DATA PROTECTION POLICY

Last updated: 10/03/2022 

  1. Purpose of this data protection policy 

In the course of its activities, TSC may collect, store and process personal data concerning you, if you:

  • Are a business partner/ client of TSC (or the contact person of one of our business partners/ clients);
  • Are a prospect of TSC; 
  • Are one of the suppliers of TSC; 
  • Participate to an event organized by TSC;
  • Subscribe to the newsletters service of TSC;
  • Are an on-site visitor of TSC;
  • Are a visitor to the website of TSC;
  • Are a visitor of a TSC social media page;
  • Apply for a job, an internship or a temporary post

The purpose of this Data Protection Policy is therefore to explain in a clear and simple way the processing made by TSC on your personal data.  

This Data Protection Policy is regularly updated. We invite you to regularly consult our website to consult the current version. This Data Protection Policy is also always accessible at the TSC’s headquarters (Chaussée de La Hulpe 185, 1170 Watermael-Boitsfort).  

  1. General information applicable to any personal data processinG
    1. 2.1.Who is processing your data?

TOP SECRET COMMUNICATION SA (hereinafter “TSC” or “We”), with registered office at Chaussée de La Hulpe 185, 1170 Watermael-Boitsfort (Belgium) and registered with the Crossroads Bank of Enterprises under number BE 0427.633.111, is responsible for the processing of your personal data (as “data controller” within the meaning of the GDPR).

For any other questions regarding the processing of your personal data or requests in relation to this Data Protection Policy, please feel free to contact us by post at the above-mentioned address or by email at the following address: finance@top-secret.be. 

If you would like more information, or if you wish to lodge a complaint, you can contact the Data Protection Authority (Rue de la Presse, 35 – 1000 Brussels, Tel. + 32 2 274 48 00 – contact@apd-gba.be ; https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte).

    1. 2.2.As a data subject, what are your rights? 

The following section explains your rights under the GDPR.

Information – You have the right to be provided with clear, transparent and intelligible information about how We use your personal data and your rights. This right to be informed is exercised through this document. If the data processed includes data of your staff, you are responsible for making them aware of this document.

Access and rectification – You have the right to access your data and to have them rectified if necessary. 

You have the right to consult your data at any time and free of charge, by sending an email to finance@top-secret.be or a dated and signed letter to TSC headquarters (Chaussée de La Hulpe 185, 1170 Watermael-Boitsfort). You also have the right to demand that incorrect data be corrected and that inappropriate or unnecessary data be deleted by sending an email to finance@top-secret.be or by sending us a dated and signed letter to the address of TSC headquarters.  

Opposition – You may object to the processing of your data by TSC on the basis of our legitimate interest. You will be able to exercise your right to object through the unsubscribe links available in the e-mails sent to you or you can directly object by sending an email to TSC finance@top-secret.be 

Withdrawing your consent – Where data is processed on the basis of your consent, you may withdraw this consent at any time, without calling into question the past processing. 

Erasure – You may obtain the erasure of your data or the restriction of processing under the conditions set out in GDPR articles 17 and 18.

Portability – The data you have provided to us may be communicated or transmitted in electronic format.

    1. 2.3.Is your data transferred outside the European Union?

As a general rule, your data are exclusively stored on servers located inside the European Union. 

However, in the event of transfer outside the European Union, your personal data can potentially be sent to non-EU countries for whom the European Commission has not established an “adequacy decision”. In such a case, We ensure that this transfer is carried out in accordance with the applicable regulations and We ensure a sufficient level of protection of individuals’ privacy and fundamental rights (mainly through the adoption of the European Commission’s standard contractual clauses and supplementary measures). 

  1. Specific data processing depending on your quality
    1. 3.1.You are a business partner/ client of TSC (or a contact person of one of TSC’s business partners/ clients)

Categories of data collected 

If you are a business partner/ client of TSC (or a contact person of one of TSC’s business partners), the following personal data about you may be processed: identification data (last name, first name), contact data (your company, company postal address, business e-mail address, business telephone number, etc), financial/accounting/ invoicing information (bank account number, account holder).

Purpose(s) and legal basis

These personal data are processed for the purposes of executing and managing the contractual relationship: contract negotiation, placing orders, communication in this regard, delivery, invoicing and possible recovery of services, etc. This processing is necessary for the proper execution of the contract concluded between you and TSC. Without this data, TSC cannot execute the contract. 

Retention period

Your data are kept during 10 years after the end of the contract concluded with TSC, except when a different legal retention time would apply. 

Recipients

In order to accomplish the purposes listed above, your data may be communicated to the following recipients:

  • TSC staff members (employees, private consultant, trainees…), as well as its partners if the processing of your data is necessary for them to do their tasks;
  • Data processors (subcontractors) working for TSC;
  • Fiscal and social administration if the law so provides;
    1. You are a prospect of TSC 

Categories of data collected 

If you are a prospect of TSC, the following personal data about you may be processed: identification (LAST name, first surname), contact data (address, e-mail address, phone number), data related to your profession (company, title…).

