Privacy policy

POLICY REGARDING PERSONAL DATA PROTECTION WITHIN THE VINÇOTTE ORGANISATION

Vinçotte is aware of the importance of the privacy and the protection of the personal data of Vinçotte's clients, suppliers and visitors to the Vinçotte (Academy) website (respectively www.vincotte.be and www.vincotte-academy.be ). With this policy, Vinçotte wishes to provide you with the following information regarding the processing of your personal data when visiting these websites or within Vinçotte's organisation.

Identity and contact details of the controller

The Vinçotte group consists of different companies which all have a joint website (www.vincotte.be), a specific website for Vinçotte Academy (www.vincotte-academy.be), as well as one for Vinçotte Jobs (www.vincotte-jobs.be). The following operational companies belong to the Vinçotte group:

The registered office of the aforementioned companies is located at Belgium, 1800 Vilvoorde, Jan Olieslagerslaan 35.

In principle, the data controller within the meaning of the General Data Protection Regulation ("GDPR") is Vinçotte International NV/ SA unless expressly provided otherwise. If you have questions about aspects relating to personal data protection, you can reach Vinçotte by e-mail via gdpr@vincotte.be.

For general questions to the contact person of the data controller, please fill in the most appropriate contact form found here: vincotte.be/contact

Processing of personal data when you visit the website of Vinçotte

When you simply visit the website of Vinçotte, no personal data is collected about you other than cookies. For more information about the cookies used on our website, Vinçotte refers you kindly to its cookie policy.

However, if you wish to make use of an online Vinçotte service, Vinçotte will in most cases be obliged to request certain personal details from you and to collect them. Through the website of Vinçotte you can use the following services:

• The newsletter, where you can subscribe to the following services as you choose: an e-zine (overview newsletter based on your interests), NewsFlash (immediately the latest news in your inbox based on your interests), invitations, wishes, legislation changes, MyVinçotte movies, Industry Day Presentations, Vinçotte Action Plan, Vinçotte Academy and Vinçotte Innovation.

• MyVinçotte (customer portal) by using a private login for a specific part of the website reserved for customers
• Requesting a quote
• Making or rescheduling an appointment
• Contacting customer service for customer-related questions
• Giving a compliment or reporting a complaint
• Job application (via the website of Vinçotte Jobs)
• Other questions

The website of Vinçotte Academy gives you the possibility to:

• Register for a training;
• Contact Vinçotte Academy if you would have a question related to a training;
• Via the same contact page, subscribe for the newsletter and/ or give your approval to be contacted by phone.

On the other hand, via the website of Vinçotte Jobs, you can:

• Apply for a job (spontaneously or for a specific vacancy). We kindly refer you to the specific personal data protection policy on Vinçotte's jobsite that appears when applying online and this policy can also be found below on the website.
• Contact Vinçotte for a general enquiry. Regarding this possibility, reference is made to this general policy.

The purpose of processing personal data received by Vinçotte via Vinçotte, Vinçotte Academy's or Vinçotte Jobs’ website depends on the service and may include the following: responding to the request of the sender, direct marketing, sending newsletters, sending e-mail notifications, ...

Regarding the legal ground of this processing, Vinçotte refers to what is explained under the chapter "Processing of personal data within the Vinçotte organisation". In principle, the legal ground will be the consent of the data subject, since the data subject will have shared its personal data for the specific purpose.

The duration of the processing of personal data of website visitors is as follows, explained below per service:

• For the newsletter, and the choices made in this respect by the applicant: as long as no request to unsubscribe has been made by the person concerned and also confirmed by Vinçotte
• MyVinçotte (customer portal): for the duration of the agreement + legal retention period
• Requesting a quotation: as long as necessary for this purpose of processing + legal retention period
• Making or rescheduling an appointment or registering your participation at a training: duration of the agreement + legal retention period
• Contacting customer service: as long as necessary in function of that purpose of processing
• Giving a compliment or reporting a complaint: as long as necessary in function of that purpose of processing
• Applying for a job: see personal data protection policy on the website of Vinçotte Jobs
• Other questions via a contact form: as long as necessary in function of the purpose of the processing

