Privacy policy

1. Introduction

Licentius BV, with registered office at Slozenstraat 41, 1861 Meise, registered in the Crossroads Bank for Enterprises under number 1004.227.043, attaches great importance to the secure, transparent and confidential collection and processing of your personal data. In particular, we want to protect the data of our prospects, customers, principals, agents and suppliers against loss, leaks, errors, unauthorised access or unlawful processing. With this Data Protection Notice, we want to inform you about the collection and processing of your personal data. Please read this Data Protection Notice carefully, as it contains essential information on how your personal data are processed and for what purpose. By providing us with your personal data, you expressly declare that you have read this Data Protection Notice and that you expressly agree with it and with the processing itself.

2. Scope

This Data Protection Notice covers all services we provide and, in general, all activities we carry out.

3. Controller and its commitments

Licentius BV, mentioned above, is the controller of your personal data. When collecting and processing your personal data, we comply with Belgian legislation on the protection of personal data and, since it entered into force on 25 May 2018, with the General Data Protection Regulation (“GDPR”).

4. Personal data

Depending on your activities and your relationship with our company, you provide us with the following personal data: your identity and contact details (name, title, address, email address, telephone and mobile number). For certain specific legal obligations towards contractors (electronic attendance registration, 30bis works notification), you may provide us with additional data to register your attendance (such as eID data or Limosa number). Please note that you are responsible for all data you provide to us and that we rely on their accuracy. If your data are no longer up to date, please let us know immediately. You are not obliged to provide your personal data, but you understand that certain services or cooperation become impossible if you do not consent to their collection and processing.

5. Purposes and legal basis of the processing

5.1. Customer data

In the context of our services and activities, we collect and process the identity and contact details of our customers (or prospects), principals, agents and suppliers, their staff, employees and other useful contact persons. The purposes of this processing are the performance of the contracts concluded with our customers, customer management, accounting and direct marketing activities, such as sending promotional or commercial information. The legal bases are the performance of the contract, compliance with legal and regulatory obligations (for example the 30bis works notification) and/or our legitimate interest.

5.2. Supplier and subcontractor data

We collect and process the identity and contact details of our suppliers and subcontractors, as well as of any of their subcontractors, their staff, employees, agents and other useful contact persons. The purposes of this processing are the performance of the contract, supplier and subcontractor management, accounting and direct marketing activities, such as sending promotional or commercial information. The legal bases are the performance of the contract, compliance with legal and regulatory obligations (for example the mandatory electronic attendance registration, the 30bis works notification, the attendance list or other obligations in the context of public procurement, etc.) and/or our legitimate interest (for example for direct marketing). For the electronic attendance registration, eID data or the Limosa number are also processed where applicable. For direct marketing activities by email (such as a newsletter or an invitation to an event), your consent will always be requested and you can withdraw it at any time.

5.3. Staff data

We process the personal data of our employees in the context of personnel management and payroll administration. Given its specific nature, this processing is governed in more detail by a data protection policy for employees.

5.4. Other data

In addition to the data of customers, suppliers and subcontractors and staff, we also process personal data of other persons, such as potential new customers or prospects, useful contacts in our sector, contacts in our network, expert contacts, etc. This processing serves the interest of our activities, direct marketing and public relations. The legal basis is our legitimate interest or, in some cases, the performance of a contract.

6. Duration of the processing

We store and process personal data for as long as necessary in view of the purposes of the processing and of the (contractual or other) relationship we have with you. Data of customers, suppliers or subcontractors will in any case be deleted from our systems seven years after the end of the contract or project, except for personal data we must retain longer under specific legislation or in the event of an ongoing dispute for which these data remain necessary.

7. Rights

In accordance with Belgian privacy legislation and the provisions of the General Data Protection Regulation, and under the conditions they lay down, we inform you that you have the following rights.

Right of access: you have the right to consult, free of charge, the data we hold about you and to check what they are used for.

Right to rectification: you have the right to have inaccurate personal data corrected and incomplete personal data completed.

Right to erasure or restriction: you have the right to ask us to erase your personal data or to restrict their processing, in the circumstances and under the conditions laid down in the General Data Protection Regulation. We may refuse to erase or restrict personal data that we need to comply with a legal obligation, to perform the contract or to serve our legitimate interest, for as long as these data are necessary for the purposes for which they were collected.

Right to data portability: you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, and to transmit them to another controller.

Right to object: you have the right to object to the processing of your personal data on serious and legitimate grounds. Please note, however, that you cannot object to the processing of personal data that we need to comply with a legal obligation, to perform the contract or to serve our legitimate interest, for as long as these data are necessary for the purposes for which they were collected.

Right to withdraw consent: if the processing of personal data is based on your prior consent, you have the right to withdraw that consent. These personal data will then only be processed if we have another legal basis for doing so.

Automated decisions and profiling: we confirm that the processing of personal data does not include profiling and that you are not subject to fully automated decisions.

You can exercise the above rights by contacting Licentius BV. We do our utmost to process your personal data carefully and lawfully, in accordance with the applicable regulations. If you nevertheless believe that your rights have been infringed and your concerns are not addressed within our company, you are free to lodge a complaint with the Data Protection Authority, Drukpersstraat 35, 1000 Brussels, tel. +32 2 274 48 00, email: contact@apd-gba.be. You can also go to court if you believe you are suffering damage as a result of the processing of your personal data.

8. Transfer to third parties

Some of the personal data we collect will be passed on to, and possibly processed by, third-party service providers, such as our IT provider, accountant, auditor or broker, as well as to public authorities (for example in the context of the 30bis works notification, electronic attendance registration or participation in public procurement). One or more of these third parties may be established outside the European Economic Area (“EEA”). Personal data will, however, only be transferred to third countries with an adequate level of protection. The employees, directors and/or representatives of the above service providers or institutions, and the specialised service providers they appoint, are bound to respect the confidential nature of your personal data and may only use them for the purposes for which they were provided. Where necessary, your personal data may be passed on to other third parties, for example in the event of a full or partial reorganisation of our company, a transfer of our activities or bankruptcy. Personal data may also have to be disclosed to comply with a court order or a specific legal obligation. In that case, we will make reasonable efforts to inform you in advance of such disclosure to other third parties. You acknowledge and understand, however, that this is not always technically or commercially feasible in certain circumstances, or that legal restrictions may apply. We will in no case sell your personal data or make them commercially available to direct marketing agencies or similar service providers, except with your prior consent.

9. Technical and organisational measures

We take the necessary technical and organisational measures to process your personal data with an adequate level of security and to protect them against destruction, loss, falsification, modification, unauthorised access or accidental disclosure to third parties, as well as against any other unauthorised processing of these data. Licentius BV can in no case be held liable for any direct or indirect damage resulting from incorrect or unlawful use of the personal data by a third party.

10. Access by third parties

For the purpose of processing your personal data, we give our employees, staff and agents access to your personal data. We guarantee a similar level of protection by making contractual obligations similar to those of this Data Protection Notice binding on these employees, staff and agents.

11. Questions?

If, after reading this Data Protection Notice, you have any further questions or comments about the collection and processing of your personal data, please contact Licentius BV.