privacy policy

First and foremost, we are delighted that you are interested in the products and services of Manzoni Agency.

In this privacy statement, we inform you about the way in which Personal Data is processed by us.

We may ask you to share certain Personal Data with us, including but not limited to your first name, last name, and email address (identification data). For certain specific obligations, you may be required to provide us with additional data, such as payment and billing information. We only collect the Personal Data necessary to inform you about our products and services, to execute an agreement with you, and to communicate with you.

We base this on the processing grounds of the agreement, legal obligation, our legitimate interest, and, in some cases, your consent (see also Article 2). The processing of your Personal Data is subject to this privacy statement. For questions and/or comments, please contact info@manzoniagency.com.

Article 1 - Definitions

"Manzoni Agency" means trading under the name 'Manzoni Agency bv,' a private company under Belgian law, with registered office at 2000 Antwerp (Belgium), Meir 80 box 5.4, and registered with the Crossroads Bank for Enterprises under enterprise number 0749.896.409.

"Personal Data" has the meaning as defined in the General Data Protection Regulation 2016/679, including any information by which a natural person (also referred to as "data subject") is identified or can be identified.

"Controller" has the meaning as defined in the General Data Protection Regulation 2016/679. Manzoni Agency will qualify as the controller who determines the purposes and means for the processing of your Personal Data.

"Affiliated Company" means a company connected to Manzoni Agency as far as it meets the conditions of an "affiliated company" within the meaning of Article 1:20 of the Belgian Code of Companies and Associations.

"Processor" has the meaning as defined in the General Data Protection Regulation 2016/679, processing Personal Data on behalf of/in instruction of the Controller.

"Website" means the website of Manzoni Agency: www.manzoni-agency.com.

Article 2 - Processing Purposes and Legal Bases

Customer Data

In the context of our services and activities, we collect and process the identity and contact details of our customers and clients, their personnel, and employees. The purposes for these processing activities are the execution of agreements with our customers, customer management, accounting, and direct marketing activities such as sending promotional or commercial information. The legal bases are the execution of the agreement, fulfilling legal and regulatory obligations (in particular accounting legislation), our legitimate interest, and, in some cases, your consent.

Supplier and Subcontractor Data

We collect and process the identity and contact details of our suppliers and subcontractors, as well as their possible (sub)contractor(s), their personnel, and employees. The purposes of these processing activities are the execution of the agreement, the management of suppliers/subcontractors, and accounting. The legal bases are the execution of the agreement, fulfilling legal and regulatory obligations (in particular accounting legislation), and/or our legitimate interest.

Employee Data

We process the Personal Data of our employees in the context of our personnel management and payroll administration.

Applicant Data

We process the identity and contact details as well as the work history and other data commonly indicated on a resume of applicants when they provide us with this information. The Personal Data are processed to determine whether they qualify for a job with us based on our legitimate interest.

If we wish to retain their Personal Data after the relevant vacancy has been filled, we will notify them and request their consent to do so.

Other Data

In addition to the data of customers, suppliers/subcontractors, employees, and applicants, we also process Personal Data of others, such as potential new customers/prospects, useful contacts within our sector, network contacts, etc. This is done via our Website or other channels. The purposes of these processing activities are in the interest of our activities, direct marketing, and public relations. The legal basis is our legitimate interest, the execution of an agreement, and, in some cases, your consent.

Very concretely, we can use the Personal Data we collect for the following purposes:

(i) to provide you with information about our products and services;

(ii) to deliver our products and services to you and execute any agreements;

(iii) to process and handle possible complaints or requests;

(iv) to process your application;

(v) to help us evaluate, correct, or improve the Website and all related products and services of Manzoni Agency;

(vi) for direct marketing purposes;

(vii) for internal reasons, including business administration and archiving purposes.

Article 3 - Confidentiality of Your Personal Data

Whenever you provide Personal Data to us, we will treat this information in accordance with the provisions of this privacy statement and the legal obligations regarding the processing of Personal Data, including the General Data Protection Regulation (GDPR) 2016/679.

We implement appropriate measures and procedures to secure and protect the Personal Data we collect. In this way, we commit, as far as reasonably can be expected, to prevent illegal processing of Personal Data and unintended loss or destruction of your Personal Data.

We strive to optimize the security of your Personal Data by restricting access to your Personal Data to persons on a "need-to-know" basis (for example: only Manzoni Agency and its employees, personnel, Affiliated Companies, or subcontractors who need your Personal Data for the purposes as described in Article 2 will have access to the data).

Article 4 - How Do We Collect Your Personal Data and How Long Do They Last?

Collecting Your Personal Data

We collect your Personal Data – without being exhaustive – in the following cases:

(i) when you enter into an (employment) agreement with us;

(ii) when you fill in the contact form provided on the Website;

(iii) when you communicate with us via the Facebook Messenger link provided on the Website (with your Facebook profile);

(iv) when you subscribe to the Website to receive our newsletter;

(v) when you call us, email us, or otherwise correspond with us other than via the Website.

We avoid the collection of Personal Data that are not relevant for the purposes as set out in Article 2.

We may combine the Personal Data we collect with information provided to us by third parties.

Storing Your Data

The Personal Data are kept and processed by us for a period necessary for the purposes of the processing.

Customer data and data of suppliers or subcontractors will, in any case, be deleted from our systems after a period of 7 (seven) years after the termination of the agreement, except in case of an ongoing dispute for which the Personal Data are still necessary.

Personal Data of employees will be deleted immediately after termination of the employment relationship, except for the Personal Data that we are required to retain based on specific legislation or in case of an ongoing dispute for which the Personal Data are still necessary.

