Privacy and personal data confidentiality policy

Alcyon is concerned with protecting the personal data that it processes. To this end, Alcyon hereby commits to respect the enforceable regulations applicable to processing of personal data and, particularly, EU regulation 2016/679 of the European Parliament and Council dated 27th April 2016 that came into effect on 25th May 2018 (also known as the “general data protection regulation”).

This privacy policy declaration aims to describe how Alcyon collects and processes your personal data, whether within the scope of the assistance which we provide to you for any questions you may ask us, the supply of your data via a form, the provision of a service by ourselves or yourselves, your application for a job vacancy or simply as part of our collaboration.

This privacy policy therefore applies to the personal data of applicants for job vacancies, our customers, our suppliers, our various partners and other persons that we may contact within the scope of developing our business.

We would like to mention that we may be led to modify this Privacy / Confidentiality policy. Please visit this page regularly to consult any modifications that we may publish.

1. What types of personal data do we collect?

1.1. Customers

It is possible to visit an off-line part of our web site without sending personal data to us. However, if you wish to become a customer and make orders or if you wish to view our on-line catalogue, it is essential for us to create a customer record for you and thus collect the following data within the scope of creating a personalised customer record form:

Surname and first name(s)

Company name and legal name

VAT number

Invoicing address and delivery address

E-mail

Telephone (and/or fax) number

Depository number

Order number

Bank details if you wish to set up a direct debit

Any other personal data that you have deliberately sent to us

We may also hold further information that a person from your company has chosen to send to us. If we require further personal data, we shall inform you of this fact.

1.2. Suppliers / sub-contractors

If you are a supplier or sub-contractor for Alcyon, we may need to collect a limited amount of personal data which you provide. In principle, Alcyon solely needs the contact details for the contact persons in your company who are in charge of the contract or contracts into which your company has entered with Alcyon in order to carry out management and follow-up of such contracts. We shall therefore request the following data:

Surname and first name(s) of the contact person

Company name and legal name

VAT number

Invoicing address and delivery address

E-mail

Telephone (and/or fax) number

Any other personal data that you have deliberately sent to us

In certain cases, we may collect your bank information in order to pay you if your account is not in the name of your company. We may also hold further information that a person from your company has chosen to send to us. If we require further personal data, we shall inform you of this fact.

1.3. Applicants for a job vacancy

Within the scope of a job offer at Alcyon, we will be led to collect the following data:

Surname and first name(s)

Address

Age / date of birth

Birth number

Gender

Photograph

Marital status

Contact details

Qualifications

Professional experience

Immigration status (necessity of a work permit or not)

Nationality / citizenship / place of birth

A copy of your driving licence and/or passport or identity card

Your social security number and other fiscal information

Information related to diversity, including racial or ethnic origin, religion or other similar beliefs, and to physical or mental health, including information related to handicaps.

Information on any criminal conviction if such information is required for the post for which you are applying.

Information on your current salary, your pension plan and your social benefits.

Information on your centres of interest and needs concerning your future job.

Any further information that you choose to send to us.

Any further information concerning you that our customers / partners may send to us.

Any personal data that you have deliberately sent to us.

Please note that the above list of personal data categories that we may collect is not exhaustive.

2. How is the personal data collected?

2.1. Customers / suppliers / partners

We receive personal data directly from you in two ways:

When you contact us pro-actively, generally by telephone or by e-mail.

By means of contact forms that you complete on our web site.

If necessary and in compliance with the applicable laws and regulations, we may obtain further information concerning you via:

Market research by third parties and analysis of on-line plus off-line media (that we may conduct ourselves or sub-contract to other companies).

From public databases.

2.2. Applicants for a job vacancy

We collect the personal data of applicants in two ways:

You send us your personal data directly by post or any electronic means.

Your data is communicated by other sources such as our customers, an employment agency, a third party, or a job offers / services web site.

3. Purposes and legal basis of processing

Generally speaking, personal data is only used to communicate with you, honour the orders you make with us, improve or develop our services or products, or propose targeted adverts and services to you.

More specifically, we use your personal data to:

Carry out missions for which we have been contracted or to be able to contact you concerning our agreements. The legal basis is your explicit agreement through signing a contract and our legitimate interest in providing you with a service perfectly adapted to your demands, or to obtain a service from you that is in accordance with our desires.

Communicate with you in order to respond to your questions or requests, subject to having obtained your express consent.

Respond to legal and regulatory obligations.

Send you invitations, promotions and offers for events, particularly networking, visits to businesses or plots, training, symposiums, seminars, exhibitions, customer events, as well as general information on business sectors that are likely to be of interest to you. The legal basis for such communication is your express consent. Similarly, subject to obtaining your prior consent, we may share your personal data with third party partners, who may send you commercial offers related to their products and services. However, at any moment, you may refuse such direct marketing communication by informing us, or via the unsubscribe link that can be found in our communication material. The legal basis for such processing is your express consent.

Assess the suitability of our job offers with your profile. The legal basis is your express consent and our legitimate interest in hiring an applicate who meets our requirements.

In the case where the legal basis for processing is our legitimate interest, Alcyon ensures that the impact of the processing on protection of your privacy shall be as limited as possible and that, in any case, the balance between the legitimate interests of Alcyon and its partners and the possible impact on protecting your privacy is not disrupted. Despite this, if you object to such processing, you may exercise your right of objection.

