Sirus Privacy Policy

Processing of personal data: Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly.

A processor: A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

A controller: A controller is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

This Privacy Policy applies to all direct customers, visitors, suppliers, applicants and all other persons who are not employees of Sirus and of whom Sirus processes personal data as controller. For the remainder of this Privacy Policy, an individual belonging to one of these groups is referred to as a “data subject”.

Only when Sirus is acting in the capacity of data controller, points 5 to 10 of this Privacy Policy shall apply.

If, as data subject, you want to exercise your rights, you must always address the data controller (responsible for the processing).

5.1        Based on the performance of a contract

Sirus processes personal data necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to the conclusion of a contract.

• When requesting a quote

When you request more information about the services or products of Sirus you can request a quote through different channels (telephone, website, social media, …). Sirus processes personal identification data (e.g. name and email) to provide you with an adequate proposal.

• When processing an order, following up on invoices and commercial agreements

When you order services or products from or deliver to Sirus, Sirus processes personal identification data and professional data to correctly follow up the order or delivery.

• When applying for a job

Sirus regularly seeks new enthusiastic and motivated employees to join our team. During the job application procedure Sirusprocesses the following categories of personal data:  personal identification data, personal characteristics (e.g. birthdate, language, …), competences, educational history, career, curriculum vitae, image, work references.

• When participating in an event

Sirus organises events. In the organisation of such an event, we process personal identification data, professional data at registration.

5.2        Based on consent

When processing personal data based on your consent, you always have the right to withdraw your consent. (see 10. What are my rights and how can I exercise them?)

• When completing a customer satisfaction survey

Sirus asks permission to link personal data (identification data and professional data) with the results of a customer satisfaction survey. We only use this data to improve our services. Sirus uses a research agency as processor for this purpose, but it will not use the data for other purposes and will not pass it on to third parties for its own use.

• When creating a recruitment reserve

If Sirus does not hire you after a job application, but would like to keep you CV for future opportunities, Sirus will ask for your permission to keep your CV.

• Use of targeted visual material on social media and the website.

When publishing targeted images on social media and the website, Sirus will ask for your permission. With targeted images we mean images in which the person is clearly identifiable (close-up, image focused on a certain person, posed photo, …).

• When indicating eating preferences if you register for an event and/or training course.

If you wish, when registering for an event or training you can indicate your food preferences, so that we can provide suitable food for catering. Only quantities and no personal details are passed on to the catering company.

5.3        Based on the legitimate interest

Sirus processes personal data based on a legitimate interest in which Sirus has made a balancing of interests.

• When using security cameras

In and around the buildings of Sirus cameras are installed for the purpose of preventing, detecting or identifying nuisances or crimes against persons and goods and maintaining public order. Images are collected, processed and stored for this purpose.

• When dealing with a question, offering help or offering information at your request

You can contact Sirus through various channels (telephone, correspondence, email, chat, contact form website, social media). We will only use the personal data you provide to answer your questions.

• When inviting a customer satisfaction survey

Sirus invites customers to participate in a customer satisfaction survey. For this purpose we work together with a research agency.

• When carrying out competency tests during the application period

In order to screen an applicant, Sirus conducts an assessment of the candidate’s competences and personality. Sirus will use an assessment agency as a processor, but we will not use the data for other purposes and will not pass them on to third parties for their own use.

• When creating an application summary list showing the status for each data subject involved

Due to the many applications that Sirus processes and the different channels through which new candidates are introduced, there is a legitimate interest in creating a list so that candidates we refuse do not re-examine after a few weeks. This list only contains personal identification data.

• When passing on a C.V. intra-group

Sirus is part of Part of The Human Factory. If someone applies for Sirus, Sirus can distribute this application within The Human Factory. If you, as an applicant, only wish to apply for Sirus, please state this explicitly.

• When keeping contact details to notify you as a friend or family member of our employee in the event of an emergency

We ask our employees to provide contact details of an acquaintance and/or family member so that we can notify them in the event of an emergency.

• When using images for public relations and/or journalistic purposes

When Sirus organises a company event, Sirus has a legitimate interest in doing public relations in order to attract new employees and/or new customers. The visitors of the event are informed in advance and have the opportunity to oppose taking the photo: at the event itself against the photographer or after the event by sending an email to info@sirus.be.

