II. Who is responsible for the processing?
III. Which categories of personal data does ALSICO processes?
IV. For what purposes does ALSICO process your personal data?
1. legal obligations
2. Contractual relationships between ALSICO and you as a customer
3. Justified interests of ALSICO
4. Specific justified inerest of ALSICO: conventional direct marketing
5. Your acceptance for the processing and the sending of electronic advertising (electronic direct marketing)
V. To whom does ALSICO transfer your personal data?
VI. How long are kept your personal data?
VII. How are your personal data secured?
VIII. what are your rights in the processing of your pesonal data?
1. Right to access, to correct, to limit, to erase, to transfer data and to object
2. Right to object to the sending of electronic advertising
3. Right to lodge a complaint
Personal data means all kinds of information that allow you to identify yourself, directly or indirectly, as a natural person.
2. ALSICO attaches significant importance to the protection of your personal data and fully respects your privacy. Therefore, ALSICO treats and protects your personal data in a lawful, proper and transparent manner.
In processing your personal data, ALSICO fully abides by the law, i.e. he European Regulation nr. 2016/679 of April 27th, 2016, about the protection of natural persons regarding the processing of their personal data and the free circulation of these data and to the withdrawal of the directive 95/46/EG (better known as ‘GDPR’) or any other legislative act amending it.
More information about your personal data can be found at the Belgian data protection authority.
3. We invite you to carefully read this statement so that you know and understand the way ALSICO manages this matter.
This statement is updated regularly. The most recent version is available on our website. We will inform you through the usual communication channels when significant changes are made.
II. WHO IS RESPONSIBLE FOR THE PROCESSING?
4. ALSICO is responsible for the processing of your data.
Name and address data:
Telephone number: +32 55 23 71 71
As such, ALSICO is your interlocutor and is accountable towards the Data Protection authority to justify the processing of your personal data. ALSICO defines the purposes for the processing of your data including the employed means and the processing characteristics.
III. WHICH CATEGORIES OF PERSONAL DATA DOES ALSICO PROCESSES?
6. Hereunder you will find an overview of the categories of personal data that ALSICO may process. It is possible that other data are processed, if they are needed or useful for the continuation of the contractual relationship with ALSICO.
The context in which ALSICO obtains or processes these data is given below. This table must be read together with the description of the purposes for which ALSICO processes these data.
|Customer Identification Data||Name, address, landline or mobile phone number and e-mail address||You provide these data when you ask for information, become a customer or when you register to use (online) ALSICO’s services, for any identification or usage.|
|Data linked to the execution of service provisioning by ALSICO||Payment transactions, including names and account numbers, communication and references, card numbers, etc.||These data relate to the payments you make to ALSICO|
|Data about ALSICO’s operations with you||Information related to your contacts with ALSICO, by phone, e-mail, fax, etc. and your interactions on the webpages regarding ALSICO, its services or its partners, social networks, etc.||These data originate from contacts of any type between you and ALSICO (events, subscription to a newsletter, social networks, etc.)|
|Data regarding behavior and preferences of the customer||Info about your behavior and preferences regarding the usage of communication and relation channels, info about your preferences and lifestyle, private or professional projects, hobbies, etc.||These data result from choices that you expressed or by ALSICO driven analyses, in compliance with this declaration and its legal obligations.|
7. ALSICO does not process data revealing your race or ethnical origins, political opinions, religious or ideological considerations, trade union membership, health and life data or sexual orientation, genetic data or biometric data.
IV. FOR WHAT PURPOSES DOES ALSICO PROCESS YOUR PERSONAL DATA?
8. ALSICO collects and processes your personal data only for the purposes described below. ALSICO makes sure that only the necessary and relevant data, for a particular purpose, are processed.
ALSICO processes your data in the situations authorized by law, more precisely:
- To comply with ALSICO’s legal obligations
- To execute a contract with you or, on your request, to take some measures before the conclusion of this contract
- For the representation of the legitimate interests of ALSICO, where these interests are balanced against your fundamental rights and freedoms.
- In specific cases and with your consent, as a response to a specific and unambiguous request, preceded by clear an understandable information; at any time and in accordance with the law, you can withdraw your consent.
1. LEGAL OBLIGATIONS
9. ALSICO must comply with legislation that under specific circumstances requires it to process your personal data within the framework of its activities. . This obligation can lead to collaboration of ALSICO with authorized authorities and/or third-parties and a possible transfer of some of your personal data.
This includes amongst others:
- The obligation to answer legitimate questions from the control authorities such as the Federal Public Service Economy and the National Bank
- The obligation to respond to a formal request from the Belgian tax and judicial authorities
The list of the legal obligations for which ALSICO needs to process your data is not exhaustive and is subject to changes.
