PRIVACY POLICY FENIX CONSULTING NV

1. Introduction

This privacy policy concerns the processing of personal data by Fenix Consulting NV, with registered office at Coremansstraat 34, 2600 Berchem and registered in the Company Database under number 0870.628.448. Fenix Consulting NV collects personal data from clients, candidates, customers, suppliers and visitors to our website. Fenix Consulting NV declares that it observes the privacy legislation in its capacity of Controller, as well as the provisions of the General Data Protection Regulation since its coming into force.

2. General Data Protection Regulation

The General Data Protection Regulation (GDPR) is European legislation with direct application within the European Economic Area. As of 25 May 2018, this regulation replaces the Law of 8 December 1992 for the protection of privacy regarding the processing of personal data. We consider your privacy to be important. Our organization processes personal data and customer information with the greatest care.

2.1 What is personal data?

The General Data Protection Regulation defines personal data as follows: Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

References to personal data in this Privacy Policy refer to this definition from the Regulation.

We do not process any special categories of personal data. The processing of special categories of personal data is understood to mean: Processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

2.2 What personal data do we process?

The processing of personal data is understood to mean among other things the collection, storage, recording, changing, collecting, requesting, consulting or destruction of personal data.

2.2.1 When you contact us directly as a (potential) customer or as a supplier
  • The contact details you supply us with, such as your first name, name, address, email address, telephone number
  • Your position
  • Your company
  • Any other personal data that you submit to us within the framework of the objectives described below in point 4
2.2.2 When you contact us directly as a candidate
  • The identity details you supply us with, such as your first name, name, address, email address, telephone number
  • Your CV
  • For online assessment / development center / screening: video and audio registration for internal validation of the observations
  • Any other personal data that you submit to us within the framework of the objectives described below in point 4
2.2.3 Via our website
  • Without registration: your IP address
  • When completing the contact form on our website: first name, surname, email address, telephone number, company name.
  • Via cookies (Google Analytics): tracking statistics. Tracking how the user visits the website, with a view to improving services and online portals.
    Privacy policy of Google

3. For what purposes do we process your personal data?

Fenix Consulting NV collects personal data for different purposes and on different fundamental principles.

3.1 General purposes, such as a (potential) customer or supplier

3.1.1 The delivery of (pre)contractual services

Fenix Consulting NV processes your personal data in order to supply you with our services. We use the data e.g. to make a quotation at your request and to subsequently execute the agreement, to maintain the relationship with you in relation to the assignment and to send an invoice.

We also use the data to answer inquiries. The legal basis for supplying (pre)contractual services is the maintenance of a contractual relationship and the shaping or execution of an agreement or contract.

3.2 General purposes as a candidate

3.2.1 The delivery of services

Fenix Consulting NV collects personal data for one or several of the following purposes:

– Assessment Centers

– Development Centers

– Coachings

– Training

– Screenings

– Online Tests and Serious Games

The legal basis for processing your personal data for these purposes is your explicit consent, which you can revoke at any time.

3.2.2 Engagement of and sharing with third parties

As a controller, Fenix Consulting NV engages other parties in order to execute an aspect or a part of the provision of services for you; this may involve e.g. an external consultant, a trainer or assessment psychologist, or an external test (system) as part of the coaching, or an ICT system or platform we use to carry out our services, e.g. a CRM system or an e-learning platform. Insofar as these third parties require access to personal data to carry out our services, Fenix Consulting NV has contracted the correct contractual, technical and organizational security measures to ensure that these third parties use your personal data exclusively for the intended purposes and in accordance with the instructions that we have agreed with these third parties.

Furthermore, your personal data is also shared with the client that ordered your assessment/ development center, training or coaching.

3.2.3 Sharing with third parties for legal reasons

We may share your personal data with third parties if we are of the opinion that access to and use of the personal data is reasonably necessary to (i) comply with applicable laws, requirements and/or judicial order; (ii) to prevent, detect or resolve fraud, (future) security issues or technical problems; and/or (iii) to protect the interests, characteristics or safety of Fenix Consulting NV, our users or the public insofar as this is in accordance with the law.

3.3 Processing via our website

3.3.1 Processing your data on the website

We collect and use your personal data on our website to deliver you (personalised) web content and to communicate with you as effectively as possible. We also use your data for research and analysis in order to improve our services. We can also use the data on our websites to send you information by email about other services provided Fenix Consulting NV.

The legal basis for processing your personal data in this respect is your emphatic and explicit consent, which you can revoke at any time.

3.3.2 Job application purposes for vacancies at Fenix Consulting NV.

We offer you the option on the website to send us your motivation letter and CV within the framework of (open) job applications. The legal basis for processing your personal data in this respect is the justified interest; it is essential for having the job application procedure run smoothly.

3.4 Marketing and sales activities

Fenix Consulting NV likes to inform customers about offers, innovations and other relevant (professional) content regarding our provision of services, in accordance with the relevant applicable regulations, or because you have explicitly given consent for this. We can do this by telephone, email, newsletters or direct personal contact.

The legal basis for supplying marketing and sales activities is your emphatic and explicit consent, which you can revoke at any time.

Under no circumstances will Fenix Consulting NV sell your data to third parties.

