Privacy Policy

1. General

1.1.     This is the privacy policy for Alterfin S.C., with head office at Haachtsesteenweg 159 in 1030 Brussels, enrolled in the Crossroads Bank for Enterprises under number 0453.804.602 (‘Alterfin’).

1.2.     Alterfin is a Belgian cooperative that has collected capital to invest in developing countries since 1994. Alterfin aims to improve the chances of survival and living conditions of socially and economically disadvantaged people and communities, and to do this primarily in the rural areas of countries with low and average incomes. With this in mind, Alterfin provides its partners with financial and non-financial services: (i) by collecting funds, primarily with individual investors and institutions that want to fulfil their corporate social responsibilities; (ii) by investing in ethical and sustainable projects and promoting them; (iii) by working with organizations that share these same values, focused on the project level. In this way, Alterfin contributes to the Sustainable Development Goals of the United Nations.

1.3.     With this Privacy policy, Alterfin is informing every involved party whose personal data is processed of all relevant procedures, practices, guarantees, goals, etc. This privacy policy can be changed by Alterfin at any time. Consult it regularly.


2.          Legal framework

2.1.     Alterfin is the controller of personal data that (i) relates to you and/or (ii) that relates to other people, but that is provided by you or in your name (‘Personal data’).

2.2.     This privacy policy is subject to legislation relating to the protection of Personal data, such as:

(i)      the law of 8 December 1992 on the protection of privacy with regard to the processing of personal data (known in Dutch as the Wet van 8 december 1992 tot bescherming van de persoonlijke levenssfeer ten opzichte van de verwerking van persoonsgegevens);

(ii)     Regulation (EU) 2016/679 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 repealing Directive 95/46/EG (General Data Protections Regulation);

(iii)    all other applicable legislation with regards to the protection of privacy and the processing of personal data;

(together or separately the ‘Privacy legislation’).

2.3.     Alterfin can use one of the following legal grounds for the processing of Personal data:

(i)      an agreement that has been closed with Alterfin;

(ii)     the free, express, unambiguous and active consent, that has been given to Alterfin by you or by the involved party in your name, in regard to the processing of Personal data. This consent can be given through any means, such as, but not exclusive to post, email, an online or offline consent form, or orally;

(iii)    a legal obligation; and/or

(iv)   the legitimate interests of Alterfin.


3.          Goal

Alterfin processes Personal data in agreement with Privacy legislation and this Privacy policy in order to:

(i)   perform its activities as described in Article 1.2 (including  entering into agreements for this purpose);

(ii)     conduct direct marketing about its activities, activities of its partners and/or activities of organizations from the same sector, with direct marketing including, but not limited to updates, newsletters, information brochures, emails, marketing material, invitations for events and other information that may be of interest to you;

(iii)  possibly ask you questions about Alterfin services and activities and possibly to respond to questions about these services and activities;

(iv)   understand your needs and the basis of these needs, and to improve the Alterfin platform and range;

(v)   make transfers to subcontractors and contracting parties for the execution of the previous points;

(vi)   obtain statistical data; and/or

(vii)  fulfil legal obligations.

 (henceforth collectively or individually the ‘Goal’).


4.          Personal data

4.1.     Alterfin can request, collect and process Personal data that:

(i)      may be useful for the Goal, such as the first name, surname, gender, date of birth, address, email address, telephone number, company name, registration number, preferred language, CV, National Register identification number, signature, financial data, activities on the Alterfin website, and other information that it is provided with;

(ii)     is collected in the framework of the activities performed by Alterfin as defined in Article 1.2:

  1. identification number in the register of shareholders
  2. National Register identification number for processing of fiscal benefits to the Belgian State.
  3. financial history in order to remit a correct dividend.
  4. collecting the necessary funds.

4.2.     You guarantee that the Personal data that you provide us with is complete and accurate and that you are legally permitted to provide us with it.


5.          Visual material

5.1.     Alterfin can make use of visual material (such as photos or videos) of people in the framework of its activities as outlined in Article 1.2. You are aware that visual material of you or of the people whose Personal data you have provided, may be taken by Alterfin or by third parties at events organized by Alterfin, such as the General Assembly, workshops, seminars, on-site, etc.

5.2.     Alterfin can use visual material as defined in Article 5.1 in the framework of the activities defined in Article 1.2:

(i)      for internal objectives (and distribute it via internal communication systems such as email) and store it on a server accessible to Alterfin (either belonging to Alterfin or to its ICT provider);

(ii)     for external objectives, such as distribution (e.g. via email or on social media) for promotional objectives, direct marketing objectives, reports to clients, publication on the Alterfin website, use in annual reports, social media or be communicated to third parties, etc.


