Privacy Policy

Privacy Policy

This “Privacy Policy” regulates the processing of your personal data by the controller: AFINIT Didital srl, with registered office at 1170 Brussels, Chaussée de la Hulpe 185 and recorded in the Crossroads Bank for Enterprises under the number BE 0699.911.319 (hereafter referred to as: “AFINIT”).

This Privacy Policy contains your rights and duties vis-à-vis AFINIT.

The Policy will be reworked or updated and you will find the most recent and applicable version on our website.

1. General

1.1. This Privacy Policy guarantees the compliance with the European Regulation 2016/679 of 27 April 2016 on the protection of personal data and Act of 30 July 2018 concerning the protection of the natural persons with regard to the processing of personal data.  

1.2. The controller of your personal data is AFINIT.

2. Personal data

2.1. Personal data that you communicate to us:

2.1.1. Contact page in our website:

• via cookies: consult our Cookie policy
• IP address
• e-mail address
• if you apply for a vacancy or application: name, telephone number, CV, motivation letter and e-mail address

2.1.3. As candidate and/or interim manager (freelancer):

• name, address, e-mail address, telephone number
• CV, motivation letters, notes made during the job interview
• information on education and work experience
• salary and salary expectations and fees             

2.1.4. As principal, customer, prospect, supplier or other business relation:

• name, e-mail address, telephone number, bank account number, address, Company registration number at the Crossroads Bank for Enterprises, contact details 

2.1.5.  When registering for our newsletter:

• e-mail address;

2.1.6. AFINIT does not process sensitive personal data.

3. Personal data that AFINIT collects indirectly

3.1.  Public data of the candidate or interim manager/freelancer:

When we use certain search engines or websites on which you have uploaded your CV, so we can search for a suitable candidate for open positions, we receive your personal information indirectly. This includes personal data that you have made available on these websites, social media, search engines, etc.

Usually this will be in the form of a CV and we can consult the following personal data (not exhaustive):

• Contact details: surname, first name, e-mail address, language, telephone number, mobile number, address, …
• Data relating to your training: curriculum vitae and motivation letter
• Data relating to your previous positions: current employer, current position and/or previous positions, experience

3.2.  Public data of the principal, customer, supplier or other business relation:

AFINIT can process public data, such as data that are subject to a publication duty, the publication of your appointment as director of a company or data that you made public yourself, information posted on your website or data that are generally known in your region or that have appeared in the press.              

4. Purposes of the processing

4.1.  General purposes:

AFINIT will use the personal data exclusively for the following purposes:

• IP address: for improving our website and including Personal Data in anonymous statistics, from which the identity of specific persons or companies cannot be discovered, with as legal basis the legitimate interests of AFINIT in continuously improving its website and provision of services.           
• By registering on our website to apply for a function: name, telephone number, CV, motivation letter and e-mail address: to be able to provide you the requested information or services or to contact you and in order to comply with the legal obligations. Our legal basis is the execution of an agreement that was requested by you.
• Photos: to be used for our internal communication, with as legal ground your prior explicit consent.
• As an employee: name, address, e-mail address, telephone number, payroll information, curriculum vitae, motivation letters, notes made during the job interview, information on education and work experience, evaluation forms and results of any tests and assessments, payroll information including national register number, address, seniority, civil status, bank account number, family composition, date of birth, salary and salary sheets: in order to be able to provide you the requested services and in order to comply with the statutory provisions, with as legal basis the execution of an agreement.
• As a candidate and/or freelancer: name, address, e-mail address, telephone number, curriculum vitae, motivation letters, notes made during the job interview, information on education and work experience, date of birth, salary information: in order to be able to provide you the requested services and in order to comply with the statutory provisions, with as legal basis the execution of an agreement.

The legal ground for the processing your personal data when indirectly consulting your personal data on websites, social media, search engines is our legitimate interest. We may contact you a first time on this legal ground. After this we ask for your explicit permission to include your personal data in our recruitment database.

• As principal, supplier, customer, prospect, or other business relation: name, e-mail address, telephone number, bank account number, address, Company registration number at the Crossroads Bank for Enterprises, contact details : in order to be able to provide you the requested services and to comply with the statutory provisions, with as legal basis the execution of an agreement that was requested by you.
  You are not obliged to release your personal data. However delivering or granting of certain services becomes impossible if you refuse the processing. 
• e-mail address (when registering for the newsletter) (see article 3.2): with a view to sending you direct marketing (automatic e-mail messages or other electronic messages), newsletters, employment information, or information on planned activities (lectures, seminars, working lunches), with as legal basis your prior explicit consent;

You are not obliged to release your personal data, but you do understand that the granting of certain services becomes impossible if you refuse the processing. 

4.2.  Transfer to third parties:

AFINIT will never pass on your personal data to third parties, unless to its customers with a view to the employment, technical service providers who handle technical support in so far as this is necessary for the technical provision of services and/or if they are obliged to do so on the basis of a statutory provision or a judicial ruling.

