1. General

This notice explains how, as a data controller, Isabel NV/SA (“we”, “us”, “our”), with offices at Keizerinlaan 13-15, 1000 Brussels (phone: +32 2 545 17 11) processes personal data we collect from you through the website www.multibanking.eu.

2. Information We collect

When you register to our newsletter, we collect your name and email address.

When you request a whitepaper or other documentation to be sent to you, we collect your email, name, function, organization and its sector, and phone number.

When you contact us through our website, we collect the following types of personal data about you:

  1. Identification data: your name and title, email address, phone number (optional) and IP address;
  2. Data relating to security: security logs, connection and activity logs, and the user agent of your web browser;
  3. The messages you are sending us.

When you register to or request information about our services, we collect the following types of personal data about you:

  1. Identification data: your name and title, address, phone number, email address and information about your company, its number of banks used and potential users of the services;
  2. We also collect all emails we exchange with  you.

While you browse our website, we collect the following types of personal data about you:

  1. Identification data: your IP address;
  2. Data relating to security: security logs, connection and activity logs, and the user agent of your web browser;
  3. When you allow us, we also collect data relating to your use of the website such as the pages you consulted or if you already visited our website in the past. 

3. Cookies

We use cookies on our websites to improve your user experience and, where you consent to it, to know you better.

A cookie is a small text file that is downloaded onto your computer or smartphone when you access a website. It allows the website to recognise that computer or smartphone and store some information about your preferences or past actions.

We use four types of cookies on our websites:

  1. Essential cookies: these cookies are required for the websites to function properly and to provide you with the services you are requesting. You may block and delete these cookies using your web browser parameters, but this may prevent the websites to function properly.
  2. Analytics cookies: these cookies are used to measure the number of unique visitors of our websites and the number of pages viewed. You may block and delete these cookies using your web browser parameters.
  3. Advertising cookies: these cookies are placed only after we have received your consent. They are used to get to know you better and to offer you advertising that suits you better.
  4. Tracking cookies: these cookies are placed only after we have received your consent. They are used to get to know you better and to recognize you when you visit our website several times.

The following cookies may be placed by our website, depending on your web browser parameters and given consent:

Cookie Name

Type

Purpose

Storage Duration

_hs_opt_out

Essential

Hubspot cookie consent.

13 months

_hs_do_not_track

Essential

This cookie can be set to prevent the tracking code from sending any information to HubSpot.

13 months

hs_ab_test

Essential

This cookie is used to provide the same version of the webpage when different versions of this page are being tested.

Until the end of the browser’s session

hs-messages-hide-welcome-message

Essential

This cookie is used to prevent the welcome message from appearing again for one day after it is dismissed.

1 day

_ga

Analytics

Google analytics anonymous visitor counting.

2 years

_gat

Analytics

Google analytics anonymous visitor counting.

Until the end of the browser’s session

_gid

Analytics

Google analytics anonymous visitor counting.

1 day

hubspotutk

Tracking

This cookie is used to keep track of a visitor’s identity.

13 months

_hssc

Tracking

This cookie keeps track of sessions.

30 minutes

_hssrc

Tracking

This cookie is used to identify returning users so we can restart their session.

Until the end of the browser’s session

_hstc

Tracking

This cookie is used to keep track of the different visits of a user.

13 months

tr [pixel]

Advertising

Retargeting information for Facebook.

