Privacy statement – personal data protection – AVG – GDPR
This privacy statement is part of our privacy tools and, in particular, of the application of the AVG (General Data Protection Regulation, GDPR). The protection of personal data is an integral part of our values, ethics and attitude. We are committed to ensure the best level of protection of your personal data in accordance with the European and Belgian regulations applicable in this field.
TCM Belgium pays great attention to the ethical aspect of its operations; both to its employees and customers, as well as to debtors. We are convinced that success can only be achieved through mutual respect and courteous communication.
1. Who is the processing controller?
The controller is:
TCM BELGIUM NV Industriepark 6 (Foodport), 3300 Tienen
Ondernemingsnummer: BE0 451 082 959
www.tcm.be; privacy@tcm.be
The controller is the entity that determines for what purpose and how your personal data will be used.
TCM Belgium processes data relating to its customers and suppliers, its employees and debtors.
TCM Belgium is a debt collection company. It offers creditors the opportunity to accelerate and optimize their cash flow by opting for amicable settlement. The amicable settlement consists of obtaining payments from debtors without going through legal proceedings.
In the context of the collection procedure, TCM’s role is that of a service provider that decides only on the means it uses and the purposes for which it handles the files it receives from its client. However, it always informs its client. It is the client (the creditor) who has determined the ultimate goal (debt collection) and who retains all control over his claim.
If you have any questions regarding the processing of your personal data, the exercise of your rights or any other questions regarding personal data, please contact our data protection officer by e-mail at the following address privacy@tcm.be.
2. Why does TCM process personal data?
2.1. PROCESSING AND PURPOSES RELATED TO COLLECTION ACTIVITY.
Collection management includes the following processing:
- Collection Management: Recording data on debtors and their receivables reported by customers, and performing collection.
- Printing and mailing of letters to debtors: communication of letters to a service provider responsible for printing, enveloping and mailing letters.
- Printing and mailing of letters to debtors: communication of letters to a service provider responsible for printing, enveloping and mailing letters.
- Sending the file to a lawyer in case the Client decides to file a lawsuit: giving a lawyer access to the debtor’s data and file (if the Client decides to file a lawsuit).
- Management of international files: Recording the data of debtors and their claims communicated by foreign customers (through TCM Group), and the procedure for debt collection. Communicating the data of foreign debtors and their receivables (through TCM Group) to collection companies abroad.
- Reporting to the client: Give the client a status of debtor recovery.
- Hosting of the CMS application: Hosting of the debt management application and its database, attached files and backups.
- Use of cookies by the CMS application:
Name: TS01e46ae7 Description: This cookie is issued by our firewall to verify that cookies sent from our server to your computer are not altered in a malicious manner, such as during a process of identity theft. Lifespan: 600 seconds Publisher: cmsonline.tcm.be Category: Functional - Generating statistics: querying the accounts receivable database for statistical and reporting purposes.
2.1.1. Legal basis
TCM Belgium processes debtors’ personal data based on its legitimate interest (GDPR article 6f), as it proceeds to collect the debt entrusted to it by its customer. As a creditor, TCM Belgium’s customer also has a legitimate interest in collecting its debt.
TCM Belgium ensures that the necessary safeguards are put in place to respect the balance of interests of the parties (the debtor, TCM, the creditor).
2.1.2. Categories of persons affected
The persons involved in these processing operations are debtors.
2.1.3. Categories of data
With respect to debtors, we deal with the following categories of data:
- Id.
- Details of their claims (contract)
- Data related to the payment(s)
- Letters and information exchanged with debtors TCM Belgium does not perform debtor profiling.
2.1.4. Origin of data
The creditor provides us with identification data, data relating to claims, as well as data relating to payments already made. If the debtor has not updated his contact data (such as a new postal address) with the creditor, as he is obliged to do, TCM Belgium requests this data from third parties authorized to communicate it (e.g.: Government agencies).
To proceed with collection, TCM Belgium generates new data regarding debtors thanks to TCM’s contacts with them.
TCM Belgium does not provide data to third parties outside the recipients listed below.
2.1.5. Data recipients.
To provide the service,
- Does TCM Belgium share the data with the creditor and other processors or subcontractors for the sole purpose of collecting the debt: assignees, collection agents, other service providers, courts, bailiffs, lawyers.
- Shares TCM Belgium data with its service provider for the development of the application and tools for the management of collections. Data processing takes place in the European Union.
- Does TCM Belgium use the services of an application and tools for hosting service providers. The data is stored in the European Union.
- TCM Belgium shares the data with Belgian or foreign collection companies or collection services according to the needs of debt management. The transfer of data outside the European Union takes place on the basis of standard data protection provisions if the country to which the data is transferred does not offer adequate protection within the meaning of the AVG.
2.1.6. Retention and duration
For the duration of storage, the data will be hosted in the European Union.
