- our prospective, current and former members of personnel;
- our suppliers who are natural persons (such as self-employed persons) or the representatives or contact persons of our prospective suppliers who are legal entities; and
- our website’s visitors and any third parties following our company, such as analysts and individuals having signed up for our newsletters.
The policy does not apply to any information processed about legal entities.
In line with our commitment to protect your personal data, we want to inform you and explain in all transparency:
- why and how KDW Horses collects, uses and stores your personal data; and
- what your rights and our obligations are in relation to such processing.
- What type of personal data do we collect?
We collect basic identification information about all individuals with whom we interact, such as your name, title, position, company name, email and/or postal address and fixed and/or mobile phone number.
This information may either be directly provided by you, communicated to us by the legal entity for whom you work (e.g. if you are the contact person designated by your employer to manage the KDW Horses account), supplied to us by one of our service providers (e.g. financial institutions or recruiters) or obtained from publicly available sources (e.g. social media profiles).
- Prospective, current and former members of personnel
For our prospective current and former employees, we may in addition also collect the following information:
- your picture; and
- (Representatives of) suppliers
For (the representatives of) our suppliers, we may in addition also collect the following information:
For website’s visitors and any third parties following our company such as analysts and individuals having signed up for our newsletters, we may in addition also collect the following information:
To the extent authorised or required by law, we may also process sensitive data, such as trade union membership or health data. KDW Horses will only do so as strictly required for the relevant purposes listed in Section 4 below or to comply with a legal obligation and, where required, subject to having obtained your prior consent. In such case, the data will be accessed and processed solely under the responsibility of a representative of KDW Horses who is subject to an obligation of confidentiality.
Whenever personal data is collected (e.g. in forms), we will indicate whether the provision of such data is mandatory (e.g. with an asterisk) and the consequences of a refusal to provide the requested data.
We may also collect your national registry number or social security number but will only process such data if and when legally required.
- When do we collect personal data?
Personal data will be collected by KDW Horses:
- whenever individuals apply to become an employee of a KDW Horses entity;
- whenever employees interact with KDW Horses, its personnel, its IT equipment and other systems;
- whenever KDW Horses interacts with former employees;
- whenever KDW Horses interacts with (the representatives of) our suppliers;
- whenever individuals visit our website or sign up for our newsletters; and
- upon request from analysts.
- On which legal basis and for which purposes do we process personal data?
- Legal basis for the processing
We are not allowed to process personal data if we do not have a valid legal ground. Therefore, we will only process personal data if:
- we have obtained your prior consent;
- the processing is necessary to comply with our legal or regulatory obligations;
- the processing is necessary to protect your vital interests or those of another natural person; or
Please note that, when processing your personal data on this last basis, we always seek to maintain a balance between our legitimate interest and your privacy. Examples of such ‘legitimate interests’ are:
- to meet our corporate and social responsibility objectives.
- Purposes of the processing
We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. In particular, we process personal data for one of the following purposes.
- Prospective, current and former members of personnel
In relation to prospective, current and former members of the personnel, we process personal data for:
- recruitment activities;
- ensuring business continuity;
- managing mergers and acquisitions involving our company; and
- any other purposes imposed by law and authorities.
- (Representatives of) suppliers
- implement tasks in preparation of or under existing contracts;
- manage our IT resources, including infrastructure management and business continuity; and
- billing and invoicing.
In relation to KDW Horses’s website’s visitors and any third parties following our company such as analysts and individuals having signed up for our newsletters, we process personal data to:
- monitor and prevent fraud, infringement and other potential misuse of our website; and
- communicate the analysts’ opinions for third-parties on KDW Horses’s website
In addition to the above specific purposes, we process all collected personal data for the following general purposes:
- storing contact details (e.g. business cards);
- manage and administer the relationship between KDW Horses and the data subjects;
- manage our IT resources, including infrastructure management & business continuity;
- comply with any legal obligations imposed on KDW Horses in relation to its activities;
- reply to an official request from a public or judicial authority with the necessary authorisation;
- archiving and record-keeping; and
- manage mergers and acquisitions involving our company.
