1. Who are we?
At Sitra Invest NV, we believe it is important to treat the personal data of every person on a safe and confidential manner. This privacy policy applies for the persons who are using this website, as well for the persons who wants to apply for job. It describes what personal data we process, on what legal basis and the reason why we do so.
Sitra Invest NV, with its registered office in Ypres and registered in the KBO under number 0508.516.461, is the controller. Sitra Invest NV declares that, as the controller, it complies with Belgian privacy legislation, as well as the provisions of the General Data Protection Regulation.
2. Definitions
The General Data Protection Regulation defines Personal Data as follows:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”
In addition, the General Data Protection Regulation defines processing as follows:
“any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”
3. Personal Data that we process
3.1 In the execution of services/administration of the website and newsletter
Sitra Invest NV processes personal data about you when you are using our services, when we are managing the website or when you subscribe to our newsletter. Below you will find an overview of the personal data that we process in this context:
- Surname;
- First name;
- E-mail;
- Phone number;
- Address;
- Location data;
- Data about your surfing behaviour across different websites (for example, because this company is part of an advertising network);
- IP address;
- Internet browser and device type;
3.2 In case of an application
Sitra Invest NV processes various personal data about you in the context of an application. In the event of a spontaneous application or application via the online application form, we will ask you for the following data:
- Surname;
- First name;
- E-mail;
- Phone number;
- Date of birth;
- Curriculum vitae;
- Motivation letter;
- Training and work experiences.
4. Why do we need these data?
Sitra Invest NV processes your personal data for the following purposes.
4.1 In the performance of our services / management of the website and newsletter
- Sending our newsletter and/or advertising brochure.
- Calling if necessary to carry out our services.
- Informing about changes to our services and products.
- Offer personalized services.
- Analysing your behaviour on the website in order to improve it and tailor our range of products and services to your preferences.
4.2 In the event of an application
- Sitra Invest NV will check whether the job suits you.
5. What legal basis do we have for these processing operations?
Sitra Invest NV uses the legal grounds below to justify these processing operations.
5.1 In carrying out our services/administration of the website and newsletter
- Processing is necessary for the performance of a contract.
- The legitimate interest of the company: optimising our website.
- Consent: sending the newsletter.
5.2 In case of an application
- The legitimate interest of the company: going through the application procedure.
6. Storage Limitation
6.1 In the performance of our services/administration of the website and newsletter
Unless these data are necessary for the performance of an agreement or you have given consent to keep these data, Sitra Invest NV will not keep these data longer than 6 months after receipt.
6.2 In the event of an application
If you and Sitra Invest NV enter into an employment agreement, the company will retain this data until 5 years after the end of the employment agreement. If Sitra Invest NV decides to stop the application procedure, the company will delete the personal data 1 year after that decision.
6.3 Exceptions
The periods mentioned in 6.1 and 6.2 do not apply if the data is kept longer because Sitra Invest NV is legally obliged to keep these data longer, or if these personal data are necessary for the establishment, exercise of defence of a legal claim.
7. Sharing with others
7.1 In performing our services / managing the website and newsletter
Sitra Invest NV manages the website itself. This means no data is shared with third parties for this.
7.2 In case of an application
Sitra Invest NV uses the Jobtoolz application during the application procedure. Sitra Invest NV has concluded a Data Protection Agreement with them.
8. The use of cookies
Sitra Invest NV uses functional, analytical and tracking cookies. A cookie is a small text file that the browser of your computer, tablet or smartphone stores the first time you visit the website. On the one hand, Sitra Invest NV uses cookies with a purely technical functionality. These ensure that the website works properly, for example remembering your preferred settings, and help us to make the website work properly. They also enable us to optimise our website. In addition, we place cookies that keep track of your surfing behaviour so that we can offer customised content and advertisements. You can unsubscribe from cookies by configuring your internet browser so that it no longer stores cookies. In addition, you can erase all information that is stored via the settings of your browser.
9. Your rights as a person
9.1 Right of access (article 15 GDPR)
The Data Subject has the right to access the personal data processed by Sitra Invest NV. He also has the right to know why that data is requested, how long we keep it, to whom we will send it, whether we send it outside the EEA, how the controller acquires it and whether we use it to make automated decisions.
Sitra Invest NV is obliged to provide the data in a comprehensible form, free of charge. If you request additional copies, we may charge an appropriate price for this. If you request this information digitally, we will, unless otherwise agreed, send you the information by e-mail.
To ensure that the Data Subject makes the request himself, we may ask you to send us a copy of the passport. To protect your privacy as much as possible, we ask you to make your passport photo, Citizen Service Number (BSN), card number and Machine Readable Zone unreadable on the copy.
We will respond to your request as soon as possible. Sitra Invest NV will reply within one month at the latest.
9.2 Right to rectification (article 16 GDPR)
For Sitra Invest NV, it is important that the information about the Data Subject is correct. That is why the person concerned always has the right to ask us to correct or supplement his/her personal data.
9.3 Right to object (article 21 GDPR)
The data subject has the right to object to the processing of his/her personal data for serious and legitimate reasons in accordance with Article 21 of the AVG.
This can only be done in cases where Sitra Invest NV processes the data subject's data on the basis of the legitimate interest of Sitra Invest NV or the public interest.
9.4 Right to restriction of processing (article 18 GDPR)
If one of the situations listed in Article 18 of the AVG occurs, the data subject has the right to have the processing of his/her data frozen. This puts the processing temporarily on hold.
9.5 Right to data portability (Article 20 GDPR)
The data subject has the right to obtain his/her personal data in a structured, common and readable form and/or to transfer them to other data controllers if this is technically possible.
9.6 Right to withdraw your consent (Article 7, 3 GDPR)
If the processing is based on your consent, you have the right to withdraw that consent at any time. This withdrawal has no negative consequences for you. Withdrawal of consent is only valid for the future and does not affect the lawfulness of the processing carried out prior to withdrawal.
9.7 Right to be forgotten (Article 17 GDPR)
The data subject has the right to have his/her data erased without unreasonable delay if:
1) The data is no longer necessary for the purposes for which it was collected.
2) The consent is withdrawn.
3) Personal data has been processed unlawfully.
4) The personal data must be deleted on the basis of a legal obligation of Sitra Invest NV.
5) The processing has been objected to and there are no compelling grounds for justification.
9.8 Automatic individual decision-making, including profiling (article 22 GTC)
The processing of your personal data does not include profiling. Nor will we subject you to any other automated decision.
10. Exercise of your rights
You can exercise your rights by contacting the person responsible for the processing:
Jens Six
J_Six@sitra-group.com
11. Complaints
You have the right to complain to the Data Protection Authority (“Gegevensbeschermingsautoriteit”) with address Drukpersstraat 35, 1000 Brussel, phone number +32 (0)2 2744800, Fax +32 (0)2 274 48 35, e-mail: contact@apd-gba.be
This is without prejudice to a remedy before a civil court.
If you, as a data subject, would suffer damage as a result of the processing of his personal data, he/she may bring an action for damages.