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Privacy statement

Introduction – who we are

Schelstraete Delacourt Associates Group (referred to below as “we” or “us”) takes your privacy very seriously and considers it important for your personal data to be treated with the necessary care and confidentiality at all times.

Schelstraete Delacourt Associates Group is made up of the following partnerships:

  • Schelstraete Delacourt Associates NV/SA, with registered office at Bagattenstraat 165, 9000 Ghent (Belgium) and registered in the KBO/BCE Crossroads Bank for Enterprises under number 0439.928.256;
  • Schelstraete Delacourt Associates BV, with registered office at Bavinckhouse - Prof. J.H. Bavincklaan 2, 1183AT Amstelveen (the Netherlands), and registered in the KVK under number 24253488;
  • Schelstraete Delacourt Associates SARL, with registered office at Rue de l'Industrie 22, 8399 Windhof (Luxemburg), registered in the RC under number B223190.

This privacy statement explains why we require your personal data and what we do with it. If you have any questions after reading this privacy statement, you are always welcome to contact us.

This statement only applies for the personal data that Schelstraete Delacourt Associates Group processes as data controller. This means that we determine the purpose and resources for processing your personal data.

We understand ‘processing of personal data’ as meaning any processing of data that could identify you as a natural person. Which specific data this concerns will be explained below in this privacy statement. The concept of ‘processing’ is broad and includes the collection, storage, use or distribution of this data.

It applies to the processing of the personal data of our clients and job applicants who use our services and products. The personal data of former clients and former applicants will also be processed with the utmost security and care, in accordance with this privacy statement.

If you have questions about this statement, or about the processing of your personal data, please feel free to get in touch with your contact at our offices. We can also be reached as follows:

f.a.o. privacy department

Bagattenstraat 165

B-9000 Gent

Belgium

If this person cannot sufficiently answer your questions, then please contact our designated data protection officer:

  • via e-mail: dpo@s-d-a.eu
  • by letter: Schelstraete Delacourt Associates Group

f.a.o. DPO

Bagattenstraat 165

B-9000 Gent

Belgium

What we do with your personal data

When do we collect your personal data as data controller?

We may process your data if:

  • you contact us, or have contacted us:

e.g., visiting our website;

e.g., filling in our contact form on our website;

e.g., applying for a job;

  • we are providing or have provided you with one of our services;
  • we may provide you with services in the future;
  • you are our contact for one of our clients or applicants.


Which data can we collect?

We may process the following data from you. However, depending on the situation, we will not necessarily possess all of the data below:

  • Your identification data: identity card data, copy of your ID card,… ;
  • Your electronic identification data: IP addresses, cookies, connection times,… ;
  • Your personal details: age, gender, date of birth, place of birth, civil status, nationality.
  • Your contact information: including your name, address and other contact details (e.g., e-mail address and telephone number),… ;
  • Your contact history: messages sent and received (e.g. e-mails),… ;
  • Your employment related details: CV, education, diplomas, language skills, employer, (incl. background), professional activities, professional skills, publications, salary, assessment & development reports, interview report, reference checks, social media profiles,… ;
  • Your lifestyle preferences and personality profile: hobbies, social activities, personality, community involvement, …
  • Your public data: publicly available data (e.g., press articles),… ;
  • Your payment details: If you make or receive payments to/from us.

Special categories of data

In principle, we will not process special categories of data (medical data, political views, religious or philosophical beliefs, trade union membership) unless you provide it to us with your explicit consent.

It may be necessary in order to execute the agreement for us to request to view a certificate of good moral conduct or other personal data concerning criminal convictions or offences. However, we will not process this data in any way, and we will therefore not ask you to provide us with a copy. In the event that other parties request such information, we ask that you provide this information – if feasible - directly to the requesting party.


What are the legal grounds that we apply for processing your data?

We only process your data for legitimate purposes, and it will always be processed according to the grounds for processing as listed in the General Data Protection Regulation (GDPR).

In general, we process data because it is essential for the execution or completion of the contract with our clients and applicants and in order to be able to provide you with our services.

In addition, we may process your data on the basis of our legitimate interests which, in specific cases, may outweigh any potential harm to your rights. This could include, for example, our use of public and other external sources, in which limited amounts of data on you may be available. Due to the nature of the available data and the fact that some of this information is publicly available, we consider that any potential harm to your rights will be minimal, while the information is important for us in order to be able to offer you our services. If we apply these legal grounds for processing data, we will limit the effects that this may have on your privacy by minimising our use and establishing appropriate access and security safeguards in order to prevent unauthorised use. In the above example, if we would need to process the data for purposes other than those for which they were obtained, we will, for example, contact you and offer you our services and/or request your permission, so that you will be informed of the processing of your data. If this contact is made by telephone, we will send you an e-mail stating that we will process your data in accordance with this statement.

Finally, we may process your personal data, such as special categories of personal data, based on your consent. If you have granted us verbal permission to process your personal data, we will always send you an e-mail confirming your consent. You may withdraw your consent at any time by contacting us. We request that you always confirm a withdrawal of consent made by telephone in writing, or notify us of your withdrawal of consent by e-mail or letter.


For what purpose do we collect this data?

We collect your data for various purposes.