All data allowing the identification of the debtor will be kept for a maximum of ten years after the cancellation of the debt or the end of the mandate. This period corresponds to the limitation period under general law (article 2262bis of the Civil Code).
TCM Belgium has taken the organizational and technical measures internally and with respect to its subcontractors to ensure that no computer backups, files or emails containing information about debtors are more than 10 years old.
However, in light of the above paragraph, data subjects have the right to have their data erased if it is no longer necessary for the purposes for which it was collected, if it has been unlawfully processed, or to comply with a legal obligation.
There is limited access to archived data.
2.2. PROCESSING AND PURPOSES RELATED TO PERSONNEL RECRUITMENT MANAGEMENT
TCM Belgium performs the following data processing operations:
- Recruitment Management: Registration and processing of applications received: unsolicited applications, responses to applications
2.2.1. Legal basis
TCM Belgium processes the personal data of the company’s employees based on Article 6b of the GDPR, as the processing is necessary for pre-contractual measures taken at the request of TCM Belgium.
2.2.2. Categories of data subjects.
The data subjects of these processing operations are the candidates for recruitment.
2.2.3. Categories of data
With respect to candidates for recruitment, we process the following categories of data:
- Id.
- The curriculum vitae
- Notes related to job interviews
2.2.4. Origin of data
The data are provided by the data subjects.
2.2.5. Data recipients.
The data – beyond legal obligations – will not be provided to third parties.
2.2.6. Retention and duration
For recruitment management purposes, data will be kept for 1 year after the application. Data may be kept for 2 years for a recruitment reserve.
2.3. PROCESSES AND PURPOSES RELATED TO CUSTOMER AND SUPPLIER DATA.
TCM Belgium performs the following processing:
- Accounting and financial management: accounting and finance management: managing invoices and payments
- Beheer van leverancierscontacten: Beheer van alle leverancierscontacten.
- Management of supplier contacts: Management of all supplier contacts.
2.3.1. Legal basis
Personal data that are part of processing operations such as accounting are processed based on the respective legal obligations for these different processing operations.As for the data of our customers and suppliers, these are personal data for professional use, which are processed based on our legitimate interest (prospecting) or for the purposes of contracts.
2.3.2. Categories of data subjects.
Contact details of suppliers or customers
2.3.3. Categories of data
- Id.
- Invoices
- Payments
- E-mails
- Contact sheets
2.3.4. Origin of data
The data are provided by the stakeholders themselves, the debtors, the customer companies, the subcontractors.
2.3.5. Data recipients.
- Accounting Office
- IT service providers for support and maintenance
2.3.6. Conservation and duration
TCM Belgium retains the data for the legal deadlines and deletes it in accordance with its terms.
Regarding the data in the company’s files and emails, TCM Belgium has a policy of destroying this data after a maximum of 10 years.
2.4. PROCESSING AND PURPOSES RELATED TO COMMUNICATION AND MARKETING (INCLUDING COOKIES).
As part of the promotion of its activities, TCM Belgium carries out the following treatments:
- External communications, sending newsletters
- Use of cookies on the website:
A cookie is a small text file sent by the website’s server to your device’s hard drive. The cookie contains a unique code that allows your browser to recognize your browser during your visit or on a subsequent visit. The content of a cookie generally consists of the name of the server that placed the cookie, an expiration date and a unique code.
The use of cookies requires your prior and express consent. You can refuse and/or delete these cookies at any time by changing your browser settings. Nevertheless, some functions of the website will be modified as a result.
There are different types of cookies; some are used for session management, for personalization, for tracking, and there are third-party cookies. For more information, we recommend you consult the following article on Wikipedia: https://nl.wikipedia.org/wiki/Cookie_(internet).
The TCM Belgium website uses functional cookies that do not affect your personal data and cookies for analyzing visitor statistics. It also uses tracking cookies, including Google Tag Manager cookies generated by the statistical tool Google Analytics. They allow us to measure the number of visits, as well as the number of pages viewed, visitors’ activity on the site and their return frequency. By authorizing these third-party services, you accept the placement and reading of cookies and the use of tracking technologies necessary for their proper functioning.
