Confidentiality declaration

PHCom attaches great importance to the protection of your privacy. That is why we strive to process your personal data in a lawful, fair and transparent manner.
This confidentiality declaration covers all personal data collected and processed by PHCom, whose registered office is located at Avenue Jules Bordet 13, 1140 Brussels, as well as by any company affiliated with PHCom or client of PHCom.

This confidentiality declaration sets out the information we collect about you, the purposes for which we use it and the parties to whom we pass it on. It also describes your rights and how you can exercise them.

1. Whose personal data do we collect?
PHCom processes the personal data of natural persons with whom we have, have had or wish to have a relationship in the future, directly or indirectly, in a business-to-business context.

This therefore concerns data relating to our clients, suppliers, principals and potential clients (prospects).

The data of past, current or potential employees (candidates) is also processed.

2. How and why do we collect personal data?
PHCom collects personal data through a phone call to your company (with your colleagues or yourself), through contacts made during networking activities or from lists received from our clients for business development purposes. We may also collect data you have made public on social media (e.g. LinkedIn) in order to initiate contact as part of our activities. With your consent, we use statistics cookies to measure the site's traffic (see the Cookies section below).

The personal data are:

• Last name, first name
• Gender, language
• Business address
• Business phone and mobile numbers
• Business email address
• Position held within the company and department

The way we process your personal data differs according to the intended purposes:

• Providing information about services that may interest your company
• Starting a business relationship with your company
• Prospecting, market research, phone qualification, invitation follow-up
• Training
• Direct marketing: sending mailings, newsletters, information about our activities or those of our clients and other topics that may interest you
• Recruitment
• Project and contract execution and management

Depending on the company and the product or service offered, the following data are also processed:

• Dates and content of the actions, calls and written exchanges (emails or letters)
• Training dates, topics covered and training satisfaction assessment
• Audio recordings for training purposes
• IP address of website visitors, mailing tracking

It is in our legitimate interest to process these data within the scope of our corporate purpose.

Other processing operations are also carried out:

• Financial administration
• PHCom processes personal data in order to keep its own accounts and invoicing. This concerns identification and invoicing data.

This processing is based, on the one hand, on PHCom's legitimate interest, in particular the ability to keep its administration and obtain payment for the services it provides. On the other hand, PHCom is legally required to keep accounts.

Maintaining relationships with clients and subcontractors
PHCom processes personal data to send mailings about products and services we believe may interest you.

Sending mailings to our clients falls within our legitimate interest. Both we and you have every interest in our clients being kept informed of our activities and new services.

Human resources management
PHCom processes personal data of its employees in order to manage them in accordance with legal requirements and to develop their careers and performance in a supportive way.

Recruitment purposes:
PHCom collects personal data in order to recruit new employees. This processing is based, on the one hand, on the consent given by the candidate and, on the other hand, on our legitimate interest in hiring the right candidate for a position.

3. With whom do we share your personal data?
Your information is never shared with third parties for commercial purposes. Each PHCom client is also the owner of the data collected as part of its assignment and is required to take the necessary measures under the GDPR.

3.1. Your personal data within PHCom
At PHCom, we handle your personal data with the utmost care and only share the information needed to offer you the best service.

PHCom has taken measures to ensure the protection of personal data exchanged or shared within PHCom.

3.2. Your personal data outside PHCom
We are sometimes legally obliged to share your personal data with external parties, in particular the following third parties:

• public authorities and regulators, where there is a legal obligation to communicate or disclose client data
• judicial authorities or investigative bodies, such as the police or the public prosecutor
• auditors of professional accreditation bodies

There are also third parties to whom we are not legally required to disclose personal data, but whom we use for the services we offer and who are therefore bound by non-disclosure obligations:
service providers who help us with: the design and maintenance of our internet tools and applications; the management of our servers; the completion of specific projects, debt collection...

We use social media applications on our website. Please note that any personal data you share with these social media applications may be read, collected and used by other users of these applications. PHCom has little or no control over these other users and therefore cannot guarantee that all social media applications comply with this confidentiality declaration.

4. How do we secure your personal data?
PHCom has developed various security measures (physical, administrative and technological) to ensure the security, accuracy and currency of your personal data. More specifically, we seek to prevent unauthorised access to these data and the unauthorised modification, disclosure or destruction of the personal data in our possession.

5. How long do we keep your personal data?
We do not keep your personal data longer than necessary to carry out our activities and provide our services, unless a legal obligation requires us to keep your personal data for a longer period or because the period during which legal action may be brought is still running.

In any event, client data will not be kept for more than 10 years after the end of our client relationship.

6. What are your rights?
You have several rights regarding the personal data we process:

• the right of access: you have the right to receive confirmation that we process personal data about you and to request, free of charge, a copy of the personal data we hold about you.
• the right to rectification: you have the right to ask us to update the personal data we hold about you or to correct or complete any inaccurate personal data about you.
• the right to erasure and restriction: you have the right to ask us to erase your personal data. In doing so, you acknowledge that, following a request to delete personal data, certain services may no longer be provided. You may also ask us to restrict the processing of your personal data.
• the right to object: you have the right to object to the use of your personal data at any time. You will, however, need to give reasons for this request. You may also expressly object to the processing of your personal data for direct marketing purposes without giving reasons ("unsubscribe" button in our mailings). PHCom respects the "Do Not Call Me" list.
• the right to data portability: you have the right to receive the personal data we process about you in a structured, commonly used and machine-readable format. You also have the right to have these data transferred to other controllers.
• the right to withdraw your consent: you have the right to withdraw your consent to the processing of your personal data at any time (where the processing is based on your consent).
• the right to lodge a complaint: you also have the right to lodge a complaint with the Data Protection Authority:

Data Protection Authority (DPA)
Rue de la Presse 35
1000 Brussels
Tel.: +32 2 274 48 00
contact@apd-gba.be

If you wish to exercise the rights described above, please contact privacy@phcom.be. Before acting on your request, we may ask you to provide proof of identity.

7. About this confidentiality declaration
Our confidentiality declaration may change from time to time. All changes will always be indicated on this page.

If you have any other questions about our privacy policy, please contact us at privacy@phcom.be.

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