Privacy Policy

Buttonwood Privacy Policy

Date: September 11, 2024

As an accountancy firm, we collect large amounts of data to be able to provide our services. This data is collected legally and processed for specific, explicit and legitimate purposes. The current privacy statement concerns all the personal data collected and processed by Buttonwood.

The personal data we process may relate to you in your capacity as a client of our firm, or to you as a business contact of any one of our clients (if you are a supplier or customer of our client). This concerns data on current and potential customers, as well as suppliers, contractors and employees. In all cases, we are obligated to inform you, as the data subject whose personal data we process, of the following.

1. Data controller

The data controller responsible for the processing of the personal data is Mondriaan Corporate & Finance:

Mondriaan Corporate & Finance BV, Ghent Register of Legal Entities, Ghent Division, with its registered office at Burchtweg 7, 9890 Gavere and company registration number 0721.660.006, registered with the ITAA under accreditation number 50630360.

For all questions regarding the protection of personal data, please contact Buttonwood by mail at the aforementioned address or by e-mail at info@buttonwood.be.

2. Purpose of processing personal data

The personal data collected and processed by the firm will be treated in accordance with the provisions of the General Data Protection Regulation (Regulation 2016/679) of the European Parliament and of the Council of April 27, 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 Act of July 30, 2018 on the protection of natural persons with regard to the processing of personal data.

The firm processes personal data for the following purposes:

1. The application of the Act of September 18, 2017 on the prevention of money laundering and the financing of terrorism and for the limitation of the use of cash (hereinafter: the Anti-Money Laundering Act).

1° In accordance with article 26 of the Anti-Money Laundering Act, our firm is obligated to collect the following personal data relating to our clients and their agents: first name, last name, date and place of birth and, where possible, their address.

2° In accordance with article 26 of the Anti-Money Laundering Act, our firm is obligated to collect the following personal data relating to the ultimate beneficiaries of the clients: first name, last name, and, where possible, their date and place of birth and address.

The processing of this personal data is a legal obligation. Without this data, we cannot enter into a business relationship (Art. 33 of the Anti-Money Laundering Act).

1. The firm’s obligations towards the Belgian government, foreign governments or international institutions in the fulfillment of a legal or regulatory obligation, the implementation of a court decision, or in the context of safeguarding a legitimate interest by means of, but not limited to, the current and future tax laws (e.g. EC sales lists for VAT and tax slips) and social security laws, require us to process personal data in the context of the assignment entrusted to us.

The processing of this personal data is a legal obligation. Without this data, we cannot enter into a business relationship.

1. Performance of a contract concerning accountancy and fiscal services. The processing of personal data relates to the data of the clients themselves, their staff, directors and similar, as well as the data of other persons who are involved in their activity, including customers and suppliers.

This data, which is required for processing, concerns:

• identification data: name, address, language, etc.;
• contact details: phone number, e-mail address, etc.;
• personal characteristics: date of birth, marital status, nationality, etc.;
• composition of the household: marriage or a different form of cohabitation, etc.;
• specific financial information: financial identification data, professional activities, etc.;
• living situation: habits, possessions, lifestyle, etc.;
• characteristics of the home: properties owned, other property rights to real estate, etc.;
• profession and position: current position, career, etc.;

If this data is not provided and processed, we cannot do our work as accountants properly.

1. Marketing purposes (including direct marketing)

We wish to provide our clients with targeted communication, promotions, offers and other advertisements relating to our firm. We always ask our clients’ explicit permission to do so. If a client relationship with our firm already exists, we send marketing communications that we suspect may interest the client in question. Clients have the right to object to the processing of their personal data for the purposes stated under point D at any time.

1. Data collected by the firm through the website

The use of cookies on the website makes it possible to process the following personal data:

Electronic identification data: IP address, cookies, browser, device, etc.

Electronic localization data: geographical location, etc.

3. What personal data and whose?

With regard to the purposes mentioned under point 2, our firm may process the following personal data: first name, last name, e-mail address, biometric data (copy of e-ID card or passport), address, company registration number, national registration number, etc.

With regard to the income tax returns submitted through Tax-on-web, the following data is also processed: composition of the household, membership of a trade union or political organizations, medical data, specific financial information, living situation, characteristics of the home, profession and position, etc.

The firm processes the personal data provided by the data subjects themselves or by their associates.

The firm also processes personal data that is not provided by the data subjects themselves, such as personal data provided by the client regarding the client’s employees, directors, customers, suppliers or shareholders.

The personal data may also originate in public sources such as the Crossroads Bank for Enterprises, the Belgian Official Gazette and its annexes, and the National Bank of Belgium (Central Balance Sheet Office).

The data is only processed to the extent necessary for the purposes stated under point 2.

The personal data is not transmitted to third countries or international organizations.

4. Recipients of the personal data

In accordance with the above, and except where the transmission of personal data to organizations or entities whose intervention as third-party service providers on behalf of and under the control of the data controller is required to achieve the aforesaid purposes, the firm will not transmit, sell or lease the personal data collected in this context to any other organization or entity, or exchange it with them, unless you are informed of this in advance and have explicitly consented.

