Private life statement

Since many years Partena Professional has devoted all the attention required to the protection of privacy with regard to the processing of personal data, whether under the law of 8 December 1992 or since 25/05/2018 under the European Regulation 2016/679 of 27 April 2016 better known as GDPR.

What principles do we respect?

We always ensure that the personal data requested and/or communicated are adequate, accurate (and, if necessary, updated), relevant and not excessive in relation to the purposes for which they are collected. We also guarantee transparency, compliance with legal provisions, confidentiality, an appropriate level of security and above all respect for your rights.

Who is this privacy statement for?

Our privacy statement applies to all processing of personal data by Partena Professional and its various entities:

• Partena Payroll Office
• Partena Enterprise Counter
• Partena Self-Employed Fund
• Partena Business Solutions

It applies to all customers, prospects, visitors to our portals and websites but also to visitors to our premises.

Who is responsible for the processing?

The entities of the Partena Professional group are responsible for the data processing they carry out. However, there are two exceptions:

• At the level of the Payroll Office: personal data processed within the framework of the service contract concluded with the employers.
• At the level of Partena Business Solutions: personal data processed within the framework of the service contract concluded with the employers.

In both cases, the processing operations are carried out as a subcontractor and are covered by a processing agreement which guarantees that the data are collected and processed only according to the customer's instructions.

What personal data is Partena Professional processing?

Personal data are all data relating to a natural person and enabling that person to be identified or made identifiable. They are his property.

The processed data are grouped into several categories:

• Identification data: allow you to be identified, such as your name, first name, user name or number, etc.
• Financial data: necessary within the framework of certain paying services or allowing to pay you the amounts which are due to you, such as the bank account, payments by mistake, outstanding balances, etc.
• Contact details: allowing us to communicate with you such as your telephone number, your address, your e-mail address, etc.
• Family data: necessary, for example, for calculating family benefits or for the correct application of withholding tax, such as the number of dependants, family composition, etc.
• Login data: information collected when using web services and applications in order to secure these online tools or your user experience such as username, IP address, language preference, etc.
• Data you provide via an online form: like when you register for a training, an event or to receive a newsletter.

All these data are either communicated to us directly by you or by your employer, in particular when we act as a subcontractor.

On what legal basis are your personal data processed?

We rely on the following legal bases to process your data:

• to fulfil any of our legal obligations
• to fulfil any of our contractual or pre-contractual obligations
• to pursue a legitimate interest of Partena Professional (always in balance with your own interests)
• when you have given your consent

What are the purposes for which we process your data?

• Meet legal or contractual obligations:
  
  Within the framework of certain services, Partena Professional entities must process personal data in order to meet their legal obligations (Family Allowance Fund, Self-Employed Fund, etc.) or contractual obligations (Payroll Office, Partena Business Solutions).
• Respond to the request for which you have provided them:
  
  Your data can be used:
  • to offer you the requested services
  • to send you the answer to the question asked via a contact form
  • Send you an email allowing you to download a brochure, a white paper
• Promote our services:
  
  Partena Professional uses personal data for:
  • send customers information about other associated or complementary products and services offered by Partena Professional or its partners
  • Send prospects information about the products and services of Partena Professional
  • Send invitations for events
• Improve and evaluate our services:
  
  Your data can be used for:
  • customer surveys, market research
  • surfing behaviour analyses in order to optimise our website or portals
• Customize the use of our tools:
  
  Depending on your use and preferences, your data may be used to offer you customization of our portals, websites and applications.
• Ensure an appropriate level of safety:
  
  Partena Professional uses your personal data in the context of the implementation of its security procedures, particularly with regard to the detection of malicious or unauthorized activity.
• Showing of personalized advertisments by associating user information collected from Partena Professional's services with information collected by Google is the user agrees

How long do we keep your personal data?

Your data are kept for as long as:

• necessary for the purposes for which they are collected and processed
• they are relevant to meeting our legal, contractual and legal obligations, and to satisfying our commercial and operational activities

These retention periods will therefore vary according to the type of service provided.

Are your data passed on to third parties?

We may transmit your personal data:

• in case of legal obligation:
  
  for certain services, Partena Professional entities are required to transmit information to official bodies (e.g. the Social Security Crossroads Bank, the Crossroads Bank for Enterprises, etc.).
  
  These transfers are governed by clear and defined procedures.
• If necessary for the provision of the services concerned:
  
  It may happen that all or part of a processing is entrusted to a processor. The latter may only act upon instructions given to him by Partena Professional and may not use your data for his own purposes.
  
