Groep De Wit is committed to handling the privacy and personal data of its customers, prospects, suppliers, the employees of the latter, its own employees, job applicants and the visitors of its website and social media in a responsible manner.
This privacy statement describes how we collect, process, store and protect personal data.
What personal data do we collect?
The personal data we collect may include, among other things:
- First and last name
- Username
- Address
- Telephone and/or mobile number
- Email address
- Date of birth
- Gender
- Job title and employer
- Marital status and family composition
- Career and education
- Remuneration
- Financial and tax data
- Specific requests expressed by the data subject
- Contractual arrangements
- IP address
- Browser type
- Language preference
- Posts on the social media applications we operate (Facebook, Instagram, blogs, forums, etc.)
- Data on online behaviour and preferences
- Audiovisual data
- Data relating to the products and services supplied
- Other relevant information
We may also collect personal data of a so-called “sensitive” nature (special categories of data), such as:
- Health (for example a disability or another specific medical condition we need to take into account (allergy, …) when the data subject enters our company buildings or when we organise a business lunch)
Our products, services and website are not aimed at or tailored to children. Consequently, apart from possibly those of our employees, we do not actively or intentionally collect and store personal data of children.
The personal data we process always depends on the specific circumstances, for example the nature of the service or product we are to provide, the legal obligations to which we are subject, the legitimate interests we have in doing so, or the specific consent you have given us.
From whom do we collect personal data?
We collect personal data from, among others:
- our customers, suppliers, business contacts and prospects (or our contact persons at these organisations);
- contact persons at government agencies and other (public) institutions;
- our employees and job applicants;
- visitors to our website and social media;
- visitors to our buildings;
- family members of our employees.
How do we collect personal data?
We collect personal data in various ways, in particular personal data we receive:
- from the data subject themselves;
- from the employer or principal of the data subject (for example when our customer or supplier is a company and the data subject is designated by that company as a contact person, or from the temporary employment agency that employs our temporary workers);
- from other parties (for example government agencies, recruitment agencies, etc.);
- through the use of our website, social media and other tools;
- from publicly available information.
Why do we process personal data?
Except in situations where we process personal data on the basis of consent, we may process personal data for the following purposes and on the following legal grounds (this list is not exhaustive):
Supply of products or services to our (potential) customers
We process personal data in the context of supplying our products and/or services to our (potential) customers (contract / pre-contractual phase / legitimate interests). The personal data is processed in the context of supplying products or services to the data subject themselves, to the employer or principal of the data subject (for example our customers and prospects) or to the contracting party of the data subject (for example our customers and prospects).
Compliance with our legal obligations
In some cases we are legally obliged to process certain personal data, for example:
- as an employer we are obliged, among other things, to collect certain data (such as the national registration number, marital status and family situation of our employees) and, where applicable, pass it on to the competent government authorities.
Administrative and financial processing
On the basis of our legitimate interests and legal obligations, we process personal data in the context of our own administrative, accounting and corporate law obligations.
Personnel administration and recruitment of employees
In the context of our personnel administration, we need to process data of our employees and former employees (contract / legal obligation).
With a view to hiring new employees, we collect personal data of job applicants (contract and, where applicable, consent for data provided to us voluntarily, but without necessity and unsolicited, by the applicant).
Direct marketing
We have a legitimate interest in processing personal data of our customers (or contact persons at our customers) for sending advertising messages, newsletters, invitations to commercial events and the like by electronic means, provided these relate to similar products and services.
For all other electronic marketing activities, we always ask for the consent of the data subject.
Finally, we have a legitimate interest in carrying out marketing activities by non-electronic means.
Collection of personal data via our website
We have a legitimate interest in processing personal data of data subjects:
- who leave their data on our website, in order to fulfil their specific request;
- who visit our website, in the context of managing and improving our website. In this respect, we refer to our cookie policy.
Internal risk analyses, audits and penetration tests
We have a legitimate interest in processing personal data in the context of internal risk analyses, audits and penetration tests, which take place either on our own initiative or on the initiative of a third party entitled to do so either by law (for example the competent data protection authority) or by contract.
To whom do we transfer personal data?
Except with your consent or where necessary for the supply of our product or service, we do not transfer personal data to commercial partners.
We also transfer personal data to our own processors (for example the social secretariat, ICT and social media partners, etc.) on the basis of a data processing agreement, to our other advisers acting as controllers (for example our lawyer, our accountant, etc.), to government and judicial authorities and to (professional or government) inspection services.
Except with your consent, where necessary for the provision of our services, or where we are legally obliged to do so (for example pursuant to an enforceable judgment or ruling), we do not transfer data to recipients established in third countries (non-EU countries).
If we need to transfer personal data to a recipient established in a third country for any of the above reasons, we will strictly comply with the legal obligations regarding such transfers.
How long do we retain personal data?
Depending on the applicable case, we retain personal data:
- until the end of our liability period after providing our products and/or services;
- for as long as we are legally obliged to retain the personal data;
- in the event of a legal dispute, administrative or arbitration proceedings, until a final decision has been reached in those proceedings, unless we are legally obliged to retain the personal data for longer;
- in all other cases, for a reasonable and proportionate period.
How is your personal data secured?
We have developed a security policy, which is tested and adjusted at regular intervals, under which technical and organisational measures have been taken aimed at:
- raising and periodically updating awareness among our employees and other staff about the handling of personal data (through checks and periodic training);
- restricting access to personal data (both organisationally and technically);
- securing personal data (through appropriate technical measures, taking into account the state of the art, the associated costs and the risks of the processing, such as encryption, anti-virus software, firewalls, transmission via secure connections, etc.);
- ensuring the accuracy of the data;
- ensuring the confidential treatment of personal data;
- preventing, detecting and remedying, as far as possible, data breaches (i.e. accidental or unlawful destruction, loss, alteration, disclosure of or access to personal data transmitted, stored or otherwise processed).
What are your rights as a data subject?
As a data subject whose personal data we process, you have the following rights:
- Right to transparency (the right to be informed in clear and understandable language about the processing of your personal data by our offices);
- Right of access, rectification and erasure of your personal data;
- Right to data portability in a commonly used machine-readable format;
- Right to withdraw previously given consent;
- Right to request restriction of processing or to object to processing;
- Right to lodge a complaint with the competent data protection authority.
Please note that these rights are not always absolute, that in certain circumstances we are entitled or even legally obliged to continue processing your personal data, and that we may therefore not always be able to (fully) comply with your request. In that case, we will inform you accordingly.
You may exercise these rights free of charge, except in case of abuse, in which case we are entitled to charge administrative costs to comply with your requests.
For all questions regarding the exercise of your rights, please contact:
Changes to this privacy statement
We reserve the right to amend this privacy statement at any time in order to bring it in line with (changes to) relevant legislation, national and international official positions and court rulings.
You can always find the most recent version of this privacy statement on our website.