6.          Transfer to third parties

6.1.     Alterfin can call on subcontractors to perform processing activities (e.g. the hosting of the website, other ICT objectives, etc.). Alterfin is to close a processing agreement with third parties that may be granted access to your Personal data.

6.2.     Alterfin guarantees that no Personal data will be transferred to third parties, unless:

(i)      there is a legal obligation for Alterfin to transfer this Personal data;

(ii)     Alterfin has a legitimate interest to do so.


7.          Declarations and guarantees

7.1.     You guarantee that you are authorized (on behalf of the involved parties) to provide their Personal data to Alterfin, e.g. from you, your employees, consultants, partners, etc. You declare that, to the extent required, you have received the necessary authorization for the transfer of the above Personal data and that you will indemnify and compensate Alterfin for every related claim for damages.

7.2.     You are aware that every violation of this provision will be considered to be a serious fault.


8.          Rights


8.1.     The Privacy legislation grants everyone a number of rights relating to their Personal data. Everyone has the right, at no cost, to: 

(i)      inspect and request a copy of their Personal data;

(ii)     to correct their Personal data in the event of an error;

(iii)    to have their Personal data deleted in the event that:

  1. it is no longer required to reach the Goal;
  2. the consent is revoked and there is no other legal ground for the processing of the Personal data;
  3. an objection is made and there is no other legal ground for the processing of the Personal data;
  4. the Personal data is unlawfully processed;
  5. there is a legal requirement to delete the Personal data;

(iv)   limit the processing of the Personal data;

(v)    to transfer the Personal data to third parties;

(vi)   object to the processing of the Personal data, particularly in the framework of direct marketing;

(vii)   revoke consent on the basis by which Alterfin is entitled to process the Personal data;

(viii) to submit a complaint with the Data Protection Authority (‘Commission for the protection of privacy’ or ‘Privacy Commission’) in the event that the complaining party is of the opinion that the processing of their Personal data breaches the Privacy legislation.

8.2.  You must provide proof of identity (a copy of the front of your identity card) to exercise the above rights. For further questions you must send a written, dated and signed request to Alterfin S.C., Haachtsesteenweg 159, 1030 Brussels, or via email to privacy [at] alterfin [dot] be.


9.          Duration

Alterfin processes the Personal data for as long as necessary to reach the Goals as stipulated by the applicable legislation, and can do this until 10 years after the conclusion of the agreement you enter into with Alterfin.

10.       Storage and security


10.1.  The Personal data is stored at Alterfin or otherwise with its ICT provider, located in the EU.


10.2.  Alterfin commits, to the best of its ability, to taking, having taken or requiring third parties to take all reasonable measures to guarantee the protection of Personal data against loss, destruction, alteration or unauthorized access, via technical security provisions and a suitable security policy.


10.3.  You recognise and accept that the transfer and storage of Personal data is never without risk and consequently that any damage or loss you endure through the unlawful use of Personal data by third parties can never be recouped from Alterfin.


10.4.  In the event that you are aware of a data leak occurring, you are required to immediately and without delay inform Alterfin (c/o Ramprasad Srinivasan, Data Manager, or Loes Verbeeck, HR Officer) within 2 hours, via telephone and email at privacy [at] alterfin [dot] be.


11.       Liability


11.1.  Alterfin can only be held liable for damage arising from the processing of the Personal data as a consequence of an error or negligence on the behalf of Alterfin. Alterfin is hereby explicitly exempt from liability for the following damages: (i) damage as a consequence of force majeure, (ii) indirect damage or consequential damage, and/or (iii) any damage resulting from the errors, shortcomings or negligence of third parties.  


11.2. The total liability of Alterfin for infringements of this privacy policy and/or the Privacy legislation is in all cases limited to 2,500 (two thousand, five hundred) euro.


12.     Severability

12.1.  In the event that a provision in this Privacy policy is deemed unlawful or unenforceable, the provision will be changed to the extent required to make the provision lawful or enforceable, with the original meaning of the provision being retained to the greatest extent possible.

12.2.  Where possible, the provisions of this Privacy policy will be interpreted in such a manner that they are valid and enforceable under the applicable law. If one or more provisions from this privacy policy appears to be entirely or partially invalid, unlawful or unenforceable, the remainder of the provision and of this privacy policy will unabatedly remain in effect as if the invalid, unlawful or unenforceable provision was never included.


13.       Applicable law

13.1.  You agree that all matters between you and Alterfin in relation to Personal data and privacy, are exclusively governed by Belgian law.

13.2.      Any dispute in relation to the Personal data is subject to the exclusive competence of the courts of Brussels, with the exclusion of all other courts. In the event of a dispute, only the Dutch or French-language versions of the Privacy policy are valid.