4. Storage periods

  • Fenix Consulting NV does not store your data for longer than necessary for the purposes for which we collected your data. The storage period depends on the nature of the information and the purposes of the processing. Following storage periods are applicable for different purposes and services:
  • Your assessment report: 2 years
  • Your development report: 2 years
  • Your coaching report: 2 years
  • Your data related to training: 2 years
  • Your data related to screenings: 2 years
  • The results of your e-tests or serious games: 2 years
  • For online assessment / development center / screening: video and audio registration: 5 business days

Storage in our talentpool: as long as necessary

Your personal data is also stored in conformity with possible legally obligated terms (e.g. accounting purposes) and possible periods of limitation.

5. Rights

You can exercise the following rights with respect to your personal data on your written request.

5.1 The right to access and consultation

You always have the right to consult your personal data at no cost, as well as how we use your personal data in accordance with the provisions applicable in the sector.

5.2 The right of rectification, erasure and restriction

You are free to choose whether to share your personal data with us. You also have the right to request rectification of your personal data, to supplement them or erase them. You may also request the restriction of the processing of your personal data.

5.3 Right to object

You also have the right to object to the processing of your personal data for serious and legitimate reasons.

5.4 Right of data portability

You also have the right to obtain your personal data that we process for you in structured, conventional and machine-readable form and/or to transfer them to other responsible parties.

5.5 Right to withdraw consent

Insofar as the processing is based on your prior consent, you have the right to withdraw such consent.

5.6 Automatic decisions and profiling

The processing of your personal data does not comprise any profiling and neither will you be subjected to automated decision-making.

5.7 Exercising your rights

You can exercise your rights by contacting our administration. Your request must consist of a dated, signed request and a copy of the front of your identity document. You can address your request for exercising your rights to:

Fenix Consulting NV Attn. Privacy Officer Coremansstraat 34, 2600 Berchem Email: privacy@fenix.be

6. Cookie Policy

6.1 What are cookies?

A cookie is a small text and numeric file that we store in your browser or on your computer’s hard disk. This enables us to remember your preferences when using our website.

As soon as you visit our website, we will ask your permission to install the various different categories of cookies that we use.

If you have not adjusted your browser settings so that it refuses these cookies, our system will install cookies as soon as you visit our website.

6.2 Why do we use cookies?

Our website uses cookies and similar technologies to distinguish your user preferences from those of other users of our website. This helps us to offer you a better user experience when you visit our website and it also allows us to optimise our website.

However, cookies and similar technologies do not allow the systematic collection of data that could identify users of our website. They only help us to improve the operation of our website, to understand our users’ interests and to measure the effectiveness of our website content.

As a consequence of recent legislative changes, all websites that focus on certain parts of the European Union are obliged to request your consent for the use or storage on your computer or mobile devices of cookies and similar technologies. This cookie policy gives you clear and complete information about the cookies that we use and their purpose.

Please read our privacy policy for information about the privacy rules that are applicable on the website. For further information about this Cookie Policy, please contact us via privacy@fenix.be

6.3 Which cookies are used on www.fenixconsulting.be?

_ga – www.fenixconsulting.be – non-functional cookie

Purpose of the cookie – Google Analytics: tracking statistics. Tracking how the user visits the website, with a view to improving services and online portals.

Privacy policy of Google.

Expires after two years

6.4 How can I manage my cookies?

Make sure that cookies are activated in your browser. To activate cookies, you have to carry out the following actions:

For browser – Microsoft Internet Explorer

In Internet Explorer, click on ‘Internet options’ in the ‘Tools’ menu.

On the ‘Privacy’ tab, move the settings slide bar to ‘low’ or ‘accept all cookies’ (setting above ‘medium’ deactivates cookies). Click ‘OK’.

For browser – Mozilla Firefox

Click on ‘Firefox’ in the upper-left corner of your browser and then click on ‘Options’.

On the ‘Privacy’ tab, make sure that ‘Let websites know that I don’t want to be tracked’ is not checked. Click ‘OK’.

For browser – Google Chrome

Click on ‘Extra’ at the top of your browser window and select ‘Options’.

Click on the ‘Under the Hood’ tab, look for the ‘Privacy’ section and select the button ‘Content settings’. Now select ‘Allow local data to be set’.

For browser – Safari

Click on the ‘Cog’ pictogram at the top of your browser window and select the ‘Preference’ option. Click on ‘Security’, check the option labelled: ‘Block cookies from third parties and advertisement cookies’. Click ‘Save’.

7. Questions, requests, complaints and supervision

If you have any questions about the cookie statement or the privacy policy, please contact us using the following contact details:

Fenix Consulting NV Attn. Privacy Officer Coremansstraat 34, 2600 Berchem Email: privacy@fenix.be

You have the right to submit a complaint with the Belgian Privacy Commission: Commission for the Protection of Privacy, Drukpersstraat 35, 1000 Brussels, Tel. +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35, email: commission@privacycommission.be.

This is without prejudice to a provision for a civil court. If you were to suffer damages as a consequence of the processing of your personal data, you can file a claim for compensation.

8. Version management for this privacy statement

Fenix Consulting NV reserves the right to change this privacy statement. Modified versions will be dated and published on our website.

This privacy statement was last modified on 13 March 2020