2. Identification of data controller and data protection officer
3. Which personal data does PMV process and for which purposes
“Personal data” means any information relating to an identified natural person (“the data subject”): “identifiable” means a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more elements characterising the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
Below is an overview of the personal data PMV processes of natural persons, as well as for what purposes:
|Purpose(s) of processing||Type of personal data|
|Communication and marketing, in particular the sending of our newsletters, annual reports, press releases and invitations to the New Year’s reception.||Name, first name and email address (“Contact Information”) and business card|
|Communication and marketing, in particular the listing of portfolio companies on our website, facebook page or in our annual report.||Image, voice, photo and name (“Testimonial data”)|
|Facilities, in particular visitor sign-in and registration, parking management, security and access within our buildings, fire safety, access badges.||Name, first name and vehicle number plate (“Identification data”)|
|Facilities, in particular camera surveillance for theft prevention and security.||Camera footage|
|Finance, in particular the execution of payments to (business) relations and service providers.||Contact data and bank account number|
|Selection and recruitment, in particular the applicant selection process.||CV, personality analysis, LinkedIn (“Application details”) and if you provide us with a reference(s), PMV may contact these reference(s) for information if necessary for the position you are applying for|
|Investment activities involving corporate loans, venture capital, real estate infrastructure and energy investments, guarantees, among others, consisting mainly of a pre-investment phase and a post-investment phase. During the pre-investment phase, processing of personal data will include analysing the investment file, conducting due diligence, appointing a consultant and making an investment decision and negotiating and concluding an agreement. During the post-investment phase, the processing of personal data will be for, inter alia, the execution of the agreement, continued analysis and follow-up of the investment file or an exit from the investment file.||Contact details, telephone number, photo, video, date of birth, marital status, financial, corporate and economic information (e.g. business plan, professional experiences and skills, CV, shareholders, directors,…), copy of ID|
4. On what legal basis does PMV process your personal data
PMV will only process your personal data if:
- the data subject has given us permission to process his/her personal data for one or more specific purposes, for example:
- for the processing of Contact Data in the context of communication and marketing;
- the processing is necessary for the performance of a contract to which the data subject is a party, or in order to take measures at the request of the data subject prior to and in view of the conclusion of a contract, for example:
- for processing Job Application Data and contacting references voluntarily communicated in the context of selection and recruitment;
- for the processing of your Personal Data within the framework of our investment activities;
- for processing Contact Data in the context of payment to business relations and service providers;
- for processing necessary to comply with a legal obligation incumbent on PMV:
- for the processing of certain personal data for the identification of our business relationship (anti-money laundering legislation);
- the processing is necessary to pursue the legitimate interests of PMV or a third party, except where the interests or fundamental rights and/or freedoms of the data subject requiring protection of personal data outweigh those interests, in particular where the data subject is a child, for example:
- for the processing of Contact Data within the framework of communication and marketing if you are a business relation of PMV;
- for the processing of the personal data on your business card if you have given it to an employee of PMV to be contacted for a specific purpose (e.g. to send you concrete information about one of our well-defined investment activities) and to invite you to subscribe to our newsletter;
- for the processing of Identification Data in the context of visitor registration and the processing of camera images in the context of theft prevention and security with a view to protecting our professional interests, our property and staff, to ensure that all authorised persons enter our site and to identify and investigate irregularities therein.
5. How does PMV obtain your personal data
Personal data processed by PMV are collected as follows:
5.1. Personal data collected directly
PMV processes personal data that we receive directly from you when you:
- communicate your personal data to us in the context of selection and recruitment, or in the context of our investment activities;
- access our premises (camera images);
- subscribe to our newsletters
- submit an application file within the framework of our investment activities.
5.2. Personal data collected indirectly
PMV also processes personal data that we receive through:
- press agencies and media companies for sending out our press releases (e.g. Contact details of journalists);
- recruitment agencies and our external service provider in the context of taking a personality analysis as part of our selection and recruitment;
- external public sources for economic, corporate and financial information such as the Belgian Official Gazette, the Crossroads Bank for Enterprises, the National Bank of Belgium, Linkedin, or your company’s corporate website, etc. in the context of our investment activities.
