Data Policy House of HR website

 

Please read this privacy policy (hereafter: the Privacy Policy) carefully because it explains how we process personal data and it describes your rights in relation to your personal data.

 

ARTICLE 1 – GENERAL

This Privacy Policy describes the processing of your personal data by the following companies:

 

  • House of HR NV, with registered office at Spinnerijstraat 97, 8500 Kortrijk, Belgium and registered in the Crossroads Bank for Enterprises under the number 0643.887.978;
  • House of IT Support BV, with registered office at Spinnerijstraat 97, 8500 Kortrijk, Belgium and registered in the Crossroads Bank for Enterprises under the number 0785.383.165;
  • House of Invest NV, with registered office at Spinnerijstraat 97, 8500 Kortrijk, Belgium and registered in the Crossroads Bank for Enterprises under the number 0552.778.551;
  • The House of Finance NV, with registered office at Spinnerijstraat 97, 8500 Kortrijk, Belgium and registered in the Crossroads Bank for Enterprises under the number 0685.593.921;
  • The House of Pledge NV, with registered office at Spinnerijstraat 97, 8500 Kortrijk, Belgium and registered in the Crossroads Bank for Enterprises under the number 0691.892.387.

 

Even though they share a unified privacy statement, each of the entities above act separately and as separate controllers when processing personal data. For the sake of convenience, each of the abovementioned entities is referred to as HOHR. In the description of purposes below, it is indicated which processing activities are undertaken by each entity.

 

The Privacy Policy is addressed to the following data subjects: interested parties, website visitors, clients and their employees, suppliers and their employees, companies and their employees, applicants and investors (including shareholders).

 

HOHR aims to comply with ‘the Regulation of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (generally known as the ‘General Data Protection Regulation’)’, with ‘the Law of 30 July 2018 concerning the protection of natural persons with regard to the processing of personal data, for the transposing, supplementing and implementing of the European Regulation 2016/679 of 27 April 2016 concerning the protection of personal data’, as well as with ‘the direct marketing provisions from Book XII of the Code of Economic Right concerning the ‘right of the electronic economy’ (to the extent applicable)’.

 

ARTICLE 2 – DATE OF THE LAST REVISION

Date of the last revision: 21 February 2024.

 

This Privacy Policy can regularly be revised or updated. To keep you informed of the latest change to our Privacy Policy, we will update the review date each time it is changed. The amended Privacy Policy will take effect on the date of the last revision. Revisions and updates will be released on the website (www.houseofhr.com) (the Website). We recommend you to consult it on a regular basis.

 

ARTICLE 3 – PROCESSING ACTIVITIES

For each entity mentioned below, it is clarified for which purposes they process personal data:

 

  • House of HR NV:
    • Client Management;
    • Supplier Management;
    • Direct Marketing;
    • Legal Obligations;
    • M&A;
    • Risk & Internal Audit;
    • Corporate & Legal Management;
    • Website administration and contact form;
    • Applicant Management; and
    • Investor Relations.
  • House of IT Support BV:
    • Client Management;
    • Supplier Management; and
    • Legal Obligations.
  • House of Invest NV:
    • Client Management;
    • Supplier Management; and
    • Legal Obligations.
  • The House of Finance NV:
    • Corporate & Legal Management;
    • Supplier Management; and
    • Legal Obligations.
  • The House of Pledge NV:
    • Corporate & Legal Management;
    • Supplier Management; and
    • Legal Obligations.

 

3.1. Client management

HOHR process the following personal data in the context of our relationship with our clients (and their employees):

 

  • Identification data and contact details (name, surname, address, phone number, e-mail);
  • Electronic identification data and metadata, if you use our Website and/or applications;
  • Personal characteristics; and
  • Professional data.

 

The legal basis is our legitimate interest, namely the freedom of entrepreneurship. The personal data must be provided to enable the performance of the contract.

 

We may obtain information from your employer. The personal data you provide may be supplemented through information obtained from public sources (e.g. social networks such as LinkedIn).

 

The personal data will be retained for a period of 10 years after the end of the client relationship

 

3.2. Supplier management

HOHR processes the following personal data for supplier management purposes (suppliers and their employees):

 

  • Identification data and contact details (name, surname, address, phone number, e-mail);
  • Electronic identification data and metadata, if you use our Website and/or applications;
  • Personal characteristics; and
  • Professional data.

 

Depending on the context of the processing, the legal ground is contractual relationship (e.g. if we have a contractual relationship) or legitimate interest (the freedom of entrepreneurship) (e.g. when you are an employee of our supplier).

 

Personal data may be obtained through external public sources (e.g. LinkedIn or websites) or from your employer and/or your colleagues.

 

The personal data shall be stored until 10 years after the end of the contractual relationship with the supplier.

 

3.3. Direct marketing

HOHR processes the following personal data for direct marketing purposes:

 

  • Identification data and contact details (name, surname, address, e-mail and phone number);
  • Financial data (in relation to investors and potential investors); and
  • Personal characteristics.

