Privacy policy

1. Introduction
VR Base NV with registered office at 2830 Willebroek, Geerhoek 5A and registered in the Crossroads Bank for Enterprises with enterprise number 0704.586.224 attaches great importance to the safe, transparent and confidential collection and processing of your personal data. In particular, we want to protect the data of our customers and suppliers, among others, from loss, leaks, errors, unauthorized access or unlawful processing. We want to inform you through this Privacy Policy about the collection and processing of your personal data. We ask that you read this Privacy Policy carefully, as it contains essential information about how your personal data is processed and for what purpose. By communicating your personal data, you expressly declare that you are aware of this Privacy Policy and also expressly agree to it, as well as to the processing itself.

2. Scope
This Privacy Policy covers all services provided by us and, in general, all activities we conduct.

3. Controllers and their commitments.
VR Base NV with registered office at 2830 Willebroek, Geerhoek 5A with company number 0704.586.224, is the controller of your personal data.

4. Personal data
VR Base NV processes the personal data of:

  • Its employees, including job applicants, former employees of VR Base NV, temporary employees working under the direct supervision of VR Base NV such as independent contractors and trainees. The collection and processing of their personal data will be the subject of a separate Data Protection Policy for employees;

  • Her clients;

  • Her suppliers;

  • Third parties (visitors to our sites/offices/websites, potential new clients/prospects, useful contacts within our industry, networking contacts, expert contacts, etc).

According to your activities and your relationship to our company, you communicate to us the following personal data:

  • Your identity and contact information (name, gender, date of birth, address, email address, telephone and cell phone number, nationality, passport photo, etc),

  • Financial and billing information (bank account number, etc);

  • Studies, training, qualifications, certification, (residence,employment) permits.

We kindly remind you that you are responsible for all data you provide to us and that we rely on its accuracy. If your information should be out of date, please notify us by return. You are not obliged to communicate your personal data, but you understand that the provision of certain services or cooperation becomes impossible if you do not consent to its collection and processing.

5. Processing purposes and legal basis

5.1 Customer data
As part of our services and operations, we collect and process the identity and contact, financial and billing information of our customers and clients, their staff, employees, appointees and other useful contacts. The purposes for this processing are the performance of agreements with our customers, customer management, accounting, visitor registration, conflict management and social media management. The legal grounds are performance of the contract, fulfillment of legal and regulatory obligations and/or our legitimate interest.

5.2 Data from suppliers
We collect and process the identity and contact information, financial and billing data, studies, training, qualifications, certification, (residence, employment) permits of our suppliers and subcontractors, as well as their subcontractor(s), if any, their staff, employees, appointees and other useful contacts. The purposes of these processing operations are the performance of this agreement, supplier/subcontractor management, accounting, conflict management, communications management, social media management, business ethics management, quality & environmental management, safety & health management. The legal grounds are performance of the contract, fulfillment of legal and regulatory obligations and/or our legitimate interest. For direct marketing activities by e-mail (such as a newsletter or event invitation), consent will always be sought and may also be withdrawn at any time.

5.3 Staff data
We process our employees’ personal data as part of our personnel management and payroll administration. Given its specific nature, this processing is regulated more comprehensively in an Employee Data Protection Policy.

5.4 Other data
Besides the data of customers, suppliers/subcontractors and staff, we also process personal data of others, such as potential new customers/prospects, useful contacts within our industry, network contacts, expert contacts, etc. The purposes of this processing are in the interest of our operations, direct marketing and public relations. The legal basis is our legitimate interest or in some cases the performance of a contract.

6. Duration of processing

Personal data will be kept and processed by us for a period necessary in function of the purposes of the processing and in function of the relationship (contractual or otherwise) we have with you. Customer data and data of suppliers or subcontractors will in any case be deleted from our systems after a period of ten years after the termination of the contract or project, except with regard to such personal data that we are required to keep longer on the basis of specific legislation or in case of an ongoing dispute for which the personal data is still necessary.