2. CONTRACTUAL RELATIONSHIPS BETWEEN ALSICO AND YOU AS A CUSTOMER
10. Sometimes, before concluding contracts, ALSICO needs to obtain and process specific data to:
- React to your request,
- Assist you in providing information and at the conclusion of the contract,
- To follow-up a request, to evaluate the suitability and the risks associated with a possible contract.
11. In the context of current contracts or contract management, ALSICO must process several data, in particular to comply with administrative and accounting requirements.
In this context, your personal data can be send to various ALSICO divisions to persons who are not directly responsible for the relation with you or for the execution of a given contract.
More precisely, ALSICO processes your data during the execution of the contract as follows:
- Management of current contracts/ordered services
- Central management and a global view of the customers
ALSICO may process your personal data for additional purposes in the context of our relationship and the execution of contracts.
3. JUSTIFIED INTERESTS OF ALSICO
12. ALSICO also processes your data for the realization of its justified interests. In doing this, ALSICO aims at a fair balance between the necessity to process data and the protection of your rights and freedoms, including the protection of your privacy.
Personal data are, amongst others, processed to:
- Personalize ALSICO services
- Improve the quality of our services by:
– Evaluation and improvement of processes, including campaigns, simulations and sale, by means of several tools such as statistical analyses, satisfaction surveys and various research methods
Improvement of existing (or in development) ALSICO products, based on ALSICO customers surveys, statistics, tests and customer feedback through social networks (Twitter, Facebook), linked to ALSICO,
– Monitor ALSICO’s activities, including the sales turnover, the number of appointments in our offices, the number of calls and visits to ALSICO’s website, the type of customer questions, etc.
- Prepare studies and statistics, with anonymization and pseudonymizing of the concerned person,
- Train our employees using practical examples for the purpose of illustration, including the recording of some telephone conversations
- Store evidence (archives)
- Determine, exercise, defend and preserve ALSICO’s rights or those of all persons it represents, for instance in case of recovery procedures or litigation.
4. SPECIFIC JUSTIFIED INEREST OF ALSICO: CONVENTIONAL DIRECT MARKETING
13. ALSICO implements customer segmentation – mainly to your specific needs – to offer you, for instance, products and services matching your professional and personal situation. Therefore, ALSICO may, among other things:
- Evaluate the services you already use and your social demographic data (age, family, revenues, etc.)
- Analyze your behavior through several channels (visits/meetings, e-mails, website visits, messages on our website), deduct your preferences and in doing so, personalize the information and the webpages that you visited,
- Adjust the advertisements on the website pages so that they match the interest you have shown when visiting our website, social networks, in an office or somewhere else (e.g. events where ALSICO was present),
- Simplify yhe completion of forms by filling in certain fields with already known data and asking you to verify the accuracy of these data and to update them if necessary,
- Evaluate the key moments when specific services could be the most convenient to you
- Send you by post or phone personalized advertising.
5. YOUR ACCEPTANCE FOR THE PROCESSING AND THE SENDING OF ELECTRONIC ADVERTISING (ELECTRONIC DIRECT MARKETING)
14. ALSICO may process your electronic contact details (namely your mobile phone number and e-mail address), to send you personal information, advertising or proposals via direct marketing and newsletters.
V. TO WHOM DOES ALSICO TRANSFER YOUR PERSONAL DATA?
15. ALSICO treats your personal data with the greatest care and shares your data only to offer you the best services in the execution if its mission.
ALSICO may send your data to other entities of the group, domestically and abroad, namely to the other entities of the group assisting ALSICO in the execution, the management and the control of the activities, including reporting, support and computer security or for the provisioning of specific services and products.
16. In some cases, ALSICO is obliged by law to share your data with third parties, including:
- Public and supervisory institutions when there is a legal obligation to transfer information
- Judicial investigative bodies at their explicit request.
ALSICO transfers also your data to specific service providers to help in:
- The design and the maintenance of computer equipment and internet applications
- The provision of advertising and communication services, including online and social network providers
- Preparing reports and statistics, document printing and the design of products or services.
- The commercialization of its activities, the organization of events and the management of the customer communication
ALSICO has also to pass on your data to online and social network providers, used by ALSICO for the offering of advertising services.
Your personal data may also be communicated to bailiffs or lawyers in the case of legal procedures.
In the aforementioned cases, ALSICO makes sure that third-parties only get access to the personal data necessary to accomplish the specific tasks. ALSICO also makes sure that third-parties commit to use your personal data in a safe and confidential manner, in accordance with ALSICO’s instructions and its data protection policy.