 

Our legal basis is your consent. If you are an existing investor, our legal basis is our legitimate interest (the freedom of entrepreneurship).

 

Your consent can be withdrawn at any time - free of charge and without any obligation to give a justification - by contacting us on the following e-mail address privacy@houseofhr.com.

 

The personal data shall be stored for a period of 5 years after our last meaningful contact.

 

3.4 Legal obligations

HOHR processes the following personal data in order to comply with its own legal obligations (including tax and accounting obligations):

 

  • Identification data and contact details (name, surname, address, e-mail and phone number);
  • Financial data; and
  • Personal characteristics.

 

The legal ground is our legal obligation.

 

The personal data shall be retained in accordance with the legal retention periods.

 

3.5 M&A

HOHR processes the following personal data in the context of M&A and corporate activities (including due diligence exercises):

 

  • Identification data and contact details (name, surname, address, e-mail and phone number);
  • Financial data; and
  • Professional data ; and
  • Judicial data.

 

The legal ground is our legitimate interest, namely the freedom of entrepreneurship.

 

HOHR may obtain personal data indirectly, namely from your employer or their advisors, or other public sources of information.

 

If the M&A or corporate activity does not lead to a specific transaction, the personal data shall be retained for a period of 10 years following the end of the negotiation period or due diligence exercise. In case a transaction takes place, the personal data is stored for a period of 30 years following the termination or the expiry of the agreement.

 

3.6 Risk & Internal audit

HOHR processes the following personal data in the context of its risk management and internal audit related activities:

 

  • Identification data and contact details (e.g. name, surname, address, phone number);
  • Personal characteristics;
  • Financial data;
  • Professional data ;
  • Judicial data (including criminal data if relevant);
  • Health data (if relevant);
  • Images and sound recordings; and
  • Location data.

 

The legal ground is our legitimate interest, namely the freedom of entrepreneurship, information security and the detection and prevention of conflicts of interest, corporate risks and fraud.

 

For special categories of personal data, the processing is based on your explicit consent (health data) or within the limitations set out in the Act of 30 July 2018 (criminal data), namely the handling of HOHR own criminal matters.

 

HOHR may obtain personal data indirectly, namely from your employer or their advisors, or other public sources of information.

 

The personal data will be stored for a period of 10 years, except if a longer or shorter legal retention period applies (which will then prevail).

 

3.7 Corporate & legal management

HoHR processes the following personal data for corporate and legal management purposes (including legal advisory work, corporate housekeeping, UBO related obligations, …):

 

  • Identification data and contact details (e.g. name, surname, address, phone number);
  • Financial data;
  • Personal characteristics;
  • Professional data ;
  • Judicial data; and
  • National registration number.

 

Depending on the context of the processing, the legal ground is our legal obligation, your consent or our legitimate interest (the freedom of entrepreneurship).

 

Personal data may be obtained from your employer or through external public sources (e.g. LinkedIn or websites).

 

The personal data shall be stored in accordance with the legal retention periods.

 

3.8. Website Administration and contact form

HoHR processes the following personal data for purposes of the management and follow-up of the contact form on the Website:

 

  • Identification data and contact details (name, surname, e-mail address)
  • Information submitted through the contact form

 

The legal ground for processing is our legitimate interest, namely the freedom of entrepreneurship.

 

The personal data shall be stored during the period required for following-up your communication and a period of 6 months thereafter.

 

3.9. Applicant management

HOHR processes the following personal data for applicant management purposes:

 

  • Identification data and contact details (e.g. name, surname, address, phone number);
  • Personal characteristics;
  • Professional data; and
  • Personal interests.

 

The legal ground for processing your personal data is contractual relationship (including precontractual measures).

 

Personal data may be obtained through external public sources (e.g. LinkedIn or websites) or from your (ex-)employer and/or your (ex-)colleagues (e.g. in case of references).

 

The personal data shall be stored until 5 years after the end of the application procedure. If the application is successful, the subsequent processing will be covered by a separate privacy statement on employee management.

 

3.10 Investor relations

HoHR processes the following personal data to maintain its relation with past, current and potential investors (and their employees):

 

  • Identification data and contact details (e.g. name, surname, address, phone number);
  • Financial data;
  • Personal characteristics; and
  • Professional data.

 

Depending on the context of the processing, the legal ground is contractual relationship (e.g. if we have a contractual relationship via a shareholders’ agreement ), legitimate interest in order to ensure proper business interaction or legal obligation.

 

Personal data may also be obtained through external public sources (e.g. LinkedIn or websites).

 

The personal data of investors shall be stored as long as they have an investment in the company and until 20 years after they cease to be an investor in the company. The personal data of potential investors shall be stored 10 years after the end of any discussion regarding a potential investment.

 

ARTICLE 4 – DISCLOSURE TO THIRD PARTIES

HOHR can share the personal data it processes with other companies within the House of HR group (which includes various companies active in personnel placement and human resources). All companies within the House of HR Group are located within the European Economic Area. More information with respect to the House of HR Group and its member companies can be found here: https://www.houseofhr.com/companies.