7. Rights

In accordance and under the terms of Belgian privacy legislation and the provisions of the General Data Protection Regulation, we inform you that you have the following rights:

  • Right of access and inspection: you have the right to acquaint yourself, free of charge, with the data we hold about you and to find out what it is used for.

  • Right to rectification: you have the right to obtain rectification (correction) of your incorrect personal data, as well as to complete incomplete personal data.

  • Right to data erasure or restriction: you have the right to request us to erase or restrict the processing of your personal data in the circumstances and under the conditions stipulated by the General Data Protection Regulation. We may refuse data erasure or restriction of any personal data necessary for us to carry out a legal obligation, the performance of the contract or our legitimate interest for as long as such data is necessary for the purposes for which it was collected.

  • Right to data portability: you have the right to obtain the personal data you have provided to us in a structured, common and machine-readable form. You have the right to transfer this data to another data controller.

  • Right to object: you have the right to object to the processing of your personal data for serious and legitimate reasons. However, please note that you cannot oppose the processing of personal data that is necessary for us to carry out a legal obligation, the performance of the contract or our legitimate interest, and for as long as this data is necessary for the purposes for which it was collected.

  • Right to withdraw consent: If the processing of personal data is based on prior consent, you have the right to withdraw this consent. These personal data will then only be processed if we have another legal basis for doing so.

Automatic decisions and profiling:
We confirm that the processing of personal data does not involve profiling and that you will not be subject to fully automated decisions. You may exercise the aforementioned rights by contacting the contact person for this purpose, Lode Snackaert, or by sending an e-mail to contact@spectr-xr.com or a letter to VR Base NV, Geerhoek 5A, 2830 Willebroek, Belgium.

We make every effort to handle your personal data in a careful and legitimate manner in accordance with applicable regulations. If, nevertheless, you believe that your rights have been violated and you do not find a hearing for your concerns within our company, you are free to file a complaint with:

Data Protection Authority
Printing Press Street 35
1000 Brussels
Tel. 02 274 48 00
Fax. 02 274 48 35
E-mail: contact@apd-gba.be

You may additionally apply to a court if you believe you would suffer damages as a result of the processing of your personal data.

8. Transfer to third parties

Certain personal data collected by us will be transmitted to and possibly processed by third party service providers, such as our IT suppliers, revisors, insurers, etc by the customers as well as by the government. One or more of the above third parties may be located outside the European Economic Area (“EEA”). However, only personal data will be transferred to third countries with an adequate level of protection.

The employees, managers and/or representatives of the aforementioned service providers or institutions and the specialized service providers appointed by them must respect the confidential nature of your personal data and can only use these data for the purposes in the context of which they were provided. If necessary, your personal data may be transferred to other third parties. This may be the case, for example, if we were to be reorganized in whole or in part, our business transferred, or if we were to be declared bankrupt. Personal data may also need to be transferred pursuant to a court order or to comply with a particular legal obligation. We will make reasonable efforts to notify you in advance of this communication to other third parties in such cases. However, you will recognize and understand that in certain circumstances this may not always be technically or commercially feasible or legal restrictions may apply. Under no circumstances will we sell or make your personal data commercially available to direct marketing agencies or similar service providers, except with your prior consent.

9. Technical and organizational measures

We take the necessary technical and organizational measures to process your personal data according to an adequate level of security and protect it from destruction, loss, falsification, modification, unauthorized access or notification by mistake to third parties, as well as any other unauthorized processing of this data. Under no circumstances can VR Base NV be held liable for any direct or indirect damage resulting from an erroneous or unlawful use by a third party of the personal data.

10. Third party access

For the purpose of processing your personal data, we grant access to your personal data to our employees, associates and appointees. We guarantee a similar level of protection by making contractual obligations opposable to these employees, associates and appointees, which are similar to this Privacy Policy.

11. Any questions?

If after reading this Privacy Policy you have further questions or comments regarding the collection and processing of your personal data, you may contact Lode Snackaert either by mail to VR Base NV, Geerhoek 5A, 2830 Willebroek or by email to contact@spectr-xr.com

Done at Willebroek on 20/09/2022. This Privacy Policy is valid in current form until next amended.

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