Why a charter on the protection of your personal data?
The company Anglo Belge Special Risks (hereinafter ‘ABSR’ or ‘we’) considers your privacy to be a priority. So we undertake to treat the personal data of our customers, potential customers and online users (hereinafter ‘you’) with the greatest care and to provide the best possible protection for such data in accordance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter ‘GDPR’) and the law.
This charter provides information about:
– the personal data that we collect about you and why we do so;
– the terms of use of your personal data;
– your rights as regards your personal data and the ways in which you can exercise them.
Most recently modified on: 20.04.2020
1. Who is responsible for the use of your data in the context of your relationship with our services?
The Controller for your personal data is the company ABSR, with its registered office at 2600 Berchem, Uitbreidingstraat 66, listed in the KBO/CBE (central business database) under No 0465.963.650. Any question or request concerning the processing of your data can be sent to the following e-mail address: info@anglobelge.com.
2. Why do we collect your personal data and on what bases?
We collect personal data about you for various reasons.
ABSR collects and uses your personal data to be able to work efficiently and offer you the best possible experience with its services.
Moreover, you should know that we can only collect and use your personal data if this use is based on one of the legal grounds defined by the GDPR (e.g. your consent or the performance of a contract concluded with you).
3. What data do we collect about you?
Below we give details of the personal data that we collect about you, the reason why they are collected, the way in which they are collected (data provided directly by you, ) information collected with your consent or data collected by our IT systems).
Purpose of the collection | Personal data collected | Direct or indirect collection of your personal data |
(1) Potential Customer Relationship Management | Personal identification data (surname, first name, postal address, e-mail address, telephone number, language)Security information (electronical, mechanical and physical protection)Insurance information | As part of this purpose, the data are collected directly from you or indirectly via a third party to whom you have given consent to pass on your data to ABSR. |
(2) Customer Relationship Management | Personal identification data (surname, first name, postal address, e-mail address, telephone number, language)Financial information (account number, payment method, other payment information)Security information (electronical, mechanical and physical protection)Insurance information | In the context of this purpose, the data are collected directly from you. |
(3) Marketing | Personal identification data (surname, first name, postal address, e-mail address, telephone number) Electronic identification data (IP address, cookies, connection log) | As part of this purpose, the data are collected directly from you or indirectly via a third party to whom you have given consent to pass on your data to ABSR. |
4. With whom do we share your personal data?
In the context of our activities, we may share your personal data. It goes without saying that should this be the case, we will ensure optimal protection of your personal data.
4.1. Sharing your personal data with our service providers, partners and/or subcontractors
Our service providers, partners and/or subcontractors can access your personal data for the processing operations they perform. Below you will find the list of subcontractors with whom we share your data, their location and the reason why we share the information in question with them.
Service providers, partners and/or subcontractors that are involved in the sharing of your personal data | Location of service providers, partners and/or subcontractors | Reason for sharing your personal data |
Verassnet | Belgium | ERP maintenance |
EASI | Belgium | Infrastructure and system maintenance |
Accel | Belgium | Hardware maintenance |
Several London Placing Brokers | UK | Placing brokers |
Several European Insurance companies | Europe | Insurance companies |
The Lloyds of London and Brussels | UK & Europe | Insurance companies |
4.2. With government bodies, in response to legal requests, including requests, including requirements regarding national security or the application of Law.
4.3. In the context of a transaction, such as a merger, a takeover, a consolidation, or a sale of assets, it may be that we have to share your personal data with buyers or sellers.
4 bis Do we capitalise on your personal data?
We do not share your data with commercial partners who may want to offer you products or services.
5. How long do we keep your personal data?
ABSR has laid down precise rules on the storage period for your personal data. This period varies depending on the respective objectives and has to take account of any legal obligations to keep some of your data.
