Privacy Policy
This Privacy Policy governs the processing of your personal data by the Spadel Group as part of your visit to our website https://thesourceventures.com (hereinafter the “Website”), your communication with us via e-mail, telephone, fax.
If you want information on how we process personal data via cookies, please see our Cookie Policy.
1/ In General
- Your personal data are processed by Spadel NV/SA, Gemeenschappenlaan 110, 1200 Sint-Lambrechts-Woluwe, with company number 0405.844.436, RPR/RPM Brussels, and its affiliate companies of the Spadel Group (hereinafter “Spadel”, “we”, “us”, “our”). You can contact us via e-mail at privacy@spadel.com.
- Any reference in this Privacy Policy to certain laws or regulations also includes any change, replacement or annulment of these laws or regulations, including any related executive decisions.
- We reserve the right to from time to time modify this Privacy Policy at our own discretion. Such modification will be communicated via the Website.
2/ Types of personal data we process
- When you contact us via e-mail, telephone, fax or social media, we might collect:
- The basic identity information that you provide us with (name, e-mail address, postal address, telephone number, country, etc.);
- The content of your communication or enquiry and the technical details of the communication itself (with whom at Spadel you correspond, date, time, etc.);
- Your preferences with regard to the communication medium used;
- Publicly available information of your profile on social media channels;
- Any other personal data you choose to provide to us.
- We receive all personal data mentioned above directly from you. It may happen that we receive additional information about your preferences and surfing behaviour from partners such as Google. If you require more information about the personal data these parties process about you and make available to others, you are kindly requested to consult their respective privacy policies.
- Whenever you visit or use our Website, we collect:
- Technical information associated with the device you use, such as your browser type, geographical location and operating system;
- Anonymized information concerning your browsing behaviour, such as how long you visit, which links you click on, which pages you visit and how many times you visit a page of the Website.
3/ Purpose and legal basis for processing your personal data
Purpose | Processed data | Legal Basis |
---|---|---|
To provide the information, products, and services you request via the website, email, telephone, social media, or fax in a personalized and effective manner. | Question as formulated, channel used, contact details | Spadel’s legitimate interest in responding to requests for information addressed to it |
To comply with our legal obligations | All personal data we hold about you, including your identity, contact details, and history of your interactions with Spadel. | Legal obligation |
To comply with all reasonable requests from competent law enforcement agencies or representatives, judicial authorities, government agencies or entities, including competent data protection authorities To disclose your personal data to the police or judicial authorities on our own initiative as evidence or if there are reasonable grounds to suspect that you have committed an unlawful act or crime while using or registering on the website or communicating with us in any other way. | All your personal data that we have, including your identity, contact details, and history of your interactions with Spadel | Spadel’s legitimate interest in cooperating with the competent authorities and preventing and remedying criminal offenses |
To protect our legitimate interests or those of our partners or third parties if your use of or registration on the website or other communication channels can be considered: a) a violation of the applicable terms of use of the websites or the intellectual property rights or any other rights of a third party b) a danger or threat to the security or integrity of our websites or other communication channels or any of the underlying IT systems of us or our affiliated companies or subcontractors due to viruses, Trojan horses, spyware, malware, or any other form of malicious code, or c) in any other way hateful, obscene, discriminatory, racist, defamatory, hateful, offensive, or otherwise inappropriate or illegal. | All your personal data that we have, including your identity, contact details, and history of your interactions with Spadel. | Spadel’s legitimate interest in preventing and remedying such behavior |
To perform statistical analyses so that we can improve our website, advertising, products, and services, or to develop new products and services. | Anonymized or pseudonymized usage statistics | Consent in the framework of our cookie banner and cookie policy |
4/ Who are we sending your data to?
- We rely on external service providers to operate our website and process your personal data.
In particular, your data may be shared with the following external service providers, who act as our processors:- Processors who assist us with our IT infrastructure (e.g., for the maintenance of our website, the storage of our data, email distribution, etc.).
