ZENTRICK NV - PRIVACY STATEMENT

v1.0.0 2018-05-16

This Privacy Statement (the “Statement”) applies to the www.zentrick.com website (the “Website”), owned and operated by:

Zentrick NV
Guldensporenpark 2
B-9820 Merelbeke
Belgium
Enterprise number: 0827.909.747
hereinafter “Zentrick”, “we” or “us”

Zentrick deems the protection of privacy of the utmost importance and wishes to enable you – as user of its Website – to maintain full control over what happens to your Personal Data and your privacy and to inform and protect you accordingly.

All capitalized terms that are not defined in this Statement shall have the meanings as defined in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”).

Your Personal Data and your privacy are protected by Zentrick in accordance with Belgian and European regulations on the protection of privacy. Please read this Statement very carefully. The following describes not only your rights, but also the way in which you can exercise these rights.

By using our Website, disclosing your Personal Data, and accepting this Statement, you expressly consent to the manner in which Zentrick collects and processes your Personal Data as described in this Statement.

Who processes your Personal Data and how can you contact us?

Zentrick is responsible for the processing of your Personal Data that you provide through the Website.

Zentrick has appointed a Data Protection Officer, whom you can always contact for questions about your privacy and the processing of your Personal Data. The Data Protection Officer can be reached at:

Zentrick NV
attn. Data Protection Officer
Guldensporenpark 2
B-9820 Merelbeke
Belgium
Name: Ivan Schwarz
Email: dpo@zentrick.com
Telephone: +32 4 83 63 16 24

What Personal Data is collected and processed?

Zentrick processes different types of Personal Data, depending on the services you use on the Website and as relevant:

Personal information

Personal information such as first name, last name, address, email address, company name …

Technical information

Technical information such as IP, User agent, …

Cookies

Reference is made to our Cookie Policy.

What are the purpose and principles of the processing of your Personal Data?

The purpose and principles of the processing of your Personal Data mainly depends on the category of Personal Data concerned. Below you will find an overview of the purpose and principles of the various Personal Data that we process.

Personal information

Purpose:

We collect your personal information in order to answer your questions submitted through the Website, provide you with any files you have requested, keep you informed about Zentrick and its products, promotional offers, events, news articles, etc., to possibly hire you and to use your personal information for direct marketing purposes

Lawfulness of Processing

Necessary for the performance of the agreement and consent

Technical information

Purpose

We collect your technical information for diagnostic purposes, for purposes of high availability and accessibility, etc. …

Lawfulness of Processing

Legitimate interest and consent

The consent you provide is always free, and you have the right to withdraw this consent at any time. Withdrawal of consent does not affect the processing of Personal Data (i) prior to such withdrawal, (ii) based on any legitimate ground for processing Personal Data, and (iii) in case of a legitimate interest of the processing.

The above reasons may not be exhaustive, and Zentrick may at any time process your Personal Data for any other legitimate reason. In such cases, Zentrick will notify you as soon as possible of the reason. Updates of this Statement may constitute such a notification.

Direct Marketing

If you subscribed to product updates, company announcements and other similar communications, Zentrick will use your Personal Data for direct marketing purposes. It is possible that your Personal Data will be subject to profiling for marketing purposes. This enables Zentrick to keep you informed about its products, updates, events, etc. You give your explicit consent for this, but you may withdraw this at any time.

With regard to this profiling, you always have the right to object, free of charge, by sending an email to dpo@zentrick.com.

Receiving and sharing Personal Data

Zentrick receives your Personal Data in cases as and when:

  • you complete the contact form (e.g. through the hiring button, the contact button, the subscription button or any other button or way for providing personal information);
  • you download content from our Website;
  • you access a file delivered by CDN;
  • certain information is forwarded via cookies or your browser;

Zentrick will always share your Personal Data in a minimal way. However, to be able to follow through on your request or action on our Website, Zentrick may sometimes need to share Personal Data with third parties. You therefore provide your express consent to share your Personal Data as described in this Statement. Processors and sub-processors of Zentrick always act under the responsibility of Zentrick. If Zentrick contracts Processors or sub-processors this will always be done in accordance with a processor agreement that meets the requirements of the GDPR and that protects your Personal Data as well as possible.

Zentrick may share your Personal Data with third parties, for sending newsletters, storing and processing your Personal Data, responding to your queries, sending content to you, and for optimizing our Website. Your Personal Data may also be shared within the Zentrick Group.

Zentrick will never share or sell your Personal Data with or to commercial enterprises.

If you are redirected to another website or application through the Website, you should take any terms and conditions that apply to that website or application into account.

