This privacy policy (the “Privacy Policy”) governs the processing of your personal data as part of your use of our Website (the “Website”) and the services related thereto (collectively referred to as the “Services”). This processing is carried out by BCW, acting as the data controller, with its registered office at Wechelsebaan 143/unit 13, 2275 Lille, Belgium (“we”, “us”), registered with the Crossroads Bank for Enterprises (CBE) under number 0439.831.157, in accordance with the applicable legislation on the protection of personal data.

By using our Website or Services, you acknowledge that you have carefully read this Privacy Policy and agree to it without reservation. We reserve the right to amend this Privacy Policy from time to time at our sole discretion. Any such changes will be communicated through the Website.

“Cookies” or similar technologies may be used as part of the Website or Services. Cookies are text files that are placed on the hard drive of a device and contain certain information, which may include personal data. More information about the use of cookies can be found in our Cookie Policy.

This Privacy Policy was last updated on 24 December 2023.

Which data do we process and why?

1. Personal data processed when using the Website and/or Services

When you use the Website and/or Services, we may process personal data relating to you:

• When? Use of the Services, use of the Website
• Which data? Identification data
• Purpose? Processing of applications
• Legal basis? Legitimate interest

2. How do we obtain and use your personal data?

In principle, we obtain the above-mentioned personal data directly from you. In addition, we may process your personal data:

• To provide you with information about products and services that you request, in a personalised and efficient manner, whether via the Website, email, telephone or social media channels.
• To process your personal data in order to provide you with our services correctly.
• For direct marketing purposes, i.e. to provide you with targeted communications, promotions, offers and other advertisements from us or our selected partners. Where required, we will ask for your consent for this.
• To perform statistical analyses in order to improve our Website and/or Services or to develop new products or services.
• To provide your personal data to a financial institution or payment service provider where necessary to enable your bank and the payment service provider to fulfil their legal obligations.
• To transfer your personal data to the police or judicial authorities as evidence of possible crimes or where there are reasonable suspicions of an unlawful act or crime committed through your registration with or use of the Website or Services.
• In the context of a possible merger, acquisition by or of, or division involving a third party, even if that third party is located outside the European Economic Area (EEA).

3. Processing in the event of unlawful or improper use

If and when your registration on or use of the Website or Services can be considered to constitute:

(a) a violation of the applicable terms or proprietary rights;

(b) a threat to the security or integrity of our Services;

(c) a threat to our Website or Services, or those of our subcontractors, or to our or their systems, due to viruses, Trojan horses, spyware, malware or any other form of malicious code; or

(d) in any way illegal, tortious, discriminatory or offensive,

we may process your personal data in the interest of ourselves, our partners or third parties.

We share your data

1. We may engage external processors to provide you with the best possible Website and Services. We ensure that third-party processors may only process your personal data on our behalf and on the basis of our written instructions.
2. We will not transfer your personal data to third parties in an identifiable manner where this is not necessary to provide the Services, unless we have obtained your explicit consent to do so.
3. We may transfer anonymised data to other organisations that may use such data to improve products and services and to organise the marketing, presentation and sale of products and services in a more targeted manner.

Where do we process your data?

1. We and our external processors will only process your identifiable personal data within the European Economic Area (EEA).
2. We may transfer anonymised data to organisations outside the European Economic Area. If such a transfer takes place, we will ensure that appropriate safeguards are in place to guarantee the security and integrity of your personal data and that all rights relating to personal data that you may enjoy under applicable law are safeguarded.

How do we process your data?

1. We will make every effort to process only the personal data that is necessary to achieve the purposes described in this Privacy Policy. We will process your personal data in a lawful and transparent manner and will make every effort to ensure that your personal data remains accurate and up to date.
2. Your personal data will only be processed for as long as necessary to achieve the purposes described in this Privacy Policy, or until you withdraw your consent where the processing is based on consent. Withdrawal of consent may mean that you are no longer able to use the Website or Services, in whole or in part. If you have registered on our Website, we will delete your personal data when you delete your profile, unless a legal or regulatory obligation or a judicial or administrative order prevents us from doing so.
3. We will take appropriate technical and organisational measures to keep your personal data secure against unauthorised access or theft and against accidental loss, manipulation or destruction. Access by our personnel or the personnel of our external processors is only permitted on a need-to-know basis and is subject to strict confidentiality obligations.

Your rights regarding your personal data

1. You have the right to request access to all personal data that we process about you. However, requests for access that are manifestly made with the purpose of causing inconvenience or damage to us may not be processed.
2. You have the right to request, free of charge, the correction of any personal data concerning you that is incorrect or inaccurate. If you have registered on our Website, you may correct much of this information yourself through your profile. If you submit such a request, you should also provide evidence demonstrating that the personal data for which correction is requested is incorrect.
3. You have the right to withdraw any consent you have previously given for the processing of your personal data. You can do so by sending an email to info@bcw.be.

4. Instead of requesting the deletion of your personal data, you may also request that we restrict the processing of your personal data if:

   (a) you contest the accuracy of the data;

   (b) the processing is unlawful; or

   (c) the data is no longer necessary for the stated purposes, but you require it for the establishment, exercise or defence of legal claims.

5. You have the right to object to the processing of your personal data if you can demonstrate compelling and legitimate grounds relating to your particular situation that justify such an objection. Where the intended processing constitutes direct marketing, however, you have the right to object to such processing free of charge and without having to provide justification.
6. Where your personal data is processed on the basis of your consent or on the basis of a contract and the processing is carried out by automated means, you have the right to receive the personal data you have provided in a structured format.
7. If you wish to submit a request to exercise one or more of the rights described above, please send an email to info@bcw.be. Your request should clearly state which right you wish to exercise and, where applicable, why. The request should be dated and signed and accompanied by a digitally scanned copy of your identity card. If the request is justified, we will process it as soon as reasonably possible and, in any event, within thirty (30) days of receiving the request.
8. If you have a concern or complaint regarding the processing of your personal data by us, you can always contact us. If you remain dissatisfied with our response, you may lodge a complaint with the competent data protection authority, the Belgian Data Protection Authority.