VANERUM
Data Protection Policy
EXTERNAL - Version 1.0 – June 2024
Contents
- Introduction
- General information applicable to all our personal data processing
2.1 Who is the data controller?
2.2 How do we receive your personal data?
2.3 Do we share your personal data outside the European Union?
2.4 What rights do you have as a data subject?
2.5 Do you have a question or complaint?
- Processing that may apply to you
3.1 You are a customer of VANERUM
3.2 You are a prospect of VANERUM
3.3 You are a supplier or business contact of VANERUM
3.4 You are a visitor of the VANERUM website
3.5 You follow one (or more) of VANERUM's social media channels
3.6 You are an applicant at VANERUM
- Introduction
This is the data protection policy of VANERUM regarding the processing of data of persons external to our organization (e.g., customers, prospects, business contacts, suppliers, visitors of our buildings or website, participants in activities, and applicants).
This policy only applies to the processing of data of natural persons, not to legal entities.
The policy may be adjusted from time to time and any changes will be published on the website www.vanerum.be.
- General information applicable to all our personal data processing
2.1 Who is the data controller?
VANERUM NV with registered office in Belgium, 3290 Diest, Kleine Schaluinweg 7, company number 0421.014.939, telephone 0800 32 220 (hereinafter "VANERUM" "we" or "us") acts as the data controller for the processing of your personal data.
You can contact VANERUM to exercise your rights regarding your data. The contact point for the data controller can be found in section 2.5 of this policy.
2.2 How do we receive your personal data?
Typically, you provide us with your personal data yourself. This can happen, for example, when you use one of the contact forms on our website or share your contact details with us at a trade fair.
Sometimes we receive your contact details through the organization where you work (your employer, your client, etc.) or through an external partner of ours (e.g., a recruitment agency).
In some cases, we can also find, update, supplement, and improve this data via public sources (including the internet) and social networks.
2.3 Do we share your personal data outside the European Union?
Our servers are located in the EU and we will not transfer your personal data to countries outside the European Economic Area unless:
- at your request; or
- as necessary for the performance of the agreement between you and us; or
- as necessary for the establishment, exercise, or defense of legal claims; or
- in the context of using certain software applications. In such cases, an adequate level of protection is provided through the use of the European Commission's model clauses.
A copy of the appropriate safeguards can be obtained upon request.
2.4 What rights do you have as a data subject?
You have several rights:
- You always have the right to access your personal data. This allows you to check which personal data we process about you.
- You always have the right to rectify your personal data. This allows you to correct or supplement inaccurate or incomplete personal data that we process about you.
- You have the right to erase your personal data. This allows you to permanently delete the personal data we process about you. We are not always obliged to erase your personal data at your request - this right only applies in the cases and to the extent provided by law.
- You have the right to restrict the processing of personal data relating to you. This allows you to freeze the use of your personal data without deleting it. We are not always obliged to restrict your personal data at your request - this right only applies in the cases and to the extent provided by law.
- You have the right to object to the processing of your personal data. This allows you to object to the further processing of your personal data. We are not always obliged to honor your objection - this right only applies when we process your personal data based on our legitimate interest.
- You always have the right to withdraw your consent when the processing of your personal data is based on your consent.
- You always have the right to object to the processing of your personal data for direct marketing purposes.
- You have the right to data portability. This allows you to easily move, copy, or transfer personal data from one data controller to another. This right can only be exercised when the processing is based on your consent or an agreement with you.
You can exercise your rights by contacting the Privacy Compliance Officer, see below.
2.5 Do you have a question or complaint?
For all questions or complaints regarding the processing of personal data, you can always contact our Privacy Compliance Officer:
VANERUM NV
Attn: Privacy Compliance Officer
Kleine Schaluinweg 7
3290 Diest
Belgium
privacy@group-i3.com
You can also always submit a request or complaint to the supervisory authority where you reside. For Belgium, this is:
Data Protection Authority
Drukpersstraat 35
1000 Brussels
contact@apd-gba.be
Tel. +32 2 247 48 00.
https://www.gegevensbeschermingsautoriteit.be/
- Processing that may apply to you
We process your personal data for the following purposes and under the following conditions, depending on your capacity.
3.1 You are a customer of VANERUM
If you (the contact person at) our customer, we process your personal data for:
- Service provision (access to our services, e.g., leasing and training with certain products) based on the necessity to perform a contract with you. Without your personal data, we cannot perform the contract.
- Customer management (service delivery, customer relationship management, invoicing, collection, etc.) based on the necessity to perform a contract with you. Without your personal data, we cannot perform the contract;
- Direct marketing based on the necessity to serve our legitimate interest. Our legitimate interest is to serve you even better as a customer by keeping you informed of our activities and expertise.