The personal data of website visitors that are processed may be of all kinds, explained below by service:

• The newsletter and the choices made in it by the applicant: e-mail address, name, language, company, date of subscription, sectors the user is interested in, version of privacy policy agreed to. Note that only the e-mail address, name, company and date of subscription are considered personal data.
• MyVinçotte: see below under "Customer data"
• Making or rescheduling an appointment or registering your participation at a training: see below under "Customer data"
• Contacting customer service: see below under "Customer Data"
• Giving a compliment: e-mail address, name, language, company and function
• Reporting a complaint: surname and first name, address, e-mail, phone number, company, sector, customer number, VAT number and report number
• Applying for a job: see personal data protection policy on the website of Vinçotte Jobs
• Other questions via a contact form: (if requested) surname and first name, e-mail, postal code, company and mobile phone number

If Vinçotte collects personal data via one of its websites, Vinçotte will take the necessary security measures to guarantee the safety of your personal data. The personal data are only processed on a need-to-know basis.

Processing of personal data within the organisation of Vinçotte

Within its organisation, Vinçotte processes personal data of various categories of persons such as customers, suppliers, job candidates and staff and other third parties. In what follows, a distinction is made to according to the category of persons involved.

Purpose of the processing:

• Customer data: providing Vinçotte's services, exercising its activities, accounting, marketing, sending newsletters, sending e-mail notifications, customer management, customer service, customer management via customer portal (My Vinçotte), event registration and executing agreements with customers.
• Supplier data: purchase of goods and services, supplier management, accounting, marketing, execution of agreements with suppliers.
• Employee and job candidates personal data: see data protection policy on the Vinçotte Jobs site.
• Data of third parties: reply to the question asked via a contact form, prospect management, identifying potential suppliers, marketing, public relations, ...

Legal ground of the processing:

Depending on the specific purpose of the processing, the personal data collected from the data subject are in principle processed on the basis of one of the following legal grounds:

• The data subject has given its consent. Vinçotte will inform the data subject at least in advance about the purpose for which consent is requested, what personal data will be collected for processing, the right to withdraw consent and the transfer to third countries.
• Consent as a legal ground will apply in case of sending newsletters, direct marketing, e-mail notifications, a job application and replying on a question when it is asked via a contact form.
• The processing is necessary for the performance of a contract to which the data subject is party or in order to take measures at the request of the data subject prior to the conclusion of a contract.
• This ground will apply if it concerns the execution of services, the purchase of goods or services, conduct of business, accounting and customer/ supplier management.
• The processing is necessary to comply with a legal obligation imposed on the organisation.
• This includes reference to the personal data protection policy on Vinçotte's jobsite.
• The processing is necessary for the protection of the legitimate interests of Vinçotte as controller or of a third party, except where the fundamental rights and freedoms of the data subject concerning the protection of its personal data outweigh those interests.

Exceptionally, the following legal ground may also apply:

• The processing is necessary to protect the vital interests of the data subject or of another natural person;
• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in the organisation acting as the processing controller

Vinçotte assures that it always invokes a legal ground when processing personal data for a specific purpose. If you have any questions about the applicable legal ground, you can always contact Vinçotte by e-mail addressed to gdpr@vincotte.be.

Duration of processing and storage:

Personal data are processed and stored by Vinçotte for the period necessary in function of the purpose and nature of the relationship between Vinçotte and yourself. Data are usually kept for the duration of the contract, plus the legal retention period if applicable (at least five years for customer data and seven years for invoicing data) and the duration of any dispute if applicable.

For each category of personal data, a general distinction can be made as follows:

• Customer data: duration of the agreement + legal retention period
• Supplier data: duration of the agreement + legal retention period
• Employee and job candidates personal data: see data protection policy on the Vinçotte Jobs site
• Third party data: personal data not linked to a contractual relationship will be deleted after a period of 18 months if there is no longer a legitimate interest on Vinçotte's part.