  These principles are set out in the processing agreement that the processor must sign in order to process data on behalf of Partena Professional.
• Within the Partena Professional Group:
  
  in order to offer you a range of services that complement and are in line with the treatment(s) we already perform for you.
• If you have expressly given us your permission

We do not sell your personal data to third parties.

We apply European regulations regarding the international transfer of personal data.

What does Partena Professional do to protect your data?

Partena applies a set of measures on a daily basis in order to ensure the protection of personal data such as:

• raising staff awareness of their contractual commitment with regard to confidentiality.
• securing physical access.
• hardware security:
  • the servers are updated regularly.
  • firewalls, based on a model at several levels, block unauthorized traffic.
  • access management: distinction between access to the company network and access to applications. Employees have access to the applications according to the needs of their work and the needs of the department. This is reflected in the internal policies.
    
    Internal level: the modification of rights and access is only possible with the approval of the persons in charge and if the procedures laid down in the matter are complied with.
    
    External level: clients, where applicable, only have access to their own data.
• data transport security: any data traffic via the Internet is encrypted according to the current standards available on the market.
• security against viruses and access to the Internet: both the servers and the stationary computers and laptops are equipped with the required anti-virus software.
• service continuity is ensured via redundant backup resources.

What are your rights and what must you do to exercise them?

If you are a staff member of an employer who is a client of Partena Payroll Office or Partena Business Solutions, you must address to your employer in order to exercise your rights.

Right of access

You have the right to access the personal data you have provided to us.

To submit your request, simply send a letter to Partena Professional - DPO Office, Rue Ravenstein 36, 1000 Brussels or an e-mail to: privacy@partena.be

We will provide you with the requested information within one month of receiving your request. If necessary, this time limit may be extended by 2 months depending on the complexity and number of requests. We will then inform you of this extension within one month of receipt of the request.

In the event of repeated requests, we reserve the right to charge a reasonable fee based on the administrative costs.

Right of rectification

If you find that your personal data:

• are inaccurate
• are incomplete

you have the right to ask to correct or complete them.

To submit your request, simply send a letter to Partena Professional - DPO Office, Rue Ravenstein 36, 1000 Brussels or an e-mail to: privacy@partena.be

Indicate clearly the data to be modified or completed.

Right to erasure ('right to be forgotten')

You have the right to request the deletion of your personal data.

To submit your request, simply send a letter to Partena Professional - DPO Office, Rue Ravenstein 36, 1000 Brussels or an e-mail to: privacy@partena.be

Clearly state the reason for your request.

This right to erase data is not an absolute right and does not apply where processing is necessary to comply with a legal or contractual obligation.

Right to limitation of processing

You have the right to obtain the limitation of the processing of your data in the following cases:

• You dispute the accuracy of your data and we need time to verify the accuracy of your personal data;
• The processing is unlawful and you are not asking for your personal data to be deleted but for their use to be restricted;

To submit your request, simply send a letter to Partena Professional - DPO Office, Rue Ravenstein 36, 1000 Brussels or an e-mail to: privacy@partena.be

Clearly state the reason for your request.

Right to data portability

You have the right to receive your personal data processed by Partena Professional in a structured, commonly used and machine-readable format.

This only concerns the data of which the processing is based on the consent or on a contract and provided that the processing is carried out by automated processes.

To submit your request, simply send a letter to Partena Professional - DPO Office, Rue Ravenstein 36, 1000 Brussels or an e-mail to: privacy@partena.be

Clearly state the reason for your request.

In all cases, the right to erase data shall remain applicable.

Right of opposition

At any time you have the right to object, for justified reasons relating to your particular situation, to the processing of your personal data, but only if such processing finds its legal basis in the legitimate interest of the employer. There is no right of opposition for data processed under contract or legal obligations.

To submit your request, simply send a letter to Partena Professional - DPO Office, Rue Ravenstein 36, 1000 Brussels or an e-mail to: privacy@partena.be

Clearly state the reason for your request.

Right to lodge a complaint

You always have the right to file a complaint with the supervisory authority if you believe that the processing of your personal data by Partena Professional infringes the GDPR.

The Supervisory Authority is the Data Protection Authority, Drukpersstraat 35, 1000 Brussels, Tel +32 (0) 2 274 48 00, website: www.dataprotectionauthority.be

Does Partena Professional have a Data Protection Officer?

Yes, he can be contacted by e-mail at privacy@partena.be or by post at Partena Professional, for the attention of the DPO, Rue Ravenstein 36, 1000 Brussels.

Partena Professional does not guarantee equivalent compliance with privacy provisions on websites to which a link is established from this site.

Version 10/03/2020