6. How long does PMV retain your personal data
PMV does not retain and process your personal data for longer than necessary for the fulfilment of the above-mentioned purposes for which the personal data are collected.
Personal data that we obtain in the context of our investment activities are kept in the investment phase for up to 10 years from the date of the decision on the application file, and in case of a positive decision for up to 10 years from the closure of the file in the (post)investment phase.
Personal data that we obtain as part of the job application process are kept for as long as necessary for the application process and up to 1 year after the completion of the application process in case of non-recruitment. Upon recruitment, the Application Data will be included in your personnel file and retained in accordance with the applicable retention periods.
Camera images from the security cameras in and on our site are kept for 1 month after your visit, except if requested by the police, the public prosecutor or our legal department in case the camera images indicate potential criminal activity and/or incidents in which case they are kept until the complaint is settled.
Personal data we obtain through the website (e.g. when you subscribe to our newsletter) will be held until such time as you inform PMV that you no longer wish to receive our mailings, or if it appears that your email address is no longer in use.
All email communication with us is stored in our backup system for a period of 1 year after the retention periods mentioned above.
7. Who has access to your personal data
7.1. Within PMV and PMV Group
Employees of PMV only have access to your personal data to the extent they need it to perform their duties. Our employees are contractually bound to treat personal data as strictly confidential.
7.2. Service providers of PMV
This applies, for example, to parties from whom PMV purchases licences for software or hardware systems, to the companies that help organise our events and send our invitations. This also applies, for example, to parties commissioned by PMV to carry out payroll administration or other tasks related to the administrative processing of human resources.
A data processing agreement will be concluded with each processor, defining the subject and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects, and the rights and obligations of the processor and the data controller.
7.3. Competent authorities
PMV may provide competent authorities (including, but not limited to, police authorities, judicial authorities, government agencies) with access to your personal data when PMV considers that access is necessary (i) under applicable regulations or legal obligation, (ii) in the context of judicial investigations or information requests (iii) for the exercise or defence in court of the interests of PMV.
7.4. Auditors, consultants and legal service providers
PMV may give its auditors, consultants and legal service providers access to your personal data in connection with the (legal) services they provide to us and to the extent necessary for, and limited to, the (legal) services.
7.5. Transfer of personal data outside the European Economic Area
Personal data may not be processed outside the European Economic Area without taking appropriate protection measures in this regard, unless the country or international organisation in question guarantees an adequate level of protection. As a matter of principle, PMV does not process your personal data outside the European Economic Area. In the exceptional cases where this would nevertheless happen (e.g. via our service providers), PMV will take the necessary measures to ensure an adequate level of protection by, among other things, standard data protection provisions adopted by the European Commission.
8. What are your rights as a data subject
If you have provided PMV with your personal data, you always have the right to ask us, free of charge, to inform you what personal data we hold and, if necessary, to ask us to correct, limit, transfer in electronic format or delete these personal data free of charge. Insofar as the personal data in PMV’s possession are kept for the purpose for which they were obtained and within the corresponding retention periods, PMV has no obligation to comply with this request. In this case, PMV will examine whether it is possible – and to what extent and under what conditions – to meet the request, and this in accordance with the requirements of the legal and regulatory framework.
Furthermore, you have the right to revoke your consent regarding the processing of your personal data at any time. However, this revocation will not affect the lawfulness of the processing of your personal data for the period preceding the moment of this revocation.
You also have the right to lodge a complaint with a supervisory authority. For the contact details of the Belgian Data Protection Authority, please refer to the following website: www.dataprotectionauthority.be/.
To exercise these rights, please contact us
In order to guarantee legitimate processing of personal data, the person concerned will be asked to identify themselves by means of a copy of the recto side of the identity card or another valid proof of identity.
9. How do we protect your personal data
PMV treats your personal data confidentially and with the utmost care. PMV secures its systems – within reason – against loss and/or against any form of unlawful use or processing. In doing so, PMV uses appropriate technical and organisational measures, taking into account the state of the art. Your data are adequately secured in accordance with the applicable privacy laws and regulations. The personal data you provide are on servers located in controlled and secured environments.
Without prejudice to the aforementioned efforts, you should be aware that there is always a risk associated with sending personal data over the Internet. We can therefore never fully guarantee the security and protection of your personal data.