AFINIT will not sell your personal data, rent them out, share them or otherwise make them commercially available to third parties, except as described above or unless with your prior consent.        

4.3.  Legal requirements:

In rare cases it can happen that AFINIT must reveal your personal data subject to a court order or in order to comply with other compelling laws or regulations.

5. Retention period and processing of the personal data

The personal data are kept and processed by us for a period that is necessary as a function of the purposes of the processing as described in article 4 and as a function of the contractual relationship between AFINIT and you:

• IP address: for the duration of your visit to the website.    
• Name, e-mail address, telephone number, CV and motivation letters: for the duration of the requested delivery of services.  
• For employees, candidates and freelancers: name, address, e-mail address, telephone number, payroll information, curriculum vitae, motivation letters, notes made during the job interview, information on education and work experience, evaluation forms and results of any tests and assessments, payroll information including national register number, address, seniority, civil status, bank account number, family composition, date of birth, salary and salary sheets : for the duration of the requested delivery of services and the employment and in accordance with the applicable legislation and statutory limitations Your personal data will be kept for as long as necessary to achieve the objectives set out in point 4.
  In any case, your personal data will be kept passively in accordance with the statutory limitations which oblige us to keep your personal data longer. 
  Subsequently, your file will be stored in an archived form.      
  As a candidate, we store and process your personal data at least as long as the selection process is ongoing. After that we keep the data 5 years after the last contact.                    
  For the data available to us via social media (linkedin etc): you upload your CV and contact details on dedicated platforms, which are specifically designed to find a suitable position. If, after an initial contact, you would be further interested in going through a selection process with us, we will, with your explicit consent, include you in our database and keep your personal data 5 years after the last contact.       
• Principal, supplier, customer, prospect, or other business relation: Name, e-mail address, telephone number, bank account number, address, Company registration number at the Crossroads Bank for Enterprises, contact details  for the duration of the requested delivery of services.            
  The aforementioned personal data are in any case kept in accordance with the specific statutory provisions, as well as the prescription periods that oblige us to maintain your personal data for a longer period, such as in order to defend ourselves against an action at law.

6. Your rights

6.1.  Right to information and access:

You have the right – at any time, free of charge – to be informed of your personal data, as well as of the use that AFINIT is making of your personal data.

6.2.  Right of rectification, erasure and restriction:

You are free to communicate your personal data, or not, to AFINIT. In addition, you always have the right to ask us to correct, supplement or delete your personal data. You acknowledge that, in case of refusal to communicate or request for deletion of personal data, certain services and products are not deliverable.

You may also ask to restrict the processing of your personal data.

6.3.  Right to object:

You also have the right to object against the processing of your personal data for serious and legitimate reasons.

In addition, you always have the right to object against the use of personal data for purposes of direct marketing; in such a case, you do not have to give any reasons.

6.4.  Right of free data portability:

You have the right to obtain your Personal Data that are processed by us in a structured, commonly used and machine-readable form and/or to transfer them to other controllers.

6.5.  Right to withdraw consent:

In so far as the processing is based on your prior consent, you have the right to withdraw this consent.

6.6.  Exercising your rights:

You can exercise your rights by contacting us for this purpose via email to privacy@afinit.be and by adding a copy of the recto side of your identity card.

6.7.  Automatic decisions and profiling:

The processing of your Personal Data does not include any profiling, nor will you be subject by us to automated decisions.

6.8.  Right to file a complaint:

You have the right to file a complaint with the Data Protection Authority.

7. Access by third parties

7.1.  In order to be able to process your personal data, we grant access to your personal data to our employees.

7.2.  We guarantee an identical level of protection by making contractual obligations that are opposable to these employees and agents and which are identical to this Privacy Policy.

8. Security and confidentiality

8.1.  We have developed security measures that are appropriate on the technical and organizational levels to prevent the destruction, loss, falsification, modification, unauthorized access or accidental disclosure to third parties of collected personal data as well as any other unauthorized processing of these data.

8.2.  Under no circumstances can AFINIT be held liable for any direct or indirect harm deriving from an erroneous or wrongful use by a third party of the personal data. AFINIT ensures that when they call upon third parties for the processing of personal data, these third parties shall be bound by the same rules.

9. Applicable law and competent court

This Privacy Policy is governed by, interpreted and executed in accordance with Belgian law, which is solely applicable.

The courts of Brussels have exclusive jurisdiction to hear any dispute that should arise from the interpretation or execution of this Privacy Policy.

In the event of any inconsistency between the Dutch, the English and the French Privacy Policy, the French version shall prevail. 

10. Cookies

This Privacy Policy is to be read in conjunction with our Cookie policy.
The latter contains information relating to the processing of your personal data via cookies.