  • operational purposes: for example, in order to keep our services user-friendly, answering your contact request, considering your application;
  • business purposes: for example, to manage the relations with our clients, applicants and prospects, and to deliver our services; for example, for sending newsletters
  • commercial purposes: transferring data to clients;

Sometimes it is necessary to provide your personal details in order to conduct our services. For example, it is not possible to apply for one of the job openings for which we are recruiting without providing us with certain personal data and without us sharing this data with your potential employer. We consider this only logical, since the potential employer would otherwise lack sufficient information to review your application.

If we wish to process your personal data for any purpose other than the one for which the data was obtained, we will contact you before proceeding with further processing.


How long do we store your data?

We do not store your personal data for longer than is necessary in order to achieve the purpose for which the data has been collected or processed.

Since the period for which the data can be stored depends on the purposes for which the data has been collected, the storage period will vary according to the individual situation. Sometimes specific legislation will require that we store certain data for a certain period. Our storage periods for personal data are based on legal requirements and a consideration of your rights and expectations in light of what may be useful and necessary to enable us to provide our services.

For example, we retain certain data and correspondence in order to be able to offer you services in the future that are similar to the ones we have already provided. Thus, we may, for example, offer previous job applicants attractive opportunities and services in the future.

When it is no longer necessary to process your personal data, we will delete your personal data or render them anonymous. If this is not (technically) possible, for example because your data is stored in backup archives, then we will retain your data, but we will not process it and will remove it when this becomes possible.


From whom do we receive your data?

We may obtain your personal data directly from you, from public sources, or from third parties.

If we receive your data from external sources and we process your data in our systems as data controller, we will notify you, at the latest at the time of our first contact with you, about the processing of your data.

In addition to consulting public sources, such as the Crossroads Bank for Enterprises, press articles and other publicly available information, we have joint operating agreements with various partners such as companies specialised in collecting business information, companies specialised in providing prospect lists and other data suppliers.

If we further process data from external sources for other purposes than those for which they were collected, we will contact you and offer you our services and/or request your permission for the processing of your data, so that you will be aware of the processing of your data. If this contract is made by telephone, we will send you an e-mail stating that we will process your data in accordance with this statement.


Where do we store your data?

We store your personal data chiefly on IT systems in Belgium. Some of these IT systems are outsourced to third parties, whereby the data may be stored within the European Economic Area (EEA). We have also engaged IT service providers located outside of the EEA, which means that your personal data may also be stored outside of the aforementioned countries. All (IT) service providers, act as data processors on our behalf.

We have taken the necessary physical and appropriate technical and organisational (precautionary) measures in order to secure your personal data against any form of unlawful processing. We restrict access to personal data to individuals and third parties who need access to this data for legitimate, relevant business purposes.


Do we share your data with third parties?

We have engaged various data processors to process your personal data on our behalf, including associated companies, our clients, members of InterSearch Worldwide, InterSearch Worldwide, ITservice providers and other business service providers. We may also share your personal data with other third parties if this is necessary for the purposes for which the data was collected. If, for example, you apply for a specific job, in certain cases, your data may be provided to the relevant employer or other employers who are interested in your profile.

Some of these external parties are located outside of the EEA. If, for example, you apply for a job outside of the EEA, in certain cases we may provide your data to the employer who is located outside of the EEA. If we provide data to external parties outside of the EEA, we will ensure that the transfer of personal data takes place in accordance with the relevant legislation and that there is an appropriate degree of protection. In addition, we will implement safeguards for this type of transfer, such as model contract clauses, consent from individuals or other legal grounds.

What are your rights?

You have various rights concerning the personal data collected about you. If you would like to exercise one of the rights described below, please contact us via the contact details provided above (by e-mail, telephone or post).

You have the following rights:

  • Rights to access and copy;
  • Right to amendment or rectification;
  • Right to have data deleted (right to be forgotten);
  • Right to limit the processing;
  • Right to object;
  • Right to transferability.

However, the exercise of the above rights is subject to certain exceptions in order to protect the public interest, our interests and the interests of other individuals.

When you submit a request to exercise your rights, we will first verify your identity by requesting a copy of your identity card. We do this in order to prevent your data from falling into the wrong hands.

Exercising your rights is in principle free of charge. If your request appears to be unfounded or frivolous, we may charge you a reasonable fee in order to cover our own administrative costs. In such cases, however, we may also simply opt to decline your request. You will then be notified of the reasons for this.

In any case, we will always notify you within a period of four weeks (for simple requests) or 3 months (for complex or multiple requests) of the response to your request.

Changes to the privacy statement

We may unilaterally decide to make changes to this privacy statement. However, the most recent version will always be made available on our website.

What are your options for filing a complaint as subject of the data?

Despite all of our efforts to protect your privacy and to comply with the relevant legislation, it is possible that you may not agree with the way in which we collect, use and/or process your personal data.

Naturally, in that case you may always contact us, but you also have other possibilities for filing a complaint.

To start with, you can submit a complaint to us.

f.a.o. complaints - privacy department

Bagattenstraat 165

B-9000 Gent

Belgium

Furthermore, you can also file a complaint with the supervisory authority, which you can contact via the data details below:

  • by telephone: +32 (0)2 274 48 00
  • by fax: +32 (0)2 274 48 35
  • by e-mail: contact@apd-gba.be
  • by letter: Data Protection Authority

Rue de la Presse 35

1000 Brussels

Belgium

Subsequently, if you have incurred damages, you can also file a claim with the competent court.

For more information concerning complaints and legal recourse, we invite you to consult the website of the data protection authority: https://www.dataprotectionauthority.be/node/19254.