At STRAIGHT BUSINESS PARTNERS, we do not only attach great importance to commitment, innovation and ambition. Protecting your privacy and more specifically your personal data is also a priority for us. We treat and secure these personal data with great care, in accordance with the applicable laws in Belgium.
- are a (natural) contact person at one of the businesses using our services;
- are a natural person who is the subject of an assessment as part of our services;
- are a (natural) contact person at one of our (potential) suppliers;
The processing of personal data is done in accordance with the Act of December 8 1992 on the protection of privacy in relation to the processing of personal data (Privacy Act) and the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
A. Who are we?
Straight Business Partners bv, established in Belgium, 3920 Lommel, Koning Leopoldlaan 28, registered in the CBE under number 0847.269.858 and controller of your personal data (data controller in the sense of the GDPR), or processor of personal data.
Telephone number: 011 755 890
B. What are personal data and what personal data do we process?
Personal data are defined in the GDPR as:
“any information relating to an identified or identifiable natural person;”.
Depending on your capacity, the following personal data are processed by us:
- a (natural) contact person at one of the businesses using our services or at one of our (potential) suppliers;
We initially process your personal data that are necessary to enable the correct execution of our services: your last and first name, your position (title), your (professional) address and your (professional) contact details (phone number and/or email address). Possibly we will also ask for other information, such as your company name and company registration number.
In this context, we can be considered as the data controller, as the objective and means of processing the personal data in question is determined by us.
- a natural person who is the subject of an assessment as part of our services;
For these individuals, this usually involves last and first names, private email addresses and answers to personality tests in order to arrive at a report on competencies and development needs. This report is generated electronically.
In this context, we can be considered as a processor, given that the personal data in question are processed on behalf of the data controller, who determines the objective and means of the processing. In many cases – though not exclusively – the data controller is your employer.
If you have any questions regarding this processing of personal data, please contact the concrete data controller.
Tip regarding changes to your personal data
You should always inform us as soon as possible of any changes to your personal data.
In this way, the personal data remain up-to-date and we can always provide our services in a correct and pleasant way.
C. Why do we need your personal data?
We process your personal data in principle for the objectives mentioned below. We will only process your personal data for other objectives if they are compatible with the objectives mentioned below. If the other objectives are not compatible, your consent for further processing will always be requested, unless the processing is imposed on us by a legal provision.
We use your personal data in general within the framework of our daily operation and continuation.
More specifically, we use – when acting as a data controller – your personal data to:
- be able to conclude a contract with you and to perform it:
- be able to provide you with information about STRAIGHT BUSINESS PARTNERS’ services in order to better tailor them to your needs and wishes or those of your business or organization.
- be able to offer and discuss a quotation;
- enter into a business relationship with you or your business or organization, to conclude and maintain a contract and to enable its execution, as well as to carry out the administrative work resulting from this: to execute assessments and their processing, to draw up strategic plans, to issue invoices and to process the accounts;
- be able to contact you in order to arrange appointments,…
It goes without saying that it would not be possible for us to perform the services if we did not process the necessary personal data in that context.
- monitor and to measure the quality of our services. To this end, we, or a third party designated by us, may ask you to participate in surveys, and use and process the information obtained to improve the quality of our services;
- ensure company safety. We may also monitor activity in our systems to prevent abuse of information from our databases and to protect our interests and those of all persons included in our databases;
- meet management objectives including providing management information, performing internal controls to prevent fraud, and performing (internal/external) audits.
- allow you to exercise your rights (see below) and to be able to prove afterwards that we have complied with these rights.
- comply with (legal) obligations, such as keeping the books.
- approach you, if you wish, for commercial offers, newsletters, events, information days, and other promotions/marketing campaigns, which may be of interest to you;
D. How do we obtain your personal data?
We process your personal data as soon as you transmit it to us yourself. This can be done by email, text message, orally (by phone, in our office, during a visit to your business, at an event, training…), by giving us your business card or by any other means.
This also happens when you are put forward by third parties, such as your organization/business/employer/… as a contact person or when you are put forward by third parties to want to use our services or to be the subject of our assessments in the context of our services.
We may also collect your personal data when these have been made publicly available, or when you yourself have made them public on public/social media (e.g. LinkedIn, Facebook).
In the cases where we can be considered as a data controller (cf supra) and where we indirectly obtain personal data, you will be informed, among other things, which categories of personal data are processed, and which is the source of these personal data.
E. With whom do we share your personal data?
Only if necessary for the realization of the objectives listed under point C, for the performance of the contract existing between us, the fulfillment of a legal obligation (ours or a third party’s), the promotion of a legitimate interest (ours or a third party’s) or with your consent, we may transfer certain of your personal data:
- to staff members/employees of STRAIGHT BUSINESS PARTNERS bv, including, but not limited to:
- the realization of the objectives of our business relationship;
- internal service provision (administrative tasks such as processing registrations, invoicing, client and supplier accounting, debt management, …);
- promotions and marketing campaigns in the context of our services;
- to suppliers (e.g. IT, administrators of our database, software developers,…) including, but not limited to:
- checks and audits;
- maintenance and security of software systems;
- fulfillment of legal and legitimate interests;
- to our accountant, auditor, audit and certification firms, collection agencies… including, but not limited to:
- preparation and audit of our annual accounts;
- compliance with VAT obligations;
- obtainment and maintenance of certain certificates;
- verification of VAT numbers, VAT and other accounting documents;
- to various government agencies in connection with inspections and investigations, including, but not limited to:
- federal and regional inspection services and accrediting bodies;
- social security authorities;
- tax authorities;
- to any other third parties where we are required to so by law, court order or judgment.
