COSUCRA PRIVACY CHARTER

Your trust in us represents the most important capital of the Public limited company “COSUCRA – GROUPE WARCOING” (in short « COSUCRA »), which has its registered office at 7740 Warcoing (Pecq), Rue de la Sucrerie 1 and registered with the Crossroads Bank for Enterprises under numbers 0883.812.926 (Register of Legal Entities Hainaut, section Tournai), (hereinafter referred to as the “Company”, “us” or “our Company”. As such, your privacy is of the utmost importance to us.

The present privacy charter (hereinafter referred to as the “Charter“) applies, inter alia, to (i) our Website https://www.COSUCRA.com/ (hereinafter referred to as the “Website“), to (ii) our social network pages, (iii) to our « JOBS », as well as, in general, (iii) to all (commercial) relationships between the Company and its clients, prospects, partners, third parties, and in general all persons with whom we may have a relationship via our Website or our social networks.

This Charter applies to all personal data processed by the Company, in the relationships described above, acting as data controller or processor, and covers all data processing for which the Company is responsible from the point of view of the data subjects in the relationships described above.

This Policy contains, among other things, information about the personal data that the Company collects and how the Company processes such personal data.

The Company tries to act at all times in accordance with (i) European Regulation (EU) 2016/679 of 27 April 2016 (the General Data Protection Regulation – “GDPR“) and (ii) the Belgian Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data.

By visiting the Website, our social networking pages, submitting your personal data when you interact with one of the Company employees, creating your “My Profile” account and applying online on our “JOBS” tab or by e-mail, requesting our services and generally communicating with the Company, you expressly agree to this Charter and therefore to the way we collect, use and process your personal data. However, the Company will never process your personal data without your consent where consent is required.

Please read the present Charter together with the conditions of use of the Website, and the general conditions of the Company.

Types of personal data

The Company may collect and process the following personal data:

• Last name;
• First name;
• Telephone number (fix/mobile);
• Email address;
• Contact details taken from the CV which can be attached to a (spontaneous) application;
• Postal address (address, postal code, locality, country);
• IP address;
• All personal data voluntarily transmitted to the Company (for correspondence in general, or the transmission of a CV, for example).

In addition, the Company automatically collects anonymous information about your use of the Website through the use of cookies. As such, for example, the Company will automatically record which parts of the Website you visit, which web browser you use, which website you were visiting when you received access to the Website. We cannot identify you through these data, but they do enable the Company to compile statistics regarding the use of the Website. Consequently, browsing the Website of the Company implies your agreement regarding the use of cookies. We invite you to consult our cookie policy for more details on the way in which we use cookies.

Method of collecting personal data

These personal data are collected in the following cases :

• The visit of the Website of the Company, through cookies ;
• The registration of your personal data via the contact form available on the Website ;
• Registering and assigning your login details to access your “My Profile” account on the « JOBS » tab ;
• Newsletter subscription ;
• The (spontaneous) application on the « JOBS » tab or by email, and therefore the transfer by yourself of your CV in order to apply for a job ;
• A request for a budget ;
• The use of a service we offer ;
• The exchange of business cards ;
• In general, correspondence with the Company (e-mail, telephone, or any other means of correspondence) and collaboration with the Company.

The personal data collected by the Company is therefore expressly and voluntarily provided by you.

The provision of certain personal data is a condition for being able to benefit from certain services (e.g. your registration to the “My Profile” account on the « JOBS » tab). We undertake to collect only the personal data we need for the purpose of processing and to process such data only in accordance with the purpose for which it is to be used.

Use of personal data

The Company may use your personal data for the purposes that you will find in Annex 1 of the present Charter.

In general, we will only use your personal data if you have given your consent, or if this use is based on one of the legal grounds provided by law:

• The pursuit of our legitimate interests;
• The conclusion, negotiation and implementation of a contract which is binding on you and us;
• Compliance with a legal obligation;
• The safeguarding of the public interest.

Disclosure of personal data to third parties

The Company will not disclose your personal data to third parties, except where necessary for the purposes of the requested service, including but not limited to :

• Management of our databases (registration/modification/deletion) ;
• Management of your “My Profile” account on the « JOBS » (registration/modification/deletion) ;
• Credit analysis where applicable ;
• Audience analysis of our Website ;
• IT storage ;
• Compliance with legal obligations imposed on the Company.

