We handle your data with care

1. Name and contact data of body responsible for processing (‘data controller’)

This Privacy Notice provides you with detailed information relating to the protection of your personal data by:

EOS Aremas Belgium SA/NV 
Head office: Montagne du Parc 8G, Bruxelles/Brussel, Belgium
Commercial Register : BE 0466.301.368
Phone: +32 2 5084-230
(further referred as “we”)

We are responsible, as a controller, for the processing of your personal data in relation to our activities. 

The purpose of this Privacy Notice is to inform you which of your personal data we use, the reasons why we use and share such data, how long we keep it and how you can exercise your rights.

The data protection officer for EOS Aremas Belgium SA/NV can be contacted at the above address or by email at dpo-eos@eos-aremas.com

Further information may be provided where necessary.

This privacy policy does not apply to data processed by the other companies of EOS Group. This is also the case if these other companies of EOS Group along with their contacts are named on our website and/or their services are shown on our website. 

The other companies of EOS Group will provide you with separate privacy policies for specific data processing activities on a case-by-case basis.
 

2. Which personal data do we use about you?

We collect and use your personal data to the extent necessary in the framework of our activities, debt collection and management, recruitment and to achieve a high standard of services.

The data we use about you may either be directly provided by you or be obtained from the following sources in order to verify or enrich our databases:

• publications/databases made available by official authorities (e.g. the official journal);
• our corporate clients or service providers;
• websites/social media pages containing information made public by you (e.g. your own website or social media) and databases made publicly available by third parties.

We collect various types of personal data about you, including:

• identification information (e.g. name, first name, ID card and passport numbers, nationality, place and date of birth, gender, picture);
• contact information (e.g. postal address and e-mail address, phone number);
• family situation (e.g. marital status, number of children);
• tax status;
• education and employment information (e.g. level of education, employment, employer’s name, remuneration);
• banking, financial and transactional data (e.g. bank account details, credit card number, money transfers including communications on bank transfers, assets, credit history, debts and expenses);
• contract information (e.g. all the information included in the contract for which we ensure debt collection)
• data relating to your habits and preferences:
  - data which relate to your use of services;
  - data concerning your transactions (e.g. : transactional data, debts, income and expenses)
  - data from your interactions with us: through our internet websites, our apps, our social media pages, calls, chats, emails, interviews.
  - data from our phone call
• data that are provided by official authorities (i.e. to fight against over-indebtedness, we may also access to public or semi-public data about your global level of debt);
• tracking measures
  We use tracking measures to ensure that our website is designed according to requirements and optimised on an ongoing basis. We also use the tracking measures to collect statistics on the use of our website and analyse them for the purpose of optimising our offering for you.
• Sensitive data 
  Unless it is a legal obligation or it results from the execution you make of our products and services (eg: you mention this type of information in your mail), we never process personal data related to your racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data or data concerning your sex life or orientation.

Usage of Siteimprove Analytics

This website uses Siteimprove Analytics, a web analytics service provided by Siteimprove. Siteimprove Analytics uses „cookies“, which are text files placed on your computer, to help EOS Aremas Belgium SA/NV  analyse how visitors use the site. The information generated by the cookies about the visitors’ use of the website will be stored and processed by Siteimprove on servers in Denmark.

IP addresses are anonymized irreversibly before data is made available in the Siteimprove Analytics or Intelligence Suite for EOS.

When you retrieve our website be.eos.solutions.com  the browser used on your device automatically sends information to our website’s server. This information is temporarily saved in a log file. The following information is collected without your intervention and saved until it is automatically deleted after three (3) days: 

IP address of retrieving computer,
date and time of access,
name and URL of retrieved file,
website from which access occurred (referrer URL),
website retrieved from our website,
your computer’s browser and possibly operating system as well as name of your access provider.

3. Specific cases of personal data collection

In certain circumstances, we may collect and use personal data of individuals with whom we could have or used to have a direct relationship.

We may also collect information about you whereas you do not have a direct relationship with us, for instance when a client, a service provider or a commercial partner provides us with information about you. This may happen if you are for example:

• a family member;
• a co-borrower / guarantor;
• a (legal) representative;
• an ultimate beneficial owner;
• a debtor of our debtor;
• a creditor;
• a shareholder;
• a staff member.