• When improving the quality of the website

Sirus uses tools to gather statistics and gain insights about the use of the website. This information is anonymised and not linked to your personal information. Analytics tools use cookies. These are text files that are placed on your computer to collect standard internet logging information and behavioural information. More information can be found in our cookie statement.

Sirus does not share your personal data with third parties, unless:

• Sirus has received your prior consent;
• Sirus is obliged to do so in the context of a regulation or legal procedure;
• Sirus is requested to do so by legislative or judicial authorities;
• Sirus organises an event together with partners or suppliers. The list of participants will also be communicated to the partners or suppliers;
• Sirus is taken over in whole or in part or split up. In that case, Sirus will impose on the third party the obligation to process the personal data only in accordance with the provisions of this Privacy Policy.

Sirus makes use of certain subcontractors such as consultants, study agencies (e.g. for conducting satisfaction surveys, tools (e.g. CRM system, mailing tool) and this in order to outsource some of our services to them. These subcontractors are not considered third parties but processors. We ensure that these subcontractors take the necessary technical and organisational measures to process your personal data legally and lawfully and under no circumstances disclose your personal data to third parties.

Sirus recognises that the security of personal data is part of data protection. Therefore, Sirus takes appropriate technical and organisational measures to protect your personal data against unauthorised processing or unauthorised access in order to prevent misuse.

Whenever personal data is transferred to a processor outside the European Economic Area (EEA), Sirus will always do so in accordance with the terms of this Privacy Policy and Sirus will follow applicable data protection laws and regulations to ensure adequate safeguards.

Sirus will only keep your personal information for the minimum period necessary to fulfil the purposes set forth in this Privacy Policy unless (i) a longer retention period is required to resolve disputes or (ii) a longer retention period is required by law. Non-personal information may be retained indefinitely for statistical purposes.

Cookies are small text files that are stored on your computer when you visit a website. This allows this website to remember your actions and preferences (such as language, font, display options, etc.) during a certain period. The advantage of this is that when you visit the website again or navigate between different web pages, you don’t have to set your preferences again.

Cookies are used to facilitate and improve the browsing experience. When you visit the website, cookies ensure that your personal settings are recalled. In addition, data is collected about how the website was consulted, and so we can improve the overall performance of the website in terms of speed and operation.

Cookies never function independently and are always linked to a website. Cookies in no way provide access to data on your computer or telephone.

If you do not want a website to place cookies on your computer, you can change the settings of your browser.

Most browsers automatically accept cookies. You can set your browser to notify you before a cookie is placed or to refuse cookies. Below you will find some links with more information about the configuration of cookies in the most common web browsers:

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari

We have no control over the content of the above links. These links can be changed by the responsible owners of the respective browsers.

More information about managing cookies can be found at http://www.allaboutcookies.org/manage-cookies/.  In addition, on the following sites you determine from which companies you no longer wish to receive cookies: https://youradchoices.com/pmc and http://www.youronlinechoices.com/.

Keep in mind that changing the settings can cause a website to stop working as expected.

If you use different devices to visit a website, you must ensure that your cookie preference is set on the browser of each device.

• Strictly necessary cookies are necessary to enable surfing and the associated functions. These cookies do not identify you as an individual. If you refuse these cookies, various functions within the website will be partially or completely disrupted.

• Functional cookies increase the user-friendliness of the website by remembering your choices (e.g. language preference). These ensure that certain settings are personalized at your request. If you do not accept these cookies, this may influence the performance and functionality of the website and may restrict access to content on the website.

• Performance / Analytical cookies collect data about the use of a website such as the number of visitors, the time visitors spend on a web page and any error messages. They help Sirus to improve the performance of the website. These cookies do not identify you as an individual.

• Advertising Cookies are used to deliver content that is more relevant to you. They can be used to deliver targeted ads or to limit the number of times you see an ad. They also help us improve the effectiveness of advertising campaigns on the Sirus website. We may use these cookies to remember websites that you have visited and we may share this information with other parties, including advertisers and our agencies.

• Third party cookies are cookies that are sent to your browser from a server or domain that is not hosted by Sirus, but by a cooperating organization. Only these third parties have access to those cookies and the information collected by the cookie.

• Legitimate interest

Sirus relies on its legitimate interest to set strictly necessary and function cookies. After all, these cookies are necessary to allow the website to function properly or to improve your user experience. These cookies are placed automatically when you visit the website.

• