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The CLOSE Group, composed of the companies CLOSE COMFORT S.A. (BE 0475.479.350), CLOSE S.A. (BE 0403.940.266), CLOSE Luxembourg S.A. (LU 147.241.34), CLOSE MAINTENANCE S.A. (BE 0455.945.926), NV BORZEE (BE 0418.071.780) and CLOSE SAS (FR 605119099105), takes great care to ensure that personal data is collected and processed in a secure, transparent and confidential manner.
It aims to protect the data of its customers, subcontractors and suppliers, in particular against loss, violations, errors and unauthorised access or processing.
The purpose of this notice is to provide information about the collection and processing of personal data.
The General Data Protection Regulation (hereafter GDPR) provides a detailed description of the concept of personal data and precise recommendations for the processing thereof. The relevant definitions can be found in article 4 of European Regulation 2016/679.
The CLOSE group is committed to complying with Belgian legislation on personal data protection and processing and the GDPR from its entry into force on 25 May 2018.
By providing the CLOSE group with your personal data, you explicitly declare that you have read this notice on personal data and you explicitly accept its content and the reserved processing of your personal data by the CLOSE group.
Please consult this notice regularly as it is subject to change.
Your personal data are processed by the CLOSE group.
The personal data processing manager is Ms M Georges. Her contact details are as follows:
Ms Myriam Georges
Address : rue de la Hé Copin 9 à 4920 Aywaille
Email : rgpd@close.be
Tel. : 04/384.53.90.
This notice applies to all existing and future customers, suppliers and subcontractors, to candidates or persons who apply to work for one or more companies of the CLOSE group.
This notice applies to all existing and future customers, suppliers and subcontractors, to candidates or persons who apply to work for one or more companies of the CLOSE group.
Because of your activities and the relationship you have with the CLOSE group, you are likely to provide the group with the following personal data:
In this regard, you are responsible for the accuracy of the data you provide. If data that you have provided turns out to be incorrect or obsolete, the CLOSE group asks you to inform them at the earliest opportunity.
The data collected and processed are the contact details of customers and principals of the CLOSE group, their staff, colleagues, employees, and any other useful contact person.
The purposes of these processing operations are:
The legal bases are the performance of a contract, observance of legal and regulatory obligations (such as registering works) and/or the legitimate interest of the CLOSE group.
The data collected and processed are the contact details of suppliers and subcontractors of the CLOSE group and those of their subcontractors if applicable, including their staff, colleagues, employees and any other useful contact person.
The purposes of these processing operations are:
The legal bases are the performance of the contract, the observance of legal and regulatory obligations (such as mandatory electronic attendance registration, 30 bis declaration of works, list of attendance or other obligations during public contracts) and/or the legitimate interest of the CLOSE group. For electronic attendance registration, if applicable, eID or Limosa data will be processed.
The CLOSE group processes the personal data of its employees as part of HR and payroll management. Taking into account its specific nature, this processing operation is expanded upon in a Data Protection Policy for employees, which is made available to them in an annex to the Work Regulations.
In addition to the data of its customers, suppliers/subcontractors and staff, the CLOSE group may also process the personal data of new customers, useful contacts within its sector, networking contacts, expert contacts, etc.
The purposes of these processing operations are in the interest of the CLOSE group’s activities, direct marketing and public relations. The legal basis is the legitimate interest of the group or, in some cases, the performance of a contract.
Personal data are stored and processed by the CLOSE group for the period of time required for the purposes of the processing operation of these data and the relationship (contractual or not) between the group and the person concerned.
Customer and supplier/subcontractor data will, in all cases, be removed from CLOSE group systems 10 years after the termination of the contract, the end of the project or the end of the commercial relationship. Personal data may nevertheless be stored by the CLOSE group after this period in the case of specific legislation or if a dispute is ongoing for which this data will be required.
Pursuant to Belgian legislation on data protection and the provisions of the General Data Protection Regulation, you have the following rights:
Right of access : you have the right to access the personal data that the CLOSE group holds on you free of charge and to verify the purpose for which these data are used.