Reason for the collection | Categories of personal data collected | Storage period |
(1) Potential Customer Relationship Management | Personal identification data (surname, first name, postal address, e-mail address, telephone number, language)Security information (electronical, mechanical and physical protection)Insurance information | The expiry date is three years from the last action / reaction of the data subject. |
(2) Customer Relationship Management | Personal identification data (surname, first name, postal address, e-mail address, telephone number, language)Financial information (account number, payment method, other payment information)Security information (electronical, mechanical and physical protection)Insurance information | The expiry date is ten years after the end of the contract. |
(3) Marketing | • Personal identification data (surname, first name, postal address, e-mail address, telephone number) • Electronic identification data (IP address, cookies, connection log) | The expiry date is three years from the last action / reaction of the data subject. |
6. What rights do you have as regard your personal data and how can you exercise these rights?
We aim to inform you as clearly as we can about your rights with regard to your personal data. And we aim to ensure that you can easily exercise these rights.
Please find below a summary of your rights and a description of the way in which you can exercise them.
• Right of access
You can ask us to grant you access to all the following information with regard to:
• the categories of personal data that we collect about you;
• the reasons why we use these data;
• the categories of people with whom we share or will share your personal data and in particular those who are located outside Europe;
• the periods for which your personal data will be kept in our systems;
• your right to ask us to correct or delete your personal data or to limit the use that we make of your personal data and your right to object to this use;
• your right to lodge a complaint with a European data protection body;
• information about the source, when we have not collected your personal data directly from you;
• the way in which your personal data are protected when they are transferred to countries outside Europe.
How can you exercise your right to access?
For this, you simply have to contact us by e-mail at info@anglobelge.com, indicating “right to access: personal data” in the subject line and attaching a copy of your identity card and a brief description of the data you wish to access. Unless you indicate otherwise, you will receive the requested data free of charge in an electronic format within one month of receipt of the request and within two months if in-depth research has to be carried out to meet the request.
If you are unable to consult your data by e-mail, you can also send us your request by post to the address below:
Uitbreidingstraat 66, 2600 Berchem
Written requests must be signed and accompanied by a copy of your identity card. The request must specify the address to which the reply must be sent. In that case, a reply will be sent to you within one month.
• Right of correction
You can ask ABSR to correct and/or update your personal data.
How can you exercise your right to have data corrected?
For this, you simply have to send an e-mail to info@anglobelge.com giving your surname and first name, indicating “right to correction: personal data” in the subject line and attaching a copy of your identity card.
Do not forget to give the reason for your e-mail in the text itself: the correction of inaccurate data and the information to be corrected, with proof of the correct information if necessary, if you have this.
You can also exercise this right by sending a letter to the following address: Uitbreidingstraat 66, 2600 Berchem. Your written request must be signed and accompanied by a copy of your identity card. The request must specify the address to which the reply must be sent. In that case, a reply will be sent to you within one month of receipt of the request.
• The right to have data deleted
If you find yourself in one of the following situations, you can contact us at any time to ask us to delete the personal data that we process concerning you:
– Your personal data are no longer necessary for the reasons for which they were collected or processed in a different way;
– You have withdrawn the consent on which the processing of your personal data by ABSR is based;
– Because you believe, for a specific reason, that further processing would adversely affect your privacy and could cause excessive damage;
– You no longer wish to receive commercial offers from us;
– Your personal data are not processed in accordance with the GDPR and the Belgian law;
– Your personal data have to be deleted to fulfil a legal obligation laid down in the law of the European Union or the national law to which ABSR is subject;
– Your personal data were collected in the context of an offer from a website directed at children.
How can you exercise your right to have data deleted?
For this, you simply have to send an e-mail to info@anglobelge.com giving your surname and first name, indicating “right to have data deleted” in the subject line and attaching a copy of your identity card. Do not forget to give the reason for your e-mail in the text itself (e.g. the deletion of your data when you have withdrawn your consent (on which the processing is based)).
You can also exercise this right by sending a letter to the following address: Uitbreidingstraat 66, 2600 Berchem. Your written request must be signed and accompanied by a copy of your identity card. The request must specify the address to which the reply must be sent. In that case, a reply will be sent to you within one month.
However, we may be unable to respond to your request to exercise your right to be forgotten. It is important to remember that this right is not absolute. We have to ensure that this right is balanced against other important rights and values, such as freedom of expression, compliance with a legal requirement to which we are subject or important reasons of public interest.
