Clear Digital NV (hereinafter Clear Digital) considers privacy and data protection to be very important. By means of this privacy statement (hereinafter referred to as "Privacy Statement"), Clear Digital wishes to inform you about the processing of personal data. Clear Digital will process your personal data with respect for your privacy and in compliance with the applicable data protection regulations.
We reserve the right to make amendments to this Privacy Statement at any time. In order to be aware of any changes, please consult this Privacy Statement regularly.
This Privacy Statement was last amended on: 27/04/2021
Processing of Personal Data: Processing is an operation or set of operations relating to personal data or a set of personal data, whether or not carried out by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction. Personal data is any information about a natural person, by which that person can be identified directly or indirectly.
A processor: A processor is a natural or legal person, a government agency, a service or another body that processes personal data on behalf of the controller.
A controller: A controller is a natural or legal person, a government agency, a department or another body that alone or jointly with others determines the purposes and means of the processing of personal data.
2 TO WHOM DOES THIS PRIVACY STATEMENT APPLY?
This Privacy Statement applies to all direct customers, visitors, suppliers, job applicants and all other persons who are not employees of Clear Digital and whose personal data Clear Digital processes as a data controller. For the remainder of this Privacy Statement, we refer to an individual who belongs to any of these groups as a "data subject".
3 CONTACT DETAILS
Name: Clear Digital NV
VAT #: 0899.850.588
Adress: Langveldstraat 51, 3500 Hasselt
Phone number: +32 (0)11 32 22 02
4 PARTY RESPONSIBLE FOR PROCESSING
Only when Clear Digital acts in the capacity of a data controller shall points 5 to 10 of this Privacy Statement apply.
If you as a data subject wish to exercise your rights, you must always approach the person responsible for processing.
5 WHAT PERSONAL DATA DOES CLEAR DIGITAL PROCESS?
5.1 Based on the execution of an agreement
Clear Digital processes personal data which is necessary for the execution of an agreement to which you are a party or in order to take measures at your request prior to the conclusion of an agreement.
When requesting an offer
If you would like more information about Clear Digital's services or products, you may request a quotation through various channels (telephone, website, social media, etc.). To this end, Clear Digital processes personal identification data (such as name and e-mail) in order to provide you with the most accurate proposal possible.
When processing an order, following up on invoices and commercial agreements
If you order products or services from or supply them to Clear Digital, the latter shall process personal identification data and professional details in order to be able to deal with and follow up the order or delivery correctly.
Clear Digital regularly seeks new enthusiastic motivated employees. During the application procedure Clear Digital processes the following categories of personal data: personal identification data, personal characteristics (such as language, date of birth, etc.), competences, educational history, career path, curriculum vitae, image, work references.
When participating in an event
Clear Digital organizes events. When organizing such an event, we process personal identification data and professional data upon registration.
When participating in a training course
Clear Digital organizes training courses. For the smooth course and administrative follow-up we process your personal identification details and professional data.
5.2 Based on your consent
When processing personal data based on your consent, you always have the right to withdraw it (see 10. What are your rights and how can you exercise them).
When you subscribe to our newsletter
When you subscribe to our newsletter, you consent to the sending of a newsletter. Clear Digital will give you the opportunity to unsubscribe from the newsletter.
In the event of the creation of a recruitment reserve
In case Clear Digital does not hire you after an application, but would like to keep your CV for future opportunities, Clear Digital will ask your permission to keep your CV.
When using specific photographs for publicity purposes
When publishing targeted images on social media and the website, Clear Digital will ask for your permission. By targeted images we mean images in which the person is clearly recognizable (close-up, image focused on a specific person, posed photo, etc.).
5.3 Based on legitimate interest
Clear Digital processes personal data based on a legitimate interest in which Clear Digital has made a balancing of interests.
When registering visitors to our offices
For security reasons Clear Digital wishes to know who is present in our offices at any given time. The employee with whom the visitor has an appointment is informed that the visit has arrived. Clear Digital processes the following personal data in this respect: personal identification data (such as name, e-mail, telephone number), identification data issued by the government (license plate), professional data (e.g. the company for which you work).
In case of the use of security cameras
Cameras are installed in and around the buildings of Clear Digital for the purpose of preventing, determining or detecting nuisance or crimes against persons and property and to maintain public order. For this purpose visual material is collected, processed and stored.
When dealing with a question, offering help, offering information at your request
You can contact Clear Digital through various channels (telephone, correspondence, e-mail, chat, contact form website, social media). We will only use the personal data you provide to respond to your inquiries.
When sending direct marketing
Clear Digital sends direct marketing and thereby processes personal identification data. Clear Digital respects the accompanying regulations, whereby direct marketing is only sent if there is a customer relationship, with regard to similar products or services which Clear Digital supplies itself. As a data subject you always have the opportunity to unsubscribe.
When carrying out competency tests during the application period
In order to screen an applicant, Clear Digital conducts an assessment of the competences and personality of the candidate. Clear Digital uses an assessment agency as a processor for this purpose, but we will not use the data for other purposes or pass it on to third parties for their own use.
When creating an application overview list with the status for each person involved
Due to the many job applications that Clear Digital processes and the various channels through which new candidates are introduced, there is a legitimate interest in creating a list so that we do not revisit candidates we reject after several weeks. This list contains only personally identifying information.
