iKanbi Group S.A. (hereinafter referred to as “iKanbi Group”) understands the importance of protecting Personal Data. This Privacy Statement (hereinafter referred to as “the Statement”) contains important information about the processing of the Personal Data of customers, suppliers, third parties and website visitors in the course of iKanbi Group’s business activities.

In this Statement:

• “iKanbi Group”: iKanbi Group S.A., Place du Champ de Mars 5, 1050 Brussels
• “Personal Data” (hereinafter referred to as “Personal Data” or “Data”): any information relating to a natural person who can be identified or who is identifiable directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data or an online identifier.
• “Data Controller”: the natural or legal person, public authority, agency or any other body which, alone or jointly with others, determines the purposes and means of the processing.
• “Subcontractor”: the natural or legal person who processes Personal Data on behalf of the Data Controller.
• “Processing of Personal Data”: any operation or set of operations which is applied to Personal Data or sets of Personal Data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, viewing, use, disclosure by transfer, dissemination or any other form of provision, association or combination, restriction, erasure and destruction.

Scope

Purpose

iKanbi Group may process the Personal Data of the contact persons of suppliers, customers or any other business contact in the course of its activities.

In accordance with applicable data protection laws, such as the General Data Protection Regulation 2016/679 and national data protection laws, iKanbi Group wants to clarify the Personal Data we collect from you and how your Data will be used for iKanbi Group’s business purposes. This Statement also sets out the rights of iKanbi Group’s customers, suppliers, third parties and website visitors regarding their Personal Data.

Audience of this Statement

This Statement applies to:

• Our suppliers and/or business partners;
• Our existing, prospective and former customers;
• Members, staff, shareholders and beneficial owners of our customer/supplier companies;
• Third parties whose Personal Data is provided to us by our customers/suppliers;
• Third parties whose Data is collected or processed via any other commercial contact; and
• Users of/visitors to our website: www.ikanbi.com.

Insofar as we are liable to collect and process Data from third parties which you have communicated to us, we kindly ask you to inform the aforementioned third parties of the existence of this Statement so that they can be aware of our processing of their Data and their rights.

Data Controller and Data Protection Officer (DPO)

Data Controller

In the course of its business activities, iKanbi Group is required to process your Data in its capacity as Data Controller insofar as it determines the means and purposes of the processing.

Contact details of the Data Controller:

• Name: iKanbi Group
• Email address: dpo@ikanbi.com
• Website: www.ikanbi.com
• Address: Place du Champ de Mars 5, 1050 Brussels, Belgium.

Data Protection Officer and GDPR Manager

We have appointed an external Data Protection Officer (or DPO) and a GDPR Manager at iKanbi Group.

It is the role of the DPO and the GDPR Manager to inform all data subjects about the processed Data. They provide guidance and ensure compliance with current regulations, particularly the GDPR.

You can contact the DPO and/or the GDPR Manager if you have any questions about the processing of your Personal Data and the exercising of your rights.

Contact details:

• Email address: dpo@ikanbi.com
• Telephone: +32 4 256 97 11
• Address:

iKanbi Group SA
Place du Champ de Mars 5
1050 Brussels
BELGIUM

Personal Data collected from our customers, suppliers and third parties

In general, the following Personal Data is collected in the course of our business relationship with our customers, suppliers and third parties:

• Identification details (first name, surname, title, etc.);
• Contact information (professional email address and phone number);
• Financial data (bank accounts, etc.);
• Data about work history, skills and training;
• Any other additional/optional information you give us when we contact you (by telephone, email or at trade fairs or events);

In principle, iKanbi Group does not collect or process so-called sensitive data, namely:

• Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership;
• Genetic or biometric data (such as facial images and fingerprints, for example);
• Health-related data;
• Data relating to sexual behaviour or orientation.

In general, we process Personal Data which we receive from you or the employer/company that you represent in the course of our business relationship.

iKanbi Group may also collect publicly available information to verify the information we have collected and to manage and develop our business.

Personal Data collected from website visitors

When you visit our website, we collect the following Personal Data:

• IP address and
• Personal Data collected via cookies.

We use “cookies” (and similar technologies) on our websites and applications. These small files which store information on your computer’s browser enable us to remember certain information about you (for example, your chosen language).

We store the data collected via cookies on our website so that we can tailor our website and applications to your needs and save your preferences for future visits. In this way, we can quickly improve your user experience and offer you relevant services.

