Privacy Statement

1. Purpose and Scope

Mitiska REIM, a limited liability company (“Naamloze vennootschap”), having its office at Alfons Gossetlaan 34/401, 1702 Groot-Bijgaarden, registered in the Crossroads Bank for Enterprises under number BE 0449.790.681 (RLE Business court Brussels, Dutch-speaking section) (hereinafter referred as the “Company” or “Us”) is committed to ensuring that any personal data it receives in relation to third parties is handled in accordance with applicable data protection laws. Third parties refer to natural persons who are not part of the Company’s own staff, including, but not limited to investors, job applicants and suppliers (hereinafter referred as “Third parties”, “Third party”, “you” or “your”).  

Safeguarding your privacy is very important to us.  

This Privacy Statement (hereinafter referred as the “Statement”) aims to provide you with information on how we collect, store, use and disclose personal data relating to you as a natural person,  and this both, before, during and after your relationship with us. We are required to provide this information to you by the General Data Protection Regulation (hereinafter referred as “GDPR”). 

It is important that you take note of this information so that you know the purposes for which the Company uses your data. This Privacy Statement also contains more information about your privacy rights and how you can exercise them. 

In addition, the Company has adopted a series of policies in order to address other specific data privacy concerns, such as issues relating to the use of our website. These policies, which can be found here [Privacy Policy / Cookie Policy] also apply to you when you are using the tools referred to in those policies. 

The Company reserves the right to update this Privacy Statement from time to time and without any obligation to notify Third Parties.

2. Identity of the data controller

The Company is a ‘data controller’ as defined in the GDPR. The Company is responsible for deciding what personal data it collects, stores, and how your personal data are processed. As a data controller, the company is responsible for ensuring that processing is done lawfully, transparently and securely.

3. What categories of personal data we process and for which purpose

To the extent necessary for our activities, we collect and use the following categories of personal data relating to you in the context of your relationship (personal and/or business) with the Company. This means personal data of you as an investor, a prospect, a supplier, a job applicant or in some other capacity.

Please find herewith an overview of the type of personal data we collect, as well as for what purposes:

4. Legal grounds for processing your personal data

For each purpose, only the data relevant to the pursuit of the specific purpose are processed.

Your personal data may be processed on the basis of at least one of the following legal grounds, depending on the category of personal data and the purposes of the processing:

• most of the time, it is processed to ensure the proper performance of our (potential) contract with you as a party
• the Company could also process your personal data in order to ensure compliance with its legal and regulatory obligations (e.g. where it is legally obliged to process and retain certain data for tax, anti-money laundering legislation and the financing of terrorism, fraud prevention, preventing and detecting market manipulation and insider trading)
• in other cases, we process your personal data where the processing is strictly necessary for legitimate interest(s) of the Company or third parties to whom the Company transfers your personal data. In performing processing activity based on these legitimate interest(s), the Company will ensure that there is a proper balance between its legitimate interests and your legitimate interests and fundamental rights and freedoms.The Company’s legitimate interests include, without limitation, the following:
  • for the processing of contact data within the framework of communication if you are a business relation of the Company;
  • protecting the Company and/or its staff from harm, by preventing or detecting illegal activities, suspected fraud or situations involving potential threats to the safety of any person or violations of the Company’s policies or terms;
  • enabling the Company to exercise and defend legal claims;
  • enabling the Company to collaborate with other organisations, for example in a joint venture or strategic alliance;
  • protecting tangible and intangible assets of the Company, its suppliers, customers and other business partners.
• in some cases, processing of your personal data can also be based on your free and explicit consent, to the extent it is required or permitted by applicable data protection laws and regulations.

5. How we obtain your personal data

As a general rule, the Company processes personal data that we receive directly from you (including in paper or electronic format), and through a variety of communications, including but not limited to:

• Agreements entered into by us;
• Subscription forms;
• Questionnaires filled in by you;
• Emails, letters you send to us.

