CUSTOMER NOTICE CONCERNING PRIVACY PROTECTION
Aaxe Titres-Services’* offices are located at 61 Boulevard Saint-Michel in 1040 Brussels, Belgium (hereafter ‘Aaxe Titres-Services’). It acts as a controller and processes and uses personal data related to its prospective clients and clients (hereafter collectively the ‘Clients’), in accordance with the relevant data protection regulations, in particular European Regulation 2016/679 from the 27th of April 2016 known as the General Data Protection Regulation (hereafter ‘GDPR’). This notice about privacy protection aims to explain why and how Aaxe Titres-Services collects personal data about its Clients (hereafter ‘Client Data’), how it protects this data and how long this data is stored for. It does not affect specific provisions included in other documents if applicable.
(*Aaxe-titres-Services: the ‘Group’ formed of AAXE -T.S. Sprl, company no. 885.284.455; AAXE sprl, company no. 879.869.479; AAXE – A.M. sprl, company no. 887.999.168; AAXE-CLASS sprl, company no. 811.628.197; AAXE-CLEAN sprl, company no. 897.264.945; AAXE-NET sprl, company no. 897.265.143; AAXE-PROP sprl, company no. 811.627.506; AAXE-PUR sprl, company no. 834.893.450;Brightnet sprl, company no. 847.582.238)
1 Why Does Aaxe Titres-Services Process Client Data?
Aaxe Titres-Services stores and processes Client Data, digitally or otherwise, for administrative purposes, marketing and client management, and more specifically for the following, non-exhaustive range of activities: processing and responding to any communication, question or request that Clients submit to Aaxe Titres-Services (including via the website) or following initial contact with Aaxe Titres-Services, processing information concerning sales (potential or completed) of products and/or services by Aaxe Titres-Services and sending the summaries and invoices to Clients, providing Clients with information letters and other marketing communication, conducting surveys and market studies, improving the products and/or services of Aaxe Titres-Services, and conflict resolution.
2 What Are the Legal Bases of Client Data Processing ?
Client Data is processed on the basis of one or more of the following legal bases:
- With a view to concluding and managing the execution of a sales contract or other form of contract with a Client, including the invoicing procedure.
- In order to comply with legal requirements incumbent on Aaxe Titres-Services (e.g. concerning taxes).
- As part of the legitimate interests of Aaxe Titres-Services and/or a third party but which, in the opinion of Aaxe Titres-Services, would also be of benefit to Clients, such as, but not limited to, direct marketing and data analysis.
- Client consent concerned (e.g. to answer a survey). The Client may withdraw their consent at any time, it being understood that such a withdrawal shall not affect the legality of any processing that occurred before consent for this was withdrawn.
3 Which Client Data Categories are Processed ?
The Client Data is all the personal data about an identified or identifiable natural person. For the purposes mentioned above, the processing of personal data may include the following categories: personal identification data, such as name and address; electronic identification data, such as email address and telephone number; personal data, such as date of birth, language(s) spoken, nationality and gender; Sodexo identification number; financial identification data (bank account numbers); purchasing habits (volume of products and services, promotional activities, interventions in the event of an accident, etc.); participation in events (including family members, if applicable); and survey result data.
4 Where Does Client Data Come From ?
When a Client contacts Aaxe Titres-Services, the initial data generally comes from the individual concerned. Aaxe Titres-Services may also contact a Client for prospecting purposes when the initial data was not obtained from the Client but from other individuals who have sent their contact details to Aaxe Titres-Services. As part of the relationship with Aaxe Titres-Services, the Client will provide additional information (e.g. the information required for the services to be provided). If the Client does not provide Aaxe Titres-Services with the information required by law or the contract, they may decide to not enter into the contract, or even to terminate it. Equally, if the Client does not provide other information, they cannot benefit from the advantages associated with it. For example, if a Client does not wish to share their email address with Aaxe Titres-Services, the Client will not receive any electronic information letters from Aaxe Titres-Services. Aaxe Titres-Services may also receive data about a Client from other Clients, from Aaxe Titres-Services suppliers or, more broadly, from other individuals that the Client comes to exchange this data with as part of their relationship with Aaxe Titres-Services.
5 Who Has Access to the Client Data ?
For the purposes mentioned above, personal data may be divulged to, and even possibly processed by:
- The Clients themselves or individuals with a mandate to do this.
- Aaxe Titres-Services staff who need to know the personal data concerned.
- The individuals and legal entities in direct contact with Aaxe Titres-Services, such as its subsidiaries and those performing services.
- The public authorities in compliance with the applicable regulations, such as the tax authorities.
- The Aaxe Titres-Service service providers and other professional advisors who need to know the information, such as insurance companies and IT service providers.
6 Is Client Data Transferred Outside of their Country of Residence ?
In general, this data is stored in Belgium, but we may transfer certain information about Clients abroad, however this is always done in connection with the management of Aaxe Titres-Services’ activities. If the data is to be transferred outside of the European Union, Aaxe Titres-Services will organise appropriate guarantees in line with the GDPR.
7 How Long is Client Data Stored For ?
The Client Data will not be stored for longer than is necessary for the purposes mentioned above. Personal data about a potential Client will not be stored for longer than the normal duration for similar procedures, this generally being a maximum of one year after the end of these procedures. Typically, and subject to other provisions for certain specific data, Client Data will be stored for the duration of the contract and following the expiration or end of the contract as Aaxe Titres-Services may have a legal responsibility for which the use of this Client Data may be relevant, taking into account applicable prescription periods and legal conservation requirements.
8 How Is the Client Data Protected ?
Aaxe Titres-Services makes its best efforts to store and protect the Client Data from loss, disclosure and unauthorised access.
9 What Rights Do Individuals Have and Who Can They Contact ?
Individuals whose personal data is collected and processed as Client Data have, at any time and provided they provide sufficient proof of their identity, the right to contact Aaxe Titres-Services if they wish to:
- Access, correct or delete their personal data.
- Restrict or object to the processing of their personal data (e.g. for the purposes of direct marketing).
- Receive the data they have provided in a structured, commonly used, machine-readable format and to transmit it to another controller if they wish, when they were processed on the basis of their consent and/or the execution of the contract.
- Receive additional information about the guarantees in the event of international transfers of data.
- File a complaint with the Belgian Data Protection Authority or another EU supervisory authority if they believe that Aaxe Titres-Services has not acted according to the applicable regulations on data protection.
- The contact person at Aaxe Titres-Services is the GDPR and data protection coordinator, Mr Bruno DELANDER.
He can be contacted:
- Via letter or pre-arranged meeting: Mr Bruno DELANDER c/o AAXE, 61 Boulevard Saint-Michel, 1040 Etterbeek – Brussels.
- Via email to the following email address: firstname.lastname@example.org
- Via telephone: Extension 148 on 02 770 70 68
The individual concerned may contact him for additional information or if they wish to assert their rights concerning the protection of personal data processed by the controller.
Aaxe Titres-Services may amend this notice on privacy protection at any time when this is necessary, in particular to comply with changes to the regulation or requirements introduced by the data protection authorities.