Right of rectification : you have the right to have any of your personal data that is incorrect rectified (corrected), and the right to complete these data if they are incomplete.
Right to be forgotten : or to limit your data: you have the right to ask the CLOSE group to remove your personal data and to limit the processing thereof in the circumstances or conditions stipulated in the General Data Protection Regulation. The CLOSE group can nevertheless refuse to delete or limit your data when they are required for payroll processing, performing a legal obligation, executing an employment contract or in the legitimate interest of the group, on the condition that these data are indispensable for the purposes for which they were collected.
Right to data portability : you have the right to be informed about the personal data that the CLOSE group holds on you in a structured, commonly used and machine-readable format. You also have the right to send these data to another data controller.
Right to object : you have the right to object to the processing of your personal data on serious and legitimate grounds. However, you cannot object to data processing operations that are required to perform a legal obligation, execute an employment contract or in the legitimate interest of the group, on the condition that these data are indispensable for the purposes for which they were collected.
Right to withdrawal of consent : as the processing of these personal data is based on your prior consent, you have the right to withdraw this consent. Your personal data will then only be processed if the CLOSE group has another legal basis.
Automatic decisions and profiling : the CLOSE group confirms that the processing of your personal data does not include profiling or fully automated decisions.
You can exercise the aforementioned rights by contacting the CLOSE group. The contact person is Ms Myriam Georges, whose contact details can be found above (page 1).
The CLOSE group does everything in its power to ensure that your personal data are processed in a careful and legitimate manner in accordance with the applicable regulations. However, if you believe that the group has not respected your rights or taken your concerns into account, you are free to make a complaint to the Privacy Commission (Commission de la protection de la vie privée), whose contact details are as follows:
Commission de la protection de la vie privée
Address : rue de la Presse 35, 1000 Bruxelles
Tel.: 02 274 48 00
Fax. : 02 274 48 35
Email : commission@privacycommission.be
You are also free to take legal action if you believe that the manner in which the CLOSE group has processed your personal data has caused you harm.
Some personal data are likely to be transferred to and processed by a third party, such as an IT provider, an accountant, a lawyer, an auditor or social security services working in collaboration with the CLOSE group. In some cases, these data may also be sent to the government (for example for the 30bis declaration of works, for electronic attendance registration or for allocating public contracts).
One or more third parties may be located outside of the European Economic Area (EEA). Nevertheless, personal data will only be sent to third countries with an adequate level of protection.
The employees, managers and/or representatives of the aforementioned service providers or institutions and the specialised service providers appointed thereby are required to observe the confidential nature of your personal data and may only use these data for the purposes for which they were provided.
If necessary, personal data may be sent to other third parties. This may occur in the case of the full or partial reorganisation of the CLOSE group, if its activities are transferred or if the group is declared bankrupt. These personal data may also be provided due to an injunction or in order to fulfil a specific legal obligation. In that case, where possible the CLOSE group will inform the person concerned in advance that their personal data is being transferred to a third party. It should however be noted that in certain circumstances this may not be technically or commercially feasible and that legal limits may apply depending on the circumstances.
The CLOSE group will under no circumstances sell personal data or make them available to direct marketing agencies or similar service providers without your prior approval.
The CLOSE group will take the necessary technical and organisational measures to ensure your personal data is processed securely. The CLOSE group also commits to protecting your data from any destruction, loss, falsification, unauthorised access, erroneous notifications to third parties or any unauthorised processing operations.
The CLOSE group can in no case be held liable for any direct or indirect damage caused by erroneous or illicit use of personal data by a third party.
The CLOSE group authorises its workers and employees to access your personal data to perform processing operations. By imposing contractual obligations on these workers and employees, the CLOSE group guarantees a level of protection similar to that described in the Data Protection Notice.
The CLOSE group authorises its workers and employees to access your personal data to perform processing operations. By imposing contractual obligations on these workers and employees, the CLOSE group guarantees a level of protection similar to that described in the Data Protection Notice.