1. DATA CONTROLLER

 
This Privacy Policy governs the processing of personal data by the ELKEM PROCESSING SERVICES, data controller, with registred office in Rue de la Bureautique 2-4, B-4460 Grâce-Hollogne, enterprise identification number 0876.098.852, and who appointed René Stassen as processing contact person:  sales@keyvestbelgium.be.
 
This privacy policy applies to all of the services we provide and to all of the activities we do.
 
By communicating your personal data, you expressly acknowledge having read it, fully understand the content and fully accept the terms of it.

In particular, you agree that ELKEM PROCESSING SERVICES  treats (collects, stores or uses your personal data) for the purposes specified below. 
 

2. PERSONAL DATA CATEGORIES

 
The General Data Protection Regulation defines the term "personal data" as follows: "Any information relating to an identified or identifiable natural person" (hereinafter referred to as "data subject").
 
An « identifiable natural person » is one who can be identified, directly or indirectly, 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;

 As part of its activities, the ELKEM PROCESSING SERVICES  may collect personal data of its customers, suppliers, subcontractors (and any of their eventual subcontractors), prospects, companies / persons belonging to its professional network and, respectively, of their principals, their staff, their collaborators, their agents and any other person of useful contact.
 
This personal data may be, among other things, personal data such as marital status, first and last names, telephone numbers, addresses or registered office, email addresses, etc., as well as any information spontaneously communicated by the data subject.
 
The website of ELKEM PROCESSING SERVICES  uses cookies (see "cookies" policy).
 

3. HOW THE DATA ARE COLLECTED AND STORED.

 
Personal data is collected as follows:
 
- By the encoding of the data by the data subjects, in the forms appearing on the website https://keyvestbelgium.be;
 
- By sending data, by the data subjects, when placing an order (by internet, email or mail).

The data communicated via the website https://keyvestbelgium.be are stored on the server of the host "INFOMANIAK", in Suisse.
 
The data communicated otherwise than via the website are stored on the secure local server (back up) of the ELKEM PROCESSING SERVICES, accessible only to the staff of the ELKEM PROCESSING SERVICES as well as to the staff of the computer maintenance company (SCALP srl) , by a secret password, via secure ERP.
 
 
4. PURPOSES OF THE PROCESSING
 
This data is collected by the ELKEM PROCESSING SERVICES  to enable it to provide the service entrusted by the contract / agreement concluded with the customer but also for the management of its customers, the establishment of invoices and their collection and in order to fulfill its legal, accounting and regulatory obligations but also, with the agreement of the people concerned, via newsletters, to send promotions, offers, news for the company, price changes, closures, seasonal greetings.

 

5. LEGAL BASIS FOR THE PROCESSING

 
The legal basis of the processing of personal data is the performance of a contract, the consent of the person concerned (if need be) as well as the respect of legal / regulatory obligations and / or the legitimate interest of the ELKEM PROCESSING SERVICES.
 

6. RECIPIENTS OF PERSONAL DATA

 
The ELKEM PROCESSING SERVICES  will keep and process the collected data itself in order to enable it to achieve the purposes of the processing.
 
However, in the context of these purposes, personal data may be disclosed to public authorities, accountants, auditors, lawyers, accountants, collection companies, IT service providers, subcontractors or collaborating companies with the ELKEM PROCESSING SERVICES.
 
It is possible that these entities are located outside the European Economic Area ("EEA"). However, in this case, personal data will only be transmitted to third countries with an adequate level of protection.
 
If need be, the personal data may also be transmitted to other third parties in connection with, for example, a reorganization of the ELKEM PROCESSING SERVICES, in case of transfer of activity, liquidation or bankruptcy, due to an injunction or in order to fulfill a particular legal obligation.

 
However, the ELKEM PROCESSING SERVICES  ensures that these persons / companies / entities have the most limited access possible to these personal data and only processes it when strictly necessary.
 

7. DURATION OF THE PROCESSING

 
The ELKEM PROCESSING SERVICES  retains the personal data entrusted to it for the duration necessary for the purpose of the processing.
 
To determine the appropriate duration, the nature and sensitivity of the personal data and the purposes for which they are processed are taken into account. Account is also taken of the need to comply with its legal and regulatory obligations.
 

8. SECURITY MEASURES

 
The ELKEM PROCESSING SERVICES  has implemented technically and organizationally appropriate security measures to prevent destruction, loss, falsification, modification, unauthorized access by third parties or the inadvertent notification of personal data to third parties, as well as any unauthorized processing of such data.
 
Thus, the ELKEM PROCESSING SERVICES  has, among others, provided for the following:
 
− use of secure passwords for its workers and managers;

− inclusion in contracts and working rules clauses providing for the confidentiality of data;

− regular updating of PCs with up-to-date security patches and antiviruses;

− regular backups of important data. 
 

9. RIGHTS OF THE DATA SUBJECT

 
9.1 Right of access, alteration, erasure and restriction.
 
You have the right to ask ELKEM PROCESSING SERVICES  to access your data and to request a rectification.
 
In accordance with the legal requirements of the RGPD, you can also request their erasure or restriction.
 
You acknowledge that in case of refusal of communication or request for erasure of personal data, the ELKEM PROCESSING SERVICES  may be unable to provide certain services.
 
9.2 Right to object
 
You have the right to oppose the processing of your personal data for compelling and legitimate reasons.
 
In addition, you have the right to object to the use of personal data for direct marketing purposes. If so, you do not even have to invoke a reason.
 
9.3 Right of free transfer of data
 
You have the right to receive personal data that you have provided to the ELKEM PROCESSING SERVICES  in a structured, commonly used and machine-readable format and to transmit this data to other data controllers.
 
9.4 Right to withdraw consent
 
As long as the processing is based on your prior consent, you have the right to withdraw that consent.
 
9.5 Exercising your rights
 
You can exercise your rights by contacting ELKEM PROCESSING SERVICES  for this purpose by e-mail at the address "sales@keyvestbelgium.com" or by mail at the address " Rue de la Bureautique 2-4, B-4460 Grâce-Hollogne", with the addition of a copy of the front and back of your identity card.
 
9.6 Automated Decisions and Profiling
 
The processing of your personal data does not include any profiling and will not be the subject of automated decisions by the ELKEM PROCESSING SERVICES.
 
9.7 Right to lodge a complaint
 
You have the right to lodge a complaint with the supervisory authority: Autorité de protection des données, Rue de la Presse 35, 1000 Brussels, Tel +32 (0) 2 274 48 00, Fax +32 (0) ) 2 274 48 35, e-mail: contact@apd-gba.be, without prejudice to any proceedings before a civil court. 

 
10. CHANGES

 
This data protection policy may be subject to change. We recommend that you regularly consult the data confidentiality policy, which can be consulted via the "https://keyvestbelgium.be" website, to learn about any changes. 
Last updated: 04/02/2021 
 
This privacy policy is established without prejudice to the rights and obligations recognized by the ELKEM PROCESSING SERVICES  under applicable provisions such as those contained in the GDPR.