Privacy policy / Personal data management policy

The data that you give us when processing your request of intervention and the data that you generate when visiting our website are essentially personal data.

SOGEPA scrupulously complies with the applicable legislation in this area as in all others. Here is how:

1. Who is this Privacy Policy for?

This policy applies to all persons directly or indirectly concerned by the processing of an application in view of an intervention of SOGEPA through its own funds or in the name and on behalf of the Walloon Region through a delegated assignment as well as to any person who has provided personal data to SOGEPA by connecting to its website.

2. Controller

Your personal data are processed by the Société Wallonne de Gestion et de Participations, abbreviated « SOGEPA », a limited liability company (“société anonyme”), with its registered seat at 4000 Liège, boulevard d'Avroy, 38, registered with the Crossroads Bank for Enterprises under the number 0426.887.397. SOGEPA processes your data as controller or, in the event of a delegated assignment in the name and on behalf of the Walloon Region, as joint controller.

3. Why are we processing your data?

3.1. Management of your request of intervention

3.1.1. Purposes

SOGEPA's mission is to manage the investments in capital or loans in the name and on behalf of the Walloon Government. It also makes the same type of investments through its own funds.

The data that you transmit to us and those concerning yourself that we receive from third parties are of course processed at your request to perform pre-contractual arrangements and to communicate with you in this respect.

3.1.2. Categories of data that are processed

To this end, we are processing the following data: your name, first name(s), gender, language, date and place of birth, address of home or residence, phone (fixed/mobile) and fax number(s), e-mail address, civil status, profession and position, as well as data relating to the company and its managers (shareholders, directors and delegate(s) for day-to-day management) and to its third-party investors (description of the activity, history of the company, financial situation, strategy, business reputation, composition of its workforce, statutes or articles of incorporation, operating permits and environmental permits, organization chart of the company and of the group of which it is part, composition of the board of directors, minutes of the board of directors and of the general assembly for the past year, information on the market, suppliers, customers and competitors, SWOT analysis of the company, capital position and structure of the shareholding, objective of the intervention, amount and nature of the concerned intervention of the Region, modes of funding to be envisaged in order to develop the current and future activity of the company, last audited annual accounts, detailed accounts, balance sheet and last commented profit and loss accounts, detailed 3 years business plan, table summarizing the financial indebtedness, copy of important agreements, sales backlog.

We are never processing any sensitive personal data in the meaning of the GDPR (see point 4 below) for this purpose.

In the event that you do not provide us with all the personal data necessary for the purpose stated in the previous paragraphs, we will collect and use the information available on the official websites freely available to the public such as the website of the Belgian Official Gazette, that of the Crossroads Bank of Enterprises, Belfirst and others (including sites gathering commercial and economic information), in order to complete and execute any contractual documents within the framework of the management of an investment in capital and/or as loan, such as requested to Sogepa.

All these data are essential to the processing of your request. Without them, we cannot carry out our mission.

3.1.3. Duration

If your request for intervention is received favorably, your personal data will be kept during our contractual relations as well as for a period of 10 years after the end of the contractual relationship.

Should your request for intervention be refused, your personal data will be erased 1 year after the SOGEPA’s notification of refusal.

3.1.4. Recipients of the personal data

They are transmitted to the Walloon Region, financial consultants, legal service, auditors. They could be passed on to our external legal counsel or to a bailiff if a judicial recovery is required.

3.2. Management of our contractual relationship

Purposes
Your financial data is also used to carry out our contractual relationship as well as, where appropriate, to recover any amount due and to notify any contract amendment or the Privacy Policy (including amendments, such as new purposes).

Data categories
Contact data, contracts, financial data. These data are essential to the processing of your file. Without them, we cannot carry out our contractual relationship.

Recipients of the data
They are transmitted to the tax and social authorities, our social secretariat and our accountant. They could be transmitted to our external legal counsel or to a bailiff if a judicial recovery is required.

Duration
We are compelled to retain invoicing data until the expiration of our tax and accounting obligations and until the expiration of our 10 years contractual liability period.

3.3. Promotion of our services - inform you

Purposes
We send you newsletters via e-mail.

Categories of processed data
Your name and e-mail address will be processed.

Duration
We retain your contact information for this purpose until you express your wish to unsubscribe from our mailing list.

3.4. Computer maintenance

Purposes
Personal data may also be accessed during the maintenance of our IT infrastructure, management software, the realization and maintenance of our website.

Recipients
In this case, our subcontractors in charge of the IT infrastructure, our management software and/or the realization and maintenance of our website could access your data to the extent strictly necessary for the execution of their respective tasks.

They will not keep the data they have access to.

3.5. Job applications

Purposes
If you send us your application, your data will be processed at your request to assess the possibility of a contractual relationship.

Data categories
Name, first name(s), gender, language, date and place of birth, address of home or residence, telephone (fixed / mobile) and fax number(s), e-mail address, civil status, function, as well as the content of the curriculum vitae and a letter of motivation, if any, may be processed by SOGEPA. All these data are essential to the processing of your application. Without them, we cannot process your application.

Duration
They will be erased within 5 years of the end of the recruitment process.

