Welcome! Thank you for your interest in HCJ.
HCJ continuously strives to offer you a website at the highest standards. This includes the protection of your personal data.
HCJ ensures that your personal data shall only be processed in accordance with the existing and applicable legal provisions concerning the protection of personal data, including the Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as ‘GDPR’) and the national implementing legislation.
Hengelhoef Concrete Joints NV (HCJ) has its registered office located at 3600 Genk, Hengelhoefstraat 158, and is registered in the Crossroad Bank of Companies under number 0877.977.088.
3. CLARIFICATION OF TERMS USED
For the purposes of this privacy statement, the concept of ‘personal data’ refers to: any information relating to an identified or identifiable natural person (the ‘data subject’).
A natural person shall be deemed ‘identifiable’ if he or she can be identified on a direct or indirect basis, 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. Hence, all information on the basis whereof a natural person can be identified must be taken into account. I.e.: amongst others the person’s name, date of birth, address, telephone number, e-mail address, license plate number and IP-address are taken into account.
The term ‘processing’ has a broad scope and inter alia refers to the 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 of personal data.
4. PERSON RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA (“CONTROLLER”):
HCJ is the legal person responsible for the processing of your personal data. This means that HCJ determines the purposes and means of the processing of your personal data.
5. WHEN DOES HCJ COLLECT YOUR PERSONAL DATA?
HCJ collects your personal data, either directly from you or indirectly through your use of the website, at the following instances:
- “Get in touch” -form;
- “Join the team” - email;
- Registration form design tool;
- Subscription to mailing list;
In principle, HCJ does not aim to collect personal data regarding persons younger than 13 years old. Persons younger than 13 years old may not provide HCJ with their personal data or with a statement of consent without providing the consent of the persons carrying the parental responsibility of such persons.
6. WHAT PERSONAL DATA DOES HCJ PROCESS, WHY AND ON WHICH LEGAL BASIS?
The schedule below provides which categories of personal data are processed by HCJ (column 1), why such personal data is being processed (the ‘purposes’ – column 2) and on which legal basis such processing takes place (column 3). The numbering used in the column ‘legal basis’ has the following meaning:
- Consent: you have given your consent for the processing of personal data for one or more specific purposes;
- Agreement: the processing of the personal data is necessary for the performance of a contract to which you are a contracting party;
- Legitimate interests: the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
|Categories of personal data
|Name, company name, e-mail address, login, IP-address
|Registration/Authentication, access and use of website
|Name, company name, e-mail address, IP-address
|Collection of feedback aiming at enhancing our website and services
|Name, company name, e-mail address, IP-address
|Information concerning our website and services by means of a newsletter
|Name, company name, e-mail address, IP-address
|Information concerning our website and services by means of a personalized e-mail
|First name, Last name, company name, function, address, postal code, Municipal, Country, phone/mobile, e-mail address, login, IP-address and any other personal data entered into the “get in touch” -form
|Collection of feedback aiming at enhancing our website and services
|E-mail address and any other personal data entered into the “join the team” email
|Recruitment, recruitment reserve
Furthermore, HCJ only processes your personal data as long as necessary and will delete your personal data as soon as this data is no longer required for the purposes indicated below, or, if applicable, for as long as the legal retention period lasts. Please note that the retention period for the different purposes can differ.
7. YOUR PRIVACY-RIGHTS
In order to provide you with more control regarding the processing of personal data, you have various rights at your disposal. These rights are inter alia discussed and provided in articles 15-22 GDPR.
In particular, you have the following rights:
Right of access to the processed personal data (art. 15 GDPR):
You have the right to obtain our confirmation as to whether or not your personal data is being processed, and, where that is the case, to obtain access to the personal data and the following information:
- The purposes of the processing;
- The categories of personal data concerned;
- The recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- The right to lodge a complaint with a supervisory authority;
- Where the personal data are not collected from the data subject, any available information as to their source;
- The existence of automated decision-making.
In the event that HCJ cannot provide you access to the personal data (for example in the event of a legal obligation to restrict the data subject from access to such information), we shall inform you of the reasons of such an inability.
Furthermore, you can also request a copy of the personal data undergoing processing free of charge. Please note however, that we are entitled to charge reasonable fee based on administrative costs for each additional copy you request.
The right to be forgotten or to request erasure of personal data (art. 17 GDPR)
In certain instances, you may request HCJ to erase your personal data. Furthermore, HCJ asks you to bear in mind that the ‘right to be forgotten’ is not an absolute right.
HCJ shall have the right to continue to store your personal data, inter alia, in the following cases: (i) where such storage is necessary for the performance of a contract to which you are a contracting party, (ii) where such storage is necessary for compliance with a legal obligation, or (iii) where such storage is necessary for the establishment, exercise or defence of legal claims. HCJ shall inform you of the reasons for the storage of your personal data in its response to your request of erasure.
The right to rectification (art. 16 GDPR):
In the event that your personal data are inaccurate, dated or incomplete, you can request HCJ to rectify or complete your personal data.
The right to data portability (art. 20 GDPR):
Under certain conditions, you shall also have the right to request HCJ to transmit the personal data you provided with and for which you have given us your consent, to another controller. HCJ shall transmit such personal data directly to the new controller in so far as such transmission is technically feasible.
Right to restriction of processing (art. 18 GDPR):
You shall have the right to obtain the restriction of processing where one of the following applies:
- You contest the accuracy of the personal data (in such an event the use of the personal data shall be limited for a period enabling us to verify the accuracy of the personal data);
- The processing of the personal data is unlawful;
- HCJ no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
- Pending the verification whether the legitimate grounds for the processing of the personal data override those of the data subject, you may request HCJ to limit the usage of the personal data.
