Privacy Policy

Passacaglia Consulting is committed to protecting your privacy.  This statement applies to all information collected or submitted by Passacaglia Consulting and is designed to provide you with details of how we collect and process your personal data in respect of the General Data Protection Regulation, GDPR (EU) 2016/679 of April 2016, and the Belgian Data Protection Act of 30 July 2018.

Passacaglia Consulting refers to “Passacaglia Consulting”, registered with the Crossroads Bank for Enterprises in Belgium (VAT number 0757530012).

Passacaglia Consulting is the data controller therefore responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

“You" and “your” refers to those of whom we process personal data.  They include current and prospective clients, employees, collaborators, website visitors, or any individual with whom Passacaglia Consulting has a professional relationship with, either directly or via a third-party organization. 

If you are not happy with any aspect of how we process your data, please contact us so that we can try to resolve it for you. You can email us at info@passacaglia.eu or call us on +32 471 75 23 07.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@passacaglia.eu indicating the changes required. All emails will be responded to within 48 hours and actioned in line with regulations.

HOW WE USE YOUR PERSONAL DATA  

We only process personal data where it is necessary to do so in line with a legal lawful basis identified. We do not process any personal data without your permission to do so. 

The most common uses of your personal data include:

  • Supporting you through the lifecycle of your training, or the training you are involved in as a trainer, assistant or service provider;

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

Passacaglia Consulting will ensure it always uses the correct legal lawful basis to process your personal information dependant on the process that is being carried out.

 WHAT WE USE YOUR DATA FOR

Set out below is a description of the ways we intend to use your personal data.  

Training

  • Course registration 

  • To send course materials via email

  • Performance feedback

  • Course correspondence 

  • Course data storage 

Finance

  • General finance 

  • Clients’ payment data 

  • Trade and training invoices

  • Expense claims 

  • Training payment 

  • Payroll 

Marketing

  • General enquiries 

  • Promotional emails

  • Newsletters

  • Professional network, to make suggestions and recommendations that may be of interest to you

General management 

  • Administration and protection of our business and its online presence (including troubleshooting, data analysis, system maintenance, reporting and hosting of data)

Marketing communications 

You may receive marketing communications from us if:

  • You have requested information from us;

  • You provided us with your details and expressed opt-in consent to receive our newsletters and/or promotional emails;

  • Your contact details are publicly available (eg online).

 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

 Any marketing done by us will be done in line with the correct legal basis dependent on the actual marketing. At all times you will be offered the option to opt out. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us for other reasons, for example course registration.

You can ask us to stop sending you marketing messages at any time by emailing us at info@passacaglia.eu

TO WHOM CAN WE DISCLOSE YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table above: 

  • Service providers who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • Regulators and other authorities based in Belgium and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the relevant legal framework. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions and all processors are asked to provide evidence that they comply.

International transfer

We do not transfer your personal data outside the European Economic Area unless it is required of us or we have your consent to do so.  Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria and additional safeguards are put in place by us. We will advise you should we require to transfer your data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or

  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

 HOW WE STORE YOUR DATA 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG DO WE KEEP YOUR DATA 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data. 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data

  • Request correction of your personal data

  • Request erasure of your personal data

  • Object to processing of your personal data

  • Request restriction of processing your personal data

  • Request transfer of your personal data

  • Right to withdraw consent

You can see more about these rights at: https://www.dataprotectionauthority.be/citizen.  You can also contact the Data Protection Authority directly. 

 If you think we have infringed your rights, please contact us at info@passacaglia.eu  

You can complain about the way we process your personal data to the Belgian Data Protection Authority.