In this context, your personal data may be made publicly available webmasters, to payment partners, software suppliers, cloud partners, our insurance company and various providers to whom the Company is likely to appeal in the framework for the provision of it services.

If the Company is required to disclose your personal data to third parties in this context, the third party in question shall be obliged to use your personal data in accordance with the provisions of the present Charter.

Notwithstanding the foregoing, it is however possible that the Company may disclose your personal data:

• To the competent authorities (i) if the Company is required to do so by law or in the context of (future) legal proceedings and (ii) to safeguard and defend our rights;
• If the Company or the majority of its assets are taken over by a third party, in which case your personal data – which the Company collected – will constitute one of the transferred assets;
• If you have expressly agreed, where applicable.

Cross-border processing of personal data

In principle, we will not transmit your personal data outside the European Economic Area (EEA).

However, in the case of certain services, the Company is forced to process your personal data outside the EEA with a recipient whose domicile or registered office is in a country which does not fall under a similar decision, promulgated by the European Commission, this treatment will be subject to the provisions of a data processing agreement, which will contain (i) the standard contractual clauses as defined in the “European Commission Decision of 5 February 2010 (Decision 2010/87/EC)”, or (ii) any other mechanism on the basis of privacy legislation or any other regulation relating to the processing of personal data.

Storage of personal data

Except when a longer storage period is required or justified (i) by law or (ii) by compliance with another legal obligation, the Company will only retain your personal data for the length of time necessary to achieve and fulfil the purposes as described in Annex 1 of this Charter, subject to a longer storage period that will be justified by the legitimate interest of the Company.

The Company will store all personal data it has collected, in its paper files kept internally in the company, on its servers and internal computer software as on a cloud server located in Europe.

Your privacy rights

In the context of the processing of your personal data, you have the following rights:

• The right to access your personal data;
• The right to rectify, supplement or update your personal data;
• In certain circumstances, the right to delete your personal data at any time (‘right to be forgotten’) (in this context, the Company points out that certain services will no longer be accessible, or may not be provided if you delete certain personal data or have them deleted);
• The right to limit the processing of your personal data;
• The right to the transferability of your personal data;
• The right of objection to the processing of your personal data.

If you wish to exercise your privacy rights, please contact gdpr@COSUCRA.com or by post (COSUCRA, 7740 Warcoing (Pecq), Rue de la Sucrerie 1).

You can find more information regarding your rights at the website of the Data Protection Authority (hereinafter referred to as the “DPA“) via the following link “https://www.dataprotectionauthority.be/“. 

Protection of personal data

The Company undertakes to take all reasonable physical, technological and organisational precautions to prevent (i) unauthorised access to your personal data, and (ii) the loss, misuse or modification of your personal data.

Notwithstanding the security policy of the Company, the controls it carries out and the action it takes in this context, an infallible level of security cannot be guaranteed. No method of transfer or transmission over the internet is 100% secure, nor is any method of electronic storage, so the Company cannot guarantee complete security in this regard.

Finally, the security of your account will also depend on the confidentiality of your password to receive access to the Platform. The Company will never ask you for your password, so you are not required to communicate it yourself. If you have nonetheless communicated your password to a third party, you yourself are responsible for any consequences that occur through the use of your account. As such, if you notice that someone has obtained access to your account, the Company strongly advises you to immediately change your password and contact us.

Update of the Charter

The Company is entitled to update the present Charter by installing a new version on the website. In this context, it is recommended that you regularly consult the website and the page in question on which the Charter is published, in order to be certain that you are aware of any changes.

The most recent version will always be available via this link.

Other websites

The Website may contain hyperlinks to other websites and social networking pages (such as Facebook, LinkedIn and YouTube). When you click on one of these links, you may be redirected to another website or internet source that may collect information about you via cookies or other technologies. COSUCRA has no responsibility or liability for, or control over, those other websites or Internet resources or their collection, use and distribution of your personal information. We invite you to check the privacy policy of these other websites and internet sources yourself to judge whether they are acting in accordance with privacy legislation.

