Privacy policy

Version 1.0
Date: 21 september 2023

1. Identity and contact details of the processing controller 

This privacy policy applies to all personal data processed by De btw-lijn (English trade name “VAT aLined”), with registered office at 2640 Mortsel, Roderveldlaan 100/6, with company number VAT BE0629.761.216, which is the controller of this website. 

The Controller attaches great importance to your privacy and therefore processes your personal data in accordance with European Regulation 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter “GDPR”) as well as any future or additional legislation implementing it, as applicable.  

For further questions or comments regarding our handling of your personal data, please contact us at any time, either by e-mail to info@btw-lijn.be or by mail to the aforementioned mailing address.  

2. What does “process personal data” mean? 

Processing personal data (hereinafter “data”) includes any processing of data that can identify you as a natural person. You can read about what data is involved in this Privacy Policy. The term “processing” is very broad and covers, among other things, collecting, storing, using your data, or sharing it with third parties.  

3. What data do we process? 

Below we clarify what data we may process from you. Depending on the specific situation, your preferences and the way you contact us, we do not process all of the following data about you.  

Main activity 

• Contact details; 
• Id, passport or other identification documents; 
• Order, billing and payment information; 
• Data provided by you as part of our services that relate to you, your company or your clients; 
• Communication data, opinions, working papers; 
• Data we process to comply with legal obligations such as anti-money laundering legislation and the UBO register such as ID card, date of birth, place of birth, nationality.  

Website Visitors 

From visitors to our website, we may process the following data:  

• Via cookies: IP address, browser type, location data, how the individual arrived at the website, interests and how the individual navigates the web page (via strictly necessary and analytical cookies). More information and a detailed overview of the cookies we may set can be found in our cookie banner which can be accessed at any time by clicking on the cookie icon at the bottom left of the website; 
• Via the registration form: Name, first name, company number, e-mail address, phone number, ITAA registration number, password (via online registration form). 

Training and commercial objectives 

Contact information such as your name, phone number and email address will be used to send newsletters or for contact.  

For training courses, additional payment information, a badge and attendance lists are processed and photos and/or videos may be taken. Registration is done on the ITAA platform. 

Suppliers – service providers 

From our suppliers and service providers, we may additionally process the following data: 

• General identification data contact person within the company (name, first name, address); 
• General contact information contact person within the company (name, first name, address, e-mail address, phone number);  
• Contractual data (e.g. company name, address, VAT number, agreement, etc.); 
• Payment and billing information (e.g. payment card details, invoices, etc.); 
• Platform account information (e.g., account creation registration information);  
• Feedback, testimonials, quotes, promotional content such as photos and videos (e.g., reviews and experiences related to our (collaboration) work, testimonials, quotes, attendance at events, etc.). 

Candidates 

In addition, we may process the following data on candidate employees. Of course, this will depend to a large extent on what data you yourself wish to provide us with in relation to your application.  

• Contact details 
• Personal details; 
• Work-related data; 
• Personality data; 
• Communications 
• Media (photos, videos)  

4. For what purposes do we process your data?

Personal data are processed exclusively within the framework of the business and in particular for the following purposes: 

• Within the framework of our main activities,; 
• Organize training and events; 
• Participating in trade shows; 
• Meet administrative and tax obligations; 
• Comply with legal obligations such as anti-money laundering laws; 
• Communication with customers and prospects; 
• Within the framework of our operation as an office; 
• For commercial purposes.  

5. On what grounds do we process your data?

We process your data only to the extent based on one of the processing grounds listed in the GDPR, and as shown below.  

Legal obligation 

Certain data are processed by us to comply with legal or regulatory obligations imposed on us. For example, in the context of tax and accounting obligations, anti-money laundering legislation or in the area of data protection. 

Necessary for the performance of the agreement 

Certain data are processed by us because it is necessary for entering into, performing or terminating a contract with you as a data subject. For example, for contacting, scheduling, responding to an inquiry, preparing and delivering an advice or requesting information in the context of entering into the contractual relationship or assignment, in order to provide you with our services or receive them from you.  

Legitimate interest 

Certain data are processed by us based on our legitimate interest which in specific cases outweighs any possible prejudice to your rights. For example, for promoting our activities to business contacts; improving the quality of our services; sending you newsletters within an existing customer relationship; training employees and evaluating and maintaining data and statistics related to our activities, in the broadest sense; preserving and using evidence in the context of liability, litigation or disputes and for the purpose of archiving activities; and ensuring security, both online on this website and on our premises. 

Permission 

Certain data is processed by us based on your consent. For example, to promote activities to potential business contacts; the use of certain analytical or marketing cookies; the posting of photos containing personal data on our website and social media channels. Data of job applicants after the recruitment process will be kept only with permission. 

