Dots & Arrows NV / BV values your privacy and handles your personal data with care. We therefore do our utmost to explain to you in clear and plain language with this privacy statement what personal data we collect from you, what we use it for and what your rights are in this regard.
This version of this privacy statement (version: 1.00) dates from (08/01/2024)
1. Who are we?
“We”, “we”, “us” or “our” means Dots & Arrows NV / BV with registered office at Diamantstraat 10, 2200 Herentals and with company number BE 0833.154.378 / NL 84755539.
If you have any questions, comments or complaints regarding this privacy statement or the processing of your personal data or you wish to exercise any of your rights, please contact us by email to privacy@bewire.be for your attention from the Privacy Officer / Data Protection Officer
2. Scope
This privacy statement applies to this website, our direct marketing activities and the general organization of Dots & Arrows NV / BV.
3. Why and how do we process your personal data?
If you visit our website and/or are in contact with us, certain personal data may be processed. Below you will find more information about the different processing activities that may apply to you.
3.1 Use of our website
When you visit our website, we may process personal data using online techniques such as cookies, trackers, scripts and similar technologies (hereinafter referred to as ‘cookies’). These may be (1) essential cookies that are strictly necessary to send a message via an electronic communications network, to ensure the security of our website or to store information about the provision of a service expressly requested by you; (2) functional cookies that further shape your use of our website; (3) analytical cookies to measure and analyze your use of our website; (4) marketing cookies to deliver you (personalized) advertisements; and (5) other third-party cookies we allow on our website.
You can find more information about this in our cookie statement .
3.2 Contact via website
Consent – Contact forms are available on our website to get in touch with us. You can always reach us by e-mail or telephone. We process this personal data to process your contact request, but we have no insight or control over any other personal data that you provide to us via the open input fields. We request that you do not share any confidential or sensitive data here.
This processing is done on the basis of your consent. Please know that you can withdraw it at any time. This withdrawal will not affect the lawfulness of the processing that took place before the withdrawal of your consent.
Which personal data do we process?
- Identification and contact details (first name, surname, address, e-mail address, telephone number, company name)
- Other information as may be spontaneously communicated in the contact form:
- Professional data
- Personal details
- …
How do we obtain this personal data? Directly from you when completing our contact form
How long do we keep them? Your personal data will not be kept for longer than is necessary to fulfill a specific purpose. However, because it is not possible to indicate a period in advance, the period will be decided as a guardian:
(a) As long as interaction can be demonstrated between you and Dots & Arrows NV / BV (or one of its related entities), the data will be kept.
(b) Once there is no longer any interaction, your personal data will be retained for another two years.
With whom may we share this personal data (other than affiliated and associated companies)? Processors (such as our hosting partner) that we use in the context of our website, contact or relationship management.
Does these activities involve automated individual decision-making? No
Do these activities involve a transfer outside the EEA? No
3.3 Customer relationship management (incl. prospecting new customers)
Legitimate interest – Dots & Arrows NV / BV is always looking for new customers, actively making new contacts and building relationships with existing customers. In this context, your personal data are processed (e.g. to invite you to other forms of communication, an event, etc.)
This processing is done on the basis of the legitimate interest of Dots & Arrows NV / BV. You can always object to this in accordance with the conditions described under ‘right to object’ in the chapter ‘What are your rights and how can you exercise them’.
Which personal data do we process?
- Identification and contact details
- Other information that may have been discussed during further contacts:
- Professional data
- Leisure activities and interests
- Personal details
- …
How do we obtain this personal data? Directly from you via relationship management.
How long do we keep them? Up to 7 years after handling a last order or contact.
With whom can we share this personal data (other than affiliated and associated companies)? Processors (such as our CRM platform) that we use in the context of our website, contact or relationship management. Do
these activities involve automated individual decision-making? No
Do these activities involve a transfer outside the EEA? No
3.4 Sending newsletters
Consent – You can register for our newsletter on our website. We process this personal data to subsequently contact you when a new newsletter is available for you.