Contact the Company

If you have any questions about the Charter or the way in which the Company collects, uses or processes your personal data, please contact us:

By email: gdpr@cosucra.com

or

By post : COSUCRA, Rue de la Sucrerie 1 7740 Warcoing

If you are not satisfied with the way in which the Company has handled any questions or remarks you have submitted to it, or if you have complaints about the way in which the Company collects, uses and/or processes your personal data, you can file a complaint with the Belgian Data Protection Authority:

BELGIAN DATA PROTECTION AUTHORITY

Rue de la Presse 35
1000 Bruxelles, Belgium
Mail : contact@apd-gba.be

What do we expect from you?

For your part, we expect you to ensure that the information you have provided to us is relevant and up to date. You must also inform us immediately of any significant change in your situation. If you are required to provide us with information about a third party, we invite you to make sure that the third party has given you its consent to do so.

Annex 1 – Purposes of the use of personal data

The Company may use your personal data for the following purposes:

Visiting our Website, optimizing the quality, management and content of the Website:

In order to improve the quality of your visits to our Website, we use certain cookies that allow us to memorize some of your personal data. However, we use very limited long-term cookies.
Please click here to find out more about how we use cookies.

This processing may be based on our legitimate interest or your consent.

Receipt and treatment of questions asked via the contact form or by any other means of communication:

An online contact form is available on our Website. You also have the opportunity to contact us by phone and e-mail. In order to honor your requests (requests for information, requests for prices, solicitation for job, etc …) we will have to process some of your personal data.

This processing may be based on our legitimate interest or pre-contractual performance.

Creating your “My Profile” account on our « JOBS » tab :

You have the opportunity to access your information and indicate your function requirements online via your “My Profile” account specifically designed for this purpose on our « JOBS » tab. To have access to those services, it is necessary to create an online account, by inserting personal data that we use to link your account to your person. These data help us identify other attractive career opportunities for you.

This processing is based on the performance of a contract or pre-contractual performance.

Registration to our newsletter :

On our Website, you are invited to send us your e-mail address if you wish to subscribe to our newsletter. We register your choice to send you our news, based on your request only. In this context, we are led to process some of your personal data.

This processing is only based on your consent.

Establishment of a price quote or an offer:

In order to write and to communicate to you a price quote or an offer, on your solicitation, we will have to treat some of your personal data. In this context, we will have to deal with some of your personal data.

This processing is based on pre-contractual performance.

Establishment of a convention:

As a customer, you may be required sign an agreement or contractual documents with the Company so that we can begin the collaboration for which you have requested some of our services. In this context, we will collect some of your personal data.

This processing is based on the performance of a contract or a legal obligation. 

Execution of services, processing of your operations and execution of your instructions as part of the services we offer:

We use your data to perform the services for which you contacted the Company. This use implies that the Company is in possession of your personal data as long as it is required for the provision of service (s) to which you have subscribed (sale, delivery, etc …).

This processing is based on the performance of any contract concluded with you and / or any commitment made by you or by the Company.

Exchange of data with the Company during formal / informal communication on fairs or other professional events:

The Company participates in trade shows and fairs. During those events, you may exchange your personal data with our sales representatives, including through the exchange of your business cards. The Company will therefore have to collect, if necessary, these personal data concerning you.

This processing is based on our legitimate interest.

The establishment of mailinglists:

As part of the various services we offer, we create a database of contacts to ensure a better monitoring of our customers. In this context, some of your personal data may be collected in a database. Your personal data will never be used for marketing purposes without your express consent.

The legal basis for processing your data for this purpose is the performance of a contract or your consent.

Compliance with legislation and regulations:

We ensure compliance with all applicable legislation and regulations. In this context, and if required, we will be obliged to process some of your personal data.

This processing is based on compliance with a legal obligation.

Protection of our rights:

We may use your data to protect our rights, in particular in the context of defending or protecting legal rights and interests, legal proceedings, managing claims or disputes, in the event of corporate restructuring or other merger or acquisition transactions. We will use these data based on our legitimate interests.

Annex 2: Retention period by purpose category, subject to the right to be forgotten (unless legally required to retain)