Your personal data will not be sold, rented or made commercially available to third parties, except with your prior consent. In the development of our business, we may sell operations or assets. In the event of a sale, merger, reorganization, dissolution or similar event, your personal data and other information may be part of the transferred assets.
When our suppliers process your personal data on our behalf, they act as processors as stipulated in the GDPR. We conclude a processing agreement with these processors and make every effort to ensure that they adequately secure your personal data.
Your personal data may in certain cases be transferred outside Belgium. In doing so, we take the necessary contractual and technical safeguards to ensure that all transferred personal data are adequately protected against loss or unlawful processing. For further questions about this, you can always contact us via the aforementioned contact details.
F. How long do we keep your personal data?
Your personal data will be retained for the time necessary to carry out the purposes described in point C and to comply with our legal obligations, being a maximum of five years after completion of accounting and legal documents. Personal data contained in these documents are subject to limited access.
We make every effort to optimally secure your personal data against unauthorized use. We do this by means of physical, administrative and technological measures. For example, only authorized individuals are granted access to our offices and our systems, and access is limited to those systems they need for professional reasons. These individuals must know and correctly apply our internal privacy and data protection policies. When personal data is provided to third parties – processors, we agree with them that they will also provide optimal security.
H. What are your rights?
You can exercise the following rights:
- right to object
You may object to the processing of your personal data. You can only do this against processing carried out based on the legitimate interests of STRAIGHT BUSINESS PARTNERS or a third party (see above in point C). When exercising this right, you will have to indicate the exact processing to which you object and for what specific reasons. This is necessary for a proper balancing of interests.
- right of inspection
You can request a ruling on whether of not your personal data is being processed.
When STRAIGHT BUSINESS PARTNERS processes your personal data, you also have the right to inspect the collected personal data. This right of inspection means that you will be able to see which of your personal data is being processed. In that case you are also entitled to information about the reason for and the period of processing and, if applicable, you will be informed of the source of these personal data. Finally, you may also obtain a free copy of the personal data that are being processed.
When providing this information, we must always take into account the rights and freedoms of other individuals.
- right to rectification (improvement and supplementation) / erasure
You may request that any (personal) data that you believe to be incorrect of incomplete be rectified or supplemented. When exercising this right you will have to indicate which personal data exactly you want to rectify or supplement.
You also have the right to have your personal data erased by us without undue delay.
You can only appeal to this in the following cases:
- When the personal data are no longer needed for the purposes for which they were originally collected;
- When the personal data – in exceptional cases – would be collected based on obtained consent and no other legal basis for the processing exists;
- When objection is made to the processing and no prevailing, compelling and legitimate grounds exist for the processing;
- When the personal data were processed unlawfully;
- When the personal data must be erased in accordance with a legal obligation.
STRAIGHT BUSINESS PARTNERS will assess whether you meet the aforementioned conditions.
- right to restriction of processing
You have the right to obtain a restriction on the processing of your personal data, during which specifically identified personal data will be blocked in the system of STRAIGHT BUSINESS PARTNERS for a certain period.
- During the period required by STRAIGHT BUSINESS PARTNERS to verify the accuracy of the personal data, in the event of a dispute;
- When you request the restriction of processing instead of the erasure of the personal data, for example in the case of unlawful processing;
- When STRAIGHT BUSINESS PARTNERS no longer needs your personal data for the processing purposes and you need the personal data for a legal claim;
- During the period required by STRAIGHT BUSINESS PARTNERS to assess and balance the presence of the cited grounds for erasure of personal data against its own interests.
- right to data portability
You have the right to obtain the personal data you have communicated to STRAIGHT BUSINESS PARTNERS in a structured, common and machine-readable format, insofar as the processing of the personal data is based on your consent or is necessary for the performance of the contract. In addition, you have the right to transfer these personal data to another data controller.
- right to withdraw consent
If processing is carried out solely based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal.
In principle, you can exercise the aforementioned rights free of charge. You can do this by sending an email to email@example.com.
At the latest within one month of receipt of your request, we will inform you in writing of the action we have taken on your request.
Depending on the difficulty of your request or the number of requests we receive from others, this period may be extended by two months. In this case, we will inform you of this extension within one month after receipt of your form.
In some cases (e.g. legal obligations, rights of others, limitation periods, etc.) you may not be able to exercise your rights fully or at all. You will then be informed of the reasons why we cannot at all or cannot fully meet your request.
I. Activities as a processor
Within the framework of our activities as a processor, your personal data will also be processed appropriately in accordance with the applicable legislation.
Technical and organizational measures are being taken to comply with the legislation in question and to protect the rights of data subject.
The actual processing will be clearly described and regulated in an agreement concluded with the data controller. This will set out included, but not limited to:
- the subject of the processing;
- the duration of the processing;
- the nature and the purpose of the processing;
- the type of personal data;
- categories of data subjects;
- rights and obligations of the data controller;
If we use a sub-processor to carry out specific processing activities on behalf of the data controller, a similar agreement will be drawn up with the sub-processor in question.
K. Questions, remarks, complaints and data breaches.
You also have the right to lodge a complaint with the Data Protection Authority (DPA) at the following address: Drukpersstraat 35, 1000 Brussels or by email at firstname.lastname@example.org.
If you are aware of a data breach, or suspect one, please notify us immediately at email@example.com.
This version was drawn up in October 2019.