Until the end of the browser’s session

 

4. Processing purposes

Your personal data is processed for the following purposes:

  1. Where it is necessary for the performance of a contract between you and us or in order to take steps, at your request, to enter into a contract:
    1. To allow users to register for the use of our services;
    2. To provide you with information when you request them;
  2. Where you have given your consent, by accepting the cookies on our website:
    1. To allow us to send you promotional offers and information on our products;
    2. To allow us to track precisely the information on the unique number of visitors, their sessions and the relevant timestamps.
  3. Where necessary for our legitimate interests, as listed below, and where not overridden by your interests or fundamental rights and freedom:
    1. To keep trace of Isabel’s business relationships with you, as our existing or prospect customer.
    2. To improve the services we provide by identifying, e.g. trends, recurrent issues, customer behaviours, through your use of our services. For these purposes, we have conducted a balancing test, as the law requires, and have determined that, taking into account the limited personal data collected, the processing performed and your reasonable expectations, our legitimate interest in conducting this processing is not overridden by your interests or fundamental rights and freedom.
    3. Where it is necessary for us to comply with our legal obligations, such as reporting crime or crime intent or tax reporting.

5. Disclosure and Transfer of personal data

In order to deliver our service to you and for the above purposes, we need to share your personal data with:

  1. Isabel personnel with access on a “need to know” basis and to contractors who have signed a confidentiality agreement with us.
  2. Third party processors, located in the European Economic Area, who support us in the processing of your personal data only on our instructions and who are subject to appropriate confidentiality clauses:
    1. Combell, who is responsible for hosting our website.
    2. Flexmail, who allows us to send bulk mailings for newsletters and marketing campaigns.
  1. Third party processors located in the United States of America, who support us in the processing of your personal data only on our instructions and who are subject to appropriate confidentiality clauses:
    1. Google Analytics, which provides us with simple statistics on the number of unique visitors on our website.
    2. Hubspot, which is our marketing automation software.

These third party processors are all part of the Privacy Shield, which is a mechanism to comply with data protection requirements when transferring personal data from the European Union to the United States.

  1. Government institutions or regulatory bodies in compliance with our reporting obligations.

6. Data Security and Retention

Your personal data is and will be kept strictly confidential.

We take all reasonable steps to protect your personal data. This includes setting up processes and procedures to minimise the unauthorised access to, or disclosure of your personal data. We ensure that the third parties we share your personal data with also have adequate security measures in place.

We will store your personal data for as long as it is necessary to achieve the purposes defined in section 4 (Processing Purposes), with maximum retention periods as defined below:

  1. Data collected when you contact us through our website will be kept for 10 years, as required by the Belgian Anti-Money Laundering (AML) regulation.
  2. Data collected when you purchase services from us will be kept for 10 years after the end of the contract, as required by Belgian law.
  3. Data collected when you request information about our services will be kept for 3 years or until you require us to delete your data.
  4. Data collected for marketing purpose will be kept for as long as we have your consent.
  5. Technical logs will be kept for a maximum of 60 days.

7. Automated decision-making and profiling

No automated decisions will be taken about you as part of the processing described in this notice.

A profile of your behaviour when you use our website will be created if you accept our advertising and tracking cookies to be placed on your computer.

8. your rights

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provided us in a structured, machine-readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular when we do not have to process your personal data to meet a contractual or other legal requirement).

Where we have asked for your consent, you may withdraw this consent at any time; however, this will not affect processing that have already taken place before the withdrawal. You may withdraw your consent by deleting the cookies linked to our domain.

You may exercise the above-mentioned rights by contacting us as described in the “Contact us” section below.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information that we are required to keep by law or that we have a compelling legitimate interest to keep.

If you have unresolved concerns, you have the right to complain to the Data Protection Authority: https://www.dataprotectionauthority.be/

9. Contact us

If you have any questions about this Privacy Notice or wish to contact us for any reasons in relation to the processing of your personal data, please contact our Data Protection Officer at Isabel NV/SA,  by sending an email to privacy@isabelgroup.eu, or by sending a dated and signed request to Isabel NV, Keizerinlaan, 13-15, 1000 Brussels, Belgium.

10. Updates to this Privacy Notice

We reserve the right to modify this notice at any time, but will in any case do so in accordance with the applicable laws and regulations. We will inform you by email, when possible, of any substantial changes to this notice.

This notice was last modified and revised on the 29/01/2019.