Delcap sa|nv - Privacy Policy
Introduction
This Privacy Policy outlines Delcap sa|nv (" we ", " our " or " or ", with registered office at 7 Rue Joseph Stevens, 1000 Brussels, Belgium, company number 724.481.419 [Brussels registry]) processes information collected from users who access our website at www.delcap.com, clients and prospects or other non-staff persons who otherwise share in-formation with us (collectively: "Data Subjects").
Delcap is committed to upholding applicable data protection laws, including the General Data Protection Regulation (“GDPR”).
What information we collect and from where ?
We collect various types of personal data (meaning, any information relating to you – hereinafter “Personal Data”), based on how you interact with Delcap and the Site.
First, some Personal Data can be collected via cookies and similar files/tags. In this respect, please refer to the “Cookies” section hereunder.
Next, we collect Personal Data that you provide to us through your use of the Site or through other means of contact (e-mail, phone etc.), in particular identification and contact details (e-mail, phone number etc.), financial data (bank details, financial situation, investor profile), financial background (investor profile knowledge and experiences) and job application data (CV, education, date of birth etc.).
In addition, we collect Personal Data in the context of performance of our services and surrounding relationship management (financial information in particular, but also any other identification or contact data, potentially also in relation to other Data Subjects).
Finally, we collect data from third-party sources, such as (i) the UBO register, the Belgian State Gazette (Moniteur belge / Belgisch Staatsblad) and other public registers, (ii) corporate websites, (iii) social networks and (iv) database providers or data brokers. To the extent such data contains Personal Data, we take care to ensure that the processing of such Personal Data is in accordance with applicable rules, in particular the transparency obligations where applicable.
Grounds and purposes for data processing
Processing of your Personal Data is necessary:
(i) for the performance of our contractual obligations towards you and providing you with our services (in particular in the case of clients; in such a case, refusal to provide Personal Data will likely make it impossible for Delcap to e.g. sign a contract or provide services to you), including online services such as a personalised display of our Site;
(ii) for our legitimate interests:
a. in promoting and improving our services (including providing you with marketing offers and promotional materials related to our Site and services, performing research, technical diagnostics or analytics and evaluating the success of our services and advertising campaigns);
b. in managing the relationship with prospects and customers (including customer profiles, as well as registered users on the Site);
c. in responding to queries and responding to customer service requests;
d. in managing potential issues; and
e. in managing recruitment processes in the case of job applicants;
and
(iii) for compliance with legal and financial regulatory obligations to which we are subject (in which case refusal to provide Personal Data will likely make it impossible for Delcap to e.g. sign a contract or provide services to you).
In specific cases (such as long-term retention of data for job applications), we may also request your consent for the intended processing of your Personal Data.
In each case, to the extent required in the context of these purposes, we may transfer or disclose Personal Data to our subsidiaries, affiliated companies and subcontractors.
We do not share Personal Data with third parties except as described in this Privacy Statement, and in any event we do not rent or sell Personal Data.
In particular, we may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) collaborate with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.
Data subject rights
You may request to:
- Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
- Receive a copy of Personal Data in a structured, commonly used and machine-readable format, in specific cases foreseen by law.
- Request rectification of your (inaccurate) Personal Data that is in our control.
- Request erasure of your Personal Data (in cases foreseen by law, such as where the Personal Data are no longer necessary).
- Object to the processing of Personal Data by us, where the processing is based on our legitimate interest as a legal ground (without prejudice to our right to override the objection if there are any compelling legitimate grounds for the processing).
- Request to restrict processing of your Personal Data by us in specific cases, such as where the processing is unlawful.
- Lodge a complaint with a supervisory authority (for Belgium, this is the Belgian Data Protection Authority).
However, please note that these rights are not absolute, and may be subject to our own rights as well as regulatory requirements.
How to contact us ?
If you wish to exercise any of the aforementioned rights, or receive more information, please contact the responsible person in charge of data protection using the details provided below: regulatory@delcap.com.
You may submit your request via the different means of communication placed at your disposal by Delcap SA|NV.
- by post, accompanied by a copy of your identity card, to the following address: Delcap SA|NV Rue Joseph Stevens 7, 1000 Brussels, Belgium
- by sending an email, accompanied by a copy of your identity card, to the following address:
regulatory@delcap.com
Retention
We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
Cookies
We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.
A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.
The Site uses the following types of cookies:
a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.
We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy .
Third party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.
This Privacy Statement does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, other than our processors.
How do we safeguard your information ?
We take great care in implementing and maintaining the security of the Site and your information. Delcap will take all necessary precautions to ensure that the Personal Data it holds is protected against physical loss or damage; that access and disclosure be restricted; and that Personal Data is not disclosed to any unauthorized third party. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.
Transfer of data outside the EEA
Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
Marketing
We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.
Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists.
Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.
Corporate transaction
We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.
Minors
We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed towards children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Data from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us at regulatory@delcap.com.
Updates or amendments to this privacy statement
We reserve the right to periodically amend or revise the Privacy Statement; material changes will be effective immediately upon the display of the revised Privacy Statement. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment of such amendments to the Privacy Statement.