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We at Pinakes value the protection of your privacy. With this Privacy Statement we inform you about how we process your personal data.
This Privacy Statement applies to you when you are:
- A customer of Pinakes (natural person);
- An employee of a Pinakes customer;
- A visitor to the Pinakes website;
- A political representative, senior official or decision-maker who is listed in the Pinakes database.
1. Data processing by Pinakes
Pinakes is a database which contains information about all the Belgian, Luxembourg and European public sector administrations and departments, as well as welfare, healthcare and non-profit organisations.
2. Information about the data we process about you: why, what data and on what lawful basis?
We collect your personal data for various reasons:
The most important service we offer is of course the Pinakes database. In order to achieve this, we process data of our customers or our customers’ employees and of persons we include in the Pinakes database.
We bring private and public institutions into contact with decision-makers in the public sector on the basis of address trading. We do this by offering our customers addresses of people for sale or rent.
If you are a customer, we collect your basic identity information such as your name, e-mail address, telephone number and postal address and your financial and commercial information such as bank account number, the history of the payment transaction and the amount to be paid.
If you are an employee of one of our customers, we will collect your basic identity information.
If you are a political representative, senior official or decision-maker and we have included you in our Pinakes database, in addition to your basic identity data, we also collect information about your education and employment, such as information about your position and the name of the organisation for which you work, a picture of you and information from your profile on social media channels such as LinkedIn or Twitter, information about which language you speak.
If you are a political representative, we also collect information about your party political affiliation.
The information we collect about you is information that you have provided to us directly or that we have obtained from one of the following sources:
- Publications/databases made available by official bodies (e.g. the Belgian Official Gazette);
- Our customers or service providers;
- Websites or social media channels that contain information that you yourself have made public (e.g. your own website or social media page); and
- Databases that were made public by third parties.
We process this information on the basis of our legitimate interest, namely to offer the Pinakes database. Offering the Pinakes database is a form of direct marketing.
If you are a customer, we will process your data to carry out the service agreement between you and us.
We only include information about political affiliation in the Pinakes database if you have manifestly made this information public. This situation can only arise if you are a member of a political party or if you are a leader of a political party and therefore fulfil a political function.
We find it important to answer your questions as soon as possible and to exchange information with you about, for example, our Pinakes database.
To enable this, we may collect information such as your basic identity, education and employment information, party-political affiliation information, the content of your communications and the technical details of the communications themselves, such as who from Pinakes you are communicating with and the date and time of your message and other information that you voluntarily share with us. When you communicate with us through social media, we will collect additional information that is available on your social media page.
We process this data on the basis of our legitimate interest, i.e. to enable smooth communication between you and us and to ensure that we can send you an appropriate response.
We only process information about your party political affiliation if you have made this information public.
With our newsletter we would like to inform you about all important appointments and changes.
If you wish to receive our newsletter, we will collect your e-mail address and your IP address. We will ask for your permission to do so.
If you have just been appointed as a political representative, senior official or decision-maker, it is possible that we will include this event in our newsletter. We collect information about you such as your basic identity, education and employment information, party political affiliation information and your age.
We process this data on the basis of our legitimate interest, i.e. to inform people of an important appointment or change. We only process information about your party political affiliation if you have made this information public.
If you would like to receive our newsletter, you are kindly referred to our homepage.
It is important to us that we can offer you a personalised range of our services. We will take the following actions to make this possible:
- Segmenting our potential customers and existing customers;
- Analysing your habits and preferences (based on your use of our services) and your interaction with us through the various channels, such as via emails, social media messages or visits to our website; and
- Comparing the products and services that you already have or use with other data that we have about you.
To enable this, we process technical information related to the device you are using, such as your IP address, browser type, geographic location and operating system, information about your browsing habits, such as how long you visit the device, which links you click on, which pages you visit and how often you visit a page and the content of your communication and the technical details of the communication itself.
This data is processed on the basis of our legitimate interest, i.e. to improve our offer and to give you an offer that is personalised to the maximum.
We make every endeavour to protect your data to the best of our ability and to protect third parties and the IT systems. To make this possible, we process your data when you visit our website.
For this purpose, we may process data such as technical information related to the device you are using, such as your IP address, browser type, geographic location and operating system; information about your surfing behaviour, such as how long you visit the device, which links you click on, which pages you visit and how often you visit a page.
This data is processed on the basis of our legitimate interest, in particular for security reasons, i.e. functional IT management, including infrastructure management, business continuity and IT security protection.
As an organisation, we also have a number of legal obligations, such as tax obligations, but we may also be required to comply with a request from a government institution or body, such as the Data Protection Authority.
Pinakes may, on its own initiative, transfer your personal data to the police or to the judicial authorities as evidence or if there is a justified suspicion of an unlawful act or crime that you have committed.
In order to comply with our legal obligations, we may process all categories of personal data listed in this Privacy Statement.
In exceptional situations, we may need your information in order to defend ourselves in legal proceedings, such as court proceedings.
In order to defend ourselves appropriately, we may process all categories of personal data listed in this Privacy Statement.
3. With who do we share your personal data?
In order to reach the above purposes, we can, if necessary, also share your personal data with:
- Service providers (such as IT companies);
- Our customers and their employees;
- Persons receiving the newsletter;
- Website visitors;
- Financial and judicial authorities, governmental or public authorities to the extent permitted by law;
- Certain regulated professions such as lawyers and auditors.
4. How long do we keep your personal data?
We will retain your personal data for as long as it is required to comply with applicable laws and regulations, or longer if necessary to achieve our purpose. For example, most customer information is kept for the duration of the contractual relationship and up to 10 years after the end of the contractual relationship.
5. What are your rights and how can you exercise them?
In accordance with applicable law, you have the following rights, to the extent applicable by law:
- Right of access: you can obtain information and a copy about the processing of your personal data;
- Right of rectification: if you believe that your personal data is incorrect or incomplete, you may request that your personal data be amended;
- Right to data erasure (“right to be forgotten”): you can request the erasure of your personal data;
- Right to limit the processing: you can request that the processing of your personal data is restricted;
- Right to transferability of data: you can ask to obtain the personal data that you have provided to us in a machine-readable form or, as far as technically possible, to have it transferred to a third party;
- Right of objection: you may object to the processing of your personal data for reasons relating to your specific situation. You have the right to object at any time to the processing of your personal data for direct marketing purposes, including profiling which relates to direct marketing and
- Right to revoke your consent: if the processing is based on your consent, you always have the right to revoke your consent.
6. How can you stay informed of changes to this Privacy Statement?
In a world of constant technological change, we will have to update this Privacy Statement on a regular basis.
We invite you to consult the latest version of this Privacy Statement online and we will keep you informed of important changes via our website or via our other usual communication channels.
7. Questions or remarks?
If you have any questions or comments about the processing of your personal data or if you want to exercise one of your rights, please do not hesitate to contact our DPO via dpo [at] pinakes.be of via Keizerslaan, 34, 1000 Brussels.
If you are not satisfied with how we deal with your request to exercise any of your rights, you can always contact the Data Protection Authority.