Privacy statement

Date: January 17, 2020

Your privacy matters to aternio. Whenever you use the services of aternio, you entrust us with your personal data. This Privacy Policy provides information about how we collect, process and disclose this information.

1. General

In this Privacy Policy, the following definitions apply:

aternio: aternio finance, private limited company, Zwaarveld 41d, B-9220 Hamme, Registry of Legal Persons Ghent, Subsection Dendermonde 0456.045.401; and aternio legal, private limited company, Zwaarveld 41d, B-9220 Hamme, Registry of Legal Persons Ghent, Subsection Dendermonde 0735.429.848.

Website: the website of aternio, atern.io, and any derivative websites developed and governed by aternio.

2. Scope

This Privacy Policy is applicable to all processing activities by means of and as a result of the use of our Website. This Privacy Policy is also applicable to all processing activities by aternio relating to all (commercial) relationships between aternio and its customers, prospective customers and business partners.

aternio finance and aternio legal act for all processing activities as described in this Privacy Policy as joint controllers. This means that they jointly determine the personal data that will be collected and determine the means and purposes for which they are processed.

The personal data collected by aternio is processed in accordance with the provisions of the General Data Protection Regulation (Regulation 2016/679) of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and the law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.

3. Which personal data is used?

Your personal data is collected and processed by aternio for a specific purpose, to register as a costumer or after you already became a customer of aternio. The data aternio collects, necessary for the purposes as described in this Privacy Policy, are the following:

• Identification details: name, address, language, etc;
• Contact details: phone number, e-mail address, etc;
• Personal traits: date of birth, civil status, nationality, etc;
• Family composition: marriage or other forms of cohabitation, etc;
• Financial details: financial identification details, business activities, etc;
• Living habits: habits, personal belongings, lifestyle, etc;
• Characteristics of your home: properties, other rights in rem on real estate, etc;
• Occupation and function: current profession, career, etc.

Data you provide to aternio when registering as a customer in accordance with European and national anti-money laundering laws:

• For almost all aternio services, you must provide us with your identification details beforehand. This is done via an order letter and an E-ID reader. These data are stored in aternio’s databases.

Data which aternio collects via the Website:

Due to the use of cookies on the Website, the following personal data can be processed:

• Electronic identification details: IP-address, installed cookies, type of browser, device, etc;
• Electronic localisation details: geographical location, etc.

Most information is available on or through the Website, without you having to provide your personal details. However, aternio processes the data, provided by you, by means of the forms available on the Website:

• Identification details: name, address, language, etc;
• Contact details: phone number, e-mail address, etc;
• Curriculum vitae;
• Motivation letter;
• Personal photo.

4. Use of personal data

aternio collects and processes your personal data, as described in this Privacy Policy, for one or more of the purposes described hereafter:

• For the provision and delivery of the services and products offered to you by aternio. The processing is necessary for the performance of a contract or for the legitimate interests of aternio.
• For the management and administration of the client database. The processing is necessary for the performance of a contract or for the legitimate interests of aternio.
• For the provision of information after a request for information originating from you. The processing is necessary for the performance of a contract.
• For the provision and sending of newsletters, advertisements and direct marketing, based on the consent of the data subject.
• To ensure and improve the functioning of aternio and the Website. The processing is necessary for the legitimate interests of aternio.
• For the provision and sending of (e-mail) messages to inform you concerning changes in legislation and issues which may be relevant to you. The processing is necessary for the legitimate interest of aternio.
• For the management and administration of suppliers and intermediaries. The processing is necessary for the performance of a contract or for the legitimate interests of aternio.
• To comply with European and national anti-money laundering legislation. The processing is necessary in order to comply with legal obligations to which aternio is subject.
• To comply with any international, European or national legislation. The processing is necessary in order to comply with legal obligation to which aternio is subject.

aternio requests your consent before using your personal data for purposes other than those described in this Privacy Policy.

5. Disclosure of personal data to third parties

aternio will not disclose your personal data to third parties, unless this is appropriate in order to fulfil the purposes as described in this Privacy Policy (including, but not limited to, maintenance, mailing, payment processing, database management). aternio can make use of processors, meaning natural or legal persons, public authorities, agencies or other bodies which process personal data on behalf of aternio.

aternio may disclose your personal data at the request of any competent authority, if we are obliged to do so by law, to comply with any other legal obligation or to safeguard and defend our rights, the rights of our clients and/or your rights during or in the context of a legal proceeding. In the context of a change in the corporate structure of aternio, including, but not limited to, a change in legal form, merger, demerger, acquisition and sale of the whole or part of the companies, your personal data collected by us will be one of the transferred assets.

If we need to disclose your personal data to third parties in this context, the third party in question is obliged to use your personal data in accordance with the provisions of this Privacy Policy.

In all other cases, we will not sell, rent out or pass on your personal data to third parties, unless (1) we have obtained your permission to do so and (2) a data processing agreement has been concluded with the third party in question, which contains the necessary guarantees regarding the confidentiality and privacy conformity of your personal data.