These third-party processors may only process your personal data on our behalf and in accordance with our express written instructions. We guarantee that these third-party processors have been carefully selected and are committed to ensuring the security and integrity of your personal data.
- Processors who assist us with our IT infrastructure (e.g., for the maintenance of our website, the storage of our data, email distribution, etc.).
- We may share your personal data with other entities within the Spadel group of companies. However, we ensure that all companies in the group will ensure that any processing of your personal data complies with the provisions of this Privacy Policy.
- Your data may also be transferred to government agencies, courts, or practitioners of regulated professions (such as accountants and lawyers) if this is necessary to comply with our legal obligations or our legitimate interests.
- Without your consent, we will not transfer your personal data in an identifiable manner to third parties other than those mentioned in this Article 4.
5/ Location and transfer
- We process your personal data within the European Economic Area (EEA). However, in order to process your personal data for the purposes outlined in Article 3 above, we may also transfer your personal data to other entities of the Spadel Group or to third parties which process on our behalf outside the EEA. Each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data. Such safeguards will be the consequence of:
- The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
- A contractual arrangement between us and that entity.
- We may transfer anonymized and/or aggregated data to organizations outside the EEA. If such transfer takes place, we will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data that you enjoy under applicable mandatory law.
6/ Quality Assurance
- We do our utmost best to process only those personal data which are necessary to achieve the purposes mentioned in Article 3 above.
- Your personal data are only processed for as long as needed to achieve the purposes mentioned in Article 3 above or up until such time where you withdraw your consent for processing them. Your withdrawal of consent may imply that you can no longer use the whole or part of our Website. We will de-identify your personal data when these data are no longer necessary for the purposes mentioned in Article 3 above, unless there is:
- An overriding interest of Spadel or any third party in keeping the personal data identifiable;
- A legal or regulatory obligation or a judicial or administrative order that prevents us from de-identifying them.
- We will take appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss tampering or destruction. Access by our personnel or of our third-party processors will only occur on a need-to-know basis and be subject to confidentiality obligations. You acknowledge, however, that safety and security are best-efforts obligations which can never be guaranteed.
7/ Your rights
- You have the right to request access to all personal data pertaining to you that we process. We reserve the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us. Each request has to specify for which processing activity you wish to exercise your right of access and which data categories you wish to gain access to.
- You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If you submit a request for correction, your request has to be accompanied of proof by the flawed nature of the data for which correction is asked.
- You have the right to withdraw your earlier given consent for the processing of your personal data.
- You have the right to request that personal data pertaining to you be deleted if these data are no longer required in the light of the purposes outlined in Article 3 above or if you withdraw your consent for processing the data. However, we will evaluate a request for deletion against:
- Overriding interests of Spadel or any third party;
- Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
Instead of deletion you can also ask that we limit the processing of your personal data if (a) you contest the accuracy of the data, (b) the processing is illegitimate, or (c) the data are no longer needed for the purposes mentioned in Article 3 above.
- You have the right to oppose to the processing of personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. If the intended processing qualifies as direct marketing, you have the right to oppose to such processing free of charge and without justification.
- You have the right to receive from us in a structured, commonly-used and machine-readable format all personal data which you have provided to us.
- If you wish to submit a request to exercise one or more of the rights mentioned above, you can send an e-mail to privacy@spadel.com. An e-mail requesting to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request has to clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form on the Website, we may ask you for your signed confirmation and proof of identity.
We will promptly inform you of having received this request. If the request proves valid, we will honour it as soon as reasonably possible and at the latest within thirty (30) days after having received the request.
If you have any complaint regarding our processing of your personal data, please feel free to contact us via e-mail at privacy@spadel.com. - You have the right to file a complaint about the processing of your data with the Belgian Data Protection Authority at the following address:
Gegevensbeschermingsautoriteit
Drukpersstraat 35
1000 Brussel
E: contact@apd-gba.be
T: +32 (0)2 274 48 00
+32 (0)2 274 48 35