PRIVACY STATEMENT

1. Who are we?

1.1. Excentis as data controller

With this statement (hereafter referred to as the ‘Statement’) we wish to inform you why and how your personal data are collected and processed by Excentis NV, with registered office at 9000 Gent, Gildestraat 8 and company number 0471.961.418 (hereafter collectively referred to as ‘We’ or ‘Excentis’).

Our contact details can be found in point 10 of this Statement.

We are responsible for processing the personal data that We request and use. As data controller, We take the measures that ensure that you:

  • continue to be informed about our processing of your personal data and your rights;
  • retain control of the personal data that We process;
  • are able to exercise your rights relating to your personal data;

More information on your rights can be found in point 9 of this Statement.
 

1.2. Data Protection Officer

We have also appointed a data protection officer. This is an expert on the protection of personal data who offers an additional guarantee for the correct processing of your personal data by us.

You can contact the data protection officer through the channels set out in point 10 of this Statement.

2. What information do We collect about you?

2.1. Personal data

‘Personal data’ means all information relating to a given living natural person. The type of personal data We collect depends on the services you request and include, where applicable, data about you and/or your representatives, personnel, self-employed staff and/or directors (hereafter jointly also referred to as ‘You’ or ‘Your’).

If We receive Your personal data from Your representatives, personnel, self-employed staff and/or directors, You must inform them of the existence and content of this Statement, including our duties, their rights and the way in which they can exercise these rights.

In particular, We collect administrative data and contact details. This makes it possible for us to identify You or contact You, or We can do business with You if You are a customer, a supplier or a business partner. These personal data may be contact details such as Your name, address, telephone number, email address, or Your bank account number.

We collect and process none of the so-called sensitive data, namely:

  • personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership;
  • genetic or biometric data (e.g. facial images and fingerprints);
  • health-related information;
  • data relating to sexual behaviour or sexual orientation.

If such sensitive personal data were to be provided to us, We would not use them and We would delete them.

2.2. Minors

It is not our intention to process the personal data of minors.

3. Why do We need Your data?

3.1. Provision of services and customer relationships

What does this purpose entail?

We may use Your personal data to be able to create Your account as a customer and to carry out our activities or services.

Which personal data do We process to this end?

We collect and process Your name, email address, telephone number and address.

3.2. Information and commercial communication

What does this purpose entail?

We wish to be able to inform You of our services, events or relevant news items. This can be done at Your explicit request, or if We suspect that You would be interested in or benefit from a service.

You will receive our direct marketing communication if You have given Your express consent. In particular, We will request Your explicit consent if You are not a customer of ours.

However, even if You do not consent You may still receive offers or advertising from us, especially if You already have an existing customer relationship with us. In this connection, We base ourselves on our legitimate interest.

If You do not wish to receive any advertising from us You can make use of Your right to object to direct marketing as stated in point 9.2 of this Statement.

Which personal data do We process to this end?

We collect and process Your name, email address, telephone number, address and data relating to the areas of interest that You have indicated.

3.3. Because it is necessary to be able to function as a company

What does this purpose entail?

This objective amounts to what is called a ‘legitimate interest’. We do indeed still have a number of legitimate interests on which the processing of personal data is based. This happens only after We have made the assessment that in any case the balance between our legitimate interests and the potential impact on Your privacy will not be disturbed.

If You nevertheless have objections to this processing You can exercise Your right to object as mentioned in point 9.3 of this Statement.

For example, personal data are processed in various situations:

  • Personal data can serve as proof (archives);
  • Personal data may be used to establish, exercise, defend and indemnify our rights or those of the persons who may represent us, for example, in the event of disputes;
  • Personal data can be used for the administration, (risk) management and monitoring of our organisation, including for matters relating to compliance (e.g. money laundering, fraud prevention and investigations and privacy), risk management, risk functions and inspection, complaint management and internal and external audit;
  • Personal data can be used to support and simplify customers’ purchasing, use and termination of services, including preventing You from having to fill in information that You previously provided.