6. Storage of personal data

aternio will only store your personal data for the period necessary to fulfil the aims described in this Privacy Policy under the heading “use of personal data”.

If a longer storage period is justified by law, to comply with another legal obligation or in the context of present or future legal proceedings, aternio may store your personal data for this longer period.

7. Your privacy rights

If you wish to exercise your rights, as specified below, please contact us in accordance with the “Contact” section below:

You have the right to withdraw your consent for a given processing activity at any time, where the processing is based on your consent. The withdrawal of consent does not affect the lawfulness of the processing prior to the withdrawal.

If you no longer wish to receive newsletters or information about our products and services, you can unsubscribe at any time after the receipt of such a communication by aternio.

• Right of access: you have the right to obtain confirmation as to whether personal data concerning you are being processed, and, where this is the case, receive access to the personal data aternio may have regarding you;
• Right to rectify: you have the right to obtain, without undue delay, the rectification of inaccurate personal data and to complete or update your personal data;
• Right to erasure: you have the right to obtain, without undue delay and under certain circumstances, the erasure of the personal data concerning you;
• Right to data portability: you have the right to receive the personal data concerning you, which you have provided, in a structured, commonly used machine-readable format and to transmit the personal data to another controller without hinderances. This right shall not adversely affect the rights and freedoms of others;
• Right to restriction of processing: you have the right to obtain, under certain conditions, the restriction of processing;
• Right to object: you have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you, unless aternio can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims;
• Right not to be subject to automated individual decision-making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;
• The right to lodge a complaint with the relevant supervisory authority.

aternio reserves the right to request a proof of identification, before acting on your request to exercise your rights.

Within one (1) month after the receipt of the request, aternio will notify you of the decision to act on your request. This term can, where necessary, be extended with an additional two (2) months. In such case aternio will notify you thereof within one (1) month after receiving your request.

aternio may refuse your request to exercise these rights, if it is unreasonably recurrent, requires disproportionate technical effort, or compromises the privacy of others. In such case aternio will notify you of this decision within one (1) month of receiving your request.

8. Personal data security

aternio takes all reasonable organisational, technical and administrative steps to protect your personal data under its management, and as required by applicable data privacy laws. Unfortunately, no data transmission over the internet or any data storage system can be guaranteed to be 100% secure. If you have any reason to believe that your interaction with us is no longer secure, please notify us immediately by contacting us using the “Contact” section below.

9. Cross-border processing of personal data

Cross-border transfers of personal data to third parties for the purposes described above may occur. This also means that data is transferred to countries or regions which have different data protection laws than your own country. We will take the appropriate measures in each case, so that in situations involving such data transfers, the transfers will always take place in a way that provides an “adequate level of protection”.

10. Anonymous data

aternio can collect and process non-personal and anonymous data and can anonymize personal data. Such data does not relate to an identified or identifiable natural person and it does not permit aternio to identify the respective natural person. aternio can share anonymous data with third parties.

11. Other websites

This Privacy Policy only relates to our Website. We are not responsible for the privacy, information or other practices of third parties, including third parties who operate a website to which our Website contains a link. Including a link on the Website does not mean that we endorse the linked website.

In addition, we may offer you access to third party features that allow you to post content to your social media account(s). Please note that any information you disclose by using these features will be governed by the applicable privacy policies of the third party and not by this Privacy Policy. We have no control over, and are not responsible for, the way in which third parties use the information you provide when you use these features.

12. Update to the Privacy Policy

aternio reserves the right to renew this Privacy Policy, by posting a new version on the Website. Whenever changes are made, the above date will be adjusted in line with the revision. The updated version applies from the date of revision. We advise you to regularly consult this Privacy Policy, so that you are aware of any changes.

13. Cookies

During your visit to our Website, so called cookies can be used to optimize your experience on the Website. Additional information regarding the use of cookies by aternio can be found in our Cookie Policy.

14. Complaints

If you wish to make a complaint about the way in which aternio collects, uses and/or processes your personal data, you can always submit a complaint to the Belgian Data Protection Authority. More information thereof can be found on the website of the Belgian Data Protection Authority.

15. Contact

If you have any questions or are concerned about the privacy of your personal data, you can always contact us via GDPR@atern.io or aternio, FAO. GDPR, Zwaarveld 41D, 9220 Hamme.

Cookie policy

Date: January 17, 2020

1. General

In this Cookie policy, the following definitions apply:

aternio: aternio finance, private limited company, Zwaarveld 41d, B-9220 Hamme, Belgium, Registry of Legal Persons Ghent, subsection Dendermonde, 0456.045.401; en aternio legal, private limited company, Zwaarveld 41d, B9220 Hamme, Belgium, Registry of Legal Persons Ghent, subsection Dendermonde, 0735.429.848;

Website: the website of aternio, atern.io, and any derivative websites developed and governed by aternio.

2. Scope

This Cookie policy is applicable to the Website.

