Privacy statement

1. Introduction

1.1. Who are we?

The website https://aspel-group.com/ (hereinafter the ‘Website’) is offered by Aspel N.V. (hereinafter Aspel).

In the context of the Website, Aspel processes personal data and acts as a data controller in accordance with the General Data Protection Regulation (GDPR). Aspel values the protection of privacy and the correct processing of personal data which are the subject of the AVG.
Through this statement, Aspel provides an overview of these processing activities, what safeguards Aspel takes to protect personal data and what rights you can exercise against Aspel when we process your personal data.

1.2. Contact

The Website is offered and operated by Aspel N.V.
Aspel N.V.
Buntjesstraat 11
3583 Paal Beringen
Belgium
0402.313.339
aspel@aspel-group.com
+32 11 71 94 00

2. Why do we process your personal data?

2.2 Communications data

What do we do with your data?

The source of communication data is the information you provide to us when you contact us.
Communication data may be processed for the purpose of this communication with you and record keeping.
The legal basis is our legitimate interest, to respond to requests, questions or comments or to contact you for questions of any kind (e.g., when you contact us via social media, phone or email).

What data do we process?

• identification data, such as your name;
• contact information, such as your email address and phone number.

How long do we retain your data?

Aspel keeps your data for communication purposes until the time you withdraw your consent or for 2 years after the last meaningful contact.

2.3 Job application data

What do we do with your data?

The source of job application data is the information you provide to us when you contact us.
Job application data may be processed for the purpose of your job application and record keeping.
The legal basis is our legitimate interest, to respond to your job application.

What data do we process?

•  identification data, such as your name;
• contact information, such as your email address and phone number;
• other information, such as your CV and motivation letter.

How long do we retain your data?

Data will be kept for a period of 6 months after application.

Notwithstanding the above, we may retain your personal data where this would be necessary for the establishment, exercise or defense of legal claims, whether in judicial proceedings or in administrative or extrajudicial proceedings. The legal basis for this processing is our legitimate interests, namely the protection and exercise of our legal rights.

3 To whom do we transfer your data?

3.1 Recipients of your personal data

Aspel does not sell personal data to third parties. Nor does Aspel disclose personal data to third parties except to:

• the data subject;
• any legal successors and affiliated companies (such as subsidiaries and sister companies) for the same purposes as those mentioned in this privacy statement;
• third parties or subcontractors for the same purposes as those stated in this privacy statement and in accordance with our data processing instructions;
• external service providers at national and international level and in accordance with our data processing instructions;
• governments, judicial institutions and regulators.

3.2 Data transfers outside the European Economic Area

Some of our processing activities require us to transfer your personal data to a partner or other organization located outside the European Economic Area (“EEA”), where the AVG does not apply.
A number of countries outside the EEA have been assessed as adequate by the European Commission: these provide the same appropriate level of protection as we know it through the AVG.
However, it could also be that we transfer your personal data to countries that do not have similar regulations and no derogations for specific situations apply in accordance with art. 49 GDPR. In this case, we take additional measures, so-called appropriate safeguards, to ensure that your personal data is processed securely in these countries. These measures include:

• contractual arrangements between Aspel and the recipient in the third country, based on the standard contractual clauses for transfer of personal data outside the EEA, which have been adopted by the European Commission and provide additional protection similar to the GDPR;
• any other mechanism allowing the transfer of personal data outside the EEA in accordance with the relevant data protection legislation.

4 What are your rights?

In accordance with the General Data Protection Regulation, data subjects have certain rights regarding the processing of personal data that they may exercise. If the data subject wishes to exercise his rights, he may send a request to this effect to Aspel at the following email address aspel@aspel-group.com. This request should be formulated clearly and as concretely as possible, in order to allow Aspel to respond in the most targeted manner possible.
If there is any doubt as to the identity of the data subject, Aspel may request verification of that identity in order to prevent an unauthorized person from exercising his rights. In this case, Aspel will contact the person concerned and together with him/her seek the most appropriate way to determine his/her identity.
Aspel aims to comply with a request within one month. If this is not possible, Aspel will inform the person concerned as soon as possible about the possibility of extending this period by two months. If Aspel is unable to comply with a request, Aspel will inform the person concerned within an appropriate period, providing motivation.
More specifically, the following rights are involved:

5.1 Right to be informed

Aspel, as the controller, is obliged to inform the natural persons concerned whose personal data are processed about this processing. This information must be provided in a precise, transparent, comprehensible and easily accessible manner, in clear and simple language. Specifically, one can exercise this right by consulting this privacy statement. For further information, Aspel may be contacted using the aforementioned details.