Strictly necessary functional cookies Naam: o2s-chl Beschrijving: This cookie is used by the host to verify that it is not an automated bot access and contains only the text expected by the server. It has a shelf life of one year. Levensduur: Duur van uw sessie Uitgever: tcm.be Categorie: Functionele cookies (strikt noodzakelijk) Naam: axptio_cookies Beschrijving: Collects consent about cookies Levensduur: 1 jaar Uitgever: tcm.be Categorie: Functionele cookies (strikt noodzakelijk) Naam: wordpress_test_cookie Beschrijving: Used on sites built with WordPress. Test whether browser has cookies enabled or not Levensduur: Duur van uw sessie Uitgever: tcm.be Categorie: Functionele cookies (strikt noodzakelijk) Naam: axptio_authorized_vendors Beschrijving: Records users’ choice of cookies. Levensduur: 1 jaar Uitgever: tcm.be Categorie: Functionele cookies (strikt noodzakelijk) Performance Cookies Naam: _gat_UA-nnnnnnn-nn Beschrijving: This is a cookie set by Google Analytics where the name contains the unique identity number of the account or website to which it relates. It appears to be a variant of the _gat cookie used to limit the amount of data Google records on high-traffic websites. Levensduur: Aanhoudend Uitgever: tcm.be Categorie: Prestatiecookies Naam: _ga Beschrijving: This cookie name is associated with Google Universal Analytics – which is a major update to the more commonly used Google Analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a customer ID. It is recorded with every page request on a site and is used to calculate visitor, session and campaign data for site analytics reports. Levensduur: Duur van uw sessie Uitgever: tcm.be Categorie: Prestatiecookies Tracking cookies Naam: VISITOR_INFO1_LIVE Beschrijving: This cookie is used as a unique identifier to track video playback. Levensduur: aanhoudend Uitgever: youtube.com Categorie: Cookies for targeted advertising Naam: GPS Beschrijving: YouTube is a platform owned by Google for hosting and sharing videos. YouTube collects user data through videos embedded in Web sites, which is aggregated with profile data from other Google services to display targeted ads to Web visitors from their own wish site and other sites. Levensduur: Persistent Uitgever: youtube.com Categorie: Cookies for targeted advertising Naam: YSC Beschrijving: YouTube is a platform owned by Google for hosting and sharing videos. YouTube collects user data through videos embedded in Web sites, which is aggregated with profile data from other Google services to display targeted ads to Web visitors from their own wish site and other sites. Levensduur: Duur van uw sessie Uitgever: youtube.com Categorie: Cookies for targeted advertising Naam: NID Beschrijving: his domain is owned by Google Inc. Although Google is primarily known as a search engine, the company offers a wide range of products and services. Its main source of revenue, however, is advertising. Google tracks users closely, both through its own products and sites, and through the many technologies embedded in millions of Web sites around the world. It uses the data collected by most of these services to profile the interests of Internet users and sell advertising space to organizations based on these interest profiles, and to tailor ads to the content of the pages on which its customers’ Web sites appear. Levensduur: Persistent Uitgever: google.com Categorie: Cookies for targeted advertising Naam: test_cookie Beschrijving: This domain is owned by Doubleclick (Google). Its main commercial activity is:Doubleclick is a real-time ad exchange of Googles Levensduur: Aanhoudend Uitgever: Doubleclick.net Categorie: Cookies for targeted advertising Naam: IDE Beschrijving: This domain is owned by Doubleclick (Google). Its main commercial activity is:Doubleclick is a real-time ad exchange of Googles Levensduur: Aanhoudend Uitgever: Doubleclick.net Categorie: Cookies for targeted advertising Naam: _gid Beschrijving: The name of this cookie is associated with Google Universal Analytics. This appears to be a new cookie and as of spring 2017. No information is available from Google. It appears to store and update a unique value for each page visited
. Levensduur: Persistent Uitgever: Google.com-uitgever Categorie: Cookies for targeted advertising 2.4.1. Legal basis
TCM Belgium processes the personal data of its contacts for communication and marketing purposes based on consent.
2.4.2. Categories of persons affected
Website visitors, people who subscribe to the newsletter
2.4.3. Categories of data
- Email address
- Name and surname
- Cookies
- IP addresses
2.4.4. Origin of data
The data is provided by the individuals themselves.
2.4.5. Data recipients.
- TCM Belgium uses the services of a mailing service provider. This is a US-based provider. The transfer of data takes place based on the principles of Privacy Shield.
- TCM Belgium uses the services of Google Analytics for analytical cookies.
2.4.6. Storage and duration
We retain the data of affected individuals until they withdraw their consent or until we find that the data is out of date.
3. What are my rights regarding the use of personal data?
3.1. RIGHTS OF THE DATA SUBJECT
All data subjects have the right of access, correction and opposition.
In accordance with the General Data Protection Regulation in Europe (AVG – EU Regulation 2016/679), you have the right to access, update, correct and, if permitted by law, delete your data.
Anyone has the right to object to the processing of his or her data on legitimate grounds, unless the processing is carried out in compliance with a legal obligation.
TCM Belgium is at your disposal to study your requests with you; in particular, please contact us by e-mail at privacy@tcm.be. We will reply to you within the statutory period of one month.
3.2. RIGHT TO COMPLAIN TO THE SUPERVISORY AUTHORITY
In accordance with Article 77 of the AVG, you have the right to lodge a complaint with the supervisory authorities if there are reasonable grounds or indications that the processing is not carried out lawfully. The address of the supervisory authority responsible for our company is:
Data Protection Authority (GBA).
Drukpersstraat 35
1000 Brussel
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