This confidentiality policy (‘Policy’) describes the methods used by us,  Financière de Tubize, to collect, manage and use information on:

• our potential investors, our shareholders and their potential shareholders and ultimate beneficiaries (‘UBO’), and their representatives; 
• the representatives of the companies in which we have invested or consider investing in, the shareholders and UBOs of these legal entities, and our co-investors; 
• our suppliers, consultants and counterparties; and
• the visitors of our website. 

Personal data, either received directly from the data subject or collected from other sources, are processed in accordance with this Policy and with the applicable laws and regulations, including the General Data Protection Regulation 2016/679 (‘GDPR’).

For the purpose of the applicable laws and regulations relating to personal data protection, Financière de Tubize, with registered office in 1070 Brussel, Allée de la Recherche 60, with company number 0403.216.429, is the data controller. When used in this Policy, the words ‘you’ or ‘your’ refer to the above-mentioned data subjects.

This Policy may be amended, supplemented, rescinded or updated.  However, we will at all times process your personal data in accordance with the Policy in force at the moment on which the data are collected.  Our aim is to inform you regularly on this page of any changes to this Policy, so that you are always fully informed of the categories of data we collect, how we use them and the circumstances under which they may be communicated.

This Policy is not a contract we conclude with you, but a commitment we undertake with respect to the processing of the personal data and the exercise of your rights as a data subject.

We will process your personal data in accordance with the procedure described in this Policy.  The term ‘personal data’ is defined in article 4(1) of the GDPR.

Depending on the category of data subjects to which you belong, we can collect the following categories of personal data:

• identifying data: first name, surname, email address, date and place of birth, legal status, personal details, address, profession, copy of identity card or passport;
• administrative data: invoicing data, VAT number, salary, bank details;
• data  relating to cookies : for more information about cookies, we refer to our Cookie Policy, which can be consulted here;
• other relevant data;
  

• If you are a potential investor, one of our shareholders and their potential shareholders and UBOs, or their representative
  

  Data categories	Purpose	Legal basis	Data retention period
  Identifying data, administrative data	Analysis of our company’s shareholder base	Article 6, (1), f) GDPR: the processing is necessary for the purpose of our legitimate interests, except where such interests are overridden by your interests and fundamental rights and freedoms which require protection of personal data.	For this purpose your personal data will be retained for the duration of your relationship with us and for a period of 10 years after it ends.
  	Marketing activities (e.g. sending emails)/procurement relating to our portfolios
  	Preparation of shareholders’ meeting and payment of dividends, if any, to our shareholders	Article 6, (1), b) GDPR:  processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;

  We take your interests into account by only sending you communications that are likely to be of interest to you, by allowing you to easily unsubscribe/object to these communications at any time and by complying with all other laws and regulations applicable to the sending of these communications. For that purpose your personal data may be retained and processed as long as you do not unsubscribe/do not object to emails or other communications sent by us.  Your personal data will never be communicated to commercial partners for marketing communication purposes, nor to anyone else.

• If you are a representative of the companies in which we have invested or consider investing in, a shareholder or UBO of these legal entities, or one of our co-investors
  

  Data categories	Purpose	Legal basis	Data retention period
  Identifying data, administrative data	Communications (e.g. sending emails) and relationship management	Article 6, (1), b) GDPR:  processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;	For this purpose your personal data will be retained for the duration of your relationship with us and for a period of 10 years after it ends.
  	Verification of your identity
  	Transaction management
  	Keeping investment records	Article 6, (1), f) GDPR: the processing is necessary for the purpose of our legitimate interests, except where such interests are overridden by your interests and fundamental rights and freedoms which require protection of personal data.
  	Statistical analysis and market studies
  	Verification of the creditworthiness and stability of the companies in which we have invested or consider investing in
  	Organisation of meetings and events
  	Requests for advice from our consultants (e.g. accountants, lawyers or others)

• If you are one of our suppliers, consultants or other counterpart
  

  Data categories	Purpose	Legal basis	Data retention period
  Identifying data, administrative data	Communication with you and management of our relationship with you	Article 6, (1), b) GDPR:  processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;	For this purpose your personal data will be retained for the duration of your relationship with us and for a period of 10 years after it ends.
  	Invoicing

   

• If you are a visitor of our website
  

  If you visit our website, we may automatically collect certain information on your use of our website, using certain technologies described in our Cookie Policy, which can be consulted here.

  When visiting our website, you may decide to contact us by email or by phone.  In this case, we may collect and process any personal data you provide in order to respond to your request.