This processing is done on the basis of your consent. You have the option to withdraw the consent given at any time without affecting the lawfulness of the data processing up to the moment the withdrawal took place. In concrete terms, this means that your consent remains valid for all previous newsletters, but you will no longer receive newsletters.
Which personal data do we process? Identification and contact details
How do we obtain this personal data? Directly from you when you register.
How long do we keep them? As long as consent is not withdrawn,
with whom can we share this personal data (other than affiliated and associated companies)? Processors (such as our e-mail platform) that we use in the context of our website or the delivery of newsletters.
Do these activities involve automated individual decision-making? No
Do these activities involve a transfer outside the EEA? No
3.5 Organization of events
Consent – When you register for one of our events, personal data will be processed for the processing of your registration and the organization of the event.
This processing is done on the basis of your consent. You have the option to withdraw the consent given at any time without affecting the lawfulness of the data processing up to the moment the withdrawal took place. In concrete terms, this means that your permission remains valid for all previous events in which you have already participated, but you will no longer be invited to events in the future.
Which personal data do we process?
- Identification and contact details
- Other information as may have been spontaneously communicated:
- Professional data
- Leisure activities and interests
- Personal details
- Allergies or dietary requirements
- …
How do we obtain this personal data? Directly from you when you register.
How long do we keep them? We store the personal data about your participation for a maximum of 1 year after the event has taken place.
With whom may we share this personal data (other than affiliated and associated companies)? Processors (such as event companies, catering, etc.) that we call upon to help organize and shape the event.
Does these activities involve automated individual decision-making? No
Do these activities involve a transfer outside the EEA? No
3.6 Recruitment and selection
Consent for (spontaneous) applications and maintaining a recruitment reserve -Legitimate interest for active recruitment –
When you (spontaneously) apply for a position at Dots & Arrows NV / BV, Dots & Arrows NV / BV processes personal data about you. We do this in order to recruit and select employees for open or future vacancies. This processing (including the creation of a recruitment reserve) is done on the basis of your consent. You have the option to withdraw the consent given at any time without affecting the lawfulness of the data processing up to the moment the withdrawal took place.
When Dots & Arrows NV / BV actively recruits itself, Dots & Arrows NV / BV processes personal data about you. This is only done on the basis of data that is publicly available about you (e.g. on platforms such as LinkedIn and Google) or data provided to us by third parties. This processing is done on the basis of the legitimate interest of Dots & Arrows NV / BV. You can always object to this in accordance with the conditions described in ‘Right to object’ in the chapter ‘What are your rights and how can you exercise them’.
Finally, we indicate that we rely on our legitimate interest to pass on your personal data to the companies affiliated and associated with us in the context of our recruitment process. Naturally, we always do this with a view to finding a suitable assignment for you. You can always object to this in accordance with the conditions described under ‘right to object’ in the chapter ‘What are your rights and how can you exercise them’.
Which personal data do we process?
- Identification and contact details
- Other information as may be stated on your CV:
- Personal characteristics
- Social contacts
- Mental data (cf. a description of your personality or character)
- Family composition
- Leisure activities and interests
- Academic curriculum
- Professional competence
- Professional experience
- Membership/participation in professional organizations
- Current position
- Career
- Business administration data (cf. (partial) disability)
- Current salary
- Current fringe benefits
- Lacing register number
- …
How do we obtain this personal data?
- (Spontaneous) application: directly from you with your application
- Active recruitment: via third parties such as public platforms or intermediaries
How long do we keep them?
- If applicants are not retained: we will store the personal data about your application for a maximum of 1 year after application.
- For applicants within our recruitment reserve: as long as consent is not withdrawn and up to a maximum of 3 years after application.
With whom may we share this personal data (other than affiliated and associated companies)? Processors (such as recruitment offices) that we use to recruit and select
Does these activities involve automated individual decision-making? No
Do these activities involve a transfer outside the EEA? No
3.7 Management of supplier relationships (incl. prospecting new suppliers)
Legitimate interest – Dots & Arrows NV / BV works together with suppliers, actively making new contacts and building relationships with existing suppliers. In this context, personal data of employees at our suppliers (e.g. account managers) are processed.