- How do we protect personal data?
We have implemented appropriate technical and organisational measures to provide a level of security and confidentiality to your personal data. These measures take into account:
- the state of the art of the technology;
- the costs of its implementation;
- the nature of the data;
- and the risk of the processing.
The purpose thereof is to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.
Moreover, when handling your personal data, we:
- only collect and process personal data which is adequate, relevant and not excessive, as required to meet the above purposes; and
- ensure that your personal data remains up to date and accurate.
For the latter, we may request you to confirm the personal data we hold about you. You are also invited to spontaneously inform us whenever there is a change in your personal circumstances so we can ensure your personal data is kept up-to-dat
- Who has access to personal data and with whom are they shared?
- Transfers to third parties
We may transfer or give access to personal data to third parties outside KDW Horses to complete the purposes listed in Section 4.2 above, to the extent they need it to carry out the instructions we have given to them. Such third parties may include:
The above third parties are contractually obliged to protect the confidentiality and security of your personal data, in compliance with applicable law.
Transfers outside the European Economic Area
The personal data transferred by KDW Horses may also be processed in a country outside the European Economic Area (“EEA”), which covers the EU Member States, Iceland, Liechtenstein and Norway. Non-EEA countries may not offer the same level of personal data protection as EEA countries.
If your personal data is transferred outside the EEA, we will therefore put in place suitable safeguards to ensure such transfer is carried out in compliance with the applicable data protection rules. You may request additional information in this respect and obtain a copy of the relevant safeguard by exercising your rights as set out below.
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- How long do we store your data?
We will only retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
We only keep data related to candidates for recruitment purposes for a maximum period of two years. For current employees, the retention period is the time of your employment, unless overriding legal or regulatory schedules require a longer or shorter retention period.
For contracts, the retention period is the term of your (or your company’s) contract with us, plus the period of time until the legal claims under this contract become time-barred, unless overriding legal or regulatory schedules require a longer or shorter retention period.
Personal data collected and processed in the context of a dispute are deleted (i) as soon as an amicable settlement has been reached, (ii) once a decision in last resort has been rendered or (iii) when the claim becomes time barred.
When the above retention periods expire, your personal data is removed from our systems.
However, if individuals wish to have their personal data removed from our databases, they can make a request as described in Section 8, which we will review as set out below.
- What are your rights and how can you exercise them?
- Your rights
You have a right of access to your personal data as processed by KDW Horses under this policy. If you believe that any information we hold about you is incorrect or incomplete, you may also request the correction thereof. KDW Horses will promptly correct any such information.
You also have the right to:
- request the erasure of your personal data;
- request the restriction of the processing of your personal data;
- object to the processing of your personal data for direct marketing purposes; or
KDW Horses will review such requests, withdrawal or objection and honour them as required under the applicable data protection rules.
In addition, you also have the right to data portability. This is the right to obtain the personal data you have provided to KDW Horses in a structured, commonly used and machine-readable format and to request the transmission of such personal data to a third party, without hindrance from KDW Horses and subject to your own confidentiality obligations.
Exercising your rights
If you have a question or want to exercise the above rights, you may send an email to info@Kdw-horses.com or a letter at KDW Horses, , Onderdijke 32, 9991 Maldegem , with a scan of your identity card for identification purpose, it being understood that we shall only use such data to verify your identity and shall not retain the scan after completion of the verification. When sending us such a scan, please make sure to redact your picture and national registry number or equivalent on the scan.
If you are not satisfied with how we process your personal data, please address your request to KDW Horses by mail info@Kdw-horses.com or by letter at KDW Horses, Onderdijke 32, 9991 Maldegem and we will investigate your concern.
In any case, you also have the right to file a complaint with the competent data protection authorities, in addition to your rights above.
- Updates to this policy
This policy may be subject to amendments. Any future changes or additions to the processing of personal data as described in this policy affecting you will communicated to you through an appropriate channel, depending on how we normally communicate with you.
(1) Regulation 2016/679 of the EU Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or “GDPR”).