Purpose(s) and legal basis

These personal data are processed for the following purposes:

  • For marketing purposes: if you have consented to the processing of your data by TSC (e.g. you provide TSC with your data), TSC will evaluate the possibilities of doing business with you. 

Retention period

TSC will retain your data for this purpose until you request it to stop. 

Recipients

In order to accomplish the purposes listed above, your data may be communicated to the following recipients:

  • TSC staff members;
  • Data processors (subcontractors) processing personal data on behalf of TSC. 
    1. You are a supplier of TSC

Categories of data collected 

If you provide services/products to TSC (or if you are a contact person of one of TSC’s supplier), the following personal data about you may be processed: identification data (last name, first name), contact data (e-mail address, telephone number), professional data (company, position), financial/accounting information (bank account number, account holder).

Purpose(s) and legal basis

These personal data are processed for the following purposes:

  • For the purpose of managing the contractual relationship: management of orders, offers, delivery, invoicing and payment and evaluation of the supplier’s performance (if any). This processing is necessary for the proper execution of the contract concluded between you and TSC. Without these data, TSC cannot execute the contract.
  • In order to ensure the security of the TSC’s infrastructures to which you have access in the context of the mission entrusted to you, your data may also be processed. This processing is justified by the TSC’s legitimate interest in ensuring the security of its offices.

Retention period

Your data are kept for 10 years after the end of the last contract with TSC. 

Recipients

In order to accomplish the purposes listed above, your data may be communicated to the following recipients:

  • The TSC’s staff members (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
  • The TSC’s subcontractors, processing personal data on behalf of TSC.

 

    1. You are an on-site visitor of TSC

Categories of data collected 

If you visit the TSC’s premises, the following personal data concerning you may be processed: identification data (last name, first name), contact data (e-mail address, telephone number), data relating to the visit (type of visitor, visitor’s contact at TSC, purpose of the visit, date and time of the visit).  

Purpose(s) and legal basis

These personal data are processed for the following purposes:

  • To ensure the security of the site (management of your arrival/departure on the site): TSC has a legitimate interest in ensuring the security of its sites, which involves organizing your visit.

Retention period

Your data are kept for 30 days after your last visit to the TSC’s premises.

Recipients

In order to accomplish the purposes listed above, your data may be communicated to the following recipients:

  • The TSC’s staff members (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
  • The TSC’s subcontractors, processing personal data on behalf of TSC. 

5. You are a visitor of the website of TSC

Categories of data collected 

If you visit the TSC’s website (www.top-secret.be), you do not have to provide any personal data. However, the provision of the website involves the collection of “cookies” (for more detailed information, see our Cookies Policy available on our website).

If you subscribe to our newsletters and/or if you contact TSC via the “Contact” form on the website, the following personal data about you may be processed: identification data (last name, first name), contact data (e-mail address), professional data (your company), any other information you include in your message (where relevant).

Purpose(s) and legal basis

These personal data are processed for the following purposes:

  • For the purpose of placing and reading cookies: some cookies are necessary to enable navigation on the website while others are optional and you are free to accept them or not. For more information, see our Cookie Policy.
  • When you subscribe to our newsletters service: to send you our newsletters, including to keep you informed of our upcoming events, news and publications. The collection and processing of your personal data is based on your consent.
  • When you send us a message via the contact form: to manage your request and respond to your request. The collection and processing of your personal data is based on your consent.

Retention period

Your personal data shall be stored/ processed: 

  • Regarding the cookies: see our Cookie Policy for more detailed information.
  • When you subscribe to our newsletters service: as long as you keep your newsletters subscription active (withdrawal of your consent being possible at any time by unsubscribing) or until TSC decides to terminate its newsletters service. 
  • When you send us a message via the contact form: until your request is processed. 

Recipients

In order to accomplish the purposes listed above, your data may be communicated to the following recipients: 

  • The TSC’s staff members (employees, freelancers, trainees, etc.) and its partners, if the processing of your data is necessary for the performance of their tasks;
  • The TSC’s subcontractors, processing personal data on behalf of TSC; 
  • To any third parties mentioned in the Cookie Policy.
    1. You are a visitor of a TSC social media page

Categories of data collected 

If you visit the TSC’s social media pages (namely, LinkedIn, Instagram and Facebook), the following personal data may be processed jointly by the relevant social media and the administrator of that page: data related to your account, data related to the sharing of content or communications you have with others.

Purpose(s) and legal basis

These personal data are processed for the following purposes:

  • For the purpose of placing and reading cookies: for more information, see the Cookie Policy;
  • For the purpose of improving the social network’s advertising system;
  • Your data may be processed by the administrator of the page (TSC) in the context of its legitimate interest to obtain statistics on the visitors of his page in order to adequately promote his page. The statistics of audience established by the social media are only transmitted to the administrator of the page in an anonymized form.

Retention period

Your data are or could be processed as long as the page exists and you visit it.