  Data categories	Legal basis	Data retention period
  Identifying data, other relevant data	Article 6, (1), a) GDPR: you have given your consent to the processing of your personal data for one or more specific purposes.	For this purpose your personal data will be retained for a period of 10 years after you contacted us, or longer depending on whether or not we enter into a contractual relationship with you.  This retention period relates to the personal data that are not yet covered by our Cookie Policy.

• To meet our legal and accounting obligations
  

  We may also use your personal data to meet our legal and accounting obligations and to comply with any request from a competent authority:

  Data categories	Legal basis	Data retention period
  Identifying data, administrative data	Article 6, (1), c) GDPR:  processing is necessary for compliance with a legal obligation to which we are subject	For this purpose your personal data will be retained for a period of 10 years after you contacted us, or longer depending on whether or not we enter into a contractual relationship with you.

• For our internal management
  

  We may use your personal data for the purpose of our internal management, e.g.:

  • Knowledge management (e.g. contracts, statistics) ;
  • Archives (e.g. records);
  • Rankings management ;
  • Organisation of contact lists.
    

    Data categories	Legal basis	Data retention period
    Identifying data, administrative data, data relating to cookies or other relevant data	Article 6, (1), f) GDPR: the processing is necessary for the purpose of our legitimate interests, except where such interests are overridden by your interests and fundamental rights and freedoms which require protection of personal data.	For this purpose your personal data will be retained for as long as they remain relevant for our internal management.

In principle, your personal data will never be sold or communicated to, nor shared with third parties.

However, in some cases we may communicate your data to certain third parties:

• to the technical manager of our website (savoirfaire.digital), who accepts to process the data in accordance with this Policy;
• to the competent public authorities;

We collect your personal data when:

• we contact (the representatives of) our existing or potential investors, our shareholders, their potential shareholders and UBOs, our suppliers, our consultants, our counterparties and our co-investors;
• we invest or consider investing in a company;
• you ask us to contact you;
• we have to meet our legal and accounting obligations. 

We do not transfer your personal data outside the European Economic Area.

Within the limits of articles 15 to 22 of the GDPR and other applicable laws and regulations, you have the following rights in relation to the personal data we process:

• the right of access to your personal data: you can at any time request access to the data we store;
• the right to rectification of your personal data: you can ask us to rectify incorrect data or to complete incomplete personal data, including by providing a supplementary statement;
• the right to erasure of your personal data: you can ask us to erase personal data the processing of which is no longer necessary;
• the right to have the processing of your personal data restricted: you can ask us to ‘freeze’ your personal data so as to restrict their processing in the future;
• the right to object: you can ask us to stop or prevent the processing of your personal data for reasons relating to your specific situation;
• the right to object to automated individual decision-making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects for you or which similarly significantly affects you;
• the right to data portability: you have the right to transmit the personal data we process in a user-friendly and secure manner from one IT environment to another.

If you want to exercise your rights or receive more information in this respect, please contact us by sending an email to the following address:  investorrelations@financiere-tubize.be.

When your data are processed on the basis of your explicit consent, you have the right to withdraw your consent at any time.  However, this withdrawal will not affect the lawfulness of the processing based on the consent given before the withdrawal.  When your data are processed on the basis of our legitimate interest, you can object to this processing within the limits of article 21 of the GDPR.

In any case, you also have the right to file a complaint with the Belgian Data Protection Authority (https://www.dataprotectionauthority.be):

• either by email: contact@apd-gba.be;
• or by post at the address: rue de la Presse 35 1000 Brussel, Belgium.
  

The procedure to be followed can be consulted here.

To ensure the security and confidentiality of the personal data we collect online, we use networks protected by standard devices such as firewalls and passwords.  When processing your personal data, we take all reasonable measures to protect them against loss, misuse, unauthorised access, disclosure, alteration or destruction.

Most of the services available via this website are aimed at people aged 18 or more. We will not knowingly collect, use and disclose personal data provided by minors under the age of 18 without having obtained the prior consent of their legal representative (parent or guardian) via direct offline contact.  We will inform this representative of the specific categories of personal data collected from the minor and of the possibility to object to the collection, use or retention of this information.  We scrupulously observe all child protection laws.

The data protection Policy only applies to this website, not to websites hosted by third parties.  We sometimes provide links to other websites that we think may be of interest to our visitors.  In those cases we can assure you that these websites meet the highest standards.  However, due to the very nature of the Internet, we cannot provide guarantees as to the rules of confidentiality and protection of personal data of websites to which we provide a link, and we cannot be held responsible for the content of sites other than this one, as this Policy does not apply to third-party sites.

If you have any questions or concerns relating to our compliance with this data protection Policy, or if you want to provide recommendations or comments on how we can improve its quality, please send an email to the following address: investorrelations@financiere-tubize.be

This page was updated on 15 March 2024.