PERSONAL DATA PROTECTION POLICY

Last updated: 29/06/2022

1. GENERAL INFORMATION

1.1. Who is processing your data?
MITIS (hereinafter "MITIS" or “We”), with registered office at Rue des Chasseurs Ardennais 5, 4031 Angleur (Belgium) and registered with the Crossroads Bank of Enterprises under number 0820.861.510, is responsible for the processing of your personal data (as “data controller” within the meaning of the GDPR).
In accordance with GDPR, when MITIS processes personal data of any kind, it shall do everything in its power to preserve their confidentiality and to inform the data subjects of the reasons for and means of the processing.

1.2. Purpose of this data protection policy
In the course of its activities, MITIS may collect, store and process personal data concerning you, if you:
- Are a business partner or the contact person of one of our business partners (such as suppliers, consultants, etc.);
- Are a client or the contact person of one of our clients;
- Are an on-site visitor of MITIS;
- Are a visitor to the websites of MITIS (including social media);
- Apply for a job, an internship or a temporary post;
- Participate to an event organized by MITIS;
- Request to receive information about a product or service of MITIS;
- Subscribe to the newsletters service of MITIS.
The aim of this Data Protection Policy is therefore to explain in a clear and simple way the processing made by MITIS on your personal data.  
This Data Protection Policy is regularly updated. We invite you to regularly consult our website to be informed of the current version.

1.3. Any questions?
For any questions regarding the processing of your personal data or requests in relation to this Data Protection Policy, please feel free to contact us by post at the above-mentioned address or by email at the following address: web-data@mitis.be.
If you would like more information, or if you wish to lodge a complaint, you can also contact the Data Protection Authority (Rue de la Presse, 35 - 1000 Brussels, Tel. + 32 2 274 48 00 - contact@apd-gba.be).

2. SPECIFIC DATA PROCESSING DEPENDING ON YOUR QUALITY

2.1. You are a business partner of MITIS (or a contact person of one of MITIS’ business partners)

Categories of data collected

If you provide services/products to MITIS (or if you are a contact person of one of MITIS’ business partners), the following personal data about you may be processed: identification data (last name, first name), contact data (e-mail address, telephone number), professional data (company, position), financial/accounting information (bank account number, account holder).

Purpose(s) and legal basis

These personal data are processed for the following purposes:
- For the purpose of managing the contractual relationship: management of orders, offers, delivery, invoicing and payment and evaluation of the business partner’s performance (if any). This processing is necessary for the proper execution of the contract concluded between you and MITIS.
- If you are a contact person of one of MITIS’ business partners, for the purpose of contacting that business partner. This processing is justified by the legitimate interest of MITIS.
- In order to send you emails/letters, including to keep you informed of our upcoming events, new activities (including new products or services)  and publications. This processing is justified by our legitimate interest in promoting our services to you, as business partner of MITIS.
- In order to ensure the security of the MITIS’ infrastructures to which you have access in the context of the mission entrusted to you, your data may also be processed. This processing is justified by the MITIS’ legitimate interest in ensuring the security of its offices.

Retention period

Your data are kept for 10 years after the end of the contract with MITIS or the last order.
As regards the sending of emails/letters to you, your data are kept for 10 years after the end of the contract with MITIS or the last order, unless you object to the processing.

Recipients

In order to accomplish the purposes listed above, your data may be communicated to the following recipients:
- MITIS’ staff members (employees, trainees, etc.) if the processing of your data is necessary for the performance of their tasks;
- MITIS’ partners or subcontractors, acting on behalf of MITIS.

2.2. You are a client of MITIS (or a contact person of one of MITIS’ clients)

Categories of data collected
If you are a client of MITIS (or a contact person of one of MITIS’ clients), the following personal data about you may be processed: identification data (last name, first name), contact data (your company, company postal address, business e-mail address, business telephone number, etc), financial/accounting/ invoicing information (bank account number, account holder).

Purpose(s) and legal basis

These personal data are processed for the following purposes:
- For the execution and management of orders, supply and delivery, after-sale services, invoicing and possible recovery of services, etc. This processing is necessary for the proper execution of the contract concluded between you and MITIS.
- If you are a contact person of one of MITIS’ clients, the processing of your personal data is justified by the MITIS’ legitimate interest in being able to contact its clients.
- In order to send you emails/letters, including to keep you informed of our upcoming events, new activities (including new products or services) and publications. This processing is justified by our legitimate interest in promoting our services to you, as client of MITIS.

Retention period

Your data are kept during 10 years after the end of the contract concluded with MITIS or the last order, except when a different legal retention time would apply.
As regards the sending of emails/letters to you, your data are kept for 10 years after the end of the contract with MITIS or the last order, unless you object to the processing.