- Placing photos of you (e.g., during a training) on our website or social media based on your consent to inform the public about our activities and services.
We keep your personal data for up to 10 years after the termination of our contract with you. For processing based on your consent or related to direct marketing, we process your data until withdrawal or unsubscribe. You can always withdraw your consent.
If you entrust us with personal data of others than yourself in the context of service delivery, we assume that you process those data lawfully and may share them with us.
For these purposes, we may share your personal data with:
- subcontractors processing personal data on our behalf (processors).
3.2 You are a training participant
If you are a training participant, we process your personal data for:
- Service provision based on the necessity to perform a contract with you. Without your personal data, we cannot perform the contract.
- Direct marketing based on the necessity to serve our legitimate interest. Our legitimate interest is to serve you even better as a customer by keeping you informed of our activities and expertise.
We keep your personal data for up to 10 years after the termination of our contract or, in the absence thereof, since the last interaction with you. For processing based on your consent or related to direct marketing, we process your data until withdrawal or unsubscribe.
For these purposes, we may share your personal data with:
- subcontractors processing personal data on our behalf (processors).
3.3 You are a prospect of VANERUM
If you are a potential customer, we process your personal data for the following purposes:
- Prospect management based on your consent (if you provided us with your contact details yourself) or based on the necessity to take pre-contractual measures (if you wish to become a customer).
- Direct marketing based on your consent. You can always withdraw your consent.
We keep your contact details as long as you do not withdraw your consent or up to 10 years after our last contact.
For these purposes, we may share your personal data with:
- subcontractors processing personal data on our behalf (processors).
3.4 You are a supplier or business contact of VANERUM
If you supply products or services to us or work at/for a supplier of products and services to us, we process your personal data for supplier management based on the necessity to perform a contract with the supplier. Without your personal data, we cannot perform the contract.
We keep your personal data for up to 10 years after the last delivery.
For these purposes, we may share your personal data with:
- subcontractors processing personal data on our behalf (processors).
3.5 You are a visitor of the VANERUM website
If you visit our website, we process your personal data:
- By answering questions, informing you about products and services to take pre-contractual measures at your request.
We keep your personal data for up to 1 year after our last contact with you.
For these purposes, we may share your personal data with:
- subcontractors processing personal data on our behalf (processors).
3.6 You follow one (or more) of VANERUM's social media channels
If you follow us via social media, we process your personal data:
- To inform you about our products and services, to take pre-contractual measures at your request.
- - Direct marketing based on your consent. You may withdraw your consent at any time.
For this purpose, we may communicate your personal data to:
- - subcontractors who process personal data on our behalf (processors);
- - the third parties mentioned in the cookie policy.
We keep your personal data for up to 1 year after our last contact with you.
3.7 You are an applicant at VANERUM
If you apply for a job with us, we process your personal data as an applicant for:
- Management and evaluation of your application in the context of taking pre-contractual measures;
- Maintaining a recruitment reserve based on the need to represent our legitimate interest. Our legitimate interest is to contact you later for a job opportunity if no vacancy is immediately available. If you do not wish to be included in the recruitment reserve, you can always object to this.
We keep your personal data for up to 10 years after your application.
For these purposes we can communicate your personal data to:
•subcontractors who process personal data on our behalf (processors)
3.8 In any case
In any case, we may also process your personal data for:
- Mergers and acquisitions, based on the necessity to protect our legitimate interest. Our legitimate interest lies in i) enabling the legal entities considering such an operation to become aware of each other's personal data, and ii) actually carrying out the merger or acquisition. We keep your personal data for up to a maximum of 10 years.
- Management of disputes, based on the law of July 30, 2018 (art. 10, §1, 1°) and the necessity to protect our legitimate interest. Our legitimate interest lies in safeguarding our rights in the context of disputes. We keep your personal data for up to a maximum of 10 years after the end of the dispute.
- Reporting of security incidents under relevant legislation (e.g., NIS law and GDPR), based on our legal obligations. We keep your data for up to 5 years after the incident is closed.
For these purposes, we may share your personal data with:
- Subcontractors processing personal data on our behalf (processors);
- Courts, lawyers, bailiffs, notaries, judicial experts, and other judicial actors, as far as necessary for the establishment, exercise, or defense of a legal claim;
- Judicial, police, or administrative authorities, when the law requires us to do so or as far as necessary for the establishment, exercise, or defense of a legal claim.
This document provides detailed information on how VANERUM handles the personal data of its customers, prospects, suppliers, website visitors, social media followers, and job applicants.