 

If HOHR shares personal data with the other companies within the House of HR group, it will be in the framework of intra-group collaboration and/or intra-group services in order to improve, facilitate and simplify the activities and services of HOHR and the respective House of HR group company (for instance ICT-services, accounting, analytics and statistics, debtor management, (possible) direct marketing, etc.).

 

In certain cases, HOHR may act as joint data controller for the processing of your personal data together with other companies of the House of HR Group. This means that they jointly determine the purpose of and the means for processing your personal data. In this case they are jointly responsible for compliance with applicable data protection legislation. However, HOHR remains your main point of contact, also for exercising your rights in relation to your personal data (for more information on exercising your rights, see article 7).

 

HOHR can share the personal data also to third party service providers who handle technical and operational support and to third party service providers (such as, but not limited to, lawyers, auditors, etc.) in general in so far as this is necessary for the professional services and/or contributes to the corporate governance structure and/or if they are obliged to do so based on a statutory provision or a judicial ruling.

 

ARTICLE 5 – TRANSFER TO THIRD COUNTRIES

HOHR may transfer your personal data outside the European Economic Area in order to process the data in accordance with this Privacy Policy. In case data is transferred outside the European Economic Area, to a country not providing an adequate level of protection, HOHR warrants undertaking all measures to protect your personal data including implementing contractual clauses that offer sufficient safeguards on data protection for the data to be transferred internationally. In practice, this will generally be achieved through standard contractual clauses with the recipient. More information on standard contractual clauses can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_nl.

 

If you want to obtain more information about the transfer of your personal data outside the European Economic Area, you can contact us by e-mail to privacy@houseofhr.com or, in relation to House of IT Support BV, by e-mail to dpo@houseofitsupport.com.

 

ARTICLE 6 – YOUR RIGHTS

You have rights concerning your personal data. Some of these rights have a specific scope, specific conditions or exceptions. When you submit a request, please identify the entity to which this request is addressed.

 

6.1. Right of access:

You have the right - at any time, free of charge - to take cognizance of the personal data that HOHR is processing of you, as well as the right of asking information about the way of processing. You are also entitled to a copy of the data being processed.

 

6.2. Right to rectify, complete and restrict:

You always have the right to ask us to rectify, complete or delete all/part of your personal data if that data is incorrect.

 

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

 

6.3. Right to erasure (‘Right to be forgotten’)

This right allows you to have your personal data processed by HOHR permanently deleted. This right may only be exercised under specific conditions.

 

6.4 Right to object:

You also have a right to object against the processing of your personal data on grounds relating to your particular situation.

 

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

 

6.5. Right to 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.

 

6.6. Right to withdraw consent:

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

 

6.7. Exercising your rights:

You can exercise your rights by contacting us for this purpose by e-mail to privacy@houseofhr.com or, in relation to House of IT Support BV, by e-mail to dpo@houseofitsupport.com.

 

HOHR is not always obliged to deal with your request to exercise your rights - your rights only apply in the cases and to the extent provided for by law.

 

If we have reasonable doubts about your identity, we may ask you to provide additional evidence.

 

6.8. Right to file a complaint:

You have the right to file a complaint with the supervisory authority (in Belgian this is the Belgian Data Protection Authority, https://www.gegevensbeschermingsautoriteit.be/burger/acties/contact).

 

Prior to filing a complaint, we invite you to contact us in order to find a swift solution for your issue by e-mail to privacy@houseofhr.com or, in relation to House of IT Support BV, by e-mail to dpo@houseofitsupport.com.

 

ARTICLE 7 – SECURITY AND CONFIDENTIALITY

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.

 

You must always observe the security rules, including by preventing any unauthorized access to your login and code. You are thus solely responsible for the use that is made as of the Website from your computer, IP address and from your identification data, as well as for the confidentiality thereof.

 

In order to be able to process your personal data, we grant access to your personal data to our employees and agents. We guarantee an identical level of protection by making contractual obligations that are opposable to these employees and agents. This means that our employees and agents are bound by confidentiality and that only those for whom it is necessary for the performance of their duties have access to your personal data.

 

ARTICLE 8 – LINKS TO OTHER WEBSITES AND SOCIAL MEDIA

The Website can contain references to other websites and applications. HOHR is not responsible for the processing of personal data via these websites and applications.

 

HOHR can only advice you to check the privacy policies/statements and the terms and conditions of these websites and applications.

 

ARTICLE 9 – APPLICABLE LAW

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

 

ARTICLE 10 – CONTACT US

You can always contact us at +32 (0)56 056 056 or privacy@houseofhr.com.

 

Where you can reach us at any time:

 

House of HR
Spinnerijstraat 97
8500 Kortrijk
Belgium

 

In addition, House of IT Support BV has appointed a data protection officer (DPO). For queries in relation to House of IT Support BV, you can either use the general contact details or dpo@houseofitsupport.com.