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Privacy Policy

Last modifications: June 2018.

 

Overview 

 

This Privacy Policy is intended for any individual who may provide thg directly or indirectly with personal data. This document is intended to inform you generally about how your data is processed and protected by thg.

 

thg is fully conscious that your personal data belong to you and that it is essential to protect and process them only in accordance with the relevant regulations, in particular the European Data Protection Regulation 2016/679 (hereafter also referred to as the "GDPR"). 

 

We want to be as transparent as possible on this matter because we consider your privacy to be essential. This is in keeping with the founding spirit of our company, which is the recognition of the responsibility, both individual and collective, of our members. 

 

The purpose of this privacy policy is therefore to inform you, among other things, about:

 

  • The personal data that thg may collect about you; 
  • Why thg processes your personal data; 
  • The people thg may share your personal information with;
  • Retention periods;
  • Security measures implemented by thg;
  • Your rights relating to the processing of your personal data and the steps to be taken in order to exercise these rights. 

This privacy policy applies to each of the entities belonging to the thg group. Each entity is a separate and independent legal entity, so this Privacy Policy applies to each of them separately. Consequently, none of the entities is liable for the acts or omissions of the other entities.

 

The entities belonging to the thg group are: thg Bruxelles; thg Louvain-la-Neuve; thg Namur; thg Liège; thg Luxembourg; thg Eupen; thg Verviers; thg Malmedy; thg Marche-en-Famenne; thg St-Vith; thg Cofiges Namur; thg IP Solutions; thg Human Resources (Luxemburg); thg Human Resources (Belgien); thg Consulting; thg Patrimonia; thg German Desk; thg Support; thg Services; JPM & Partners.

 

When we refer to "our web site" in this policy, we mean web pages with a URL beginning with https://www.thg. 

  • For data collected via the website:

    thg Support SA
    61, Gruuss-Strooss
    9991 - Weiswampach (Luxembourg)

  • Data collected in the context of your professional relations with an entity of the thg group: 

    The entity with which you are in direct contact.

In the course of our activities, we collect or obtain personal data about you. We obtain this personal data either directly from you or from a third party (for example, your employer, your advisors, public authorities, etc.). In addition, some of your personal data is publicly accessible.

 

You will find below the data that we process, the reasons why we process them (the different purposes of processing) and finally the different legal bases that justify these data processing.


1. Purpose: customer and business management

What data?

Identification and contact data

Name ; First name ; Age ; Date of birth, Sex ; National register or social security affiliation number ; E-mail address ; Telephone or mobile phone number ; Home address ; Country of residence ; etc.

Family status

Marital status; Your dependants; etc.

Financial identification

Data Bank account number; Account details; Credit history; Credit references; etc.

Financial, patrimonial and fiscal information

Your sources of income; Your tax residence; etc.

Professional information

Your company; Title/Function; Department; etc.

Government and other official identification numbers

Social Security number Tax identification number or any other identification number issued by a government.


Who is concerned?

  • Our customers;
  • Our prospects (only identification and contact data);
  • Our customers' employees, if applicable.

Why?

  • Ensure effective communication with you and/or our customers: some of your personal data allows us simply to communicate with you. Please note that this correspondence data may, in compliance with the relevant legal provisions, be shared with other members of the thg network, with our service providers or with the competent public authorities;
  • Completion of our missions / provision of our services: some of your personal data are essential to the accomplishment of our various missions;
  • Keep you informed about our new services or other existing services: thg network members can use the data you provide to present services that match your profile and interests. If you are already a thg network customer, we may, unless you object, use your personal data to contact you for commercial purposes.
  • Management of our accounting and invoicing;
  • To respect our legal and ethical obligations: for example, as accountants, the law requires us to collect a whole series of information concerning you in order to fight money laundering and terrorist financing. Please note that a privacy policy regarding compliance with legal obligations in the fight against money laundering and terrorist financing is provided to each of our potential clients during the pre-contractual phase;
  • To respond to requests from the competent control authorities;
  • To ensure effective communication with our professional advisers, intervening where necessary on your behalf, such as lawyers, notaries and others.
  • To protect our rights and those of our clients in the event of litigation.

On what legal basis?