If you subscribe to our newsletter, iKanbi Group may collect and process the following categories of Personal Data about you:

• First name, surname, title;
• Address;
• Contact details (email address, phone number, fax);
• Company;

You may also choose to provide additional/optional information when you fill in a form on our website or when we contact you (by telephone, email or at events).

 iKanbi Group may also collect publicly available information to verify the information we have collected and to manage and develop our business.

Why do we collect Personal Data from our customers, suppliers and third parties?

iKanbi Group collects the aforementioned information for the following purposes:

• Performance/provision of our services
• To manage our business relationship with the company you represent (administrative management, contracts and invoicing);
• To manage our own business arrangements;
• Public relations and marketing
  • We may use your Personal Data to contact you about our activities, services or newsletters which we think may be of interest to you.
  • We will contact you if you explicitly ask us to do so or if we think you might be interested in a service or that a particular service could benefit your company/organisation.
  • If you do not yet have a business relationship with us, you will only receive our marketing communications if you have given us explicit prior consent to contact you.
  • If you already have a business relationship with us or if you have already provided us with your contact details, you may receive advertising from us without giving us your prior consent. This is the case, for example, for anyone who has signed up for newsletters and/or provided contact details during commercial correspondence. In this instance, we have a legitimate interest in maintaining and continuing our business relationship.

Why do we collect Personal Data from visitors to our website?

iKanbi Group collects the aforementioned information for the following purposes:

• Information and communication

We may use your Personal Data to inform you about our activities, services or newsletters or to contact you if you have asked us a question.

We also collect your Data to provide you with information about the company and to comply with legal, regulatory and compliance obligations and requirements.

• Website security

As part of our legitimate interest in securing our website, we collect and process your IP address.

• Use of cookies

When you browse our website, we install “cookies”:

• which are necessary for the proper functioning of our website, given our legitimate interest in providing you with a functional website, and
• for the purpose of analysing your browsing habits on our website, but only if you have given your prior consent.

If you would like more information on how we use cookies, how long they are stored for, etc., please view our Cookie Policy on our website.

• Use of social media

To increase our visibility on the Internet and to maintain contact with current and future customers, we also have a presence on social media including [Facebook, LinkedIn and YouTube].

When visiting these websites, you can choose to share some of your Personal Data with us directly by contacting us, commenting and/or sharing our articles.

In addition, we recommend that you read the Privacy Statement published by these third parties on their websites to find out how your Personal Data is processed by these third parties in their capacity as Data Controllers.

Legal basis for processing Personal Data

We are only authorised to use and process your Personal Data if one of the following conditions is met:

• The use of your Personal Data is necessary for the fulfilment of a contract you have entered into with us or to take the necessary steps to enter into such a contract at your request.
• We have obtained your express and explicit consent to use your Personal Data for a specific purpose.
• Your Personal Data is used in accordance with our legitimate interests and in accordance with your interests and rights.
• We are legally obliged to process and communicate certain data to the relevant authorities and bodies, such as the Data Protection Authority (DPA).
• How will your Data be used and shared?

Your Personal Data will only be transferred to other parties on a need-to-know basis, i.e. the recipients who must carry out the various processing operations in relation to the aforementioned purposes.

We may share your Personal Data with group companies and/or our affiliates, for example, when another group company also provides goods or services for or purchases goods or services from the company you represent.

We may also share your Personal Data with third parties who perform functions on our behalf and provide us with services such as IT, legal, financial, accounting and other services. Given that these third parties have access to Personal Data to perform the requested services, we have taken technical, organisational and contractual measures to ensure that your Data is only processed and used for the purposes mentioned in articles 5 and 6 of this Statement.

We may disclose your Personal Data to comply with our legal obligations or in the interests of safety, the public interest or law enforcement. We may disclose Data in connection with actual or potential litigation or to protect our property, safety, staff and other rights or interests.

Your Personal Data will not be sold or leased to third parties.

Transferring your Personal Data outside the EU/EEA

iKanbi Group endeavours to process Personal Data only within the European Union (EU) or the European Economic Area (EEA). However, it is possible that Personal Data may also be accessible or transferred to our partners or service providers in countries outside the EU or the EEA. If such a transfer occurs, iKanbi Group ensures that a level of protection equivalent to that in force within the EU/EEA is guaranteed, in accordance with the GDPR.

Should your Personal Data be transferred to a third party in a country which is not deemed to offer a level of protection of the rights of natural persons regarding their Personal Data equivalent to that of the EEA, the transfer of your Personal Data will be governed by one of the mechanisms provided for in Chapter 5 of the GDPR.

How long do we retain Personal Data?

Your Personal Data will be retained for as long as necessary to achieve the purposes mentioned in articles 5 and 6 of this Statement or for as long as you do not withdraw your previously given consent.