Recipients

In order to accomplish the purposes listed above, your data may be communicated to the following recipients:
- MITIS’ staff members (employees, trainees, etc.) if the processing of your data is necessary for the performance of their tasks;
- MITIS’ partners or subcontractors, acting on behalf of MITIS.
- Fiscal and social administration if the law so provides;

2.3. You are an on-site visitor of MITIS

Categories of data collected

If you visit the MITIS’ premises, the following personal data concerning you may be processed: identification data (last name, first name, company), contact data (e-mail address, telephone number), data relating to the visit (type of visitor, visitor's contact at MITIS, purpose of the visit, date and time of the visit).  
Purpose(s) and legal basis

These personal data are processed for the following purposes:
- To ensure the security of the site (management of your arrival/departure on the site): MITIS has a legitimate interest in ensuring the security of its sites, which involves organizing your visit.

Retention period

Your data are kept for 30 days after your last visit to the MITIS’ premises.

Recipients In order to accomplish the purposes listed above, your data may be communicated to the following recipients:
- MITIS’ staff members (employees, trainees, etc.) if the processing of your data is necessary for the performance of their tasks;
- MITIS’ partners or subcontractors, acting on behalf of MITIS.

2.4. You are a visitor of the websites of MITIS

Categories of data collected

If you visit the MITIS’ website https://www.mitis.be, you do not have to provide any personal data. However, the provision of the website involves the collection of "cookies" (for more detailed information, see our Cookies Policy).

If you subscribe to our newsletters and/or if you contact MITIS via the "Contact" form on the website, the following personal data about you may be processed: identification data (last name, first name), contact data (e-mail address), any other information you include in your message (where relevant).

Purpose(s) and legal basis

These personal data are processed for the following purposes:
- For the purpose of placing and reading cookies: some cookies are necessary to enable navigation on the website while others are optional and you are free to accept them or not. For more information, see our Cookies Policy.
- When you subscribe to our newsletters service: to send you our newsletters, including to keep you informed of our upcoming events, news and publications. The collection and processing of your personal data is based on your consent.
- When you send us a message via the contact form: to manage your request and respond to your request. The collection and processing of your personal data is based on your consent.

Retention period

Your personal data shall be stored/ processed:
- Regarding the cookies: see our Cookie Policy for more detailed information.
- When you subscribe to our newsletters service: as long as you keep your newsletters subscription active (withdrawal of your consent being possible at any time by unsubscribing) or until MITIS decides to terminate its newsletters service.
- When you send us a message via the contact form: until your request is processed.

Recipients

In order to accomplish the purposes listed above, your data may be communicated to the following recipients:
- MITIS’ staff members (employees, trainees, etc.) if the processing of your data is necessary for the performance of their tasks;
- MITIS’ partners or subcontractors, acting on behalf of MITIS.
- To any third parties mentioned in the Cookie Policy.

2.5. You are a visitor of the MITIS’ LinkedIn page

Categories of data collected If you visit the MITIS’ LinkedIn page, the following personal data may be processed jointly by LinkedIn and the administrator of that page: data related to your account, data related to the sharing of content or communications you have with others.

Purpose(s) and legal basis These personal data are processed for the following purposes:
- For the purpose of placing and reading cookies: for more information, see the Cookies Policy;
- For the purpose of providing and personalising the Linkedin’s services (including advertisements);
- Your data may be processed by the administrator of the page (MITIS) in the context of its legitimate interest to obtain statistics on the visitors of his page in order to adequately promote his page. The statistics of audience established by LinkedIn are only transmitted to the administrator of the page in an anonymized form.

Retention period Your data are or could be processed as long as the page exists and you visit it.
The Privacy Policy of LinkedIn can be found by clicking on the following link: https://www.linkedin.com/legal/privacy-policy.

Recipients In order to accomplish the purposes listed above, your data may be communicated to the following recipients:
- MITIS’ staff members (employees, trainees, etc.) if the processing of your data is necessary for the performance of their tasks;
- MITIS’ partners or subcontractors, acting on behalf of MITIS.
- LinkedIn.

2.6. You participate in an event organised by MITIS

Categories of data collected

If you register to an event organised by MITIS, the following personal data concerning you may be processed: identification data (last name, first name), contact data (e-mail address, postal address, telephone number), professional data (position, company). If you consent, we may also use your image.

Purpose(s) and legal basis

These personal data are processed for the following purposes:
- When you register for one of our (offline or online) event it is necessary that you fill in a registration form. The data you provide when filling in this form is processed by MITIS for the purpose of organising and following up the event. Without it, we cannot sign you up for the event and provide you with the information on such an event. The processing of your personal data is necessary for the performance of the contract between us in the context of the event to which you have subscribed.
- Where applicable, your image may be processed on the basis of your consent : to reproduce, store stream or communicate audio recordings, photos, videos, images and publish photos, audio recordings or videos where you may appear to report on activities, and to promote activities organized by MITIS on the MITIS’ website and extranet, social medias, newsletters or in any other MITIS’ publications.

Retention period

Your data are processed for a maximum period of 5 years from the date of the event you participated. As regards your image, the duration of the processing is 5 years , unless you withdraw your consent.

Recipients

In order to accomplish the purposes listed above, your data may be communicated to the following recipients:
- MITIS’ staff members (employees, trainees, etc.) if the processing of your data is necessary for the performance of their tasks;
- MITIS’ partners or subcontractors, acting on behalf of MITIS.
- The public via the MITIS’ website and LinkedIn page.

