September 11, 2020

DATA PROTECTION POLICY – CONTACTS AT SUPPLIERS AND CUSTOMERS AND OTHER BUSINESS CONTACTS 

SABCA Group understands the importance of the protection of personal data. Present policy outlines the handling and processing of the personal data we collect through our commercial activities. 

In this policy: 

SABCA Group” means SABCA NV, Haachsesteenweg 1470, B-1130 Brussels (Belgium) and any company that is directly or indirectly owned by SABCA NV. 

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 (...). 

1. Scope 

The companies part of the SABCA Group 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 Group wishes to tell you which personal data we collect from you and how your data will be used following the commercial activities between the SABCA Group and the company you represent in a way to try to ensure you the proper handling of your data. 

2. Collected personal data 

Generally the following personal data is collected when doing business: 

  • Name, surname, title, 
  • Contact details (professional e-mail and phone number); 
  • Company; 
  • 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). 

SABCA Group may also collect publicly accessible information in order to verify information we have collected and to manage and expand our business. 

3. Why do we collect this information 

SABCA Group 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 

4. The legal basis for processing personal data 

The above mentioned personal data are processed based on the legitimate interest of the SABCA Group in order to run the business efficiently. 

When your personal data is processed because you gave your consent (for example by handing over your business card or equivalent), you have the right to withdraw your consent at any time. You can do this by contacting us (see infra). 

5. How will your information be used and shared 

5.1. 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. 

5.2. SABCA Group 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. 

5.3. We may also share your personal information with third parties who perform functions on our behalf and provide services to us such as professional advisors or IT consultants carrying out development work on our business technology systems. 

5.4. 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. 

5.5. Your personal data will not be sold or rented to third parties. 

6. Transfer of your personal data 

When your personal data is transferred to a Group company, another company when doing business or to an external service provider that processes data on our behalf, 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.

7. How long do we keep personal data 

Your personal data are processed as long as the company which you represent is likely to be in a business relationship with the SABCA Group, or as long as you don’t withdraw your given consent. 

8. Your rights 

8.1. You have certain rights in relation to personal information we hold about you: 

  • 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. 

8.2. 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. 

8.3. 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 the SABCA Group, Haachtsesteenweg 1470, B-1130 Brussel, T : 02.729.58.62, E-mail : dataprotectionofficer@sabca.be. 

8.4. 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: contact@apd-gba.be.