5.2 Right of access

Where Aspel processes personal data, the data subject has the right to request access to these data, as well as to obtain additional information such as the purposes of the processing, the retention period and the origin of the data. The data subject may also ask Aspel for a copy of these data, provided that this request is not manifestly unfounded or excessive. The first copy will be provided free of charge, but in the event of a repeated request, Aspel reserves the right to charge a reasonable fee.

5.3 Right to restriction of the processing

The data subject has the right to request Aspel to restrict the processing. In this case, Aspel will keep this data and use it only for certain limited purposes. The data subject may exercise this right in the following cases:

• The data subject disputes the accuracy of his data, whereby the data processing will be restricted for the period of time necessary for Aspel to verify the accuracy.
• The processing is unlawful, but the data subject opposes the erasure of these data and requests instead a restriction on the use of these personal data.
• Aspel no longer needs the data for the purposes of the processing, but the data subject needs these data for the establishment, exercise or support of legal claims.
• When the data subject objects to a processing, pending verification whether the legitimate grounds of Aspel as a controller outweigh your personal interests.

In case of a restriction of processing, Aspel may only process the data in question with the consent of the data subject, for the initiation, exercise or substantiation of legal proceedings, for the protection of the rights of another natural or legal person or for reasons of public interest.

5.4 Right to erasure

The data subject has the right to ask Aspel for the erasure of his data in the following cases:

• The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
• The data subject withdraws their consent, in cases where the processing is based on their consent and there is no other legal basis for the processing.
• The data subject objects to the processing and his personal interests prevail over the legitimate interests of Aspel.
• The personal data have been processed unlawfully.
• The erasure of the data is necessary to comply with a legal obligation under European or Belgian law.

Aspel will comply with your erasure request unless one of the following situations arises:

• The processing is within the framework of exercising the right to freedom of expression and information.
• For reasons of public interest in the field of public health.
• To satisfy the need for archiving in the public interest or for statistical purposes.
• To comply with a legal obligation to keep records.
• To establish, exercise or defend a legal claim.

5.5 Right to data portability

Where data processing is based on the data subject’s consent or on the basis of necessity for the performance of the contract and such processing is carried out using automated processes, the data subject shall have the right to receive his personal data that he has provided to Aspel in a structured, common and machine-readable form. In addition, the data subject shall have the right to request Aspel to transfer the data in question to another controller, insofar as this does not infringe the rights and freedoms of others.

5.6 Right to rectification

If the personal data that Aspel processes are incomplete or incorrect, Aspel will take the necessary steps to supplement and/or correct them. If Aspel suspects that certain data are incorrect, Aspel will contact the person concerned in order to rectify the situation. The person concerned can also contact Aspel himself about this via the appropriate channels if he discovers an inaccuracy or incompleteness.

5.7 Right to object

Where Aspel invokes the public interest or legitimate interest in processing personal data, the data subject has the right to object. In this case, Aspel will no longer process the personal data in question, unless Aspel can demonstrate compelling legitimate grounds for the processing which outweigh the personal interests, rights and freedoms of the data subject.
If Aspel processes personal data for direct marketing purposes, the data subject may always object to this free of charge. This is also the case when Aspel carries out profiling with regard to direct marketing. In this case Aspel will always terminate the data processing.

5.8 Right to withdraw consent

Where data processing is based on the data subject’s consent, the data subject has the right to withdraw consent at any time. The withdrawal of consent only takes effect for the future and does not affect processing operations prior to the withdrawal. Aspel is making every effort to make the withdrawal of consent as easy as granting it.

5.9 Right to oppose to automated, individual decision-making

The data subject whose personal data are processed by Aspel has the right to object to automated individual decision-making, including profiling, if that decision produces legal effects or otherwise significantly affects the data subject.
The data subject may not oppose such a decision where:

• it is necessary for the performance of the contract;
• it is authorized on the basis of Union or Belgian law;
• it is based on the explicit consent of the data subject.

If the data subject cannot oppose for the aforementioned reasons, Aspel provides for human intervention, the possibility for the data subject to express his/her point of view and to challenge the decision.

5.10 Right to lodge a complaint

The data subject has the right to complain to the competent supervisory authority. In Belgium, the competent supervisory authority is the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit). Filing a complaint can easily be done via the complaint form on the website of the Belgian Data Protection Authority.
If one is dissatisfied with the way in which Aspel processes personal data or if you intend to file a complaint, Aspel encourages the data subject to first get in touch using the aforementioned details, in order to reach together a quick solution to this problem.