  • The processing of some of your personal data is necessary for the fulfilment of a contract concluded between you and an entity of the thg group or for the fulfilment of pre-contractual steps in order to offer you our services.
  • Legal, ethical or regulatory obligations impose it on us. For example, we are sometimes required by law or ethics to process your personal data in order to fulfill our obligations to "know your customer" and to combat money laundering and terrorist financing. Similarly, when the processing is necessary for the performance of our obligations under labour law or social security.

 

What data?


Cookies Management

All information about our cookies can be found in our cookie policy.

polyfills

Connection details (such as your IP address which can identify your approximate location and/or the name of your Internet service provider) ; The URL of the web page that made the request to the Service.

Plugins
(share button on social networks)

Our website hosts various links to social media services (example: LinkedIn, Facebook, etc.) that allow you to share content with other users. We inform you that your IP address is then transmitted to the social network in question. We have no control over the process used by social networks to collect information related to your browsing our site and associated with the personal data they hold. For more information about the purpose and scope of data processing by the social network, as well as your rights in this regard and to set options to protect your privacy, please see the privacy policy of the social network in question.

Logfiles

Date and time of visit; Name of page viewed ; Quantity of data viewed ; IP address ; Reference URL ; Browser type ; Browser version ; User's operating system ; Internet service provider ; etc.


Who is concerned?

All users of our website.

Why?

  • Adapt the content of our website, based on your usage habits;
  • To offer you a more personalized and simplified browsing experience, for example, when you visit our website, information about your visit to our site is recorded in so-called "logfiles", which are stored on the server. This data is used by us exclusively for statistical purposes to make our website more user-friendly. However, we reserve the right to investigate these logfiles further in the event of concrete suspicion of illegal use of our website.

In addition, we use Polyfill Service software. The program provides small sections of code, called "polyfills". They ensure that pages that are actually designed for modern browsers can also be used with older browsers. When you visit a website that uses Polyfill Service, your browser will download the Polyfills needed to successfully display the site. The company's privacy policy can be found here (https://polyfill.io/docs/privacy-policy).


On what legal basis?

  • Consent: in fact, we have set up an "active opt-in" system on our website. Thus, we obtain your consent prior to the deposit of cookies on your device. You can change your choice and preferences at any time. We also invite you to browse our cookie policy for more information on this subject (such as the type of cookies used and the lifetime of these cookies).
  • Our legitimate interest: certain cookies and other technologies are essential to the proper functioning of our Website. It is in our legitimate interest to use this type of cookies and other technologies in order to best manage the operation of our Website. Under no circumstances will the data collected for this purpose be processed for other incompatible purposes.
What data?

  • Email ;
  • Title ;
  • First and last name.

Who is concerned?

Any natural person who subscribes to our newsletter.

Why?

To send you our newsletter. Concerning our newsletter, it will only be sent to you if you have previously consented (opt-in active) and each correspondence will allow you to easily unsubscribe from it.

On what legal basis?

Your Consent: We are legally required to obtain your express consent. Therefore, we will only send you our newsletter if we have obtained your explicit consent beforehand. Moreover, if you no longer wish to receive our newsletter, simply click on the unsubscribe function in each of our communications. The data collected for this purpose will not be used for any other purpose in the future.
What data?

Identification and contact details

Name, first name, age, date of birth, gender, e-mail address, telephone number, mobile phone, place of residence, country of residence, photo,...

Family status

Marital status, household composition,...

Information about personal preferences Hobbies

personal interests, personal preferences, ...

Information relating to school and professional careers

Cover letter, CV, language skills, school career, professional career, copies of diplomas and certificates, references, evaluations,...

Information about the job for which you are applying

Job description.

Other data

Other data that you consider relevant and that you send us as part of the recruitment process


Who is concerned?

Anyone applying for a position at thg

Why?

  • The management of applications for a job at thg;
  • Proposing similar job offers from a thg network member company.

On what legal basis?

  • Your consent: every person applying for a position with thg will receive the relevant information, in due time, which will enable him/her to give informed consent to the processing of his/her data.
  • Our legitimate interest: the processing of some of your personal data allows us to manage your applications as well as possible. For example, checking your diplomas.

thg undertakes to keep your personal data only as long as necessary for the accomplishment of our mission / the time necessary to accomplish the purpose.

