Last update of this privacy statement: 9 June 2020
Moore Belgium attaches great importance to the protection of your privacy, and strives to process your personal data in a transparent and confidential manner in accordance with the applicable regulations.
1. Purpose of this privacy statement
This privacy statement applies to the website www.moore.be and to all (commercial) relationships between Moore and its customers, prospects and business partners. This privacy statement relates to marketing, including visiting the website or other applications, the organisation of business, the content or marketing events, all forms of information provision via newsletters, articles on the website or via social media, and (customer) relationship management. The customer relationship is governed by a different privacy statement that you can request if you are, or wish to become a customer.
This statement describes, among other things, the types of personal data we collect about you, where we obtain the data from, how we use the data we collect about you, how long we retain your data, to whom we may provide this information, and your rights with regard to the processing of your personal data.
2. Who is the data controller?
This is the privacy statement of Moore Belgium BV, registered with the Crossroads Bank for Enterprises under number 0406.878.277, RPR Brussels-Dutch-language, with its registered office at 1020 Brussels, Esplanade 1, bus 96, DPO@moore.be.
This statement explains how and why Moore Belgium and its affiliated companies within the meaning of Article 1:20 of the Companies and Associations Code (hereinafter jointly referred to as "Moore" or "we" or "us") process your personal data. These affiliated companies are the following:
- Moore Finance & Tax BV, registered in the Crossroads Bank for Enterprises under number 0451.657.041, RPR Brussels – Dutch language, having its registered office at 1020 Brussels, Esplanade 1, bus 96.
- Moore Audit BV, registered in the Crossroads Bank for Enterprises under number 0453.925.059, RPR Brussels – Dutch language, with its registered office at 1020 Brussels, Esplanade 1, bus 96.
- Moore Stephens-Engelen NV, registered in the Crossroads Bank for Enterprises under number 0669.896.747, RPR Hasselt, with its registered office at 3500 Hasselt, Ilgatlaan 21.
- Moore Corporate Finance NV, registered in the Crossroads Bank for Enterprises under number 0463.402.256, RPR Mechelen, with its registered office at 2800 Mechelen, Schaliënhoevedreef 20, bus C.
- Moore Strategy & Operations BV, registered in the Crossroads Bank for Enterprises under number 0897.152.010, RPR Ghent, with its registered office at 9031 Ghent, Deinsesteenweg 114.
- Moore Interim Management BV, registered in the Crossroads Bank for Enterprises under number 0664.521.066, RPR Dendermonde, with its registered office at 9220 Hamme, Wielstraat 62.
- Element61 SA, registered in the Crossroads Bank for Enterprises under number 0888.581.168, RPR Brussels – Dutch language, with its registered office at 1020 Brussels, Esplanade 1, bus 96.
The data controller relates to Moore Belgium and/or the companies associated with it, as described above (Moore).
3. What is personal data?
Personal data is any data relating to identified or identifiable natural persons.
An 'identifiable' person is one who can be identified, directly or indirectly, by means of a number or by one or more specific elements characteristic of his or her physical, physiological, psychological, economic, cultural or social identity.
4. What personal information do we collect from you?
Moore may process the following personal data to the extent and, if relevant, for the purpose referred to in this privacy statement:
- Identification details
First name and surname, gender, date of birth, company, position, etc.
- Contact details
Address, email address, telephone number, possibly other contact details.
- Company data or data related to your professional activity
Activity, turnover, number of employees, directors and management, shareholders, VAT/KBO registration number, position or professional activity, company name or name of the activity.
- Professional and business interests
Which services or products from Moore are or could be of interest to you or your company. The preferences that are shown from your visit to our websites or applications, as well as preferences or interests that are expressed by participation in business, content or marketing events, but, of course, also from interests that you yourself have indicated or that we determine on the basis of professional social media use.
- Opinions about our products and services
We process your opinions relating to our products, services and information when they are relevant in a professional context, or in order to provide you with even more targeted information.
- Online data
This includes data from visits to our websites or other applications, and your surfing behaviour or other online contacts, but also data that we process based on your social media use in a professional context, such as likes, comments or similar.
