Privacy Policy for Facile
PROCOS Group places great importance on respecting your privacy and protects your personal data in accordance with applicable laws, the privacy regulation and our ISO 27001 certification.
1 The Data Controller
PROCOS Group operates as a European Economic Interest Grouping (EEIG), which consists of three distinct legal entities. The designated data controllers for the purposes of this Privacy Policy are:
PROCOS BV
Registration number: BE 0439.985.169
Address: Jan Blockxstraat 1, 2018 Antwerpen, Belgium
PROCOS Nederland B.V
Registration number (KVK): 57165882
Address: Parkstraat 83, 2514JG ‘s-Gravenhage, Netherlands
PROCOS Portugal Plc
Registration number (NIPC): 507310381
Address: Rua Calvet de Magalhaes 244, 2770-022 Paço de Arcos, Portugal
Throughout this Privacy Policy, these entities will be collectively referred to as "PROCOS Group."
2 Scope of the Privacy Policy
PROCOS Group places great importance on respecting your privacy and protects your personal data by applying the European General Regulation 2016/679 on the Protection of Personal Data, hereinafter "GDPR". In cases where the Belgian law of July 30, 2018, concerning the protection of individuals with regard to the processing of personal data, contains stricter requirements, we will act in accordance with this legislation.
PROCOS Group is committed to protecting the (personal) data of all its stakeholders with the utmost care and to processing it only fairly and lawfully. This privacy statement contains essential information about how PROCOS Group, as the data controller, collects and processes personal data, defines the purposes, and explains your rights as a data subject.
It applies to any subscriber or client acting as a natural person and, in general, to all individuals who come into contact with PROCOS Group. It also applies during visits to our offices and our events, use of our applications and visits to our website.
3 Processing of Personal Data
Personal data can be defined as any information that directly or indirectly identifies a natural person. You may provide us with your personal data during the following activities, for the corresponding purposes, and based on the specified reasons:
Contact form or correspondence: By filling out one of the forms on our websites or helpdesk, you consent to PROCOS Group processing your name, first name, email address, phone number and your question or message. If you contact us directly (by email, phone, or mail), we will process your contact information and the content of this correspondence. We use this information solely to properly address your question or message. Phone and video calls to our customer service or other services are neither recorded nor stored.
Job applications: If you send us your application, PROCOS Group processes your name, first name, phone number, email address, postal address, resume, cover letter, and diplomas to evaluate the possibility of a contractual relationship.
Office security: To ensure the safety of our employees, visitors, and premises, cameras are installed at our main offices on the parking lot, in the entrance and in the main room upstairs to monitor unlawful access as well as fire prevention.
Events: When you register for an event we are hosting, we may take photographs to capture the atmosphere. Photos may then be published on our social media channels to highlight our participation in the event. The publication of photos on social media is based on our legitimate interest. If you no longer want a photo or video in which you appear to be made public, you can report it by sending a link or reference to the photo or video to dpo@procosgroup.com. It will be removed from online publications as soon as possible and in compliance with technological constraints.
Other relationships: We collect contact information of our current or future suppliers, clients and partners, such as name, first name, professional phone number, professional email address, workplace address, name of the organization represented (if applicable), duration of the relationship (start and end date), as well as bank account number, VAT number, resume and tax status of the supplier, partner, or person representing them. We process this information to conclude our agreements and manage our relationships or collaborations.
Browsing our website: Whenever you visit our website, we collect information using cookies and other technologies to ensure the optimal functioning of our website. For more information on this, you can also consult our cookie policy.
Using our applications: When you use our applications, we collect information using tokens, forms and cookies to ensure safe and reliable functioning of the application. The type of data we collect depends on the purpose of the application and is subject to a data processing and/or non-disclosure agreement with your organization.
PROCOS Group considers your personal data as confidential and commits to processing it only in a manner consistent with the purposes for which it was initially collected.
4 Your Rights as a Data Subject
The data subject has the opportunity to exercise their rights as described in the General Data Protection Regulation at any time. The data subject can exercise the following rights:
Right of access
You have the right to access your personal data at any time and for free, and to request a copy of the personal data that PROCOS Group collects about you.
Right of rectification
You always have the right to correct inaccurate personal data or complete incomplete personal data.
Right to erase ("right to be forgotten")
You can request the deletion of your personal data from PROCOS Group systems. The request to delete your personal data may not always be granted due to contractual or legal obligations. PROCOS Group will take these obligations into account when responding to your request.
Right to object
You have the right to object to the processing of your personal data if the processing is done for reasons of PROCOS Group's legitimate interest or public interest. We will stop processing unless we can prove that there are compelling legitimate reasons for processing or for the exercise of legal rights.
Right to withdraw consent
For the processing of your personal data collected by PROCOS Group with your consent, you can withdraw your consent at any time. For example, you can always request to withdraw a photo or video online for which you had given your consent. However, the withdrawal of your consent does not apply to processing carried out previously by PROCOS Group.