• The right to be forgotten
Our website may contain personal data that concern you. If you do not wish these data to appear on the website, you can ask us to remove them if you are in one of the following situations:
– Your personal data are no longer necessary for the reasons for which they were collected or processed in a different way;
– You have withdrawn the consent on which the processing of your personal data by ABSR is based;
– Because you believe, for a specific reason, that further processing would adversely affect your privacy and could cause excessive damage;
– You no longer wish to receive commercial offers from us;
– Your personal data are not processed in accordance with the GDPR and the Belgian law;
– Your personal data have to be deleted to fulfil a legal obligation laid down in the law of the European Union or the national law to which ABSR is subject;
– Your personal data were collected in the context of an offer from a website directed at children.
Furthermore, we are also obliged to take reasonable measures to inform the other companies (data controllers) which process the personal data for which you have submitted the request to delete any reference or any copy.
How can you exercise your right to be forgotten?
To have certain information concerning you removed from our website, you simply have to send an e-mail to info@anglobelge.com, giving your surname and first name, indicating “right to be forgotten: personal data” in the subject line and attaching a copy of your identity card. Do not forget to give the reason for your request in the text of your e-mail, for example a brief explanation, and the precise address (URL) of the page in question.
You can also exercise this right by sending a letter to the following address: Uitbreidingstraat 66, 2600 Berchem. Your written request must be signed and accompanied by a copy of your identity card. The request must specify the address to which the reply must be sent. In that case, a reply will be sent to you within one month of receipt of the request.
However, we may be unable to respond to your request to exercise your right to be forgotten. It is important to remember that this right is not absolute. We have to ensure that this right is balanced against other important rights and values, such as freedom of expression, compliance with a legal requirement to which we are subject or important reasons of public interest.
• The right to object
• You can object to the use of your personal data for the following purposes: commercial requests, and more specifically advertisements.
• You have the right to object to our processing of your personal data because you believe, for a specific reason, that further processing would adversely affect your privacy and could cause excessive damage.
You cannot, under any circumstances, prevent us from processing your data:
– if the processing is necessary to conclude or fulfil your contract;
– if the processing is required by a law or legal provision. This is the case in particular when you move to a different commune;
– if the processing is necessary to be able to establish, exercise or assert your rights before the courts.
How can you exercise your right to object?
For this, you simply have to send an e-mail to info@anglobelge.com giving your surname and first name, indicating “right to object: personal data” in the subject line and attaching a copy of your identity card.
It is important to indicate the reasons for your request to object.
You can also exercise this right by sending a letter to the following address Uitbreidingstraat 66, 2600 Berchem. Your written request must be signed and accompanied by a copy of your identity card. The request must specify the address to which the reply must be sent.
ABSR has two months in which to respond to your request to object. If your request is insufficiently precise or does not contain all the elements to enable us to undertake the requested operations, we will ask you to supply us with the necessary information within this period.
However, we may not be able to respond to your request. In that case, we will of course reply to you as clearly as possible.
In addition, any e-mails or information letters that may be sent to you will include a link which you can click so that you no longer receive any promotional information from us.
• The right to the transferability of data
This right offers you the possibility of controlling your personal data more easily yourself and more specifically:
– retrieving your personal data processed by us for your personal use and for example storing them on a device or in a personal cloud;
– transferring your personal data from us to another company, either doing this yourself or having it done directly by us, on condition that such a transfer is ‘technically possible’.
This right relates to data provided actively and knowingly to create your online account (e.g. e-mail address, username, age), and data collected by ABSR.
Conversely, the personal data derived, calculated or put together from the information provided by you, such as the result of an assessment of your health, are excluded from the right of transferability of data because they were created by ABSR.
How can you exercise your right to the transferability of data?
For this, you simply have to send an e-mail to info@anglobelge.com, giving your surname and first name, indicating “right to the transferability of data: personal data” in the subject line and attaching a copy of your identity card. Do not forget to specify the respective files and the type of request (return of data and/or transfer to a new service provider) in your e-mail.