In some cases, processing of your personal data can also be based on your free and explicit consent, to the extent it is required or permitted by applicable data protection laws and regulations. We will seek your consent for the preparation and distribution of newsletters, targeted images (photo, video) within a private circle, publications on the Internet.

The Company may also receive and/or collect your personal data indirectly from other sources through:

• External service providers;
• Recruitment agencies;
• External public sources such as the Belgian Official Gazette, the Crossroads Bank for Enterprises, Linkedin, websites.

6. Who we share personal data with – who has access

For the purposes described in this Statement, your personal data may be shared with the Company’s Staff, professional advisers, third party agents and service providers (such as IT service providers, banks, financial institutions involved in the investment process, tools for Customer Relationship Management, email providers, file storage systems).

We do not sell your personal data to any third parties or otherwise share your personal data with third parties for marketing purposes.

To comply with financial regulations and legal obligations we can share your personal data with controlling authorities or regulators.

We can share your personal data with other organizations in the event of strategic collaboration purposes, or with a prospective buyer of any or all of the Company’s business or assets for the reasons described above.

When we share your personal data as described above, we will do so in accordance with applicable data protection laws and will, where necessary, put in place appropriate or suitable safeguards to protect your personal data.

7. International transfers

In principle the processing of your personal data is done in Belgium. However, some of your personal data may be transferred to countries other than the country in which that data was originally collected. Those countries may be outside the European Economic Area and may be countries which the European Commission has decided do not yet have an adequate level of data protection.

If we transfer your personal data to a country for which an equivalent GDPR level of protection does not apply, we will do so in accordance with applicable data protection laws and will, where necessary, put in place appropriate or suitable safeguards to protect your personal data.

8. How long we keep your personal data

We do not retain your personal data any longer than is necessary for the purposes for which they were collected, as set out in this Privacy Statement. In principle, your personal data will be kept during your cooperation agreement and for the agreed period following the end of the cooperation relationship.

In the event you withdraw your consent or you object to our use of your personal data (where applicable), we will remove your personal data from our database.

Your personal data may, however, be retained for longer than the specified retention period if this is necessary to comply with our legal, contractual or operational obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.

9. How we protect your personal data

We take all necessary measures to ensure proper security of your personal data taking into account the state or art, the costs of implementation and the nature, scope, context and purposes of processing. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk. We have appropriate policies and procedures, provide training in data protection, the importance of confidentiality and security of data.

10. Your rights in relation to your personal data and how to exercise them

According to the GDPR regulation, you have various rights in relation to the processing of the personal data we hold, this depending on the processing and the legal basis:

• you can request access to any personal data held about you by the Company and be provided information in relation to that data insofar as this does not infringe the rights and freedoms of others;
• have inaccurate personal data amended or rectified, and to have incomplete personal data completed;
• in some circumstances, you have the right to request the erasure of your personal data without undue delay (e.g. as soon as there is no longer a legitimate ground to process them);
• request that we restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes);
• Right to data portability: you can request to receive your personal data in a structured, commonly used format to transfer your personal data to another data controller;
• object to the processing of your personal data where we are processing on the basis of our legitimate interests;
• withdraw your consent at any time where your personal data is processed with your consent, and
• when you consider that our processing of your personal information infringes data protection laws you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.

To exercise any of your rights, please send us a written request to exercise your rights as set out above.

a) Via e-mail to the attention of our Data Protection Officer (email address: data.protection@mitiska-reim.com)

b) By letter at the following address: Alfons Gossetlaan 34/ bus 401, 1702 Dilbeek.

11. Status of this Privacy Statement

This Statement supersedes all previous versions, and the Company reserves the right to change this Statement at any time. Any change to this Statement will become effective when the Company notifies you of the revised Statement, whereby such notification may be limited to the posting on the Company website.

Contact details

If you have any questions about this Privacy Statement or the Company’s use of personal data, you can contact us at the following email address: data.protection@mitiska-reim.com or at Alfons Gossetlaan 34/ 401, 1702 Dilbeek.