Right to restrict processing
In certain cases, the data subject has the right to obtain the restriction of the processing of their personal data. We will continue to store your data, but we will limit its use. For example, you can submit this request when you believe that your personal data is inaccurate or that PROCOS Group's processing is not justified. We are required to comply with these requests only in particular cases as defined by law.
Right to data portability
The data subject has the right to receive the personal data concerning them, processed by PROCOS Group, in a structured, commonly used, and machine-readable format and/or to transmit this data to another data controller.
These rights can be exercised for free by sending an email to dpo@procosgroup.com. We commit to responding to your request within one month of its reception. We may ask you for additional information to confirm your identity and ensure the request is coming from you.
If, at any time, you believe PROCOS Group is infringing on your privacy, you have the right to file a complaint with the Belgian Data Protection Authority: Data Protection Authority, Rue de la Presse 35, 1000 Brussels, phone: +32 (0)2 274 48 00, email: contact@apd-gba.be.
5 Disclosure to Third Parties
PROCOS Group will refrain from disclosing or selling personal data to third parties as well as from publicly disclosing the personal data of data subjects, except in the following specific cases:
Personal data may be shared among different branches of PROCOS Group and other affiliated companies if this transfer is necessary for providing our products or services according to the predetermined purpose.
Personal data may be shared with third-party service providers to whom PROCOS Group has entrusted certain processing activities. In all cases, it is limited to processing your personal data according to our instructions, and if necessary, a data processing agreement will be concluded so that they are required to comply with all obligations required by applicable data protection legislation.
Personal data may be shared with subcontractors and third parties for the execution of a contract we have with them or that we have with you.
Personal data may be shared with government agencies or authorities if required by applicable laws or regulations.
Regarding international transfers of personal data and their processing outside the European Economic Area (EEA), your data is only transferred to third parties in third countries, such as software providers and cloud or mailing services, if allowed by applicable data protection legislation. We ensure appropriate safeguards to guarantee that your rights are respected by the recipient of the data outside the EEA according to an adequate level of data protection.
6 Retention of Your Personal Data
PROCOS Group recognizes the importance of protecting personal data. We do not retain your personal data for longer than necessary to achieve the purposes for which we received it, or to fulfil a contract or legal obligation. Retention periods differ depending on the type of processing and the purpose for which personal data was collected.
Personal data collected based on your consent will be retained by us for as long as your consent remains valid.
In any case, personal data may be retained for a longer period if there is a legal or regulatory reason to do so, or for a shorter period if the data subject objects to the processing of their personal data and there is no longer a legitimate reason to retain it.
We ensure that access to your personal data is limited and that your personal data is deleted or anonymized once the retention period has expired.
7 Security and Confidentiality of Your Personal Data
PROCOS Group has taken technical and organizational security measures to prevent the destruction, loss, alteration, unauthorized access, or disclosure of your personal data to third parties and any other unauthorized processing of this data.
We have made every reasonable effort to ensure the confidentiality, integrity, and availability of information systems and services that process personal data. These measures include physical and operational security measures, access control, awareness, and confidentiality clauses. All our employees and third parties we engage are required to respect the confidentiality and security of your data.
PROCOS Group informs you that our website may contain links, hyperlinks, or references to other sites such as YouTube and LinkedIn, which PROCOS Group does not control, and to which our Privacy Policy and Cookie Policy do not apply. These sites are not managed by PROCOS Group. Therefore, PROCOS Group is not responsible for the content of these referenced sites, nor for the offers, products, or services mentioned on them. We recommend that you carefully read the privacy policy of each site you visit, as it may differ from our Privacy Policy and Cookie Policy.
8 Applicable Law
This Privacy Policy is governed, interpreted, and implemented according to Belgian law, which applies exclusively in case of dispute. The Dutch-speaking courts and tribunals of the judicial district of Antwerp have exclusive jurisdiction to rule on any dispute that may arise from the interpretation or application of this Privacy Policy, which could not be resolved amicably.
9 Contact Details
If you have comments, questions, or concerns about the information contained in this statement or any other questions regarding the processing of your personal data by PROCOS Group, please contact our Data Protection Officer at dpo@procosgroup.com.
If you prefer to contact us by mail, you can do so at the following address: DPO C/O PROCOS Group, Jan Blockxstraat 1, 2018 Antwerpen, Belgium.
10 Updating this Privacy Policy
We may modify or update this Privacy Policy from time to time to reflect changes in our practices regarding the processing of your personal data or changes in applicable laws. We will do this by posting the updated version on PROCOS Group's website.
We don't share your Personal Data with anyone.
If you are concerned about a possible interference with your privacy or misuse of your Personal Data by us you can contact us to make a complaint (see below).