This processing is done on the basis of the legitimate interest of Dots & Arrows NV / BV. You can always object to this in accordance with the conditions described under ‘right to object’ in the chapter ‘What are your rights and how can you exercise them’.
Which personal data do we process?
- Identification and contact details
- Other information that may have been discussed during further contacts:
- Professional data
- Leisure activities and interests
- Personal details
- …
How do we obtain this personal data? Directly from you via relationship management.
How long do we keep them? Up to 7 years after handling a last order or contact.
With whom can we share this personal data (other than affiliated and associated companies)? Processors (such as our CRM platform) that we use in the context of our relationship management.
Are these activities involved in automated individual decision-making? No
Do these activities involve a transfer outside the EEA? No
4. Sharing personal data with third parties
When you visit our website or use our products and services as a customer, we may rely on third parties, such as partners, affiliated and associated companies and suppliers, to whom we pass on your personal data. These third parties help us deliver, support, develop and understand the use of our products and services and provide services such as hosting, customer and technical support, marketing, analytics, content delivery and/or fulfillment of online payment(s).
In addition, we may also share data (including personal data) with third parties in the context of a reorganization, restructuring, merger, sale or other transfer of assets. We share the information you provide, automatically collected information and information from others with these third parties as necessary to enable them to provide their services or support. In the activities described above, we indicate per activity with which categories of third parties, other than affiliated and associated companies, we share your personal data.
Furthermore, we may have to provide access to your data or pass on your data because of a legal obligation. This to authorities, government institutions or other third parties.
Finally, we may pass on your data if this proves necessary in the context of your vital interests.
5. Transfer of personal data outside the EEA
Dots & Arrows NV / BV always tries to limit the transfer of personal data to third parties outside the European Economic Area (hereinafter: “EEA”).
If this were to be the case, we will ensure that this transfer is done as quickly as possible in accordance with the GDPR (including by the presence of an adequacy decision in the country concerned or by arranging a suitable alternative, additional measures if necessary). , etc.) is brought.
For specific transfers, we refer to the chapter “Why and how do we process your personal data?”).
6. How long do we keep your personal data?
We do not store your personal data for longer than is strictly necessary to achieve the purposes for which the personal data was collected or in accordance with the legal obligation imposed on us. For the specific retention period, we refer to the chapter “Why and how do we process your personal data?”).
7. Automated individual decision making
European data protection law (GDPR) imposes certain conditions on organizations when they make decisions about individuals based solely on processing that is fully automated, including profiling, and when these decisions have legal effects or other significant consequences. Dots & Arrows NV / BV does not engage in this type of decision-making.
8. What are your rights and how can you exercise them?
Dots & Arrows NV / BV believes it is important that you always maintain control over the processing of your personal data. Below you will find more information about the various rights you have and can invoke with regard to the processing of your personal data:
Depending on the processing and the legal basis for that processing, certain conditions or restrictions may be associated with the exercise of the rights below.
To exercise the above rights, or information regarding this, you can contact privacy@bewire.be. We will therefore provide more information if certain modalities are linked to your request. Furthermore, we may request additional information to verify your identity so that your personal data is not wrongly deleted or shared with someone who is not entitled to it. We will endeavor to respond to your request without unreasonable delay, but in any case within one month of receipt of your request. If we cannot respond within one month and wish to extend the period, or if we do not respond to the request, we will inform you of this.
8.1 Right of access:
In the event that we process your personal data, you have the right to access your personal data, as well as to certain additional information as described in this privacy statement. You have the right to receive from us a copy of the personal data we hold, provided this does not adversely affect the rights and freedoms of others. The first copy will be delivered to you free of charge, but in case of repeated requests we reserve the right to charge a reasonable fee.
8.2 Right to improvement:
If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information corrected or, taking into account the purposes of the processing, completed.