The firm makes use of third-party service providers:

• The firm uses electronic bookkeeping software and an accompanying portal;
• The firm employs external staff to fulfill certain tasks or specific assignments (statutory auditor, notary public, lawyer, etc.).

The firm may take all necessary measures to guarantee proper management of the website and its IT system.

The firm may transmit the personal data at the request of any legally authorized government body, or even on its own initiative if it believes in good faith that the transmission of that information is necessary to comply with laws and regulations, or to defend and/or protect the rights or goods belonging to the firm, its clients, its website, and/or yourself.

Your personal data can likewise be transmitted in the context of a change to the corporate structure of the firm, including but not limited to a change to its legal form, an acquisition, merger, demerger and the full or partial sale of the business or a business unit.

5. Security Measures

In order to prevent unauthorized access to the personal data thus collected, the firm has set up procedures for security and organization relating to both the collection of this data and its storage. Our security measures are regularly evaluated and adjusted to guarantee a high level of protection.

These procedures also apply to all data processors called upon by the firm.

6. Retention period

6.1. Personal data that we are obligated to retain under the Anti-Money Laundering Act (see 2.A.)

This refers to the identification data and the copy of the supporting documents relating to our clients, the internal and external agents and our clients’ ultimate beneficiaries.

In accordance with Article 60 of the Anti-Money Laundering Act, this personal data will be retained for a maximum of ten years after the end of the business relationship with the client, or ten years from the date of an occasional transaction.

6.2. Other personal data

The personal data of persons other than those mentioned above will only be retained for the periods required by the applicable legislation, such as accounting legislation, tax legislation and social security legislation.

6.3 Once the aforementioned periods have expired, the personal data will be erased, unless another applicable law stipulates a longer retention period.

7. Your privacy rights

7.1. With regard to the personal data that we are obligated to retain in application of the Anti-Money Laundering Act

This concerns the personal data of our clients, the agents and the clients’ ultimate beneficiaries.

In this regard, we refer to Article 65 of the Anti-Money Laundering Act:

To exercise your rights in relation to your personal data under the Anti-Money Laundering Act, you must therefore approach the Data Protection Authority.

7.2. All other personal data

If you wish to exercise your rights, as defined below, please contact info@buttonwood.be.

You have the right to withdraw your consent to a certain form of data processing at any time, if this processing is based on your consent. The withdrawal does not affect the validity of processing prior to withdrawal. If you no longer wish to receive newsletters or information about our products and services, you can also unsubscribe at any time after receiving the e-mail from the firm.

Right of access: you have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, to obtain access to that personal data.

Right to rectification: you have the right to obtain the rectification of inaccurate personal data concerning you without undue delay.

Right to be forgotten: under certain circumstances, you have the right to obtain the erasure of personal data concerning you without undue delay.

Right to data portability: subject to the rights and freedoms of third parties, you have the right to receive the personal data concerning you, which you have provided, in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another controller.

Right to restriction of processing: under certain circumstances, you have the right to obtain the restriction of a certain processing activity on personal data concerning you.

Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you, unless the controller demonstrates compelling legitimate grounds for the processing, or in the context of the establishment, exercise or defense of legal claims.

Right to refuse profiling: 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.

Right to lodge a complaint with the Data Protection Authority.

The firm is entitled to request proof of your identity before it complies with your request.

The office will provide you with information on the action taken regarding your request within one (1) month of receipt of the request. This period may be extended by two (2) months if necessary. In that case, the office will inform you of this within one (1) month of receipt of the request.

The firm may refuse requests to exercise these rights if they are repeated in an unreasonable manner, require disproportionate technical efforts or put the privacy of others at risk. In that case, the office will inform you of this within one (1) month of receipt of the request.

If you provide us with your e-mail address, you may be contacted by e-mail with information about our services, newsletters or events. If you no longer wish to receive such e-mails, please contact us at the address stated above.

8. Complaints

If you have complaints about the processing of personal data by our firm, please contact our firm first before filing a complaint with the Data Protection Authority at https://www.dataprotectionauthority.be/citizen/actions/lodge-a-complaint

9. Update to privacy policy

The firm is entitled to update this privacy policy by placing a new version on the website. When changes are made, the date stated above will be adjusted to reflect the revision. The amended version shall apply from the date of revision. We advise you to consult this privacy policy regularly, so that you are aware of any changes.

10. Other websites

This privacy policy only applies to our website. The firm is not responsible for the privacy practices, information practices or other practices of third parties, including third parties operating any website to which our website contains a link. Our inclusion of a link on the website does not mean that the firm endorses the linked website.

Furthermore, we may give 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 is governed by the applicable third-party privacy statement and not by this privacy policy. We have no control over, and neither are we responsible for, the way in which third parties use the information you provide when you use these features.

11. Cookies

During your visit to the website, cookies may be used to optimize your experience on the website. Additional information on how the firm uses cookies can be found in the cookie policy.