You can also exercise this right by sending a letter to the following address: Uitbreidingstraat 66, 2600 Berchem. Your written request must be signed and accompanied by a copy of your identity card. The request must specify the address to which the reply must be sent. In that case, a reply will be sent to you within one month.
However, you should know that ABSR has the right to refuse your request for the transferability of data. This right only applies to personal data that were collected on the basis of your consent or the performance of a contract concluded with you. (To find out more specifically about the personal data that may be the subject of the right to the transferability of data, click on the purposes and bases section). Moreover, this right may infringe the rights and freedoms of third parties, whose data may form part of the data which would be transferred further to the request for transferability.
• The right to limit processing
You have the right to ask us to limit your data, that is to say the marking (for example, a temporary move of your data to another processing system or a lock of your data making them inaccessible) of your personal registered data, in order to limit future processing.
You can call upon this right when:
• the accuracy of the data in question is disputed;
• your personal data is not processed in accordance with the GDPR and Belgian law;
• the data is no longer necessary to achieve the original purposes but cannot yet be removed for legal reasons (in particular for the ascertainment, the execution or defense of your rights in court);
• the decision regarding your request is in progress.
In case of processing limitations, your personal data will no longer be subject to any treatment without your prior consent, with the exception of their storage.
Your personal data may nevertheless still be processed for the purpose of ascertaining, exercising or defending legal rights, or for the protection of the rights of another legal or natural person, or for important reasons of public interest in the Union or the Member State.
In case of limitation of the treatment of some of your personal data, we will keep you informed about the timing when the measures will be lifted.
How to call upon your limitation right?
In order to do this, simply send us an email to info@anglobelge.com, indicating your last name, first name and subject “right to limitation: personal data” as well as a copy of your identity card.
Don’t forget to mention the reason why, in the body of your email.
You can also exercise this right by sending us your request by postal mail at the following address:
Uitbreidingstraat 66, 2600 Berchem, Belgium.
Your written request must be signed and accompanied by a copy of your identity card. The request must specify the address to which the answer must be sent. A response will be sent to you within 1 month after we received your postal mail.
7. Are your personal data transferred abroad?
Data transfer within Europe
Within the European Economic Area (hover over: 27 EU members states, Iceland, Norway, Liechtenstein) personal data will benefit from the same level of protection.
Data transfer outside Europe
We do not transfer any of your personal data to a location outside Europe. All our servers are located in the EEA.
8. Would you like to contact us about this Charter on the protection of your personal data and/or would you like to lodge a complaint with a data protection authority?
Do you have a question or a suggestion about this Charter on the protection of your personal data?
If so, do not hesitate to pass this on to us by contacting us here or sending a letter to:
Uitbreidingstraat 66, 2600 Berchem.
We will be pleased to read your message or letter and reply as soon as possible.
Do you think we do not protect your personal data sufficiently?
If you think ABSR does not process your personal data in accordance with the GDPR and the Belgian law, you have the right to lodge a complaint with:
– the data protection authority of the European country in which you are usually resident; or
– the data protection authority of the European country in which you work; or
– the data protection authority of the European country in which the infringement of the GDPR was committed.
Lodging a complaint with the Belgian data protection authority.
→ By letter:
Gegevensbeschermingsautoriteit
Drukpersstraat 35, 1000 Brussels
→ By e-mail: contact@apd-gba.be
Lodging a complaint with another European data protection authority.
Please consult the list here to lodge a complaint with another data protection authority.
9. How can you find out whether this Charter on the protection of your personal data has been modified?
This Charter on the protection of your personal data may be modified at any time, in particular to take account of any legal or statutory changes and the development of our services.
Any major changes that may be made will be announced via our website or by e-mail, as far as possible at least thirty days before they come into force.
When we publish modifications to this Charter, we will adapt the date of the “most recent update” at the top of the confidentiality policy and describe the modifications on the page entitled “History of the modifications”.
We advise you to consult this Charter regularly to find out how ABSR protects your personal data.