1 We care about your Privacy
1.1 With this information notice concerning the protection of privacy and the Processing of Personal Data (« Privacy Notice ») we wish to inform you, as a (prospective) client, supplier, authority, applicant or other business relationship (« Data Subject ») about the Processing of your Personal Data and the rights you can invoke in this respect, according to the European General Data Protection Regulation (« GDPR ») and other privacy and data protection local legislation interpreted in a large sense (e.g. laws, regulations and other similar legal instruments) (« Applicable Laws »).
1.2 All terms used with a capital letter that are not defined in this Privacy Notice, shall have the meaning provided for in the Applicable Laws.
2 Our Processing of your Personal Data
2.1 ELCOS BVBA, with registered office at 2240 Massenhoven (Belgium), Zagerijstraat 24 (VAT BE0879259666, Register of Legal Entities Antwerp, BE, E.U.) (hereinafter « ELCOS ») Processes Personal Data about you, your employees, directors, agents or other representatives (hereinafter « Data ») according to the provisions as described below.
2.2 If you are a legal entity, please inform your employees, directors, agents and other representatives of our Processing of their Personal Data, sufficiently before sending us any Data. Every time you transfer Data to us in the context of our business relationship, you must ensure that such transfer is done lawfully and in line with Applicable Laws.
3 Who is involved in the Processing ?
3.1 ELCOS acts as the Data Controller in the meaning of the Applicable Laws with respect to the Processing of your Data, which means that we determine the purposes and means of the Processing and that we will be the primary responsible for ensuring that this Processing is done in a lawful, transparent and secure manner.
3.2 We guarantee that any person acting under our authority and having access to your Data (e.g. our employees), (i) only Processes such Data in accordance with our instructions and (ii) have in particular committed themselves to confidentiality.
3.3 ELCOS may engage subcontractors as « Processors » in the meaning of Applicable Laws with respect to the Processing of your Data (e.g. IT service providers, …). In this case, we only call on Processors providing sufficient guarantees on the lawful, transparent and secure Processing of your Data.
3.4 We may also be required to transfer your Data to other Recipients such as public authorities, enforcement authorities, public prosecutors and courts, our attorneys, advisors or other service providers, auditors or other third parties, if and only insofar we estimate in good faith that such disclosure is reasonably necessary or useful (e.g. in order for us to comply with a legal obligation or procedure, in the context of (the preparation of) a merger, acquisition or reorganization of our company, for quality control, to broaden or improve our activities, our products or services, to protect our rights and interests or the security and safety of our organization, our infrastructure, our business, our clients or partners or the public in general, fully taking into account our obligations under the Applicable Laws. 3.5 ELCOS does not intend to transfer your Data outside of the European Economic Area.
4 Which data will be Processed, where do these originate from, for what purposes and for how long will the Data be Processed ?
4.1 We will collect and process the following categories of Data : identification data, financial specificities, educational data, professional data, image data (e.g. from events), family composition / marital status, hobbies and personal interests. In addition to the above categories of Data, we may Process other types of Data voluntarily provided to us or that you provide us with in the context and in view of our business relationship (e.g. in emails or other communications), as well as the information we deduce or generate in this context.
4.2 It may be possible that we receive or collect indirectly Data about you, for example, from your employer (client or provider of ELCOS), from public authorities or from public sources such as social networks (e.g. LinkedIn) or public websites.
4.3 We will Process the Personal Data for the following purposes (the « Purposes»): supplier management, customer management, public relations management, recruitment and human resources management, management of possible disputes (conflicts, disputes and protests), protection of our organization, our activities, our partners, our visitors and the public (security and safety) and communication and (direct) marketing, including the management of our websites and other communication channels. Prior to processing the Data for other purposes than those described in this Notice, ELCOS will update this Notice to inform you of such changes and your rights in view of such changes.
4.4 We Process your Data based on one of the following legitimate grounds:
- 1. The Processing is necessary for the performance of a contract to which you are party or in order to take steps at your requests prior to entering into a contract;
- 2. The processing is necessary for compliance with our legal obligations;
- 3. The processing is necessary for the purposes of the legitimate interests pursued by ELCOS or by a third party, such as:
- The good execution and continuation of our activities and the broadening or improvement of our products and services, in line with applicable laws, regulations and best practices;
- Building and maintaining a good business relationship with you, including being able to inform you and communicate with you on our products, services and events that we consider relevant taking into consideration your previous purchases/sales or requests, including the sending of our newsletters;
- The protection of our organization, our business, our partners, our visitors and the public in general (security and safety);
- 4. You have consented to the Processing of your Data for one or more specific purposes.
4.5 We will only Process your Data for as long as it is necessary for the Purposes listed above. In this respect, we have established a data retention policy in the framework of our internal data protection policy.
5 Which rights do you have with respect to your Data?
5.1 ELCOS, with support from its Processors, implements appropriate technical and organizational measures to ensure that the Processing of your Data is performed in accordance with Applicable Laws, in particular ensuring an appropriate level of security to protect your Data from loss, misuse, alteration or destruction taking into account.
5.2 By contacting us, as concerned Data Subject, you may request (with an acceptable proof of identity) taking into consideration the limits and conditions of these rights under the Applicable Laws:
- 1. to confirm as to whether or not Data concerning you are being processed by us and, where that is the case, you may request access to or receipt of your Personal Data;
- 2. to correct inaccurate or complete incomplete Data relating to you;
- 3. to erase Data or to restrict the processing of (certain) Data relating to you;
- 4. to oppose yourself to the Processing of Data relating to you;
- 5. to have your Personal Data transferred to another controller; and
- 6. for a Processing based on your consent, to withdraw such consent.
Before responding to your request, we will verify if your request is sufficiently founded, if it is not excessive and if all other conditions under the Applicable Laws are fulfilled, and if it is the case, we will revert to you with an answer within 30 working days.
6 Any further questions?
6.1 In case you have any questions with respect to the Processing of your Personal Data, you can contact us through the following contact information: ELCOS Privacy Contact – Phone +32 3 206 74 81 – Email: firstname.lastname@example.org 6.2 Please note that you have the right to lodge a complaint with the Belgian Data Protection Authority or another supervisory authority of your choice at any time if you are of the opinion that the Processing of your Personal Data by ELCOS infringes any Applicable Laws. For further information, we refer you to the website of the Belgian Data Protection Authority: https://www.dataprotectionauthority.be.