3.6. Consultation of our website

In principle, access to the information available on or via the website takes place without having to provide personal data.

3.6.1. Complementary services and contact form

Exceptionally, in order to obtain additional services (request for information, registration for an event), certain personal data may be requested from the user of the site.

Purposes
The data provided is only used to satisfy your request for additional service or your request for contact.

Data categories
Name, first name, e-mail address, company, phone, address, content of your message. All these data are essential for the processing of your request.

Duration
If your request for contact leads to a contractual relationship, your personal data are kept during the contractual relationship as well as for a period of 10 years after the end of the aforesaid relationship.

If not, they are erased 1 year after the first contact.

3.6.2. Cookies

A « cookie » is a small piece of information saved by a website within your computer's internet browser. This "cookie" can be retrieved during a subsequent visit to this same site. The "cookie" cannot be read by another website than the one that created it. The site uses "cookies" for administrative purposes, for example, to record your preferences for certain types of information, which will save you from having to repeat the same keyboard entries each time you visit our site.

The list and description of the cookies used on our website and our extranet can be found here.

Most cookies only work during one session or visit. None of them contain information that makes you likely to be contacted by phone, email or post.

Most browsers automatically accept cookies. However, it is possible to set your browser to receive a warning before registering a cookie on your computer or to block them. You will find more information on the setting of your browser via the "Help" button of the latter or via the following links:

Purposes 
We use cookies for technical and statistical information reasons relating to navigation.

Data categories
For technical reasons, we use cookies to:

  • Remember the language you have chosen;
  • Allow sharing;
  • Protect our site.

For statistical reasons, when the user accesses the SOGEPA website, the servers that are consulted automatically collect the following data:

  • The IP address assigned to you when you connect;
  • The date and time of access to the site;
  • The pages consulted;
  • The type of browser used;
  • The platform and/or operating system installed on the PC;
  • The search engine and the keywords used to find the site.

Duration
The respective retention period of each cookie is specified here.
This information is kept for the sole purpose of measuring the number of visitors to the various sections of the site and making improvements.

Social network cookies
It is also possible that cookies are installed by the social networks listed on our site. These social networks may themselves use cookies, in particular, to collect information they use for their own purposes.

4. Legal basis for the processing of personal data by SOGEPA

It is also possible that cookies are installed by the social networks listed on our site. These social networks may themselves use cookies, in particular, to collect information they use for their own purposes.

  • With your consent (legal basis: article 6a of the Privacy Regulation):
    Your personal data are processed on the basis of your consent for the purposes set out in Article 3.3 (if you are not bound to SOGEPA by a contract) and 3.6.2.

  • In connection with the execution of a contract to which SOGEPA is a party or the execution at your request of pre-contractual measures (legal basis: article 6b of the Privacy Regulation)
    The processing of personal data mentioned above makes it possible to fulfill the purposes set out in Articles 3.1, 3.2, 3.5 and 3.6.1.

  • In order to fulfill the legal obligations to which we are subject (legal basis: article 6c of the Privacy Regulation)
    We are also subject to tax and accounting obligations requiring the retention and transmission of certain personal data to the accounting and tax administrations.

  • For the purposes of our legitimate interest that we pursue as controller (Article 6f of the Privacy Regulation)
    The processing of the personal data listed above makes it possible to fulfill the purposes set out in Articles 3.4 and (if you are bound to SOGEPA by a contract) 3.3.

5. Can your personal data be passed on to third parties, if necessary outside the European Union?

Your data are exclusively stored by SOGEPA on servers located within the U.E.

They may be communicated to SOGEPA's subcontractors for services performed on behalf of SOGEPA exclusively (for example: financial consultants, legal service providers, auditors, IT service providers and others) and only on the basis of our instructions. These recipients are in principle located in the European Union. If, exceptionally, they were to be transferred to a country that did not provide an adequate level of protection, we would ensure that appropriate safeguards are in place to ensure that transfer. A copy of these appropriate warranties would then be available upon request.

6. How does SOGEPA protect your personal data?

Your personal data will be processed confidentially. SOGEPA makes every effort to take the necessary technical and organizational measures to ensure their safety.

7. What are your rights? How may you exercise them?

Information
This right is exercised through this document. If the processed data includes the data of your staff members, you commit yourself to let them know about this document.

Access and rectification
You have the right to access your data and have it rectified if necessary.

Opposition
You may object to the processing of your data that we do on the basis of our legitimate interest.

Withdraw your consent
When the data is processed under your consent, you may revise this decision at any time, however without questioning past processing.

Deletion
You may request the deletion of your data or to limit the processing of your data under the conditions provided for in Articles 17 and 18 of the Privacy Regulation.

Portability
The data you have provided to us may be communicated to you or transmitted to another controller in electronic format.

To exercise these rights:

You may send a written request, accompanied by a proof of your identity (copy of your ID card), to our data protection officer at the following address: privacy@sogepa.be.
You also always have recourse to the Data Protection Authority whose contact details are listed on the website: https://www.autoriteprotectiondonnees.be/contact

8. Social networks

If you share information from the SOGEPA website through social networks, personal data may be viewed by visitors of your personal pages on these sites.
SOGEPA can not in any way be held liable for any data processing through this type of media.