3.4. Profiling

Your personal data are not used for profiling purposes.

3.5. Cookies

Our website www.excentis.com uses cookies, which are small text files stored on Your device, and similar technologies. You can find more information about the use of cookies in our Cookie Statement.

4. Do We request Your consent for processing?

4.1. General

Your personal data may only be lawfully used and processed by us if one of the following conditions is met:

  • The use of Your personal data is necessary for the implementation of an agreement that You have concluded with us or, at Your request, to take the necessary steps to conclude an agreement with us.

This forms the basis of the processing purposes stated in point 3.1 of this Statement.

  • We have Your express and free consent to use Your personal data for a particular purpose.

For example, We will request Your permission to contact You for direct marketing purposes, as mentioned under point 3.2 of this Statement, if You do not yet have a customer relationship with us.

  • The use of Your personal data is necessary for the purposes of our legitimate interests, to the extent that this is balanced against Your interests and rights;

We base the processing necessary to operate as a company on our legitimate interest, as mentioned under point 3.3 of this Statement, and to be able to contact our existing customers for direct marketing purposes, as mentioned under point 3.2 of this Statement.

  • We may be required by law to process certain data and, in particular, to pass them on to the relevant authorities.

5. With which other persons do We share Your personal data?

  • Only our employees who effectively need access to perform their duties have access to Your data. These persons act under our supervision and responsibility.
  • We also call on external suppliers that carry out certain processing operations for us so that We can offer You our products and activities, such as, among other things, IT services, financial, accounting and similar other services. Since such third parties have access to personal data within the scope of the services We have requested, We have taken technical, organisational and contractual measures to ensure that Your personal data are only processed and used for the purposes stated in point 3 of this Statement.
  • Only if We are legally obliged to do so can Your personal data be provided to supervisory institutions, tax authorities and investigation services.

6. Where are the data stored and processed?

Your data will not be transported outside the EU and, in any case, We will ensure that the minimum legal requirements and security standards are respected at all times. If We suspect that Your data will be stored and processed outside the EU, We will explicitly inform You of this and ensure that the same level of protection is used as is applicable within the EU.

Apart from these cases, Your personal data will never be transferred to or made available to third parties and will only be used for our purposes. Other companies can therefore not use Your data, e.g. to send You advertising.

7. How long do We retain Your personal data?

We only store Your data for as long as this is necessary for the purposes for which the data are to be used as stated in point 3 of this Statement. Any deviations or clarifications of this principle are explicitly stated under the various purposes mentioned in item 3 of this Statement.

Since the need to retain data may vary by the type of data and by the purpose of the processing, the actual retention periods may vary considerably.

We can hereby inform You that We take the following criteria, among others, into account when determining the retention periods:

  • How long are the personal data needed for the requested service to be provided?
  • Have We established and announced a specific retention period?
  • Have We been given permission for a longer retention period?
  • Do We have a legal, contractual or similar obligation to retain the data?

As soon as Your data are no longer required and We do not have a legal obligation to retain them, We will permanently erase them or, if this is not possible, anonymise them in our systems.

Your personal data will be retained and used for as long as necessary to comply with our legal obligations, to settle disputes or to enforce our agreements.

8. How do We protect Your personal information?

Your personal data are considered to be strictly confidential. We take the appropriate technical and organisational measures to protect the provided and collected personal data from destruction, loss, unintended alteration, damage, accidental or unlawful access or any other unauthorised processing.

9. What are Your rights?

9.1. The rights of access, rectification, erasure and transferability of data and of objection

9.1.1. The right to access Your personal data

You have the right at all times to access and inspect Your personal data processed by us. We will provide You with a copy of Your personal data in this connection free of charge if You so request.

To exercise Your rights, please refer to point 9.3 of this Statement.

9.1.2. The right to rectify Your personal data

You have the right at any time to have incorrect, incomplete, inappropriate or outdated personal data erased or rectified.

To exercise Your rights, please refer to point 9.3 of this Statement.

9.1.3. The right to withdraw Your consent

If the processing is based on Your consent as set out in point 4.1., then You have the right to withdraw this consent at any time.

