1. Who we are
“We”, “us” or “our” means Zebanza, a devision of Exitas NV with its registered office at Prins Boudewijnlaan 43, 2650 Edegem and with company number BE0544.808.121. We act as controller for the personal data we gather through your use of our website.
(a) Via-mail: firstname.lastname@example.org, to the attention of our Data Protection Officer;
(b) By post: to DPO, Zebanza, Prins Boudewijnlaan 43, 2650 Edegem.
2. How we use and collect your personal data
Personal data is defined as any information relating to an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.), that can be used to directly or indirectly identify a natural person.
The personal data we collect, is collected and used for the purposes as listed hereunder:
(a) In the event you use the contact or job application form on our website, we will use your personal data in order to reply to your query, via e-mail or telephone.
(b) We process your personal data for the purpose of supporting the website and enhancing your user experience, which includes ensuring the security, availability, performance, capacity and health of the website.
(c) We process your personal data to enforce or exercise any rights that are available to us based on the applicable law, such as use for the establishment, exercise or defense of legal claims.
The following categories of personal data can be distinguished:
(d) Contact data: in the event you make use of the contact or job application form, you will be asked to provide the following information: name, e-mail address, phone number (optional), and any personal data that you choose to put in the designated blank field (please do not provide us with any sensitive information, such as health information, information pertaining to criminal convictions, or credit card/account numbers). This is information that is provided directly by you.
(e) Profile data: If you make use of the job application form on our website, you will be asked to provide a resume (upload file) and motivational letter (in text box). Please do not provide us with any sensitive information, such as health information, information pertaining to criminal convictions, or credit card/account numbers. This is information that is provided directly by you.
(f) Usage data: We collect personal data regarding your activities on our website: IP address, device ID and type, referral source, browser type, operating system, geographical location, length of visit, page views, or information about the timing, frequency and pattern of your service use. This information may be aggregated and used to help us provide more useful information regarding the use of our website. This is personal data that is automatically collected through your use of the website when all cookies are allowed. A subset of the above mentioned data can be collected when a selection of cookie types is allowed. When cookies are denied by you, we will only track functional cookies (cookies that are strictly necessary for the normal operation of our website).
The legal basis for the processing of your personal data:
Contact data (provided directly by you in order for us to contact you): consent
Profile data (provided directly by you in order for us to contact you in the context of a job application): consent
Usage data: consent (based on the consent in our cookie banner)
You will, at all times, have the right to withdraw your consent. This will, however, not affect the lawfulness of any processing done prior to the withdrawal of consent.
Your personal data will solely be used for the purposes as set out in this article.
3. Retention of your data and deletion
Your personal information will not be kept for longer than is necessary for a specific purpose. However, considering it is not possible for us to specify a period in advance, the period of retention will be determined as follows:
(a) Category of personal data
(b) The purpose for which the personal data is processed
In the event you withdraw your consent or you object to our use of your personal data, and such objection is successful, we will remove your personal data from our databases. Please note that we will retain the personal data necessary to ensure your preferences are respected in the future.
The foregoing will, however, not prevent us from retaining any personal data if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.
4. Your rights
This article lists your principal rights under data protection law. We have tried to summarize them for you in a clear and legible way.
The right to access
You have the right to receive from us a copy of your personal data we have in our possession, provided that this does not adversely affect the rights and freedoms of others. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies.
The right to rectification
If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed.
The right to erasure (right to be forgotten)
In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include:
(a) The personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed;
(b) You withdraw your consent, and no other lawful ground exists;
(c) The processing is for direct marketing purposes;
(d) The personal data have been unlawfully processed; or,
(e) Erasure is necessary for compliance with EU law or Belgian law.
There are certain exclusions to the right to erasure. Those exclusions include where processing is necessary,
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation; or,
(c) for the establishment, exercise or defense of legal claims.
The right to restrict processing
You have the right to restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes), if:
(a) You contest the accuracy of the personal data (and only for as long as it takes to verify that accuracy);
(b) The processing is unlawful and you request restriction (as opposed to exercising the right to erasure);
(c) We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; or,
(d) You have objected to processing, pending the verification of that objection.
In addition to our right to store your personal data, we may still otherwise process it but only:
(a) with your consent;
(b) for the establishment, exercise or defense of legal claims;
(c) for the protection of the rights of another natural or legal person; or,
(d) for reasons of important public interest.
We will inform you before we lift the restriction of processing.
The right to data portability
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
You also have the right to have your personal data transferred directly to another company, if this is technically possible, and/or to store your personal data for further personal use on a private device.
The right to object to processing
You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
(a) (a) The performance of a task carried out in the public interest or in the exercise of any official authority vested in us;
(b) The purposes of the legitimate interests pursued by us or by a third party.
If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
The right to complain to a supervisory authority
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In Belgium, you can submit a complaint to the Authority for the protection of personal data (Privacy Commission), Drukpersstraat 35, 1000 Brussel or via https://www.gegevensbeschermingsautoriteit.be/burger/acties/klacht-indienen.
5. Providing your personal data to others
If you register via one of the forms on our website (contact or job application form), we may pass on your data to our HR/Recruitment colleagues (employees of our cluster company) to perform the services for which you registered.
We may also disclose your personal data in the event such disclosure is required or necessary in order to fulfil a legal obligation. We may also disclose personal data in order to protect your vital interests or the vital interest of another natural person.
We do not disclose your personal data to our social media partners. We do, however, make use of social media plugins to direct you to our social media channels and to allow you to interact with our content. These social media channels are Facebook, LinkedIn and Twitter. In the event you click such link, such social media service provider may collect personal data about you and may link this information to your existing profile on such social media.
We are not responsible for the use of your personal data by such social media service provider. In such case, the social media service provider will act as controller. For your information only, we have included the relevant links (these may be changed from time to time by the relevant service provider):
(a) Facebook: http://facebook.com/about/privacy;
(b) LinkedIn: http://linkedin.com/legal/privacy-policy;
(c) Twitter: http://twitter.com/privacy;
6. International transfers
We will not transfer your personal data outside of the European Economic Area.