 

However, some of your personal data are kept for a longer period required by law and for the time necessary to process any litigation proceedings.

 

For example, our anti-money laundering and anti-terrorist financing obligations require us to retain certain of your personal information for at least five years after the end of our business relationship.

 

In addition, you will find all information about the lifespan of our cookies in our cookie policy.

 

Finally, we will also retain your personal data for the time necessary to assert our rights in the event of any litigation or investigation relating to our services.

For one or more of the purposes described in the section "What type(s) of data do we collect?  Why and on what legal basis(s)? " we may, always in your interest and subject to compliance with the relevant legal obligations, share your personal data with:

 

  • Our subcontractors;
  • The competent supervisory authorities;
  • Government authorities;
  • Courts and tribunals;
  • Your employer and/or their advisors.

In principle, thg will not share, transfer or otherwise distribute your personal data to third countries (outside the European Economic Area), unless required by the purpose of the contract, required by law or you expressly consent to such transfer.

 

In the event of a transfer to a third country, we will personally inform you of the appropriate protection measures taken to best protect your personal data.

We use a variety of technical and organizational measures necessary to protect your personal data to limit the risks of destruction, loss, alteration, unauthorized access or processing, including physical, electronic and managerial measures to ensure the security, accuracy and currency of your personal data. These measures include:

 

  • Awareness and training of our employees so that they are fully aware of our obligations to protect privacy when processing personal data.
  • Administrative and technical controls to restrict access to personal data on a need-to-know basis.
  • Technological security measures, including firewalls, encryption and antivirus software.

These security measures are periodically reviewed and adapted to ensure an adequate LAYER of protection.

You have a number of rights regarding the protection of your personal data. Indeed, subject to the scope of the relevant legal provisions, you have the right:

 

  • To obtain a list of the personal data we hold about you (right of access).
  • Request that we update the personal data we hold about you or that we correct personal data that you consider incorrect or incomplete (right of rectification).
  • Subject to the conditions contained in Article 17 of the DGPS, to request the deletion, as soon as possible, of personal data concerning you (right to be forgotten).
  • To request, subject to compliance with the legal provisions to which we are subject, that we delete the personal data we hold about you, or that we limit the way in which we use this personal data (right of limitation).
  • To withdraw your consent to the processing of your personal data, insofar as such processing is based on consent (right to withdraw consent).
  • To receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit them to a third party, insofar as the processing is based on your consent or on a contract (right to portability).
  • To oppose the processing of your personal data (right of opposition).
  • Except in certain specific cases, the right not to be the subject of a decision based exclusively on automated processing, including profiling, producing legal effects concerning you or significantly affecting you in a similar manner (automated individual decision, including profiling).
  • If you are not satisfied with the way we handle your personal data, you have the right to file a complaint with the supervisory authority of your jurisdiction. If you wish to be referred to the appropriate supervisory authority, please contact us as indicated below (right to file a complaint with the competent supervisory authority):

    • In Belgium, the competent supervisory authority is the Data Protection Authority (DPA);
    • In Luxembourg, it is the National Commission for Data Protection (CNPD);
    • In Germany, the competent supervisory authority is the Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BFDI).

If you wish to exercise any of your rights or file a complaint, please send us a written request, dated and signed, with a copy of your identity card to the following address This email address is being protected from spambots. You need JavaScript enabled to view it. and/or to the following physical address (Attention: thg IP / ICT Solutions):

 

Gruuss-Strooss, 61

L-9991 Weiswampach

Luxembourg

 

(Generally, you will receive a response within 30 days).

We may change or amend this Privacy Policy from time to time. In particular due to changes in legislation, the development of new services or changes in the way we process personal data.

To keep you informed of any changes to this Privacy Policy, we will change the revision date at the top of this page. The new modified or amended Privacy Policy will apply as of that date. Therefore, we encourage you to periodically review this Privacy Policy to be aware of any changes.

If you require any further information regarding thg's use of your personal data or would like a PDF version of this privacy policy, please contact thg's data protection department by sending an email to This email address is being protected from spambots. You need JavaScript enabled to view it.  or writing to the following physical address (to thg IP / ICT Solutions):

 

Gruuss-Strooss, 61

L-9991 Weiswampach

Luxembourg


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