Transfer of Personal Data to countries outside the EEA

In principle, Zentrick does not transfer your Personal Data to countries outside the EEA. It is, however, possible that Zentrick – through its Processors or sub-processors - does transfer your Personal Data to countries outside the EEA. Should a less strict protection for Personal Data apply in a specific country, than within the EEA, Zentrick will then ensure that the same level of protection is achieved (e.g. by concluding an agreement with the processor located in a country outside the EEA).

How will my Personal Data be retained?

Zentrick applies the following retention periods for your data:

Personal information

Retention of the information (i) as long as necessary for the performance of the agreement, (ii) as long as the consent is valid and has not been withdrawn and (iii) for the duration of the hiring process.

Technical information

Maximum 7 days after collecting such information; after this 7 days period, technical information is erased, aggregated or anonymized

Zentrick retains your Personal Data in its own databases and/or in the databases of its Processors or sub-processors. You may ask Zentrick to provide a copy of the list of these Processors and sub-processors at any time.

How are my Personal Data safeguarded?

Zentrick has developed appropriate technical and organizational measures, safeguards and assurances to process your Personal Data in accordance with applicable Belgian and European regulations, in particular to protect your Personal Data against loss, misuse, or unauthorized alteration.

Zentrick maintains a team of technicians, automated systems, and advanced technologies such as encryption, threat detection, and other security measures in accordance with the best security practices such as two-factor authentication, least privilege policy etc. to ensure that only authorized people can access the data.

Zentrick makes all reasonable and appropriate efforts to protect the confidentiality of your Personal Data.

Despite the above measures taken by Zentrick, you should be aware that there are always risks associated with sending Personal Data over the Internet. The security and protection of your Personal Data can never be fully guaranteed.

What rights do I enjoy?

If and in as far as provided for in the applicable Belgian and European regulations, you have the right:

  • to confirmation as to whether Zentrick processes your Personal Data and, where this is the case, to access the Personal Data that Zentrick processes;
  • to corrections by Zentrick, without undue delay, of any inaccurate or incomplete Personal Data;
  • to have your Personal Data deleted by Zentrick;
  • to obtain your Personal Data and to transfer them to another Controller or Processor;
  • to obtain a limitation of the processing of your Personal Data from Zentrick, in as far as this is possible;
  • to receive your Personal Data in a structured, common and machine-readable format;
  • to prevent the Processing of your Personal Data and the use of your Personal Data for direct marketing purposes.

You may exercise these rights by contacting the Data Protection Officer (Article 2) and providing him or her with a copy of the front side of your identity card (e.g. no identification number may be visible) .

If and to the extent provided for in the applicable Belgian and European regulations, you have the right to file a complaint with the competent supervisory authority should the processing of your Personal Data violate the applicable regulations. In Belgium, this is the Commission for the Protection of Privacy (“Commissie voor de bescherming van de persoonlijke levenssfeer”) https://www.privacycommission.be/nl .

Amendments to this Statement

Zentrick may amend this Statement at any time. The date of the most recent version is shown in the top right-hand corner of the Statement. Amendments are posted on the Website to keep you informed at all times of the information that Zentrick collects and of how it uses and shares this information.

Amended versions of this Statement take effect ten (10) days after their publication on the Website. Where required they will always be submitted for prior approval.

Consent for disclosure

You acknowledge, confirm, and expressly consent that we may disclose your Personal Data if this is required by law, or if Zentrick determines in good faith that such disclosure is required in order:

  • to comply with any pending judicial inquiry, judicial order or litigation pertaining to the Website;
  • to compel observance of the general terms and conditions of Zentrick;
  • to respond to claims against Zentrick regarding Personal Data that violate any rights of third parties;
  • to safeguard the rights, property and safety of Zentrick, its employees, users, and the general public.

Zentrick may disclose your Personal Data to competent police or judicial authorities or other official government authorities if Zentrick deems this useful or necessary, in its sole discretion, for the investigation of fraud, intellectual property infringement or any other harmful activity, or if Zentrick reasonably suspects that such activity may expose Zentrick or you to any liability.

Liability

If Zentrick has legitimately transmitted your Personal Data to a third party (not being a Processor or sub-processor), Zentrick shall not be liable for any unlawful processing or unlawful use by that third party.

Under no circumstances does Zentrick accept responsibility for any direct or indirect damage resulting from faulty or unlawful use of the Personal Data by a third party.

Zentrick is in any case only liable for the damage caused by Processing of Personal Data if it did not comply with its specific obligations of GDPR. Zentrick shall in no event be liable for any special, incidental, indirect or consequential losses or damages.

Applicable law and competence clause

This Statement shall be governed, interpreted, and implemented in accordance with Belgian law, which applies exclusively in the event of any dispute.

The Belgian Courts and the Ghent division within the jurisdiction of Ghent are exclusively competent to decide on any dispute that may arise from the interpretation or implementation of this Statement, without prejudice to the consumer’s right to present a dispute before the competent court on the basis of a mandatory statutory provision.