Last updated on 29 June 2018

 

Scope

This privacy statement applies to Recticel NV/SA, registered in Belgium at Bourgetlaan 42 Avenue du Bourget 2, 1130 Brussels, registered under number 0405666668, and its subsidiaries and affiliates in the EEA (further: “Recticel”), as listed in our last annual report on our website.

It concerns personal data which Recticel processes in relation to customers, suppliers and prospective and actual end-consumers. For Recticel’s processing of personal data through your visit of our website, we refer to our “Recticel Privacy Notice for Website Visitors”. 

Recticel is committed to comply with all applicable data protection laws and regulations. 

 

For which purposes does Recticel process end-consumer, customer or supplier related personal data?

In relation to customers, end-consumers and suppliers, Recticel processes personal data for the purpose of performing activities that form part of our business operations, like :

• Applicable legal or regulatory requirements, or ensuring compliance herewith
• Customer and supplier management
• Order and supply management
• Financial accounting and invoicing
• Providing or requesting information on the products and services Recticel acquires or supplies 
• (Direct) marketing
• Research
• Dealing with the enquiries, complaints and requests including on social media of customers, suppliers, our customers’ or suppliers’ business partners and of prospective and actual end-consumers;
• Dispute management
• Public relations and business development
• Risk analysis and due diligence checks relating to the products and services acquired or supplied
• Statistics
• Access control and security 
• Protecting our rights and those of our business partners

 

Which personal data does Recticel process for these purposes?

For these purposes, Recticel may use amongst other: 

• Contact data (for example the data typically featuring on name cards such as your name, phone number, e-mail address, your language for communication, your availabilities, your professional field of responsibility)
• History of when and where we meet, and of communications
• Past employment , educational details, publications or postings (for example when relevant for the contemplated partnership between Recticel and the company your work)
• Complaint details
• Lifestyle and social circumstances if you have volunteered such information (for example pastimes, food preferences, birthday)
• Sensitive data for specific, explicit purposes (for example health data for security purposes when you visit certain parts of our premises) 

We collect such data when you provide them to us, because other persons provide these data to us (eg. your employer, a third party service provider) or because it is publicly available.

 

What is the legal ground for processing these data for such purposes?

For these purposes, Recticel may use amongst other: 

We use your personal data for the purposes listed above because :

• Recticel is obliged by law or by the order of any court or regulatory authority to process the personal data (eg. keep records for regulatory reporting, providing information to a public body or law enforcement agency)
• Processing of personal data is permitted in order to establish, execute or terminate a contractual relationship (eg. use and keep cv’s of consultants or persons working with a supplier to decide whether to work with them)
• This is necessary for the purposes of pursuing Recticel’s legitimate interests, but only if these interests are not overridden by the interests or fundamental rights and freedoms of the individual. (eg. we may request formal identification before allowing you access to our buildings for safety and security reasons)
• You have given your explicit consent (for the processing of sensitive data or for direct marketing when you are not a customer)

 

Transfer and sharing of your personal data

We may share your personal data with Recticel affiliates, competent authorities, your employer and/or their advisers, your advisers, or other third parties which reasonably need your personal data for the purposes and on the grounds listed above. 

We may transfer your data to a Recticel entity or a third party established outside of the EEA. If we do, we will implement personal data transfer agreements based on the standard clauses published by the European Commission to protect your personal data, or on other adequate protection measures.  If you want more information, please contact us as set out below in the “Contact” section.

 

Your Rights

If you are a resident in the European Economic Area, you have - depending on the situation and the conditions listed in the GDPR -  the right to: (a) access your personal data including asking for a copy of it; (b) request rectification of your personal data; (c) request portability of your personal data; (d) request restriction of processing of your personal data; (e) object to the processing of your personal data, in particular with regard to direct marketing; (f) request erasure of your personal data; (g) request cancellation of your personal data; and (h) if you have provided your consent to the processing of your personal data, you have the right to withdraw your consent at any time. 

You also have the right to lodge a complaint with the supervisory authority in your home country. 

To exercise any of your rights, please contact us as set out below in the “Contact” section. 

 

Recticel preserves your data

We will keep and process your personal data for the longest of following periods: (a) as long as necessary for the purpose for which they are required, (b) the legal or statutory retention period, (c) as long as a litigation or investigation may arise in respect of the relevant activity.

During the time that we keep your personal data, we will take the technical and organizational measures to ensure an appropriate level of security to protect them, including drafting and implementing procedures regarding access control to personal data , physical access control to premises, fire walls, encryption, anti-virus software. We further provide data protection and IT security training to employees.

 

Contact

If you have any questions regarding this website or how we respect your right to privacy, please contact us via mail to Recticel Flexible Foams - Privacy desk, Damstraat 2, 9230 Wetteren, or via email to privacy.flexiblefoams@recticel.com.

If you do not receive an adequate answer from us, you have the possibility to file a complaint to one of the national supervisory data protection authorities , of which you will find the contact details here: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm