Privacy policy
In our capacity as accountants, we are responsible for the processing of many data, some of which are personal data.
The personal data that we process may concern you as a client of the firm, but also as a business relationship of our clients (if you are a supplier or a client of our client, for example).
We are obliged to inform you, in your capacity as the data subject whose personal data we process, of the following.:
1. Responsible for processing personal data
The person responsible for the processing of personal data is Fidelium srl.
The head office of the responsible party is located in Etterbeek, Boulevard Saint- Michel n° 65 box 6 and its company number is 0465.950.881.
The manager is registered with the Institute for Tax Advisors and Accountants (I.T.A.A.) under the registration number 70266800. For any questions regarding the protection of personal data, please contact Fidelium srl, by post at the above address or by e-mail (info@fidelium.eu).
2. Purposes of the processing of personal data
The firm shall process personal data for the following purposes :
A. Application of the Act of 18 September 2017 on the prevention of money laundering and terrorist financing and on restrictions on the use of cash (hereinafter referred to as the Act of 18 September 2017).
1° Pursuant to Article 26 of the Law of 18 September 2017, our firm is required to collect the following personal data concerning our clients and their representatives: surname, first name, date of birth, place of birth and, as far as possible, address.
2° Pursuant to article 26 of the law of 18 September 2017, our firm is required to collect the following personal data concerning our clients' beneficial owners: surname, first name and, as far as possible, date of birth, place of birth and address.
The processing of this personal data is a legal obligation. Without this data, we cannot enter into a business relationship (article 33 of the law of 18 September 2017).
B. The obligations incumbent upon the firm vis-à-vis the Belgian authorities, foreign authorities or international institutions, in application of a legal or regulatory obligation, in application of a judicial decision or in the defense of a legitimate interest, in particular, but not exclusively, if current and future tax laws (VAT listings, tax forms, etc.) and social security laws oblige us to process personal data in the context of the mission for which we have been entrusted.
C. Performance of this contract for accounting, tax and management services.
The processing of personal data relates to data of the clients themselves, their staff members, directors, among others, as well as other persons, such as clients and suppliers, involved in their activities. Without the communication and processing of these data, we are not able to carry out our task as accountants.
3. What personal data and from whom?
For the purposes mentioned in point 2, our firm is authorized to process the following personal data: first name, surname, date and place of birth, e-mail address, biometric data (copy of electronic identity card or passport), address, telephone number(s), company number, national number.
The following data is also processed in the context of personal tax returns via Tax- on-Web: children, membership of a trade union or political organisation, medical data. The firm processes personal data which the data subject or his/her relatives have themselves provided.
The firm also processes personal data that have not been provided by the data subject, such as personal data transmitted by the client and concerning his employees, directors, clients, suppliers.
Personal data may also come from public sources such as the Crossroads Bank for Enterprises, the Belgian Official Journal and its appendices and the National Bank of Belgium (Central Balance Sheet Office).
The data shall only be processed if such processing is necessary for the purposes mentioned in point 2.
Personal data are not transmitted to third countries or international organizations.
4. Recipient of the data
In accordance with the foregoing, and unless it is necessary to disclose personal data to organisations or entities whose intervention as third party service providers on behalf and under the control of the person in charge is required for the aforementioned purposes, the Firm will not transmit the personal data collected in this context, nor will it sell, rent or exchange them with any organisation or entity, unless you have been informed in advance and have explicitly given your consent.
The firm uses third party service providers:
- the firm uses electronic accounting software and its portal ;
- the firm uses CRM software;
- the firm uses external collaborators for the execution of certain tasks or specific missions (chartered accountants, auditors, notaries, etc.) ;
- the firm can take all necessary measures to ensure proper management of the website and its IT system.
The firm may transmit personal data at the request of any legally competent authority or on its own initiative if it believes in good faith that the transmission of this information is necessary in order to comply with the law or regulations or to defend and/or protect the rights or property of the firm, its clients, its Internet site and/or yourself.
5. Security measures
In order to prevent, as far as possible, any unauthorised access to personal data collected in this context, the firm has developed security and organisational procedures. These procedures concern both the collection and storage of such data. These procedures also apply to all subcontractors used by the firm.
6. Retention period
6.1. Personal data that we must keep in accordance with the law of 18 September 2017 (see point 2A) This includes identification data and copies of evidence concerning our clients, internal and external agents and the beneficial owners of our clients.
In accordance with articles 60 and 62 of the law of 18 September 2017, these personal data are kept for a maximum of ten years after the end of the professional relationship with the client or from the date of an occasional transaction.
6.2. Other data of a personal nature. The personal data of persons not referred to above are only kept for the periods provided for by the implementing legislation, such as accounting, tax and social legislation.
6.3. Once the abovementioned periods have expired, personal data shall be erased unless other legislation in force provides for a longer storage period.
7. Rights of access, rectification, right of oblivion, data portability, objection, non-profiling and notification of security breaches
7.1. Personal data that we must keep in accordance with the law of 18 September 2017 This includes the personal data of our clients, mandataries and beneficial owners of clients. In this respect, we must draw your attention to article 65 of the law of 18 September 2017: "Article 65.
The person concerned by the processing of personal data pursuant to this law does not have the right to access and rectify his or her data, nor does he or she have the right to oblivion, the right to portability of said data, or to object, nor does he or she have the right not to be profiled or to be notified of security breaches.
The data subject's right of access to personal data concerning him or her is exercised indirectly, pursuant to Article 13 of the aforementioned Act of 8 December 1992, at the Commission for the Protection of Privacy established by Article 23 of the said Act.
The Commission for the Protection of Privacy only informs the applicant that the necessary checks have been carried out and the result with regard to the lawfulness of the processing in question.
Such data may be communicated to the applicant when the Commission for the Protection of Privacy, in agreement with CTIF and after having obtained the opinion of the controller, establishes that the communication of such data is not likely to reveal the existence of a suspicious transaction report as referred to in Articles 47 and 54, of the follow-up given to it or of the exercise by CTIF of its right to request additional information pursuant to Article 81, nor to call into question the purpose of the fight against the BC/FT, and, on the other hand, that the data concerned are related to the applicant and held by the reporting entities, CTIF or the supervisory authorities for the purposes of the application of this Law.
For the application of your rights relating to your personal data, you should therefore contact the CVP or the Data Protection Authority (see point 8).
7.2. All other personal data
For the application of your rights relating to all other personal data, you can always contact the firm by post at the address below or by e-mail (info@fidelium.eu).
8. Complaints
You can lodge a complaint regarding the processing of personal data by our firm with the Data Protection Authority:
Commission for the Protection of Privacy
Rue de la Presse 35, 1000 Brussels
Phone: +32 (0)2 274 48 00
Fax: +32 (0)2 274 48 35
E-mail: commission@privacycommission.be
URL: https://www.privacycommission.be
