25 May 2018

PRIVACY POLICY – STIRR ASSOCIATES BVBA

1. INTRODUCTION

In this privacy policy, you will read everything about the way your personal data is collected and how it is handled by Stirr Associates. This explains where your data is stored and for which purposes your data is stored. In addition, you will also find all your rights regarding your data and how you can make use of these rights.

With this document, we want to offer transparency in the way we process, store and use your data.

2. STIRR ASSOCIATES

World class football players and other elite athletes deserve a world class partner. Someone who ensures their current career and their life afterwards. At Stirr Associates, we understand what drives the competitive mind of high profile athletes. We’re at home in their world of clubs, contracts and investments. We act as the CEO of elite athletes. Treating their career and ‘brand’ as a genuine business. Making sure they get the most out of their active career and afterwards.

At Stirr Associates we know also the ins and outs of the international sports market. With our extensive experience, we can act as a truly independent spokesmen and intermediary between clubs and players. Stirr Associates keeps the focus on the long-term relationship with the client and carefully helps him or her with the right career steps.

Stirr Associates addresses the challenges elite athletes are confronted with. We provide in depth know-how and management in all relevant domains: contracts, investments, wealth planning, tax, insurances, …

In order to provide these services there are situations where Stirr Associates collects and processes personal data of different data subjects. With this privacy policy, we want to inform the data subjects about this collecting and processing of their personal data and show them how they can indicate their wishes about their data.

If you have questions or are uncomfortable about the use of your data by Stirr Associates, please contact us!

3. WHERE IS YOUR DATA STORED?

We collect personal data amongst others of our clients, website visitors, suppliers, (potential) partners, job applicants and staff.

The processing of this personal data may, depending on the situation, be necessary for the execution of our agreements (article 6.1.b GDPR), can rely on the data subjects consent (article 6.1.a GDPR) or can be performed in our legitimate interest (article 6.1. .f GDPR).

This data is generally stored in digital format and/or in paper format. In both cases we have taken measures to protect this information as well as possible.

4. THE PURPOSES OF THE DATA PROCESSING

Personal data is collected by Stirr Associates for a number of purposes. These are explained below:

A. To communicate with you

We use your contact details to communicate with you in relation to our services, to answer your questions or to handle your complaints.

When you contact Stirr Associates via the website, you will be asked for the necessary information to contact you and to answer your question, such as your name and e-mail address.

B. For record keeping and to comply with legal and fiscal obligations.

We collect, store and use your data for internal business purposes, such as record keeping and to comply with our legal and fiscal obligations.

C. Providing know-how and assistance

As indicated earlier, Stirr Associates supports the athlete on multiple levels. If our client requests it, we can offer know-how and assistance for his or her insurances, tax declarations, investments, wealth planning….

In order to fulfil these services, we collect and store certain personal information from our clients. This concerns, among other things, identification data, financial data, national register number, lifestyle habits, composition of the family, ….

D. Act as facilitator between client and service providers

Dealing with banks, insurers, accountants, notaries, etc. can be a time-consuming and intensive activity. At Stirr associates we help the client with these complex matters. For this service, it is also necessary to store certain personal data (identification data, financial data, national register number, composition of the family, data concerning health,) and transmit it to the various service providers (banks, insurers, accountants,).

It is possible that we transfer this personal data to processors and/or other third parties within or outside the European Economic Area. This is of course only if it benefits the client and in light of the execution of our offered services, e.g. to insurers to draw up a policy for the client. We implement specific measures to this end in order to ensure an adequate level of data protection and to ensure its confidentiality.

Stirr Associates must always ask the explicit consent of the client when processing special categories of personal data (e.g. data concerning health,…).

E. Job placement services

At Stirr Associates we know the ins and outs of the international sports market. With our extensive experience, we can act as a truly independent spokesmen and intermediary between clubs and players.

In order to bring the different parties into contact with each other, we are sometimes compelled to keep personal information in that context and to pass it on from one party to another and vice versa.

5. STORAGE PERIOD

Our client’s data are only processed and stored by authorized persons and only to the extent that these data are necessary for the above-mentioned purposes. In general, this data will not be stored for longer than 2 years from the end of our contractual relationship with the client, unless a longer period custody is required by law (for example, to comply with statutory accounting obligations).

6. SECURITY

Stirr Associates must report any problem that occurs with the security of data of natural persons within 72 hours to all concerned. If this happens, we will make every effort to solve these problems as quickly as possible and we will update our security policy to avoid similar problems in the future.

Stirr Associates guarantees to take physical, technological and organizational precautions with a view to preventing unauthorized access to your personal data, as well as loss, misuse or alteration of your personal data. Only authorized persons have access to the respective relevant data on the basis of their assigned rights and documents.

Notwithstanding the safety policy of Stirr Associates, the controls it carries out and the actions it imposes in this context, an infallible level of safety cannot be guaranteed. No method of transfer or retransmission via the internet nor any method of electronic or physical storage is 100% secure. Stirr Associates cannot guarantee absolute safety in this context.

Stirr Associates will not disclose your personal information to third parties, unless it is necessary for the provision of the services of Stirr Associates. If it is necessary for Stirr Associates 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 and the GDPR.

It is possible that Stirr Associates may disclose your personal data to the competent authorities if Stirr Associates is required to do so by law or in the context of judicial or future legal proceedings and to safeguard and defend our rights.

7. YOUR RIGHTS

A. Right of access

You have the right to request your data that are recorded and stored at Stirr Associates at all times. You can do this by sending an e-mail to privacy@stirrassociates.com with a copy of your ID-card annexed. You will then receive an overview of your data.

B. Right to rectification

If your data is not correct or when it has changed, you have the right to have this rectified by Stirr Associates. You can do this by sending an e-mail to privacy@stirrassociates.com with a copy of your ID-card annexed.

C. Right to erasure

If you no longer want your data to be stored with Stirr Associates, you can request to have your data deleted. You can do this by sending an e-mail to privacy@stirrassociates.com with a copy of your ID-card annexed.

D. Right to restriction of processing

If you no longer want your data to be processed by Stirr Associates in a particular way, you can request to restrict the processing. You can do this by sending an e-mail to privacy@stirrassociates.com with a copy of your ID-card annexed.

E. Right to data portability

You also have the right to receive your personal data in a structured, standard and machine-readable form from us and, if possible, have it forwarded to another controller. You can request this by sending an e-mail to privacy@stirrassociates.com with a copy of your ID-card annexed.

F. Right to file a complaint

You have the right to file a complaint with the Belgian Data Protection Authority (Drukpersstraat 35, 1000 Brussels – commission@privacycommission.be ).