To exercise Your rights, please refer to point 9.3 of this Statement.

9.1.4. The right to object to certain processing

If Your personal data are processed for statistical purposes, then You have the right to object to the processing of Your personal data for reasons relating to Your specific situation.

To exercise Your rights, please refer to point 9.3 of this Statement.

9.1.5. The right to have Your personal data erased

You are entitled to have Your personal data deleted. Based on this, if You no longer wish to have a relationship with us You can ask us to stop using Your personal data. However, We may keep personal data that are required for purposes of proof.

Under this right of erasure, You also have the right to ask us at any time to stop using Your personal data that are processed on the basis of Your consent or our legitimate interest. Due to legitimate interests, We may still continue to process Your personal data after weighing Your interests against ours, unless You decide to terminate Your relationship with us.

To exercise Your rights, please refer to point 9.3 of this Statement.

9.1.6. The right to transfer personal data

With respect to the processing of Your personal data based on Your consent or because it is necessary in order to provide the requested products or services, You may ask us to forward Your personal data to You - in a structured, commonly used and digital form - so that You can keep Your data for personal (re)use, or to forward Your data directly to another data controller, to the extent that this is technically feasible for us.

To exercise Your rights, please refer to point 9.3 of this Statement.

9.1.7. The right to limit certain processing operations

You may request that We limit the processing of Your personal data in any of the following cases:

  • if You dispute the accuracy of Your personal data, You may request a limitation of its processing for a period that enables us to verify the accuracy of Your personal data;
  • if the processing is unlawful and You object to the erasure of the personal data and You request us instead to limit their use;
  • if We no longer need Your personal data for the processing purposes referred to in point 3, but You still need Your data for the establishment, exercise or defence of a legal claim;
  • if You objected to a processing operation, We will continue processing pending the verification whether our legitimate grounds override Yours.

If You have obtained the right to have the processing of Your data limited, We will no longer perform any operations with the personal data concerned, other than the storage of these data.

9.2. The right of objection to direct marketing

As indicated above in point 4.1, We request Your consent to address commercial information, advertising or personal proposals to You (via direct marketing campaigns or electronic newsletters). You have the right to object to the processing of Your data for direct marketing purposes if You do not wish to receive such communications from us (any longer). In this case, We will no longer process Your data for direct marketing purposes. Your request will be carried out as soon as possible.

To exercise Your rights, please refer to point 9.3 of this Statement.

If You have exercised Your right to object, You may, if You wish, again allow direct marketing activities via the same channels.

We draw Your attention to the fact that Your exercise of the right to object does not prevent us from contacting You, where appropriate, for any other purpose, including the execution of the contract, in accordance with this Statement.

9.3. How You can exercise Your rights

To exercise the rights mentioned above You may send us a written request:

  • by email: info@excentis.com
  • at the following postal address: 9000 Gent, Gildestraat 8

When exercising Your right, We request that You clearly state the right to which You wish to appeal and any processing operation(s) You oppose or which consent You wish to withdraw.

9.4. Issues to consider when exercising rights

We wish to inform You that the objection to certain processing operation(s) or the withdrawal of Your consent for certain processing operations involving Your personal data may result in You no longer being informed of, or being able to use, activities or services that We offer.

10. How can You submit questions or complaints?

If You have a question or complaint about our processing of personal data please contact us through the following channels:

  • by email: info@excentis.com
  • at the following postal address: 9000 Gent, Gildestraat 8

If You are not satisfied with our response, if You have any comments regarding the exercise of Your rights or if You believe that our processing of Your personal data does not comply with the legislation, then You are entitled to file a complaint with the Data Protection Authority. All information on this matter can be found at https://www.privacycommission.be.

11. Amendments to this Statement

We may amend or supplement this Statement as We deem necessary.

If significant changes are made to this Statement the date of amendment of the Statement will be provided and We will also notify You accordingly and provide You with a copy of the amended Statement.

We also encourage You to review this Statement periodically to find out how We process and protect Your personal data.