4. Why and on which basis do we use your personal data?

a. To comply with legal and regulatory obligations

We use your personal data to comply with various legal and regulatory obligations, including:

• prevention of money-laundering and the financing of terrorism;
• compliance with legislation relating to sanctions and embargoes;
• fight against tax fraud and fulfilment of tax control and notification obligations;
• replying to an official request from a duly authorized public or judicial authority;
• debt collection regulatory obligations.

b. To perform a contract to which you are party

We use your personal data to perform contracts or contracts of our clients to which you are party, including to:

• provide you with information;
• assist you and answer your requests;
• evaluate if we can offer you a service, an agreement, a plan and under which conditions; 
• ensure debt collection and debt management;
• ensure the execution of all the clauses and conditions of the contract or applicable to the contract;

c. To fulfil our legitimate interest

We use your personal data in order to deploy and develop our products and our services, debt management, debt collection, recoveries, to improve our risk management and to defend our legal rights, including:

• proof of transactions;
• fraud prevention;
• audit and control;
• IT management, including infrastructure management (e.g. shared platforms), business continuity and IT security;
• establishing statistical models;
• establishing aggregated statistics, tests and models, for research and development;
• training of our personnel for instance by recording our phone calls;
• personalizing our offering to you by improving our services and their quality;
  
  This can be achieved by:
• segmenting the products, debtors and clients;
• analyzing your habits and preferences (in your use of our services or in your interaction with us through the various channels (emails or messages, visits to our website, etc.));
• monitoring transactions to identify those which deviate from the normal routine.

d. To respect your choice if we requested your consent for a specific processing

In some cases, we must require your consent to process your data, for example, if we carry out further processing for purposes other than those above in this Section 4, we will inform you and obtain your consent where necessary.

e. To process data from electronic communications

In addition to any recording of electronic communications that is either legally authorized or imposed or to which you have consented, we may record electronic communications with you, including the related traffic data, if we do so in the course of lawful business practice for the purpose of ensuring the training and supervision of employees and improving the quality of the service; 

We may retain such records as long as legally required or permitted including for the period of time during which a dispute may arise further to the electronic communication recorded between you and us.

The above applies to phone conversations as well as all other electronic communications (such as e-mails, SMS, instant messaging services or other equivalent technologies).

5. Who do we share your personal data with?

In order to fulfill the aforementioned purposes, we only disclose your personal data to :

• Other companies of EOS Group;
• Our employees;
• Creditor;
• Thirds for the sole purpose of collecting debts (e.g. assignees, debt collectors, courts, public officers, lawyers,…);
• Service providers which perform services on our behalf;
• Financial or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law;
• Certain regulated professionals such as lawyers, notaries or auditors.
• the Commission for the Protection of Privacy within the limits of its mission

6. Transfers of personal data outside the European Economic Area (“EEA”)

In case of international transfers originating from the EEA to a non-EEA country which the European Commission has recognized as providing an adequate level of data protection, your personal data will be transferred on this basis.

For transfers to non-EEA countries which level of protection has not been recognized by the European Commission as adequate, we will either rely on a derogation applicable to the specific situation (e.g. if the transfer is necessary to perform your contract) or implement one of the following safeguards to ensure the protection of your personal data:

• Standard contractual clauses approved by the European Commission;
• Binding Corporate Rules.

To obtain a copy of these safeguards or details on where they are available, you can send us a written request as set out in Section 13.

7. Social media and YouTube

a. Shariff solution

We use Shariff buttons from social networks Facebook, Twitter, Google+, LinkedIn and Xing on our website. The buttons are simple HTML links. The procedure we use is within the framework of the Shariff solution. With the Shariff solution a script retrieves the number of times, e.g., the share button on a page has been clicked on: for this the script contacts the social network via the programming interfaces and retrieves the numbers. None of your personal data are transmitted in the process. Rather than your IP address, only our server address is transmitted to Facebook, Google and Twitter. You only become directly connected to Facebook, Google or Twitter if you perform an action. Before that the social networks cannot collect any data about you. As long as you do not click on a link to share content, you remain invisible to the networks. If you click on a link, the obligation to provide information about data collection and processing no longer rests with us, but rather with the operator of the social network.

b. YouTube videos

Our website contains links to videos from YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. If you visit a website on our website that contains such a video, a direct connection is established between your browser and the YouTube server after you have activated the video.
YouTube receives the information that you have visited our website with your IP address. If you click on the link to the video, your IP address will be forwarded to YouTube. We would like to point out that, as the provider of our website, we have no knowledge of the content of the transmitted data or of its use by YouTube. For more information, please see YouTube's privacy policy (https://www.youtube.com/)

8. Cookies

We use cookies on our website. These are small files that are automatically created by your browser and stored on your end device (laptop, tablet, smartphone or similar) when you visit our website. Cookies do not cause any damage to your terminal device, do not contain viruses, Trojans or other malware. Information is stored in the cookie that is related to the specific terminal device used. This does not mean, however, that we obtain direct knowledge of your identity.