Personal Data of applicants will be deleted after the relevant vacancy has been filled or after a period of 2 (two) years after obtaining consent to inform applicants about future job opportunities.

Other data will not be kept for longer than a period of 2 (two) years after the last meaningful contact with you, except with your explicit consent to keep this data longer.

Article 5 - Transfer of Personal Data

We will not transfer Personal Data to third parties located outside the European Economic Area, except to subcontractors or personnel who have committed themselves in accordance with the Standard Contractual Clauses of the European Commission and provide an adequate level of security for the processing of Personal Data.

Furthermore, we will not transfer Personal Data to other parties located within the European Economic Area than with your consent, unless:

(i) the transfer is necessary to allow personnel, agents, or subcontractors to provide a service or perform a task on our behalf, which is necessary for the execution of the agreement we have with you or in the context of our legitimate interest (including but not limited to providing marketing support, conducting market research, or providing customer service);

(ii) this is legally required.

Any transfer of Personal Data to a recipient as listed above is in accordance with the provisions of the General Data Protection Regulation 2016/679.

We ensure that measures are taken so that the recipients cannot use the Personal Data for purposes other than those listed exhaustively in Article 2 and that the recipients have taken sufficient technical and organizational measures to protect this data.

In order to ensure the security of the Personal Data, we will always conclude a processing agreement with the abovementioned recipients of the Personal Data.

We will take all necessary precautions to ensure that the employees and personnel who have access to the Personal Data process them solely in accordance with this privacy statement and the legal obligations under the General Data Protection Regulation 2016/679.

Article 6 - Data Subject Rights

Based on both Belgian and European legislation on the protection of Personal Data, you have the rights described below. If you wish to exercise these rights, you must send us a written request accompanied by a copy of the front of your identity card to myprivacy@manzoniagency.com.

We will inform you within a period of 1 (one) month after receiving the request about the action that will be taken. This period may be extended up to a maximum of 3 (three) months, in which case you will be informed within 1 (one) month after the original request of the reasons for this delay.

The Right of Access to Personal Data

You have the right to instruct us to provide all Personal Data we hold about you, provided that the rights of other data subjects are not affected.

The Right to Rectify Personal Data

We kindly ask you to ensure that the Personal Data in our database are as accurate and complete as possible. If you believe that the data provided to us are incorrect or incomplete, please notify us as described above. We will correct or supplement your Personal Data as soon as possible.

The Right to Erase Personal Data

You have the right to have your Personal Data erased without undue delay in the following cases:

(i) when it is no longer necessary to retain the Personal Data for the purposes for which they were collected or otherwise processed;

(ii) in case of withdrawal of consent for consent-based processing;

(iii) processing for direct marketing purposes; and

(iv) if the Personal Data have been processed unlawfully.

However, there are certain general exclusions to the right to erasure. These general exclusions include cases where processing is necessary:

(i) for the exercise of the right to freedom of expression and information;

(ii) to comply with a legal obligation; or

(iii) to establish, exercise, or defend legal claims.

The Right to Restrict Processing of Personal Data

In the following cases, you have the right to restrict the processing of your Personal Data:

(i) to contest the accuracy of your Personal Data;

(ii) when processing is unlawful, but you do not want the Personal Data to be erased; or

(iii) if you object to the processing of your Personal Data, pending verification of that objection.

If processing is restricted on this basis, we may continue to store your Personal Data. However, we will only process the data with your express consent to establish, exercise, or defend legal claims, to protect the rights of another natural or legal person, or for reasons of significant public interest.

The Right to Object

You have the right to object to our processing of your Personal Data in the following cases:

(i) if we process your Personal Data for direct marketing purposes (including profiling for these purposes) based on our legitimate interest; and

(ii) because of your specific situation (your particular personal circumstances).

The Right to Data Portability

If you wish to exercise your right to data portability, we will transfer the Personal Data in a structured, commonly used, and machine-readable format to a data controller of your choice.

The Right to Withdraw Consent

To the extent that the legal basis for our processing of your Personal Data is your consent, you have the right to withdraw this consent at any time. However, this withdrawal does not affect the lawfulness of the processing that took place before the withdrawal.

The Right to Lodge a Complaint with a Supervisory Authority

You can contact the Data Protection Authority at any time by sending an email to contact@apd-gba.be or by sending a written request to the Data Protection Authority, located in 1000 Brussels (Belgium), Drukpersstraat 35.

Article 7 - Reference to Third Parties

The Website may contain links to other websites not operated by us, such as Facebook, Instagram, and Soundcloud. While we make every effort to ensure that the references only lead to websites that have corresponding security and confidentiality standards, we are in no way responsible for the protection and confidentiality of Personal Data, including data provided on other websites after leaving the Website.

We emphasize the need to proceed with caution and always consult the privacy policy applicable to the respective website before providing personal data on other websites.

Article 8 - Changes

We have the right to amend this privacy statement at any time by publishing a new version on our Website.

We recommend that you consult the Website regularly to verify whether you agree with any changes to this privacy statement.

In any case, you will be informed by email of any changes to this privacy statement to the extent that we have your email address.

Article 9 - Cookies

Manzoni Agency uses "cookies" whenever you use the Website. A "cookie" is information sent to your device via the server and stored on the device's hard drive. Cookies help Manzoni Agency recognize your device when you use the Website. This allows Manzoni Agency to make processing more user-friendly and provide you with personalized service.

For more information, please refer to our cookie statement, which you can find here.