4. What are your rights concerning processing of your personal data by alcyon and who can you contact?

You have rights related to processing of your personal data. While Alcyon may ask you for express authorisation for specific processing of your data, we may subsequently cancel your consent at any moment.

The principle rights that you have are as follows:

Right to consult your personal data.

You may consult your personal data at any moment. All you need to do is to contact us at the following address: secretariat@alcyonbelux.be or on our web site via the “GDPR” form. We will then provide you with as comprehensive an overview as possible of your data.

Right to correct your data.

It may happen that your data that is in our possession is no longer up to date or correct. At any moment, you may request that this data is corrected or supplemented.

Right to objection or deletion of your data.

If you feel that your data is not used in an appropriate manner, you may request that your data is deleted from our records.

You may exercise your rights, ask us any questions or make any comments concerning this declaration by contacting the address mentioned in the “Data Controller” section. We shall do our utmost to process your request as soon as possible and, in any case, within one month (subject to extensions authorised by law).

Please note that we will not be able to grant your right to objection if we can demonstrate that we have either legitimate and pressing reasons to process your data which take precedence over your interests or any other reason that justifies maintaining processing of your personal data (e.g., legal obligations, contracts, etc.).

5. The data controller for your personal data

In compliance with Belgian law of 8th December 1992 concerning protection of privacy with regard to processing of personal data, and its subsequent modifications, as well as with the European Regulation 2016/679, also referred to as the General Data Protection Regulation (GDPR), the data controller for your personal data is:

Alcyon Belux SA – 17 rue le Marais, 4530 Villers-le-Bouillet, Belgium. Tel.: (+32) (0)4/338 34 90

To contact us, you can send your request directly to the e-mail address secretariat@alcyonbelux.be or to the postal address mentioned above.

For all requests, we require proof of your identity in the form of a copy of the front and back of your identity card (or the relevant pages in your passport), or provision of your customer identification number, or any other data that will allow us to ascertain your identity. We may also request any further information that we deem to be necessary concerning your request. We will not invoice access to the data that we hold concerning you, unless your request is “manifestly unfounded or clearly abusive”. In such a case, we may invoice reasonable administrative costs to you within the extent permitted by law.

Supervisory Authority

The supervisory authority is the Belgian Privacy Commission.

You may contact it by the following means:

By telephone: (+32) (0)2 274 48 00

E-mail: commission@privacycommission.be

By its on-line contact form: https://www.privacycommission.be/en/contact-form

By post: Commission de la protection de la vie privée, 35 Rue de la Presse, 1000 Brussels, Belgium

Fax: (+32) (0)2 274 48 35

6. Security

Alcyon has implemented many technical, physical and organisational security measures in order to ensure the integrity, confidentiality and availability of the data concerning people who interact with Alcyon.

Alcyon has implemented security techniques in order to protect the personal data stored on its computer servers against unauthorised access, inappropriate use, alterations, illegal or accidental destruction and accidental loss.

Alcyon has committed to a process of monitoring and continual improvement of its security procedures in order to take account of new technology and new risks.

If you suspect improper use, loss or unauthorised access concerning your personal data, please inform us immediately at: secretariat@alcyonbelux.be

7. Who has access to your personal data?

We share your personal data with the following categories of people:

Our employees involved in processing your files. However, should they have a pressing requirement for knowledge of your personal data, they will only have access to your data on a need-to-know basis for the mission they are responsible for accomplishing.

The employees of our institutional partners such as the services of the Walloon Government, or any other Belgian ministry or public authority.

The employees of the tax authorities or any other public body in the case where the law or any other regulation requires your personal data to be communicated.

Service providers who work on our behalf including in particular lawyers, bailiffs, external consultants, auditors, IT service providers, communications agencies, etc.

8. Will your personal data be transferred outside belgium’s borders?

In principle, Alcyon does not transfer personal data outside Belgium’s borders.

However, if Alcyon is led to transfer your personal data to countries located outside the European Economic Area, standard contractual clauses adopted by the European Commission shall be imposed on the recipient if protection of personal data is deemed to be insufficient in the country in question.

9. For how long will your personal data be kept?

We only keep your personal data for the time necessary to fulfil the purposes described above.

In principle, we will delete your personal data from our systems in the absence of contact with you or with the company for which you work that has a business relationship with Alcyon or following the end of the contract linking your company or yourself to Alcyon for an uninterrupted period of five years. However, we may store your personal data for a longer duration if required by laws or regulations.

For the personal data of the employees working for our partners or that of our customers, such personal data shall be deleted on completion of a two-year period after the notification by our partner or our customer that you no longer work for them.

For applicants for a job vacancy with Alcyon, the personal data shall be kept following completion of the selection process for the job vacancy in question for a maximum period of 2 years.

10. Modifications and amendments

We may occasionally make modifications to this Privacy and Confidentiality Policy Declaration in order chiefly to comply with new regulatory requirements. Any modification shall take effect immediately after publication of the updated Privacy and Confidentiality Policy Declaration. In the case of a substantial modification, before it enters into force, a notification shall be published or shall be directly sent to you. Should you continue to use our services following the effective date of the updated Privacy and Confidentiality Policy Declaration, we shall consider that you accept these modifications.