3. What are cookies?

When you visit the Website, so called cookies can be used. Cookies are small pieces of information that are installed on your device (computer, smartphone, tablet, etc). During a visit to our Website, they will ensure the functioning of the Website, save your preferences and/or ensure that services of third parties can be provided. The information collected by these cookies can relate to your device, your behaviour and/or your preferences and can be used to set up a personal profile which ensures that the provided information matches your wishes and preferences.

Before cookies are placed on your device by our Website, you are presented with the possibility to decline the use thereof. When refusing the use of certain categories of cookies, it is important to understand that we can no longer ensure the full functioning of the Website and the optimal use of certain services and functions thereof.

4. List of cookies used

4.1 Session- and Permanent cookies

Cookies often have a predefined lifespan, after which the cookie will be automatically removed from your device. This lifespan will vary from cookie to cookie.

Session cookies are cookies that are placed on your device when you visit the Website. The lifespan of these cookies is limited to the duration of your session. This means that these cookies will be automatically deleted when the browser is closed.

Permanent cookies persist on your device for a longer period of time or until you remove them manually. Using permanent cookies, we can recognise you when you visit our Website again. As such, the Website can be specially configured to your preferences. Also, when you have given us permission to place cookies, we can remember this by means of a cookie. You can delete permanent cookies via your browser settings.

4.2 Essential cookies

Essential cookies are necessary for the Website to function, and to facilitate communication over the internet. Without these cookies, the Website will not function in the way we intend it to, or we will not be able to provide you with the services and functions you request. Therefore, it is not possible to decline the use of these cookies on our Website. In case you delete or block these cookies, by means of your browser-settings or otherwise, the Website or parts thereof, will not function as intended.

4.3 Functional cookies

Functional cookies are used to provide additional functionalities and services on our Website, that are not essential to the base function of our Website. On our Website, you can share certain articles via social media. Hereto our Website makes use of cookies provided by third parties. aternio has no control over these cookies and is not responsible for the way these third-party providers collect and handle your personal data. When refusing these cookies, certain parts of the Website might not function as intended.

4.4 Analytical cookies

When you visit our Website cookies can be placed to collect information on the use of our Website. This information allows the assessment and improvement of the functioning of the Website. Analytical cookies allow us to determine which pages are often visited and the geographical origin of our visitors. The collected information is made as anonymous as possible. Your IP-address is specifically not provided. When refusing these cookies your visit to our Website will not be taken into account in the statistics of our Website.

Our Website makes use of the “Google Analytics” service provided for by the American company Google. The information is transferred to Google and stored by them on servers in the United States. Google may also transfer this information to third parties if they are required to do so by law, or if such third parties process the information on Google’s behalf. Google processes the personal data considering an adequate level of protection and is a member of the Privacy Shield Program of the US Department of Commerce. aternio does not control and is therefore not responsible for the way Google collects and handles your personal data.

4.5 Marketing cookies

When you visit our Website, third party (LinkedIn and Facebook) cookies can be placed on your device. These cookies, provided for by the respective third party, are used to set up a personal profile based on your behaviour. The third parties will, based on this profile, provide you with relevant advertisements on other websites. aternio does not control these cookies and is therefore not responsible for the way these third parties handle your personal data. You need to consult the relevant third-party website for more information about these cookies.

When refusing these cookies, the respective third party will not be able to follow you on our Website.

4.6 Table of cookies used

Essential cookies
Provider	Name	Expiring
atern.io	CookieConsent	1 year
atern.io	Craft_Csrf_Token	Session
atern.io	stg_debug	Session
Analytical cookies
Provider	Name	Expiring
atern.io	stg_last_interaction	1 year
atern.io	stg_returning_visitor	1 year
atern.io	_pk_id#	1 year
atern.io	_pk_ses#	1 day
www.googletagmanager.be	td	Session
Marketing cookies
Provider	Name	Expiring
atern.io	stg_traffic_source_priority	1 day
atern.io	stg_externalReferrer	1 day
atern.io	ViewHistory	400 days

5. Disabling cookies

You have the possibility to configure your browser in such a way that you receive a message when a cookie is generated, or when cookies are refused. Through these browser settings, you can also delete and refuse cookies. The way in which these browser settings can be adjusted will vary per browser.

More information on how to change the browser setting can be found in the “Help” menu of your browser or on www.aboutcookies.org.

To make optimal use of our Website, it is recommended to accept the use of cookies by our Website. When cookies are refused or deleted, a visit to our Website can no longer be guaranteed to be problem-free. More specifically because your preferences are not remembered and/or certain parts of our Website might no longer function (optimally).

6. Updates to Cookie policy

aternio reserves the right to renew this Cookie policy, by posting a new version on the Website. Whenever changes are made, the above date will be adjusted in line with the revision. The updated version applies from the date of revision. We advise you to regularly consult this Cookie policy, so that you are aware of any changes.

7. Privacy policy

With the use of cookies personal data can be collected and processed. More information regarding the processing of personal data by aternio, collected through the website, can be found in our Privacy policy.

8. Contact

In case you have any question, remarks or concerns regarding this Cookie policy, you can always contact us via GDPR@atern.io or aternio, FAO. GDPR, Zwaarveld 41d, B-9220 Hamme, Belgium.