8.3 Right to restriction of processing:
You have the right to have the processing of your personal data restricted. This means that the personal data may only be stored by us and may only be used for limited purposes. This right applies if one of the following situations occurs:
- You contest the accuracy of the personal data, for a period that allows us to verify the accuracy of the personal data;
- The processing is unlawful, but you oppose the erasure of the personal data and instead request a restriction of its use;
- We no longer need your personal data for the processing purposes described above, but you need it for the establishment, exercise or substantiation of a legal claim; or,
- You have objected to processing and ask us to restrict processing pending the answer to the question whether our interests outweigh yours.
In addition to our right to store your personal data, we may still process it, but only:
- With your permission;
- To establish, exercise or defend a legal claim;
- To protect the rights of another natural or legal person; or
- For reasons of public interest.
You will be informed before we lift the restriction on the processing of your personal data.
8.4 Right to data portability:
If the processing of your personal data is based on your consent, and the processing is carried out via automated processes, you have the right to receive a copy of your personal data in a structured, commonly used and machine-readable format. You also have the right to have your personal data delivered directly by us to a third party, if this is technically possible. This right does not apply where it would adversely affect the rights and freedoms of others.
8.5 Right to object:
You have the right to object to the processing of your personal data in the activities described above. In the latter case, this is only possible if the activity is related to (1) the performance of a task of general interest or in the exercise of a task in the context of the exercise of public authority vested in us or (2) the representation of our legitimate interests or those of a third party.
If you object to the processing of your personal data, we will no longer process the personal data unless we can demonstrate legitimate interests for the processing that outweigh your interests, fundamental rights and freedoms.
If your personal data is processed for direct marketing purposes, regardless of whether it concerns initial or further processing, you have the right to object to this processing at any time and free of charge, including in the case of profiling to the extent that it concerns on direct marketing. If you make such an objection, we will stop processing your personal data for this purpose.
8.6 Right to erasure (right to be forgotten):
You have the right to request us to erase your personal data. This means that the personal data must be deleted by us without unreasonable delay. This right applies if one of the following situations occurs:
- The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
- You withdraw your consent on which the processing is based, and there is no other legal basis for the processing of your personal data;
- Your personal data has been processed unlawfully;
- Deletion of your personal data is necessary to comply with European or Belgian law;
If you request us to delete your personal data, we will delete the personal data unless one of the following situations (exceptions) applies:
- The processing is part of the exercise of the right to freedom of expression and information;
- Erasure is not appropriate for public health reasons;
- Erasure is not an issue given the need for archiving in the public interest or statistical purposes;
- There is a legal obligation to retain the data; or,
- Deletion is not appropriate given the institution, exercise or substantiation of a legal claim.
8.7 Right to withdraw your consent:
If you have given permission for certain processing of your personal data, you can withdraw this at any time. We try to make withdrawing your consent as simple as possible and, to the extent possible, as simple as giving your consent.
8.8 Right to object to the processing of your personal data in automated individual decision-making:
If your personal data is used in the context of automated individual decision-making and if these decisions have legal effects or other significant consequences, you can request us to no longer use your data. If you object to this processing, we will stop or limit the processing unless there are compelling reasons to do so.
9. Who can I contact with further questions or complaints regarding privacy?
If, after reading this privacy statement, you have further questions or comments regarding the collection and processing of your personal data, you can always contact us at the following email address: privacy@bewire.be.
In addition, you have the right to submit any comments, comments or complaints to the supervisory authority responsible for data protection. You can do this in the EU member state where you reside, the place where you work or the place where the alleged infringement took place. In Belgium you can file a complaint with the Data Protection Authority:
Data Protection Authority
Drukpersstraat 35, 1000 Brussels
+32 (0)2 274 48 00
www.gegevensbeschermingsautoriteit.be/burger/acties/klacht-indienen
www.gegevensbeschermingsautoriteit.be
Because we attach great importance to our mutual relationship, we request that you always contact us first so that we can work out a solution for the underlying cause of your complaint.
11. Adjustments to the privacy statement
Our organization and therefore also our website are a dynamic and innovative environment. This privacy statement can be adjusted if our services or applicable legislation so require. This means that we are constantly looking for better services tailored to your needs. It is possible that there will be new applications in which we will collect or process your personal data in a different way. We will of course inform you if there are important changes to this privacy statement and we will ask your permission if necessary.