DATA PROTECTION NOTICE FOR CLIENTS, SUPPLIERS AND THIRD PARTIES
SABCA understands the importance of the protection of personal data. The present Notice (hereinafter “the Notice”) contains important information on the processing of your personal data by SABCA (hereinafter “SABCA”) through our commercial activities.
In this Notice:
“SABCA” means SABCA NV, Haachsesteenweg 1470, B-1130 Brussels (Belgium) and SABCA LIMBURG NV, Dellestraat 54, 3560 Lummen (Belgium).
“Data Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Data Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
“Personal Data” means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, location data or an online identifier (...).
SABCA may process personal data of the persons of contact of suppliers, customers or any other business contacts when doing business.
In application of the applicable data protection laws, such as the General Data Protection Regulation 2016/679 and national data protection laws, SABCA wishes to tell you which personal data we collect from you and how your data will be used following the commercial activities between SABCA and the company you represent in a way to try to ensure you the proper handling of your data.
1.2. Addressee of this Notice
This Notice applies to :
- our suppliers and/or business partners
- our existing clients, prospects and former clients
- members, staff, shareholders, beneficial owners of our corporate clients/suppliers
- third parties whose personal data are provided to us by our clients/suppliers
- any other business contacts.
Insofar as we are likely to collect and process data from third parties communicated to us by you; we ask you to kindly inform the said third parties of the existence of this Notice so that they may be aware of the processing we carry out on their data and of their rights.
2. Data controller
2.1. Data controller
In the context of its activities, SABCA is required to process your data in its capacity as data controller insofar as it determines the means and purposes of the processing(s).
Contact details of the data controller:
- SABCA NV: 02.729.55.11
- SABCA LIMBURG NV: 02.729.75.89
- SABCA NV: Chaussée de Haecht 1470, B-1130 Brussels
- SABCA LIMBURG NV: Dellestraat 54, 3560 Lummen.
2.2. Data Protection Officer
We have also appointed a data protection officer.
The data protection officer's task is to inform everyone about the data processed. He/she provides advice and ensures compliance with the regulations in force, including the GDPR.
You may contact the Data Protection Officer for any question relating to the processing of your Data and the exercise of your rights.
Telephone : 02.729.58.62
Postal address : Chaussée de Haecht 1470, B-1130.
3. Collected personal data
Generally the following personal data is collected when doing business:
- Identification data (name, surname, title, etc.)
- Contact details (professional e-mail address and phone number);
- Financial data (bank accounts, etc.;
- Professional / Skills and training;
- Any other additional/optional information you give us when we have contact with you (by telephone, by e-mail or at trade fairs or events).
In principle, SABCA does not collect or process so-called sensitive data, i.e. :
- 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);
- data relating to health;
- data relating to sexual behaviour or sexual orientation.
Generally speaking, we process personal data which we receive from you or from your employer/the company you represent in the context of our business relationships.
SABCA may also collect publicly accessible information in order to verify information we have collected and to manage and expand our business.
4. Why do we collect this information
SABCA collects the abovementioned information for the following purposes:
- Managing business relationship with the company that you represent
- Managing our own business arrangements
- Public relations and marketing
We may use your personal data to inform you about our activities, services or newsletters, which we believe may be of interest to you.
We will contact you if you explicitly ask us to do so, or if we believe that you may be interested in a service or that a given service could benefit your company/organisation.
If you do not yet have a business relationship with us, you will only receive our marketing communication if you have explicitly given us your permission to contact you.
If you already have a business relationship with us or have already provided your contact details you could receive advertisements from us without your explicit permission. This is the case, for example, for anyone who has signed up for the newsletters and/or for contact details provided during commercial exchanges. In this context, we are guided by our legitimate interest to conduct our business relationship.
- Ensuring security of property and persons and business continuity (through our surveillance security system when you visit our premises)
The processing of your data is justified and necessary within the framework of our legitimate interest, and in particular to secure our premises and protect our assets.
As such, we collect and process the photos/videos taken by our surveillance cameras system when you visit our premises.
5. The legal basis for processing personal data
The personal data mentioned above are processed and collected only insofar as they are necessary to achieve the purposes described in point 4 and insofar as the processing operation(s) :
- is (are) necessary for the execution of a contract that you/your company have/has concluded with SABCA and/or in order to carry out, at your request, the necessary steps for the conclusion of a contract with SABCA;
- is (are) necessary for the purposes of the legitimate interests of SABCA .
- is (are) necessary to enable us to comply with a legal obligation to which SABCA is subject.
- has (have) been explicitly accepted by you. When your personal data are processed because you gave your consent, you have the right to withdraw your consent at any time. You can do this by contacting us (see infra).
6. How will your information be used and shared
6.1. Your personal data will only be transferred to the collaborators on a need-to-know basis, which means the recipients who have to carry out the various processing operations with regard to the above-mentioned purposes.