Since the need to retain this Data depends on the type of data and the purpose of processing, retention periods may vary.

You will find the criteria we use to determine data retention periods below:

• How long do we need the Data to be able to provide the requested service?
• Have we determined and announced a specific retention period?
• Have we obtained consent to extend the retention period?
• Are we bound by a legal or contractual obligation or another comparable obligation?

As soon as we no longer need your Data and are no longer legally obliged to retain it, we will delete it permanently or, if this is not possible, make it anonymous in our systems.

However, your Personal Data will be retained and used for as long as is necessary to fulfil our legal obligations, settle disputes or enter into contracts.

Personal Data processed as part of newsletter subscriptions will be retained until you choose to withdraw your consent to receive future newsletters from us (see below). Please note that this withdrawal of consent will only take effect going forward.

Security of Personal Data and the procedure in the event of a breach

Your Data is considered to be strictly personal. To this end, iKanbi Group has taken all appropriate technical and organisational measures to protect it against any destruction, loss, accidental alteration and any damage, accidental or unlawful access or other unjustified processing of the Data.

Data subjects’ rights

You have certain rights relating to the Personal Data we hold about you:

• The right to be informed

You have the right to be informed about the processing which we carry out, your rights relating to this processing and how to exercise these rights; at the latest, you should be informed of this when your Data is collected.  To this end, we have produced this Statement.

• The right to access

You have the right to request access to the Personal Data which we process and you also have the right to view it. At your request, we must provide you with a copy of your Personal Data. You can also obtain an answer to any question you may have regarding the processing of your Personal Data (purposes of the processing, recipients of the Data, retention period, etc.).

• The right to rectification

You may ask us to rectify, complete or delete any obsolete, incorrect or incomplete Data which we hold about you.

• The right to restrict processing

You have the right to request the restricted processing of your Personal Data. iKanbi Group can temporarily and/or partially stop the processing being carried out. You can put an end to a specific kind of processing or all processing of your Personal Data by iKanbi Group by exercising your right to object.

• The right to erasure/the right to be forgotten

In certain circumstances, you have the right to request the erasure of the Personal Data we hold about you: for example, when the Personal Data is no longer necessary for the purposes for which it was collected or when you have withdrawn your consent and there is no other legal basis for the processing.

• The right to Data portability

You also have the right to receive the Personal Data which you have provided iKanbi Group and to transfer it to another Data Controller.

• The right to object to certain types of processing/the right to withdraw consent

When processing is in iKanbi Group’s legitimate interest, you have the right to object to the processing of your Personal Data in the future. This right cannot be exercised where processing is necessary for the fulfilment of legal obligations.

When processing is subject to consent, you have the right to withdraw your consent at any time and without giving reasons. Your withdrawal of consent will only take effect going forward.

Exercising your rights as a data subject with regard to your Personal Data

If you would like more information about the processing of your Personal Data or if you wish to exercise your rights, please contact us via one of the following channels:

By email: dpo@ikanbi.com

By post: Place du Champ de Mars 5, 1050 Brussels, Belgium.

Please make clear which right you wish to invoke, which type of processing you wish to object to or restrict or which consent you wish to withdraw.

In the event of reasonable doubts about the identity of the person making the request, iKanbi Group may request additional information to confirm your identity.

When you exercise your rights, you will not be charged unless we consider the request to be patently unjustified or excessive (as would be the case, for example, for a repeated request).

However, we may charge you a reasonable sum which will not exceed our costs for any additional copies requested.

We will respond to any request about your rights within one month. However, this period may be extended to two months if the request is complex and/or because of the number of requests we have to handle. If this period is extended, we will inform you and explain the reason for this decision.

iKanbi Group will notify third parties to whom the Data has been communicated of any rectifications, deletions or restrictions made, unless this proves impossible and/or involves a disproportionate effort.

Please note that in certain circumstances provided for by law, we may refuse access to your information or not accept your request if we are authorised to do so by the applicable data protection legislation.

If you are not satisfied with the way we process your Personal Data or with the way we handle your requests to exercise your rights, you have the right to make a complaint to the Belgian Data Protection Authority, Rue de la Presse, 35, B-1000 Brussels, T: +32 (0)2 274 48 00; F: +35 (35)2 274 48 35; E: contact@apd-gba.be.

Modification of this Statement

We reserve the right to modify or add to this Statement if necessary.

In the event of significant modifications, the date of modification will be updated and a copy of the new Statement will be published on our website.

We encourage you to review this Statement periodically to find out about how we process and protect your Data.