6. Origin of data 

We also obtain most of the data we process from you directly. Within the scope of our services, we may obtain data from you through external service providers or public sources. 

7. With whom do we share your data? 

We do not disclose your information to third parties, except when strictly necessary in light of the above-mentioned purposes, or if we are required to do so by law. 

Where necessary, we use external service providers (processors) to support our operational purposes such as the management of our websites and IT systems. Where appropriate, these external service providers carry out certain data processing operations on our behalf. We will only share your data with these external service providers to the extent necessary for the relevant purpose. The data may not be used by them for other purposes. In addition, these service providers are contractually bound to ensure the confidentiality of your data by means of a “processing agreement” concluded with these parties.   

Specifically, as relevant in your situation, we share your data with the following third parties for the following purposes, with these third parties acting as processors on our behalf in certain cases: 

• Postal, transportation and delivery companies if we need to send you something by mail;  
• Payment service providers if we receive payments from you, or vice versa;  
• External representatives and consultants or any other parties involved as part of our main or ancillary activities;  
• The processors who assist us in IT to operate our organization for the purpose of secure and efficient digital data management within our organization;  
• Government bodies, judicial authorities and practitioners of regulated professions such as accountants and lawyers, for the purpose of complying with our legal obligations and defending our interests, as required. 

8. How long do we keep your data? 

We do not retain your data longer than necessary for the purpose for which the data was collected or is processed. Since the period for which the data can be kept depends on the purposes for which the data was collected, the storage period may vary in each situation. Sometimes specific legislation will require us to keep the data for a certain period of time. Our retention periods are always based on legal requirements and a balancing of your rights and expectations with what is useful and necessary to fulfill the purposes. At the end of the retention period, your data will be deleted or anonymized.   

9. Where do we store your data and how is it protected? 

We provide appropriate security measures on a technical and organizational level, to avoid, within the scope of our activities, the destruction, loss, falsification, modification, unauthorized access or unauthorized notification to third parties as well as any other unauthorized processing of this data.  

We are also careful to ensure that the processors we rely on also take appropriate security measures to minimize risks of incidents as much as possible. 

If, when using specific services or software tools, your data is processed outside the European Economic Area (EEA), it will only be processed in/to countries that the European Commission has confirmed as providing an adequate level of protection for your data, or measures will be taken to ensure the lawful processing of your data in these third countries. 

10. What are your rights? 

You have various rights regarding the data we process about you. If you wish to invoke any of the rights set out below, please contact our GDPR Officer using the contact details included under the first heading of this Privacy Policy. 

Right of inspection and copy 

You have the right to access your data and obtain a copy. This right also includes the possibility of requesting further information about the processing of your data, including the categories of data processed about you and for what purposes. 

Right of adaptation or rectification 

You have the right to have your data amended if you believe we have incorrect data. 

Right of data sharing (right to oblivion). 

You have the right to request that we delete your data without unreasonable delay. However, we will not always be able to comply with such a request, including when we still need the data in function of an ongoing contract, or when keeping certain of your data for a certain period of time is required by law. 

Right to restriction of processing 

You have the right to restrict the processing of your data. In this way, the processing is temporarily stopped until, for example, there is certainty about its accuracy. 

Right to withdraw your consent 

Where processing is based on your consent, you have the right to withdraw this consent at any time by contacting us. For marketing messages you receive from us via e-mail based on your consent, you can easily withdraw this consent by clicking on the unsubscribe link at the bottom of any such message. 

Right to object 

You have the right to object to the processing of your data based on legitimate interest. This should be based on reasons specific to your situation. You may also object to the use of your data for direct marketing purposes. For marketing messages by e-mail, an opt-out will always be provided. 

Right to transferability 

You have the right to obtain in electronic form your data that you yourself have provided to us with your consent or in performance of a contract. In this way, they can be easily transferred to another organization. You also have the right to request us to transfer your data directly to another organization, if this is technically possible. 

Right to complain to your supervisory authority 

Should you believe that we are processing your data in an incorrect manner, you always have the right to lodge a complaint with your data protection supervisory authority.  

Belgian Data Protection Authority (GBA). 
Printing Press Street 35 
1000 Brussels 
contact@apd-gba.be 

11. How can you exercise your rights? 

You may exercise your rights by contacting us, either by email to info@btw-lijn.be or by mail 2640 Mortsel, Roderveldlaan 100/6, provided that you enclose a copy of the front of your identity card or other document that identifies you. The copy will only be used to identify you in accordance with the GDPR. 

12. Changes 

We reserve the right to change this Privacy Policy. The most recent version is available on our websites at all times. The date this Privacy Policy was last amended can be found at the top. In case of a substantial change to the Privacy policy, we will directly inform the data subjects on whom it may have an impact, if possible.