In principle, we do not process sensitive personal data about you. If this data is actually processed, this is purely for the purpose of general data processing and never with the intention of using this particular data. In principle, we only process personal data that are relevant in a professional context.
Our website and/or our services do not intend to collect information about persons under the age of 13, unless they have parental or guardian consent or we are bound by our legal obligations. However, we cannot verify whether a website visitor is over 13 years of age. We encourage parents to be involved in their children's online activities in order to prevent the collection of information about children without parental consent.
If you believe that we have collected personal information about a minor without this consent, please contact us (see contact details).
5. How is this personal data collected?
Your personal information is usually collected when you decide to provide it to us or our employees. This occurs in the following situations, among others:
- Visiting Moore's websites or using other Moore applications
- Your interest in Moore's products or services
- When subscribing to the Moore newsletter
- When connecting to professional social media channels with Moore or its employees
- When participating in business, content or marketing events
- From correspondence or contacts with Moore.
We can also supplement your profile with data from our CRM and ERP systems or other internal sources of information.
Moore may also receive your personal data via other sources of information that are publicly accessible, such as the Belgian Official Gazette, your own website or profile, the National Bank, KBO.
Exceptionally, we may obtain information from other databases or sources of information. Before we do so, we check with the providers of these databases or sources to ensure that they comply with the applicable privacy regulations.
We use both paper and digital documents and forms for the collection of data.
6. The legal basis on which personal data is processed
When Moore processes personal data, one of the following legal grounds is invoked:
- Consent from you: personal data will be processed after you have given your consent.
- Legal obligations: personal data must be processed in order for Moore to comply with its legal obligations.
- Carrying out the agreement: the personal details that are processed are necessary for the execution of the agreement that exists between you and Moore.
- Legitimate interest: personal data may be processed if this is in the legitimate interest of Moore as a company, provided that your personal interests do not outweigh our interests.
7. The purposes for which personal data are processed
Personal data is processed for:
- The execution of the agreement between you and Moore
- The request for information or an offer
- The improvement of our services
- The enrichment of your profile
- Direct marketing activities, if you do not want your data to be used for these purposes, you can always adapt this via a notification, as well as via your cookie settings.
- The optimisation and analysis of the quality, the management and the content of Moore's websites or other applications
- The optimisation of the relationship with you
- Carrying out customer satisfaction surveys, surveys and other market surveys
- The organisation or facilitation of business, or the content of marketing events
- For the protection of our legitimate interest
- To inform you about changes or expansion of our services and products
- The execution of a legal obligation.
The way in which your personal details are processed may vary depending on the service Moore provides to you.
Furthermore, your personal data will be used for the application of legal requirements and obligations, and for administrative purposes (accounting, invoicing).
8. Conditions of use of the website
9. With whom is your personal data shared?
Your data will only be used within Moore. Apart from the exceptions mentioned below, your details will, in principle, not be shared with third parties.
- Your data may be shared with third parties if you have given your explicit consent.
- Your information will be shared with third parties if this is necessary for the performance of our activities, such as service providers. Moore only cooperates with reputable partners who comply with the applicable regulations and provide the necessary security measures for the protection of personal data.
- Your details will be shared with third parties if this is necessary for the execution of the agreement with Moore, or to provide you with more targeted information.
- Your data can be shared with logistics partners to organize mailings or to organise business, content or marketing events.
- Your details may be shared with third parties if Moore is legally obliged to do so (e.g. the government, the tax administration).
- Your data may be shared between Moore's entities, as described above, if this is necessary for administrative purposes or to provide or offer professional services to clients or prospects.
- In the event of re-organisations or the sale of Moore entities to another organization, Moore may disclose personal data in connection with the sale or other transfer of the company to which the data relates. In that case, Moore will inform the acquiring party of their obligations under the applicable regulations.
Under no circumstances will your personal data be shared with third parties for purely commercial purposes.
We enter into a processing agreement with the companies/persons who process your data on our behalf in order to ensure the same level of security and confidentiality of your data.
10. How is your data secured?
Moore takes all reasonable and appropriate security measures to secure your personal data, at both a technical and organisational level, as well as at an administrative level. In doing so, we take into account the state of the art, the implementation costs, the nature, scope and context of the processing and the probabilities and seriousness of the potential risks as identified by us. In this way, unauthorised access, unwanted destruction, loss or modification of data and data leaks are avoided as much as possible. Systems are continuously monitored and improved so that security can be guaranteed. Nevertheless, no system or procedure can completely exclude the above-mentioned risks.
