Privacy Policy

1. Introduction

This policy aims to inform you about the type of data we collect, the reasons for this collection, how we use it, and how we share it. It also explains your rights in relation to your personal data, including how to contact us and make a complaint.

2. Data Controller

Proboss SA (“we”) is responsible for processing your personal data. Proboss is a Belgian public limited company with its registered office at 1050 Brussels, Chaussée de Waterloo, 412F. Proboss is registered with the Crossroads Bank for Enterprises under the number 0847.388.436.

For any questions regarding this policy or the exercise of your rights concerning your personal data, please contact us by mail at the address above or by email at the following address: info@proboss.be.

3. Processing of Your Personal Data

Proboss processes the personal data of its clients, employees or other independent collaborators of its clients, or other contacts of its clients whose personal data have been communicated to Proboss by its clients for the following purposes:

• to implement a stock option plan you have commissioned us for and to exchange information with you and answer your inquiries (via mail, e-mail, telephone, etc.) in the context of the service;
• to meet the legal obligations incumbent upon us;
• to keep our database updated, use the information you provided to better know you, understand you, and enhance our service offerings and mailings;
• for invoicing, administrative, and other purposes.

4. Legal Basis for Processing Your Personal Data

If you are our client, the processing of your personal data by us is necessary for the execution of the contract between you and Proboss, regarding the service provided by Proboss to you.

Proboss also processes your personal data in compliance with the legal obligations imposed on it.

If you are an employee or an independent collaborator of our client and our client has designated you as a contact, we process your personal data based on our legitimate interest and our client’s legitimate interest to interact with you.

If you are a contact of our client and they have provided your personal data to us because you are an expert, accountant, or collaborate with our client in some capacity, we also process your data based on our legitimate interest and our client’s legitimate interest to manage our client’s file effectively.

We believe that our legitimate interest and our client’s legitimate interest to process said personal data does not override your interests, freedoms, or fundamental rights. If you do not wish your personal data to be processed for the purposes described above, you can contact us by email at info@proboss.be to exercise your right to object.

5. Types of Personal Data Collected

We process the following personal data:

• name, surname, title, position, company, business address, legal form, email address, phone/mobile number, and fax number,
• VAT number, bank account number, company number,
• preferred language, areas of interest, memberships, business sector, etc.,
• information gathered in the context of files: such information may include personal data of other individuals. We do not process these data in a separate database. These personal data are processed as part of the files in our document management system.

Not providing some of your personal data may be a legal requirement and/or a prerequisite to enter into a contract with Proboss. Failure to provide these data may result in not entering into the contract with Proboss or Proboss being unable to deliver its service.

6. Personal Data Sharing

As a general rule, we do not share your personal data with third parties.

However, in certain instances, we may:

1. When mandated by law or a court order,
2. When deemed necessary or useful, with processors acting on our behalf to undertake certain data processing tasks; under these circumstances, we enter into a processing agreement with these third parties that might have access to your personal data in the course of their services,
3. For internal organization purposes to fulfill the legal mandate you entrusted us with.

7. Retention Period of Your Personal Data

7.1. Processing of Personal Data for the Purpose of the Mandate You Entrusted to Proboss

We process your personal data for as long as it’s necessary to fulfill the mandate you entrusted to Proboss.

Once our contractual commitment ends, we retain these personal data for as long as required for accounting, tax, or other legal mandates.

8. Your Rights

You have several rights concerning the protection of your privacy, including the following:

• Right of Access: You have the right to ascertain the type of personal data we hold about you, our processing purposes, and to receive a copy of your data.
• Right to Rectification: You can request the rectification of inaccurate personal data concerning you.
• Right to Erasure: Under specific circumstances, you can demand the deletion of the personal data we hold about you.
• Right to Restriction of Processing: In certain scenarios, you can request us to cease the use of your personal data, such as if you believe the data we have is incorrect or if you think our use of your data is illicit. Should you validly exercise this right, we will retain your personal data but stop processing it until the matter is resolved.
• Right to Object: Whenever we process your personal data based on our legitimate interests, you can object to this processing.
• Right to Data Portability: You have the right to obtain personal data you provided to us in a structured, commonly-used, and machine-readable format. You also have the right to request the direct transmission of this data to another data controller, provided this is technically feasible.

To exercise your privacy rights, you can contact us at the following email: info@proboss.be.

We may require proof of your identity for security reasons to prevent unauthorized access and misuse of personal data.

Proboss will handle your request within a maximum period of one month.

9. Complaints

For any questions, remarks, or complaints related to this policy or how Proboss processes your personal data, please email info@proboss.be.

You can also lodge a complaint regarding Proboss’s handling of your personal data with the Belgian Data Protection Authority.

10. Amendments

Proboss reserves the right to modify this policy to align with applicable privacy legislations. We may revise this policy at any given time. You can always find the most recent version of this policy on our website.