The Privacy Policies of each social network used by TSC can be found by clicking on the following links:

Recipients

In order to accomplish the purposes listed above, your data may be communicated to the following recipients:

  • The TSC’s staff members (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
  • The TSC’s subcontractors, processing personal data on behalf of TSC;
  • The relevant social network.
    1. You participate in an event organized by TSC

Categories of data collected 

If you register to an event organised by TSC, the following personal data concerning you may be processed: identification data (last name, first name), contact data (e-mail address, postal address, telephone number), professional data (position, company). If you consent, we may also use your image.

Purpose(s) and legal basis

These personal data are processed for the following purposes:

  • When you register for one of our (offline or online) event it is necessary that you fill in a registration form. The data you provide when filling in this form is processed by TSC for the purpose of organising and following up the event. Without it, we cannot sign you up for the event and provide you with the information on such an event or training session. The processing of your personal data is necessary for the performance of the contract between us in the context of the event to which you have subscribed. 
  • We may also process your data to promote our events (including the sharing of the recordings to participants who want to rewatch the event or people who were not able to attend the event). In this case, your data are processed on the basis of our legitimate interest in promoting our services to the public. 
  • Where applicable, your image may be processed on the basis of your consent : to reproduce, store stream or communicate audio recordings, photos, videos, images and publish photos, audio recordings or videos where you may appear to report on activities, and to promote activities organized by TSC on the TSC’s website and extranet, social medias, newsletters or in any other TSC’s publications.

Retention period

Your data are processed for a maximum period of 5 years from the date of the event you participated unless you object to the processing or withdraw your consent.

Recipients

In order to accomplish the purposes listed above, your data may be communicated to the following recipients:

  • The TSC’s staff members (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
  • The TSC’s subcontractors, processing personal data on behalf of TSC;
  • The public via the TSC’s website and social media accounts.
    1. You apply for a job, an internship or a temporary post

Categories of data collected 

If you apply for a job/internship/interim position at TSC, the following personal data may be processed: identification data (last name, first name, image, date of birth), contact data (e-mail address, postal address, telephone number), data related to your professional background (experience, CV, previous employers, language skills, etc.), data related to the interview and to the job questionnaire (evaluation, comments), previous or alleged remuneration, and any information contained in your curriculum vitae and/or covering letter.

Purpose(s) and legal basis

These personal data are processed for the following purposes:

  • To evaluate your application: TSC examines your application in order to assess the possibilities of a contractual relationship.
  • For the purpose of building up a recruitment reserve: the TSC’s legitimate interest is to contact you at a later date regarding the job offer in the event that the person initially recruited withdraws or in the event of a vacancy for another similar position that is immediately available. If you do not wish to be included in the recruitment pool, you may always object.

Retention period

If your application is unsuccessful, your data is automatically deleted one year the end of the selection process.

Recipients

In order to fulfill the purposes listed above, your data may be communicated to the following recipients:

  • The TSC’s staff members (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
  • The TSC’s subcontractors processing personal data on behalf of TSC (in particular, recruitment agencies).

4. In any case

In any case, TSC can process your personal data in the following cases:

    1. 4.1.Possible legal dispute 

 

Your personal data may be processed for the purpose of managing any dispute that may arise between you and TSC. In this case, TSC has a legitimate interest to process your personal data to exercise its legal rights.

TSC may also process sensitive data (special categories of personal data), where this is necessary for the establishment, exercise or defense of its legal rights in accordance with the provisions of Article 9 §2, f. of the GDPR.

For the fulfillment of this purpose, your personal data may be communicated to the following recipients:

  • Members of the TSC’s staff (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
  • To TSC’s lawyers, debt collection companies, bailiffs;
  • To police and/or judicial institutions;
  • To TSC’s subcontractors, processing personal data on behalf of TSC. 
    1. 4.2.Prevention of fraud and abuses

Your data may be processed to combat fraud and abuse (only for processing involving a contract between you and TSC): TSC is under a legal obligation to carry out certain checks relating to the reputation and solvency of its contracting parties, in order to guard against the risks of fraud and abuse.

For this purpose, your data may be communicated to the following recipients:

  • Members of the TSC’s staff (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
  • To TSC’s lawyers, , debt collection companies, bailiffs;
  • To police and/or judicial institutions;
  • To TSC’s subcontractors, processing personal data on behalf of TSC; 
  • To authorities, public bodies, carrying out controls.
    1. 4.3.Direct marketing

Your identification data (last name, first name), professional data (company, function, country, sector of activity), contact data (e-mail, language of communication) may be processed by TSC for direct marketing purposes:

  • If you have already registered for one of the events organized by TSC, TSC has a legitimate interest to promote its activities (to inform people about upcoming events, news and publication). However, you have the right to object to the processing of your data at any time.
  • If you give your consent, your personal data may be processed for the purpose of sending you direct marketing (e.g. via our newsletter service). You can withdraw your consent at any time.

For this purpose, your data may be communicated to the following recipients:

  • the TSC’s staff members (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks ;
  • the TSC’s subcontractors, processing personal data on behalf of TSC.
0
0
0
0