11. How long will your data be stored?
We retain your personal information for the purpose of providing our newsletters and other promotional or marketing purposes for as long as you wish to receive this information from us. If you decide to unsubscribe or withdraw your consent to our newsletters and other promotional or marketing information, we will no longer use your personal information for this purpose. We may, however, need to keep your personal information for a different purpose (legal obligation).
12. What are your rights with regard to your personal data
12.1 Right of access
You have the right to receive confirmation that we process personal data from you, and you have the right to request access to the personal data. Before Moore grants you access to the details, it may ask you for proof of identification.
You can request a free copy of the personal data that Moore processes. If you wish additional copies or if you wish to inspect them repeatedly, Moore may charge a fee for this due to its administrative costs.
12.2 Right of improvement
You have the right to have your personal data adapted free of charge if it is incorrect or incomplete.
12.3 Right to revoke your consent
If the processing is based on your consent, you may revoke this consent at any time. This shall not affect the lawfulness of the processing based on your consent prior to its withdrawal, however.
12.4 Right of removal
In the following cases, you can request the deletion of your personal data free of charge:
- The personal data is no longer necessary for the purposes for which it was collected and/or processed
- You revoke your consent and there is no other legal basis for processing the personal data
- The personal data has been processed unlawfully
- The personal data must be deleted in order to comply with a legal obligation incumbent on Moore.
- You object to the processing and there are no overriding compelling legitimate grounds, or
- In case of direct marketing, you have the right to remove your personal data at any time;
The consequence of such a removal may well be that certain Moore services can no longer be provided.
12.5 Right to restrict the processing of your personal data
You have the right to block or limit the processing of your personal data if:
- You dispute the accuracy of the personal data (during the period that allows Moore to verify the accuracy of the data)
- The processing is unlawful and you oppose the deletion of the data, but insist on a limitation of the processing.
- The data is no longer required for processing purposes, but you need it for legal proceedings
- If you have objected to the processing, pending clarification, or if Moore's legitimate interests outweigh your interests.
If data processing is restricted, Moore may store the personal data, but may not further process them.
12.6 Right of objection
You have the right to object:
- Against the processing of data, unless Moore invokes compelling legitimate grounds that would outweigh your interests, rights and freedoms, or which are related to a legal action;
- At all times against processing for direct marketing;
- Against processing for the purpose of scientific or historical research and statistics, unless the processing is necessary for the performance of a task in the public interest.
12.7 Right to transferability
If the processing is based on your consent, or on an agreement with Moore, and the processing is carried out using an automatic process, you have the right to obtain your personal data in a structured, commonly used and machine readable format. In such a case, you also have the right to transfer the data in that format to another data processor. If the processing is based on a legal basis other than your consent or your agreement with Moore, the right of transferability does not apply, without prejudice to your other rights.
12.8 Right to complain
Moore strives to process your personal data as transparently and correctly as possible. If you still feel that something is wrong, you can always contact our Data Protection Officer via the e-mail address : DPO@moore.be.
You also have the right to lodge a complaint with the supervisory authority, the Belgian Data Protection Authority:
- Drukpersstraat 35
- 1000 Brussels
- Telephone: 02/274.48.00
- Fax: 02/274.48.35
- E-mail: firstname.lastname@example.org
13. Exercise of your rights
If you wish to exercise one of your above-mentioned rights, you can send your request by registered letter to Moore Belgium, 1020 Brussels, Esplanade 1, bus 96, or by e-mail to DPO@moore.be.
14. Other websites
Moore's website contains hyperlinks to other websites. In such cases, we refer you to the privacy policies of these providers. Moore has no control over this.
15. Amendments to this statement
Moore will review this statement at regular intervals and amend it if necessary. If necessary, the date of any change will be mentioned on its website page. The current statement was last updated on 9 June 2020.
If you have any questions about this privacy statement or about the way in which we collect, use or process your personal data, you can always contact Moore's Data Protection Officer via the e-mail address DPO@moore.be.