Introduction

Drylock finds the protection of personal data primordial.

This policy applies where Drylock or any of its affiliates, being a company which controls, is controlled by, or is under common control with Drylock (“Affiliates”) processes personal data and determines purposes and means with respect to such processing of its customers, employees and suppliers. Whenever this data protection policy refers to Drylock, it is deemed to refer to Drylock and its Affiliates. Whenever this data protection policy refers to “You” or “Your”, such reference should be read as meaning customers, suppliers, employees or applicants, as the case may be.

Drylock may amend this policy from time to time by publishing a new version on its website. Drylock will notify you of significant amendments to this policy by email, if available.

Customers and suppliers

Drylock processes personal data relating to the use of its website and services (including cookies – see for more info on its cookie policy) (“usage data“). Such data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit and page views. Usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is the legitimate interest of Drylock to maintain and improve its website.

Drylock processes personal data relating to contact details (“contact data“). Such data includes your name, surname, gender, phone number, e-mail-address, and, if you are an independent customer or supplier (not acting on behalf of a company), your address. The data is provided by you or your employer (while creating an account or directly through e-mail or any other means of contact). The contact data is processed with the aim to provide its (customer and supplier) services properly, record-keeping, maintaining back-ups of its databases and (specifically but not limited to the context of processing gender data) communicating with you. The legal basis for this processing is consent.

Drylock processes personal data that is provided in the course of its customer or supplier relationship (“relationship data”). Such data may include your name, your employer, your job title or role, your contact data (as mentioned above), and information contained in communications (such as requests, questions or demands regarding its goods and services) between Drylock and you or your employer, being a customer or supplier of Drylock. The relationship data is processed with the aim to provide its (customer and supplier) services properly and for the purposes of communicating with you and record-keeping. The legal basis is the performance of a contract between you or your employer being a customer or supplier of Drylock and Drylock or its Affiliates and/or taking steps, at your or your employers’ request, to enter into such a contract.

Drylock processes personal data relating to transactions, (e.g. the purchase of Drylock goods and/or Drylock purchase of your goods or services) (“transaction data“), and may include your contact details, your card details and the transaction details. Such transaction data is received from you or your payment service provider. The transaction data may be processed for the purpose of supplying the purchased goods and services or purchasing a requested good or service and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you or your employer, being a customer or supplier of Drylock, and Drylock, as well as any steps taken, at your or your employers’ request, to enter into such a contract.

Drylock processes personal data that you provide to it for the purpose of subscribing to Drylock email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

Drylock may process any of your personal data identified in this policy where necessary for the preparation, establishment, exercise or defense of legal claims, whether or not such claim is formulated in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is Drylock’s legitimate interests, namely the protection and assertion of its legal rights, your legal rights and the legal rights of others.

Applicant data

Drylock values every application for vacancies and undertakes to treat each application with care and in accordance with the principle of confidentiality.

Drylock processes from its applicants personal data provided by them relating to the application process (“applicant data”). Such data may include name, surname, address, e-mail address, qualifications and age and any other information spontaneously communicated by the applicant. Such information is processed for management of the recruitment process, applicant management, record-keeping and contacting the applicant. For the applicant who is selected to become an employee of Drylock, the legal basis for this processing is that it is a step taken prior to entering into a contract on the applicant’s request. Applicant data, processed from applicants who are not selected in the recruitment process, will be processed on the basis of its legitimate interests to maintain an applicants database.

Transfer of personal data to others

Drylock may disclose your personal data to any affiliate, insofar as this disclosure would be reasonably necessary for the purposes, and on the legal bases, set out in this policy.

Drylock may disclose your personal data to its insurers and attorneys-at-law if that is necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining legal advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Drylock may disclose contact data and transaction data to its suppliers or subcontractors insofar as reasonably necessary for the performance of the customer or supplier relationship.

In general, Drylock may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which Drylock is subject.

International transfers of personal data

In certain circumstances, Drylock may transfer personal data to third countries (including countries outside of the European Economic Area) in which case Drylock shall ensure that such transfer takes place in accordance with applicable data protection laws and this data protection policy.

Data retention

The term pursuant to which Drylock will process or keep any personal data is limited to the term that is necessary for the realization of the purpose of the processing.

Drylock will retain your personal data as follows:

  • usage data will be retained for a minimum period of one year following the date of visiting its website, and for a maximum period of two years following such visit.
  • applicant data will be kept for a period of five years following the application;
  • contact, relationship, transaction and notification data will be kept during the relationship and for a period of ten years following the termination thereof.

Notwithstanding the previous provisions of this article 6, Drylock may retain your personal data where such retention is necessary for compliance with a legal obligation to which Drylock is subject.

Rights of the natural persons from whom Drylock processes personal data

Data protection law grants you the following rights:

  • the right to access;
  • You have the right to ask confirmation as to whether or not Drylock processes your personal data and, where Drylock does, receive access to said data, together with certain additional information. Upon your request, Drylock will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
  • the right to rectification;

You have the right to rectify any inaccurate personal data about you and to complete any incomplete personal data about you.

  • the right to erasure;

Some circumstances allow you to ask for erasure of your personal data, namely:

  1. when the processing of personal data is no longer necessary for the purpose for which it was collected or otherwise processed;
  2. whenever you withdraw consent to processing based on such consent;
  3. whenever you exercise the right to object to the processing (cf. hereunder);
  4. whenever the personal data was acquired for direct marketing purposes; and
  5. whenever the acquired personal data has been unlawfully processed.
  6. Exceptions to the right of erasure may be applicable, including in the situation where processing is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
  • the right to restrict processing;

You have the right to restrict the processing of your personal data under various circumstances. This means that Drylock will stop processing your personal data in certain situations, namely

  1. when you contest the accuracy of the personal data;
  2. whenever processing is deemed unlawful but you want to oppose to erasure of your personal data;
  3. whenever you would need the personal data for the establishment or preparation of a judicial claim; and
  4. you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, Drylock may continue to store your personal data, for the establishment, exercise or defense of legal claims.
  • the right to object to processing, if the processing is based on its legitimate interests;

Whenever Drylock processes your personal data on the basis of its legitimate interests, you are granted the right under applicable data protection law to object to such processing on grounds relating to your particular situation. If you make such an objection, Drylock will cease to process the personal information unless Drylock can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or unless the processing aims at the establishment, exercise or defense of or against legal claims.

Whenever Drylock processes your personal data for direct marketing purposes you have the right to object (“opt-out”) to its processing of your personal data for such purposes. If you make such an objection, Drylock will cease to process your personal data for this purpose.

  • the right to data portability, under some circumstances described hereunder;

Your right to data portability means that you have the right to receive your personal data from Drylock in a structured, commonly used and machine-readable format (such as an excel or pdf file). This right can be exercised under the following conditions:

  1. Drylock processes personal data on the basis of your consent or on a (pre) contractual basis; and
  2. such processing is carried out by automated means.
  • the right to lodge a complaint to the competent supervisory authority;

You have the right to lodge a complaint with the competent supervisory authority relating to infringements of data protection law.

  • the right to withdraw consent, if your personal data is being processed on the basis of consent.

Whenever Drylock process your personal data on the basis of consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing prior to that withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us at the contact details mentioned above. Drylock shall reply as soon as possible and in any case within a month following receipt from your letter or e-mail.

Please note that the above description of rights is a summary of the applicable data protection law. Such summary is designed to explain applicable law in easy, understandable language. For further background and details, reference is made to the applicable data protection laws themselves as you may find them on the website of the Belgian Data Protection Authority: https://www.dataprotectionauthority.be/.

 

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