6.2. SABCA may share your personal data with companies in the group and/or our affiliates for example, where another Group company is also providing goods or services to or purchasing goods or services from the company you represent.
6.3. We may also share your personal information with third parties who perform functions on our behalf and provide services to us such as IT, legal, financial, accounting and other services. Given that these third parties have access to personal data in the context of the performance of the requested services, we have taken technical, organizational and contractual steps in order to ensure that your data are only processed and used for the purposes mentioned in point 4 of this Notice.
6.4. We can disclose your personal data to comply with our legal obligations or in the interests of security, public interest or law enforcement. We can disclose data in connection with actual or proposed litigation, or to protect our property, security, people and other rights or interests.
6.5. Your personal data will not be sold or rented to third parties.
7. Transfer of your personal data outside the EU/EEA
SABCA does not transfer your personal data outside the European Union (EU) or the European Economic Area (EEA). If this is the case, you will be informed accordingly. If your personal data is transferred to a third party in a country that is not deemed to provide a similar level of protection for individuals’ rights in relation to their personal data as in the European Economic Area (EEA), your information will be covered by a data transfer agreement in a form approved by the European Commission or as provided by the General Data Protection Regulation 2016/679.
8. How long do we keep personal data
Your personal data will be retained for as long as is necessary to achieve the purposes mentioned in point 4 of this Notice, or as long as you do not withdraw your previously given consent.
Since the need to retain data depends on the type of data and the purpose of the processing, the retention periods may vary.
Below are the criteria on which we base our retention periods:
- the length of time necessary to achieve the purpose;
- We comply with the retention periods as laid down by law;
To defend ourselves or to take legal action (e.g. according to the limitation periods).
Images recorded by surveillance cameras in our premises are kept for thirty days from the visit, except otherwise requested by the authorities.
9. Data security
Your data is considered to be strictly personal. To this end, SABCA has taken all appropriate technical and organisational measures to protect them from any destruction, loss, accidental alteration and any damage, accidental or illegal access or other unjustified processing of data.
10. Your rights
10.1. You have certain rights in relation to personal information we hold about you:
- Right to be informed: You have the right to be informed, at the latest at the time of collection of your data, about the processing we carry out, your rights relating to it and the exercise of these rights. To this end, we have drawn up this Notice.
- Right of access: You are entitled to see the information hold about you and to obtain a copy of the personal data SABCA has about you.
- Right of Correction or Completion : If your personal data have changed or are incorrect, you are entitled to ask SABCA to rectify, complete or erase the incorrect or incomplete data SABCA holds about you.
- Right of Erasure: In certain circumstances, you have the right to request that your personal data is erased e.g. if the personal data is no longer necessary for the purposes for which it was processed or when you have withdrawn your consent and there is no other legal basis for the processing.
- Right to object to or restrict processing: Furthermore, and in certain circumstances, you have the right to obtain the restriction of the processing of your personal data and to object to the processing of your personal data. This right cannot be exercised when the processing is required for the execution of legal obligations.
- Right of Data Portability : You have also the right to receive your personal data which you have provided to SABCA and transmit these data to another data controller.
10.2. We may require you to provide verification of your identity to ensure that you have a legitimate right to make the request and to verify that we provide the answer to the person that has the legitimate right to send us one of the abovementioned requests and to obtain the information.
Please note that in certain circumstances as provided by law we may withhold access to your information or that we may not grant your request where we have the right to do so under applicable data protection legislation.
10.3. You have the right to lodge a complaint with the Belgian data protection authority, “Gegevensbeschermingsautoriteit” – “Autorité de protection des données”, Drukpersstraat 35, 1000 Brussel, T: +32 (0)2 274 48 00; F: +32 (0)2 274 48 35; E: email@example.com.
10.4. If you wish to obtain more information regarding the processing of your personal data or if you wish to exercise your rights, please contact the Data Protection Officer of SABCA, Haachtsesteenweg 1470, B-1130 Brussel, T : 02.729.58.62, E-mail : firstname.lastname@example.org.
We ask you to clearly indicate which right you wish to invoke and to which data processing you wish to oppose or limit or which consent you wish to withdraw.
10.5. When you exercise your rights, no fee will be charged unless we consider the request to be manifestly unfounded or excessive (this will be the case, for example, when it is a repeated request).
However, we may charge you a reasonable sum not exceeding our reproduction costs for any additional copies requested.
For any request relating to your rights, we will respond to your request within one month. However, this period may be extended to two months if the request proves to be complex and/or because of the number of requests we have to deal with. In the event of an extension of this period, we will inform you of this by giving you the reason for this decision.
11. Modification of the present Notice
We reserve the right to modify or supplement this Notice if necessary.
In the event of significant changes, the date of modification will be updated and a copy of the new Notice will be posted on the SABCA website.
We encourage you to review this Notice periodically to be aware of how we treat and protect your data.