name, address, telephone number, email address, VAT number, and we request a copy of your identity card. This processing is based on the legal obligation incumbent upon us.
· Provision of services: Crowe collects personal data in order to provide the requested services to you or our clients. We collect socio-demographic data (e.g. marital status and family situation), financial data (e.g. income and assets), personal characteristics (e.g. age and gender), lifestyle data (e.g. information about social contacts or accidents), memberships, housing characteristics, training and education data, and employment data. Given our extensive range of services, the way we process personal data may vary depending on the service(s) the client engages. This processing is necessary for the performance of our contract with our client.
· Financial administration: Crowe processes identification and invoicing data to maintain its own accounting and invoicing. This processing belongs on the one hand to the legitimate interest of Crowe, namely the ability to maintain its administration and obtain payment for the services it has provided, and on the other hand a legal obligation rests on Crowe to keep its accounts.
· Maintaining client relationships: Crowe processes personal data for sending newsletters about our products and services that we believe may be of interest to you. Sending newsletters to our clients belongs to our legitimate interest. When you receive newsletters from us, you always have the option to adjust your preferences or to unsubscribe entirely. You will, however, continue to receive communications regarding the timely submission of documents and/or information relating to, for example, your personal tax return.
· Facilitation of acquisition opportunities: when you leave your contact details on our website to express interest in potential acquisition opportunities, we process this data to contact you about this. This processing is based on your explicit consent.
· Recruitment: Crowe collects personal data for the purpose of recruiting new employees. This processing is based on the one hand on the consent of the candidate employee and on the other hand on the legitimate interest of Crowe to recruit the suitable candidate for a vacancy.
· Direct marketing: if you are not a client of Crowe but wish to be kept informed of our services and activities, you can always subscribe to our newsletters. In this case, we process your personal data solely with your consent. You always have the option to adjust your preferences or to withdraw your consent by using the unsubscribe link at the bottom of the newsletter.
· Improvement of services: if you are a client of Crowe, we may supplement your profile with data obtained from our CRM and ERP systems or other sources of information. We also have access to data available from publicly accessible sources such as the National Bank, KBO and the Belgian Official Gazette.
· Security: when you enter our office buildings, you may be filmed. These camera images serve solely for the security of our office buildings. It belongs to our legitimate interest to process these data in the context of the security of our infrastructure, our employees and clients.
· General purposes: Crowe processes all the above-mentioned personal data where necessary to comply with legal obligations, as well as to comply with a legitimate request from competent officials or representatives of the police, judicial authorities, government bodies, including data protection authorities. Crowe also processes this data where necessary to prepare and execute business transactions, such as mergers, acquisitions or demergers, for which we rely on our legitimate interest.
· Special categories of data (art. 9 GDPR): Crowe may also collect special categories of personal data, such as medical data (in the context of estate planning or other optimisations). These data are only processed with your explicit consent.
Your data is not shared for commercial purposes with third parties.
Within the Crowe group, we handle your personal data with great care and only share the data necessary to provide you with the best service. Your data may be shared between the various entities of Crowe Spark Belgium if this is necessary for administrative purposes or to provide the services you wish to engage. In the event of reorganisations within the group, Crowe may share personal data in connection with the transfer of the entity to which the data relate. Crowe has taken measures to ensure that personal data exchanged or shared within Crowe are protected.
Sometimes we are legally required to share your personal data with external parties, namely public authorities and regulatory bodies where a legal obligation exists to communicate or disclose client data (such as the tax administration), and judicial or investigative bodies (such as the police, public prosecutor). In addition, there are also third parties to whom we are not legally obliged to transfer personal data, but on whom we rely for many of the services we provide: service providers who assist us with the design and maintenance of our internet tools and applications, and the management of our servers.
If you share personal data via social media, it may be read, collected and used by other users of these applications. Crowe has little or no control over these other users and therefore cannot guarantee that all social media applications comply with this Privacy Statement.
Crowe has developed various security measures to keep your personal data safe, correct and up-to-date. Specifically, we seek to prevent unauthorised access to, or unauthorised alteration, disclosure or destruction of personal data in our possession.
We do not keep your personal data longer than necessary for the exercise of our activities and the provision of our services, unless we are required by a legal obligation to keep your personal data longer or because the period within which legal proceedings may be brought is still ongoing. The facilitation of acquisition opportunities is based on your consent. You always have the right to withdraw your consent. Your data will be retained for 3 years by default after obtaining consent. At the end of this period, you will be informed by us and given the choice to reconfirm your consent. Your client file will in any case not be retained for longer than 10 years after the termination of our client relationship.
You have various rights regarding the personal data we process:
· Right of access: you have the right to obtain confirmation that we process personal data about you and to request a free copy of the personal data we hold about you.
· Right of rectification: you have the right to request that we update the personal data we hold about you or that we correct or supplement any inaccurate personal data.
· Right of erasure and restriction: you have the right to request that we delete your personal data. You acknowledge that in the event of a request for deletion, certain services may not be provided. You may also request that we restrict the processing of your personal data.
· Right to object: you always have the right to object to the use of your personal data. You must, however, motivate this request. You may also expressly object to the processing of your personal data for direct marketing purposes, for which you do not need to provide any motivation.
· Right to data portability: you have the right to obtain your personal data processed by us in a structured, commonly used and machine-readable format. You also have the right to have this data transferred to other data controllers.
· Right to withdraw consent: you have the right at any time to withdraw your consent for the processing of your personal data (provided that the processing is based on your consent).
· Right to lodge a complaint: you also have the right to lodge a complaint with the Belgian supervisory authority: Data Protection Authority, Drukpersstraat 35, 1000 Brussels, Tel. 02/274.48.00, Fax. 02/274.48.35, [email protected].
If you wish to exercise the above rights, you may contact [email protected]. Before complying with your request, we may ask you to provide proof of identity.
Our Privacy Statement may change from time to time. All changes will always be indicated on this page. If you have questions about the processing of your personal data by Crowe, you may contact our Data Protection Officer (DPO) via dpo@vdl.be or by letter to DPO Crowe – Sneeuwbeslaan 14, 2610 Antwerpen.