Release date: 20 March 2018

Thank you for visiting www.ebtt.biz. Your interest in the EBTT Programme and The Trusted HR Practices (hereafter “EBTT”) is very much appreciated.

This document is a summary of our approach to collecting and processing the information we will be collecting from you when you visit our website (“the Site”). We hope that it provides you with sufficient information and the comfort of knowing that your data will be in good hands and treated with the greatest care.

By using the Site, you agree to the collection and use of information as stated in this policy.

Collection and use of personal data
GCZ International HR Services is a division of Czanik & Vanhout BVBA, a company with its registered office at Parklaan 26, 3910 Neerpelt, Belgium, registered by RPR Antwerpen dep. Hasselt, VAT registration number: BE 0553 672 535, (hereinafter referred to as either “GCZ International HR Services” or “we” or “us” or “our”), and is the data controller of any personal data you submit during your visits to our Site.

Cookies and log data
When you access our Site, we use cookies and other tracking technologies from Google Analytics. Using these cookies, we will collect anonymous demographic and interest category-specific statistical information about our visitors. However, we will NOT collect your computer’s IP information or any device identifiers. Web log data include statistical information about the type and version of the browser you are using and the traffic to and from our Site, the pages of our Site that you visit, the time and date of your visit and the time you have spent browsing those pages, among other statistics. We will use Google Analytics to collect, monitor and analyse this data.
We will not share your data with Google. Google Analytics data will not be used in combination with other Google services (e.g., DoubleClick, AdWords).
We use this information to:
1. Recognize you as a visitor;
2. Recognize whether you are accessing the Site via a referral link;
3. Improve the Site, to mitigate risk and prevent fraud; and
4. Measure the effect of our online marketing activities.

We will NOT use your data to build user profiles or interest profiles for remarketing purposes.

Personal data submitted by you
As part of your visit, you may decide to submit personal data to obtain content that we share with our registered contacts, to book an appointment or to use our Employee Trust Mini-Scan facility. This includes personal data (hereinafter referred to as “personal data”) such as:
Your first name, last name, job title, email and phone number.

It may also include data about your company (hereinafter referred to as “company data”) such as:
The name and address of your company, VAT registration number or reference to the use of purchase orders (if any).

We use this information as follows:

a) When you book an appointment (meeting, call or WebEx) through our booking site, we will ask you to provide us with your name, email address and phone number so as to be able to send you the WebEx login details and/or to be able to communicate with you in the case of changes to the planned agenda. We will also ask you to give us feedback about your experience with EBTT and our company. We will contact you to invite you register as a registered contact and to join the “The Trusted HR Practice” group on LinkedIn.

b) When you register to obtain any of our content (white papers, etc.) or to run an Employee Trust Mini-Scan, which we only offer to our registered contacts, we will use your email address to send you information relative to the ongoing activities and developments of EBTT. We will also contact you to invite you to join the “The Trusted HR Practice” group on LinkedIn and to ask for your feedback regarding the content with which you have been provided and your experience with EBTT and our company.

c) When you order our Trust Scan & Assessment service, your contact details will be used to organize the necessary communication between you and our company:
1. to confirm your order;
2. to coordinate the delivery of the ordered services;
3. to follow up on any developments in your company following the delivery of our services;
4. to ask for feedback on your experiences during our cooperation; and
5. to invite you to join the “The Trusted HR Practice” group at LinkedIn.

Granularity: If you do not agree with how we use your data as mentioned in paragraphs a) to c., we will adapt how we use your data upon request. Simply email us at hello@ebtt.biz.

Unsubscribe
Our email communications will always contain a clear link that will allow you to unsubscribe from our registered contact list.

Data review
Upon written request (by sending an email to hello@ebtt.biz), we will provide you with an extract of any data we store on you within five business days. Please write “Personal data extract” in the subject line of your email.
Upon written request (by sending an email to hello@ebtt.biz), we will always update and rectify your data within 72 hours.
Upon written request (by sending an email to hello@ebtt.biz), we will remove your data from our records within 72 hours. Please mention in your email the email address that you used to register with us and write “Unsubscribe” in the subject line of your email. However, we may need to retain certain information for legal or administrative purposes (e.g., GDPR compliance audit). Those retained data will be filed separately from any other data.

Disclosure
Your data will not be disclosed to third parties, except in the following cases:
We may share your data with our sub-contractors, who contribute to or deliver in full or in part any EBTT services. These sub-contractors will always act on our behalf and they will be obliged to protect your personal data in accordance with the terms of this privacy policy.

We may need to involve service providers to process your data (e.g., the Employee Trust Mini-Scan, the booking site, mailing, etc.). These service providers will always act on our behalf and they will be obliged to protect your personal data in accordance with the terms of this privacy policy.

We may need to disclose your data, at our sole discretion, when we believe it to be necessary:
1. to protect the legal rights and/or safety of GCZ International HR Services and/or its employees, agents and contractors;
2. to meet the inquiries or requests of public authorities; and
3. to comply with the applicable laws.

The following list contains the names of our current service providers, a brief description of their services and the terms governing data privacy in relation to their services provided to EBTT:
Microsoft, used for booking appointments (https://privacy.microsoft.com/en-us/privacystatement)
ClassMarker Pty Ltd, used for Employee Trust Mini-Scan (https://www.classmarker.com/online-testing/privacy/)
MailChimp, used for ad-hoc landing pages for registering for events or content and collecting feedback (https://mailchimp.com/legal/privacy/)

Security
In accordance with GDPR, we use adequate systems and procedures to protect your personal data. Currently, no Internet-based data transmission or storage method is 100% secure; therefore, while we strive to protect your data, we cannot guarantee its absolute security.

Retention of personal data
If you or your company become a client of GCZ International HR Services, we will store your personal data until the end of the second calendar year after the completion of our last dealings with our commercial relationship with you or your company, unless otherwise required by applicable law.

If you have registered to receive updates from us about developments at EBTT, we will keep your personal data until you decide to de-register. We will store your company data and data regarding our commercial relationship with your company until the end of the second calendar year after the applicable terms of limitation have lapsed, unless otherwise required by applicable law.
If you or your company do not become a client of GCZ International HR Services, we will store your company data until the end of the second calendar year after your registration on www.ebtt.biz, the booking site or the Employee Trust Mini-scan site.
Any data related to our eventual connection with you on LinkedIn is governed by the applicable terms of LinkedIn.

Changes
This privacy policy is effective as of the date indicated under “release date” (above) and will remain in effect until it is modified.
GCZ International HR Services reserves the right to modify this privacy policy without prior notice at any time. Any updated versions of the privacy policy will always be effective from the time of posting on www.ebtt.biz. Should the updated policy contain any material change to these terms, we will post a notice of said change on www.ebtt.biz 30 days in advance of the effective date of the change. If you do not agree with these changes, please advise us by emailing hello@ebtt.biz. This privacy policy, as well as the processing of your data during and related to the delivery of EBTT services, is governed by the laws of the Kingdom of Belgium.

Complaints
If you consider that your right to privacy has been infringed and, upon your request, GCZ International HR Services did not solve the matter, you are entitled to file a complaint with the relevant Belgian authority to settle your request.
The relevant authority in Belgium is the CBPL (Commissie voor de bescherming van de persoonlijke levenssfeer)
Website: https://www.privacycommission.be/en
Address: Drukpersstraat 35, B-1000 Brussels | Belgium
Telephone: +32 2 274 48 00
Telephone for first line support: +32 2 274 48 78
Fax: +32 2 274 48 35
Email: commission@privacycommission.be