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Effective date: October 2022
The policy does not apply to any information processed about legal entities.
In line with our commitment to protect your personal data, we want to inform you and explain in all transparency:
We collect basic identification information about all individuals with whom we interact, such as your name, title, position, company name, email and/or postal address and fixed and/or mobile phone number.
This information may either be directly provided by you, communicated to us by the legal entity for whom you work (e.g. if you are the contact person designated by your employer to manage the Alto Domo NV account), supplied to us by one of our service providers (e.g. financial institutions or recruiters) or obtained from publicly available sources (e.g. social media profiles).
For our prospective current and former employees, we may in addition also collect the following information:
For (the representatives of) our suppliers, we may in addition also collect the following information:
For website’s visitors and any third parties following our company such as analysts and individuals having signed up for our newsletters, we may in addition also collect the following information:
To the extent authorised or required by law, we may also process sensitive data, such as trade union membership or health data. Alto Domo NV will only do so as strictly required for the relevant purposes listed in Section 4 below or to comply with a legal obligation and, where required, subject to having obtained your prior consent. In such case, the data will be accessed and processed solely under the responsibility of a representative of Alto Domo NV who is subject to an obligation of confidentiality.
Whenever personal data is collected (e.g. in forms), we will indicate whether the provision of such data is mandatory (e.g. with an asterisk) and the consequences of a refusal to provide the requested data.
We may also collect your national registry number or social security number but will only process such data if and when legally required.
Personal data will be collected by Alto Domo NV:
We are not allowed to process personal data if we do not have a valid legal ground. Therefore, we will only process personal data if:
Please note that, when processing your personal data on this last basis, we always seek to maintain a balance between our legitimate interest and your privacy. Examples of such ‘legitimate interests’ are:
We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. In particular, we process personal data for one of the following purposes.
In relation to prospective, current and former members of the personnel, we process personal data for:
In relation to Alto Domo NV’s website’s visitors and any third parties following our company such as analysts and individuals having signed up for our newsletters, we process personal data to:
In addition to the above specific purposes, we process all collected personal data for the following general purposes:
We have implemented appropriate technical and organisational measures to provide a level of security and confidentiality to your personal data. These measures take into account:
The purpose thereof is to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.
Moreover, when handling your personal data, we:
For the latter, we may request you to confirm the personal data we hold about you. You are also invited to spontaneously inform us whenever there is a change in your personal circumstances so we can ensure your personal data is kept up-to-dat
We may transfer or give access to personal data to third parties outside Alto Domo NV to complete the purposes listed in Section 4.2 above, to the extent they need it to carry out the instructions we have given to them. Such third parties may include:
The above third parties are contractually obliged to protect the confidentiality and security of your personal data, in compliance with applicable law.
Transfers outside the European Economic Area
The personal data transferred by Alto Domo NV may also be processed in a country outside the European Economic Area ("EEA"), which covers the EU Member States, Iceland, Liechtenstein and Norway. Non-EEA countries may not offer the same level of personal data protection as EEA countries.
If your personal data is transferred outside the EEA, we will therefore put in place suitable safeguards to ensure such transfer is carried out in compliance with the applicable data protection rules. You may request additional information in this respect and obtain a copy of the relevant safeguard by exercising your rights as set out below.
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We will only retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
We only keep data related to candidates for recruitment purposes for a maximum period of two years. For current employees, the retention period is the time of your employment, unless overriding legal or regulatory schedules require a longer or shorter retention period.
For contracts, the retention period is the term of your (or your company’s) contract with us, plus the period of time until the legal claims under this contract become time-barred, unless overriding legal or regulatory schedules require a longer or shorter retention period.
Personal data collected and processed in the context of a dispute are deleted (i) as soon as an amicable settlement has been reached, (ii) once a decision in last resort has been rendered or (iii) when the claim becomes time barred.
When the above retention periods expire, your personal data is removed from our systems.
However, if individuals wish to have their personal data removed from our databases, they can make a request as described in Section 8, which we will review as set out below.
You have a right of access to your personal data as processed by Alto Domo NV under this policy. If you believe that any information we hold about you is incorrect or incomplete, you may also request the correction thereof. Alto Domo NV will promptly correct any such information.
You also have the right to:
Alto Domo NV will review such requests, withdrawal or objection and honour them as required under the applicable data protection rules.
In addition, you also have the right to data portability. This is the right to obtain the personal data you have provided to Alto Domo NV in a structured, commonly used and machine-readable format and to request the transmission of such personal data to a third party, without hindrance from Alto Domo NV and subject to your own confidentiality obligations.
Exercising your rights
If you have a question or want to exercise the above rights, you may send an email to firstname.lastname@example.org or a letter at Alto Domo NV, , De Blokskens 6, Zoersel , with a scan of your identity card for identification purpose, it being understood that we shall only use such data to verify your identity and shall not retain the scan after completion of the verification. When sending us such a scan, please make sure to redact your picture and national registry number or equivalent on the scan.
If you are not satisfied with how we process your personal data, please address your request to Alto Domo NV by mail email@example.com or by letter at Alto Domo NV, De Blokskens 6, Zoersel and we will investigate your concern.
In any case, you also have the right to file a complaint with the competent data protection authorities, in addition to your rights above.
This policy may be subject to amendments. Any future changes or additions to the processing of personal data as described in this policy affecting you will communicated to you through an appropriate channel, depending on how we normally communicate with you.
(1) Regulation 2016/679 of the EU Parliament and of the Council 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 (General Data Protection Regulation or “GDPR”).
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