Type of personal data that may be processed:

• Customer data: name, (professional) address, function, (primary) language, (professional) telephone number, (professional) e-mail address, gender, VAT number, bank account number of the customer.
• Supplier data: name, (professional) address, function, (primary) language, (professional) telephone number, (professional) fax number, (professional) e-mail address, gender, VAT/business number, bank account number of the supplier.
• Employee and job candidates personal data: see data protection policy on the Vinçotte Jobs site
• Data of third parties (where applicable): name, (professional) address, function, (primary) language, (professional) telephone number, (professional) e-mail address, gender, date of birth, VAT number.

Recipients or categories of recipients of the collected personal data

In order to fulfil its purpose, Vinçotte is obliged to process your personal data or have them processed internally. In principle, personal data will only be transferred to the recipients on a need-to-know basis and appropriate technical and organizational security measures have been taken to protect your personal data.

Internally, your personal data will only be processed by Vinçotte employees who must process your personal data (e.g. your contact person, management, the planning department, the accounting department, the IT department, the legal department, marketing, etc.).

If needed, your personal data can be shared externally with various other companies that provide services to Vinçotte, such as insurance companies, banks, medical/ technical/ legal advisors and other professional advisors, etc. Vinçotte has concluded a data processing agreement with all persons/ entities that can be regarded as processors in accordance with the (data protection) legislation or contractual safeguards have been agreed in order to ensure that your personal data are adequately protected. Whenever necessary, your data will also be shared with government agencies.

In principle, Vinçotte does not transfer personal data to (organizations in) third countries outside the European Economic Area. Should this still be necessary, Vinçotte will take the appropriate protective measures in accordance with the GDPR with a view to protecting the personal data.

Your rights with regard to your personal data

With regard to your personal data, you have:

• the right to obtain confirmation from Vinçotte as to whether or not your personal data is being processed. If the answer is positive, you may request to access your personal data.
• the right to have your personal data rectified or supplemented if the personal data held by Vinçotte are incorrect or incomplete in your opinion.
• the right to request Vinçotte to erase your personal data in the circumstances and under the conditions as determined by (data protection) legislation, with the exception of legal obligation, justified interest or performance of a contract.
• the right to request Vinçotte to restrict the processing in certain cases determined by (data protection) legislation.
• the right to obtain the personal data you have provided to Vinçotte in a structured, customary and machine-readable form or to have these transferred by Vinçotte to another controller.
• the right to object to a processing operation in the cases provided for by (data protection) legislation.
• the right, in the cases determined by (data protection) legislation, not to be subjected to automated individual decision-making that has legal consequences for you or that significantly affects you otherwise, such as the evaluation of personal aspects relating to the performance of work, reliability, creditworthiness, etc.
• the right to withdraw your consent at any time if you have authorized Vinçotte to process your data for a certain processing purpose.

You can exercise your rights by sending an e-mail to gdpr@vincotte.be.

If your rights seem to be violated, you also always have the right to lodge a complaint with a supervisory authority. This is for Belgium the Data Protection Authority, that can be contacted via its contact options (see its website).

Protocol agreement regarding the exchange of personal data between Vinçotte (Controlatom) and the FANC

Vinçotte NV/ SA and the Federal Agency for Nuclear Control (FANC) signed a protocol agreement for the exchange of data between Vinçotte and the FANC within the framework of the specific activities of Controlatom. This protocol agreement applies to the access to, the communication and the transmission of personal data between Vinçotte (Controlatom) and the FANC in connection with the activities of Controlatom as specifically described in the protocol agreement. In application of article 20, §3 of the Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data, Vinçotte complies with its obligation of disclosure through this communication.

Declaration concerning the personal data provided – modifications of the policy

You declare that all data provided by you are sincere and correct and that Vinçotte will not be liable for any damage resulting from errors in the data provided by you.

Vinçotte may at any time, for various reasons, make improvements, additions or changes to this policy. The most up-to-date version can be consulted on the website at all times. Vinçotte invites you to check the changes regularly.

By making your personal data available through these means, you declare that you have read, understood and agreed to this policy.

We would like to thank you in advance for your interest in Vinçotte's services.