The right to object (art. 21 GDPR):
You have the right to object, on grounds relating to your particular situation, the processing of your personal data in case that such processing is done for the performance of a task carried out in the public interest or for the purposes of the legitimate interests pursued by HCJ. In such an event, HCJ shall no longer process the personal data unless (i) there are compelling legitimate grounds for the processing which override your interests, rights and freedoms, or (ii) the processing of the personal data is done for the establishment, exercise or defence of legal claims.
Automate individual decision-making, including profiling (art. 22 GDPR):
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or which may significantly affect you in a similar manner.
Such right can however not be invoked in the following circumstances:
- If the decision is authorised by law (for example: in order to prevent tax fraud);
- If the decision is based on the data subject’s explicit consent;
- If the decision is necessary for entering into, or performance of, a contract between the data subject and the data controller (note that in such instances, we shall always make a case by case assessment of whether less privacy intrusive methods can be applied to facilitate the entry into, or performance of the contract).
The right to withdraw your consent (art. 7 GDPR):
Where the processing of personal data is based on consent, you shall have the right to withdraw such consent at any time through a simple request.
8. THE EXERCISE OF YOUR RIGHTS
To exercise the rights listed above, you can contact HCJ via e-mail on the following e-mail address: email@example.com.
In order to verify your identity, HCJ asks you attach a copy of the front side of you ID-card to your e-mail.
All rights can be exercised free of charge, unless your request is manifestly unfounded or disproportionate (for example: due to the repetitive character of your request). In such cases, HCJ has the right to charge you with a proportional fee or to refuse to adhere to your request.
9. TRANSFER OF PERSONAL DATA TO AFFILIATED COMPANIES AND THIRD PARTIES
HCJ may also send your personal data to third parties whose intervention as data processor, on behalf and under control of HCJ, is required for the purposes indicated above. These data processors are natural persons or legal entities that process the personal data on behalf of HCJ. These processors were carefully selected by HCJ and offer all the adequate guarantees with regard to technical and organizational security measures regarding the processing of your personal data.
Your personal data shall only be transferred to third parties in conformity with the legal provisions in that regard, when you have provided HCJ with your prior consent to do so, or when such transfer is necessary to ensure access to our website and services (on the basis of our legitimate interests). No personal data shall be transferred to third parties under any other circumstances, unless HCJ is obligated to do so on the basis of compulsory legal or regulatory provisions (e.g.: the transfer of personal data to external bodies or authorities, such as law enforcement authorities).
HCJ ensures that your personal data will not be rented nor sold in personally identifiable form to anyone but companies within the Continental Group, or the trusted and reputable third party processors described under this title. All third party processors are bound to keep your information confidential. All information provided to third party processors is used by them only to carry out the service they are providing for HCJ.
10. CATEGORIES OF RECIPIENTS
Your personal data shall only be accessible within our company to those persons who require access to the personal data in order to comply with the contractual and legal obligations.
In some circumstances, HCJ ‘s employees and staff are assisted by external service providers in the execution of their tasks. In order to protect your personal data, HCJ has concluded an agreement with all such external service providers in order to guarantee the safe, respectful and cautious management and administration of your personal data.
11. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
Your personal data shall only be transferred or disclosed to processors or controllers in third countries in so far as HCJ is legally authorised to do so.
In so far as such disclosure or transfer is necessary, HCJ shall take appropriate measures to ensure that your personal data shall be significantly protected and that all disclosures or transfers of personal data outside of the EEA take place in a lawful and legitimate manner. In the event that a disclosure or transfer takes place to a country outside of the EEA, for which the European Commission has not determined that this country does not maintain an equivalent level of protection of the personal data, such disclosure or transfer shall always be subject to contractual or other legally binding instruments which under the terms and conditions for the transfer of personal data to third countries, such as the approved standard terms and provisions for the transfer of personal data to third countries as established by the European Commission.
12. PROTECTION OF YOUR PERSONAL DATA
HCJ has taken all reasonable and suitable technical and organizational measures in order to protect your personal data as well as possible against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. As such, HCJ stores your personal data on one central and secured place on our server in order to ensure that third parties shall not have access to your personal data.
13. STORAGE OF PERSONAL DATA
HCJ stores your personal data for the period of time necessary for achieving the purpose for which such personal data is processed. Please note that HCJ must take into account a number of (legal) storage periods (time limits) which obliges HCJ to continue to store your personal data. In the event that no obligation or duty to store the personal data exists, the personal data shall be erased and destroyed on a routine basis once the purpose for which the personal data is collected has been achieved.
Furthermore, HCJ may store your personal data if you have given us your consent to do so or where such storage is necessary for the establishment, exercise or defence of legal claims. In this last instance, certain personal data shall be used for evidence purposes. Such personal data shall therefore be stored in line with the legal prescription period, which can amount up to a period of thirty years; the usual limitation period in relation to actions in personam amounts up to ten years.
The protection of your personal data is HCJ ‘s primary concern. As such, HCJ aims to take all necessary measures in order to guarantee the protection of your personal data. Should you have a complaint regarding the manner in which your personal data is processed, please feel free to contact HCJ. HCJ shall try to live up to your expectations and meet your concerns as soon as practically possible.
You may also file your complaint to the supervisory authority for personal data protection. The authority assigned to supervise our organization is the Belgian Data Protection Authority:
Data Protection Authority
Rue de la Presse 35, 1000 Brussels
tel: +32 (0)2 274 48 00
fax: +32 (0)2 274 48 35
15. DO YOU HAVE ANY FURTHER QUESTIONS?
Please feel free to contact HCJ. We are happy to be of any further assistance.
Last date of modification: April 2020.