The use of cookies serves on the one hand to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted when you leave our website. In addition, we also use temporary cookies to optimise user-friendliness, which are stored on your end device for a certain fixed period. If you visit our website again to use our services, we will automatically recognize that you have already been with us and which entries and settings you have made so that you do not have to enter them again.

The cookies are divided into four categories: Necessary, Statistics, Comfort and Marketing: 

The necessary cookies are required for the operation and basic function of our website. They enable the security-relevant functionality of this website. These cookies are automatically deleted after leaving the website. The data processed by the cookies are required for the purposes mentioned above to safeguard our legitimate interests and those of third parties in accordance with Art. 6 (1)(f) GDPR.

The statistical cookies are used to improve our offer and to ensure a needs-based design and the continuous optimization of our website. For this purpose, we collect anonymised data for statistics and analyses, for example to determine the number of visitors, page impression statistics and user behaviour and to adapt and improve our content and website experience. The legal basis for this data processing is Art. 6 (1)(a) GDPR (consent).

The comfort cookies are used to make our website easier to use. If you visit this website again to use our services, it is automatically recognised that you have been on our website and which entries and settings you have made, so that you do not have to enter them again. For example, you do not have to re-enter your user data each time you visit the website, but can access the data you have already entered when you return. The legal basis for this data processing is Art. 6 (1)(a) GDPR (consent).

We use the marketing cookies to provide you with content that is relevant to your interests when you visit our website. The legal basis for this data processing is Art. 6 (1)(a) GDPR (consent).

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or so that a message always appears before a new cookie is created.

Cookie management:

Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or so that a notification always appears before a new cookie is set. Each browser differs depending on your cookie settings. This is described in each browser's help menu, which explains how to change your cookie settings. Follow the links below depending on the browser you are using:

• Internet Explorer 
• Firefox 
• Chrome
• Safari
• Opera

However, completely deactivating cookies may mean that you will not be able to use all the functions of our website.

9. Data security

Within the website be.eos-solutions.com we use the widespread SSL (secure socket layer) method in conjunction with the highest level of encryption supported by your browser. In general this is 256-bit encryption. If your browser does not support 256-bit encryption, we fall back on 128-bit v3 technology instead. You can recognise that an individual webpage in our internet presence is being transmitted in encrypted form by the closed key or padlock icon in the bottom status bar of your browser.
We also take suitable technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorised access by third parties. Our security measures are being improved continuously according to technological developments.

10. How long do we keep your personal data for?

We will retain your personal data for the longer of the period required in order to comply with applicable laws and regulations or another period with regard to our operational requirements, such as account maintenance, facilitating client relationship management, and responding to legal claims or regulatory requests. For instance, clients’ data is kept for the duration of the contractual relationship and for 10 years after the end of the contractual relationship.

We delete the personal data collected after processing your enquiry provided we are not legally entitled or obligated to process it further.

11. What are your rights and how can you exercise them?

In accordance with applicable regulations, you have the following rights: 

• To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
• To rectify: where you consider that your personal data are inaccurate or incomplete, you can require that such personal data be modified accordingly.
• To erase: you can require the deletion of your personal data where one of the following grounds provided in GDPR Article 17 applies.
• To restrict: you can request the restriction of the processing of your personal data.
• To object: you can object to the processing of your personal data, on grounds relating to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
• To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
• To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party.

You can exercise the rights listed above by (please also send a copy or a scanned copy of your identity card) :

• letter to EOS Aremas Belgium SA/NV – Data Privacy Officer, Montagne du parc 8G, 1000 Bruxelles/Brussel;
• e-mail to dpo-eos@eos-aremas.com

In accordance with the applicable regulations, you are entitled to lodge a claim with the competent supervisory authority (Autorité de protection des données / Gegevensbeschermingsautoriteit) 

e-mail : contact@apd-gba.be
Phone: +32 (0)2 274 48 00

12. How can you keep up with changes to this privacy notice? 

This privacy policy is currently valid and was last updated in December 2021.

In a world of constant technological changes, we may need to regularly update this Privacy Notice. 
We invite you to review the latest version of this notice online and we will inform you of any material changes through our website or through our other usual communication channels.

13. How to contact us?

Should you have any questions relating to our use of your personal data or this Privacy Notice, please contact our data protection officer by e-mail to dpo-eos@eos-aremas.com, Phone: +32 2 5084-230 or by letter to EOS Aremas Belgium SA/NV – Data Privacy Officer, Montagne du Parc 8G, 1000 Bruxelles/Brussel, who will investigate your query.

Note d'information du Règlement Général sur la Protection des Données (RGPD).

Note d'information RGPD

Please find our privacy statement here.