2.7. You apply for a job, an internship or a temporary post

Categories of data collected

If you apply for a job/internship/interim position at MITIS, the following personal data may be processed: identification data (last name, first name, image, date of birth), contact data (e-mail address, postal address, telephone number), data related to your professional background (experience, CV, previous employers, language skills, etc.), data related to the interview and to the job questionnaire (evaluation, comments), previous or alleged remuneration, and any information contained in your curriculum vitae and/or covering letter.

Purpose(s) and legal basis

These personal data are processed for the following purposes:
- To evaluate your application: MITIS examines your application in order to assess the possibilities of a contractual relationship.
- For the purpose of building up a recruitment reserve: the MITIS’ legitimate interest is to contact you at a later date regarding the job offer in the event that the person initially recruited withdraws or in the event of a vacancy for another similar position that is immediately available. If you do not wish to be included in the recruitment pool, you may always object.

Retention period

If your application is unsuccessful, your data is automatically deleted 6 months the end of the selection process.

Recipients

In order to fulfill the purposes listed above, your data may be communicated to the following recipients:
- MITIS’ staff members (employees, trainees, etc.) if the processing of your data is necessary for the performance of their tasks;
- MITIS’ partners or subcontractors, acting on behalf of MITIS (in particular, recruitment agencies).

2.8. In any case

In any case, MITIS can process your personal data in the following cases:

2.8.1. Possible legal dispute
Your personal data may be processed for the purpose of managing any dispute that may arise between you and MITIS. In this case, MITIS has a legitimate interest to process your personal data to exercise its legal rights.
MITIS may also process sensitive data (special categories of personal data), where this is necessary for the establishment, exercise or defense of its legal rights in accordance with the provisions of Article 9 §2, f. of the GDPR.
For the fulfillment of this purpose, your personal data may be communicated to the following recipients:
- MITIS’ staff members (employees, trainees, etc.) if the processing of your data is necessary for the performance of their tasks;
- MITIS’ partners or subcontractors, acting on behalf of MITIS
- MITIS’ lawyers, debt collection companies, bailiffs;
- To police and/or judicial institutions;
- To authorities, public bodies, carrying out controls.

2.8.2. Prevention of fraud and abuses
Your data may be processed to combat fraud and abuse (only for processing involving a contract between you and MITIS): MITIS is under a legal obligation to carry out certain checks relating to the reputation and solvency of its contracting parties, in order to guard against the risks of fraud and abuse.
For this purpose, your data may be communicated to the following recipients:
- MITIS’ staff members (employees, trainees, etc.) if the processing of your data is necessary for the performance of their tasks;
- MITIS’ partners or subcontractors, acting on behalf of MITIS
- MITIS’ lawyers, debt collection companies, bailiffs;
- To police and/or judicial institutions;
- To authorities, public bodies, carrying out controls.

3. LOCATION OF YOUR DATA

Your data are stored both on servers located inside the European Union and outside the European Union.
As part of our business activities, We indeed need to transfer your personal data to hosting service providers, IT service providers and other service providers located outside the European Union. Your personal data can thus be sent to non-EU countries for whom the European Commission has not established an “adequacy decision”. In such a case, We ensure that this transfer is carried out in accordance with the applicable regulations and We ensure a sufficient level of protection of individuals’ privacy and fundamental rights (mainly through the adoption of the European Commission’s standard contractual clauses and supplementary measures). These contractual clauses are available upon request.

4. YOUR RIGHTS

The following section explains your rights under the GDPR.

Information

You have the right to be provided with clear, transparent and intelligible information about how We use your personal data and your rights. This right to be informed is exercised through this document. If the data processed includes data of your staff, you are responsible for making them aware of this document.

Access and rectification

You have the right to access your data and to have them rectified if necessary.
You have the right to consult your data at any time and free of charge, by sending an email to web-data@mitis.be or a dated and signed letter to MITIS’ headquarters (Rue des Chasseurs Ardennais 5, 4031 Angleur). You also have the right to demand that incorrect data be corrected and that inappropriate or unnecessary data be deleted by sending an email to web-data@mitis.be or by sending us a dated and signed letter to the address of MITIS’ headquarters.  

Opposition

Within the limits of what is provided by law, you may object to the processing of your data by MITIS on the basis of our legitimate interest. You will be able to exercise your right to object through the unsubscribe links available in the e-mails sent to you or you can directly object by sending an email to MITIS at web-data@mitis.be.

Withdrawing your consent

Where data is processed on the basis of your consent, you may withdraw this consent at any time, without calling into question the past processing.

Erasure

You may obtain the erasure of your data or the restriction of processing under the conditions set out in GDPR articles 17 and 18.

Portability

The data you have provided to us may be communicated or transmitted in electronic format.

MITIS SA
+32 4290 5010
Rue des Chasseurs Ardennais 5
4031 Angleur
Belgium

This project has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement No 946903.

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