17. ALSICO keeps your data within the EEA. No data will be transferred outside the EEA.
VI. HOW LONG ARE KEPT YOUR PERSONAL DATA?
18. ALSICO will not keep your personal data longer as necessary to fulfil the purposes for which the data is collected.
This period is linked to ALSICO’s legal and fiscal obligations, but also to the legal obligation to keep your data outside the retention period as proof or to react to requests of information from competent bodies, such as:
- 10 years as part of ALSICO’s contractual liability
Outside these periods, your personal data are removed or anonymized.
VII. HOW ARE YOUR PERSONAL DATA SECURED?
19. ALSICO applies strict norms to protect data under its control against unauthorized or unlawful processing and against unintentional loss, destruction or damage.
ALSICO takes therefore technical and organizational measures, such as encryption, antivirus, firewalls, access control, thorough selection of employees and providers to avoid and detect all inadequate access, loss or disclosure of your personal data.
In the unlikely and unfortunate event that your personal data controlled by ALSICO are compromised by infringement of the data protection, ALSICO will act immediately to identify the cause of such infringement and act through adequate corrective measures. If necessary, ALSICO will inform you of the incident according to the prevailing legislation.
VIII. WHAT ARE YOUR RIGHTS IN THE PROCESSING OF YOUR PESONAL DATA?
1. RIGHT TO ACCESS, TO CORRECT, TO LIMIT, TO ERASE, TO TRANSFER DATA AND TO OBJECT
20. For the above-mentioned purposes, you have:
- Right to access your personal data at ALSICO. This means that you can ask ALSICO, if they process your personal data, for which purposes these are processed, which data categories are processed and to whom they are communicated.
- Right to rectification, if you notice that your personal data are incorrect or incomplete.
- Right of limitation, if you object to the rightness of your personal data and this for a period giving ALSICO sufficient time for verification.
- Right to erase your personal data. When your contract with ALSICO terminates, you can ask ALSICO to erase your personal data if the purpose for which they were collected is no longer necessary. At any time, you have the right to ask ALSICO to erase your personal data they process based on your acceptance (except if ALSICO has another legal foundation for the processing) or based on a justified interest of ALSICO (unless prevailing justified compelling grounds for the processing). In any case, ALSICO can retain these data if, for proof, they would be required in legal claims.
- Right to transfer data that you provided to ALSICO, if your personal data are processed based on an agreement or based on your acceptance of sending electronic communication, provided that these personal data are processed by means of automated processes. This right allows you to ask ALSICO to send your personal data to yourself or to send them immediately to another data processing controller, if technically possible for ALSICO.
You have the right to object to the processing of your data for purposes mentioned in article IV.3 and IV.4. In the case of IV.3, ALSICO may continue to process your personal data if there are compelling legal grounds for the processing outbalancing your interests, rights and freedoms or are fundamental to the setting, execution or the foundation of a legal claim.
You can exercise your right by sending a written request, dated and signed and with a copy of your ID enclosed, to NV ALSICO, 9600 Ronse, Zonnestraat 223-229 or by e-mail to firstname.lastname@example.org or by using the contact form on our website: https://www.alsico.eu/en/contact-us/.
2. RIGHT TO OBJECT TO THE SENDING OF ELECTRONIC ADVERTISING
In IV.5 we asked for your permission to process your electronic contact details and to use them for sending you commercial information, advertisements or personalized proposals (through direct marketing campaigns or electronic newsletters). This is valid for communications to your mobile telephone numbers and e-mail address.
You have the right to object to the processing of your personal data for direct marketing and to refuse any further sending of such advertisements.
You can inform us by:
- Sending an e-mail and a copy of your ID to NV ALSICO: email@example.com
- By letter with a copy of your ID to 9600 Ronse, Zonnestraat 223-229
- By clicking on the ‘unsubscribe’ button at the bottom of an e-mail or electronic newsletter sent by ALSICO
- By introducing a request through the contact page on our website https://www.alsico.eu/en/contact-us/
The execution of the right to object does not forbid ALSICO to contact you for any other purpose, including for a legal obligation or the execution of the contract, in accordance with this statement.
3. RIGHT TO LODGE A COMPLAINT
If you have complaints regarding the processing of your personal data, please contact us:
- By post: NV ALSICO, 9600 Ronse, Zonnestraat 223-229
- By e-mail: firstname.lastname@example.org
- By phone: +32 55 23 71 71
- By fax: +32 55 23 71 79
- Through the contact form on our website: https://www.alsico.eu/en/contact-us/
23. You can also file a complaint with the Data Protection Authority, by mail at Drukpersstraat 15, 1000 Brussels or by e-mail at Data Protection Authority email@example.com or by phone at number +32 2 274 48 00.
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