Privacy Policy

1. General

1. This privacy policy (“Privacy Policy”) addresses the processing of your personal data as part of your use of our Website (the “Website”). This processing is carried out by J&W Security nv as data controller, with registered office at jagersdreef 4b, 2900 Schoten, registered with the CBE under number BE 0737 871 872, in accordance with applicable legislation on the protection of personal data.
2. By using our Website, you acknowledge that you have read this Privacy Policy carefully and agree to it without reservation. We reserve the right to modify the Privacy Policy according to our sole discretion. Such changes will be communicated through the Website.
3. Please note that we may use so-called “cookies” or similar technology as part of the Website and/or the Services. Cookies are small text files placed on a device’s hard drive that contain certain information, sometimes including personal data. For more information regarding our use of cookies, please read our cookie policy (www.spidersecurity.be/cookie-policy).
4. This Privacy Policy was last updated on 11/05/2020

2. What & why we process data

1. When you use the Website, we process personal data relating to you. Your personal data is processed for the following purposes (each indicating the legal grounds), including:

When and on what basis?

• Use of the Website (consent and if applicable legitimate interest)
• Contacting us (consent and if applicable legitimate interest)
• Apply for jobs (permission)
• Sending newsletters and other forms of communication

Which?

• Identification information (name, address, e-mail, phone,…)
• Contact details
• ..

Why?

• Improving the visitor’s user experience on the website
• Acting on request for contact
• Enabling application process

2. In principle, we obtain the personal data mentioned above directly from you. However, if you choose to register through a social media account (e.g. Facebook, LinkedIn or Google), this data is collected through your social media profile. We recommend consulting the privacy policy of your social media service provider to find out what data is processed by your social media service provider when you use the social media login feature.
3. We generally do not transmit any of the personal data you provide through the Website to social media providers unless you consent.
4. In addition to the above purposes, we may also process your personal data:
5. To provide you with information about products and services that you request in a personalized and efficient manner, whether through the Website, email, telephone, or social media channels.
6. To process your personal data so that we can provide you with certain Services.
7. For direct marketing purposes, i.e. to provide you with targeted communications, promotions, offers and other advertisements from us or our selected partners. For this, we will ask for your prior consent.
8. To perform statistical analyses to improve our Website and/or Services, or to develop new products or services.
9. To provide to a financial institution or payment service provider, to enable your financial institution and the payment service provider to comply with their legal obligations.
10. To transfer to the police or judicial authorities as evidence of possible crimes or if there are reasonable suspicions of an unlawful act or crime committed by you through your registration with or use of the Website or the Services.
11. In the context of a possible merger with, acquisition of/by or division by a third party, even if that third party is located outside the EEA.

3. With whom we share data

1. We do not send your personal data in an identifiable manner to third parties if this is not required for the operation of the Website and/or to provide the Services, without your explicit consent to do so.
2. We may rely on external processors to offer you the Website and/or Services. We ensure that third-party processors may only process your personal data on our behalf and on our written instructions. We guarantee that all external processors are selected with the necessary care so that we can count on the security and integrity of your personal data.
3. We may transfer anonymized and/or aggregated data to other organizations that can use this data to improve products and services and organize the marketing, presentation and sale of customized products and services.

4. Where we process data

1. We ourselves and our third-party processors will process your identifiable personal data only in the EEA.
2. We may transfer your anonymized and/or aggregated data to organizations outside the EEA. If such a transfer occurs, we will ensure that appropriate safeguards are in place to ensure the security and integrity of your personal data, and that any rights in relation to personal data that you might enjoy under applicable mandatory law are guaranteed and the necessary legal protection mechanism is put in place.

5. How we process data

1. We will use our best efforts to process only the personal data necessary to achieve the purposes stated in this Privacy Policy. We will process your personal data in a lawful, fair and transparent manner. We will use our best efforts to keep personal data accurate and up-to-date.
2. Your personal data will only be processed for as long as necessary to fulfill the purposes stated in this Privacy Policy or until you withdraw your consent to its processing. Please note that withdrawal of consent may imply that you are no longer able to use all or part of the Website and/or Services. If you have registered with our Website, we will delete your personal data when you delete your profile, unless a legal or regulatory obligation or a court or administrative order would prevent us from doing so.
3. We will take appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft and from accidental loss, manipulation or destruction. Access by our personnel or personnel of our third party processors is only possible on a need-to-know basis and is subject to strict confidentiality obligations. However, you understand that concerns for safety and security are only best efforts obligations that can never be guaranteed.
4. If and when your registration on the Website or use of the Website or Services may be considered (a) a violation of the terms or intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Services, (c) a threat to the Website or Services or systems of us or our subcontractors as a result of viruses, Trojan horses, spyware, malware, or any other form of malicious code, or (d) is in any way illegal or unlawful, discriminatory or offensive, we may process your data in the interest of ourselves, our partners or third parties.

6. How long do you keep my data?

Retention periods vary depending on the nature of the service provided. We retain your data:

• as long as necessary for the purposes for which they are collected and processed.
• as long as they are necessary to comply with our legal, contractual and judicial obligations and to fulfill our commercial operational activities.

7. Your rights

1. You have the right to request access to any personal data we process about you. However, requests for access made with the apparent intention of causing inconvenience or damage to us will not be processed.
2. You have the right to request that any personal data about you that is incorrect or inaccurate be corrected free of charge. If you have registered on our Website, you can correct many of these data yourself through your profile. If such a request is made, you must also attach to this request proof that the personal data for which correction is requested is inaccurate.
3. You have the right to withdraw your previously given consent to the processing of your personal data. You may withdraw your consent at any time by emailing info@spidersecurity.be, or by deleting your profile
4. You have the right to request that personal data relating to you be deleted if it is no longer necessary in light of the purposes set forth in this Privacy Policy or if you withdraw your consent to its processing. However, you should note that a deletion request will be assessed by us in light of legal or regulatory obligations or administrative or court orders that may prevent us from deleting the personal data in question.
5. In lieu of deletion, you may also request that we restrict the processing of your personal data if (a) you dispute the accuracy of such data, (b) the processing is unlawful or (c) the data are no longer necessary for the stated purposes, but you need them to defend yourself in legal proceedings.
6. You have the right to oppose the processing of personal data if you can prove that there are serious and legitimate reasons related to special circumstances that justify such an opposition. However, if the intended processing is classified as direct marketing, you have the right to oppose such processing free of charge and without justification.
7. Where your personal data is processed on the basis of consent or on the basis of a contract and the processing is carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and, if technically feasible, you have the right to transmit this data directly to another service provider. The technical feasibility of this is assessed solely by us.
8. If you wish to make a request to exercise one or more of the rights listed above, please send an e-mail to info@spidersecurity.be. This request must clearly state which right you wish to exercise and why. We will promptly notify you of the receipt of such request. If the request appears to be justified, we will grant it as soon as reasonably possible and no later than thirty (30) days after receipt of the request. Additional identification may be requested.
9. If you have a complaint about the processing of your personal data by us, you can always contact us at the e-mail address info@spidersecurity.be. If you remain dissatisfied with our response, you are free to file a complaint with the competent data protection authority, the Belgian Data Protection Authority, Rue du Printing Press 35, 1000 Brussels. For more information, visit https://www.gegevensbeschermingsautoriteit.be.

8. Details of our Data Protection Officer (dpo).

Eric Vanhorenbeke

eric.vanhorenbeke@spidersecurity.be