When maintaining contact information to notify you as an acquaintance/family of our employee in the event of an emergency
We ask our employees to provide contact information for an acquaintance and/or family member so that we can notify them in the event of an emergency.
When using footage for public relations and/or journalistic purposes
When Clear Digital organizes a large corporate event, Clear Digital has a legitimate interest to engage in public relations in order to attract new employees and/or new customers. The visitors of the event are informed in advance and have the possibility to oppose the taking of the picture: at the event itself against the photographer or after the event by sending an e-mail to #EMAILADRES.
In improving the quality of the website
5.4 Consistent purpose
If we collected your personal data under a legitimate interest or agreement, we may also use these data in the future for another purpose that is compatible with the original purpose. In doing so, we pay attention to the following points:
The relationship between the original purpose and the new/future purpose;
The context in which the data was collected (what is the relationship between you and Clear Digital);
the type and nature of the data (does it concern sensitive data?);
the possible consequences of the intended further processing (what are the consequences for the data subject?);
The existence of appropriate safeguards (such as encryption or pseudonymization).
6 WHO DO WE SHARE YOUR DATA WITH?
Clear Digital does not share your personal data with third parties unless:
Clear Digital has received your prior consent to do so;
Clear Digital is obliged to do so in the context of regulations or legal proceedings;
Clear Digital is requested to do so by legislative or judicial authorities;
Clear Digital organizes an event together with partners or suppliers. The list of participants is also communicated to the partners or suppliers;
Clear Digital is taken over or split up, in whole or in part. In such case Clear Digital shall impose on the third party an obligation to process the personal data only in accordance with the provisions of this Privacy Statement.
Clear Digital makes use of certain subcontractors such as, amongst others, consultants, research agencies (e.g. for conducting satisfaction surveys), tools (e.g. CRM system, mailing tool) and this for the purpose of outsourcing part of our services to them. These subcontractors are not regarded as third parties but as processors. We ensure that these subcontractors take the necessary technical and organizational measures to process your personal data validly and lawfully and also under no circumstances to disclose them to third parties.
7 SECURITY OF YOUR PERSONAL DATA
Clear Digital recognizes that the security of personal data is an element of data protection. Therefore, Clear Digital shall take appropriate technical and organizational measures to protect your personal data against unauthorized processing or unauthorized access in order to prevent misuse.
In the event of any transfer of personal data to a processor outside the European Economic Area (EEA), Clear Digital will always do so in accordance with the terms of this Privacy Statement and will follow applicable data protection laws and regulations to ensure adequate safeguards.
8 RETENTION OF YOUR PERSONAL DATA
Clear Digital will retain your personal data only for the minimum period necessary to fulfil the purposes set out in this Privacy Statement, unless (i) a longer retention period is required in the resolution of disputes or (ii) if a longer retention period is required by law. Non-personal information may be retained over time without limitation for statistical purposes.
Cookies are text files placed on your computer to collect standard internet logging information and behavioral information. This information is used to track visitor behavior on the website and to compile statistical reports on the website.
10 WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?
10.1 What are your rights?
Right of access:
You can ask us what personal data we process from you, what we process it for, what categories of personal data we process, with what categories of third parties we share your personal data, what is the origin of the processed data and - when applicable - what logic we use in the automatic processing of personal data.
Right to rectification:
If information is incorrect, you can ask us to correct it.
Right to erase your data: If data is not processed lawfully or if your data is no longer needed beyond the purpose for which it was collected, you can ask us to delete your data.
Right to restrict processing:
By restricting the processing of your personal data, your personal data can still be kept but its use is limited. If you have requested a processing restriction, we may only store your data. This means that no other transactions can be carried out with your data.
Right to object:
You have the right to object to your data being processed if such processing is based on a public interest or legitimate interest of the person processing your data. In addition, you can also assert this right to object if your personal data is processed for direct marketing purposes. This right to object also applies to profiling which forms the basis of processing for direct marketing purposes.
Right to withdraw consent:
If the processing of your personal data is based on the basis of consent, you have the right to withdraw this consent at any time.
Right to data portability:
You have the right to obtain the personal data you have provided in a comprehensive, structured and machine-readable form and you have the right to transfer this personal data to another controller if the processing is based on the legal grounds of consent or contractual relationship.
The above rights are only a summary and remain at all times subject to the limitations of applicable data protection law.
10.2 How can you exercise your rights?
You can exercise your rights by sending an email to email@example.com. In order to prevent any unauthorized disclosure of your personal data, Clear Digital may request more information to verify your identity.
Clear Digital has one month to respond to your request. This period begins when Clear Digital has received your application and has all the required information to fulfill your request. The one month period may be extended upon notice and explanation from Clear Digital.
Clear Digital will provide the requested information free of charge. Where requests are unwarranted or excessive, particularly due to their repetitive nature, Clear Digital may charge a reasonable fee or may deny the request.
If for any reason you believe that Clear Digital has not handled your request correctly, you may contact Clear Digital again and we will work with you to find a solution.
For the sake of completeness we inform you that, in the event that Clear Digital does not respond to your request, refuses it or our response does not meet your expectations, you are at all times entitled to lodge a complaint with the Data Protection Authority, rue du Mail 35, 1000 Brussels, Tel +32 (0)2 274 48 00, or via the e-mail address firstname.lastname@example.org.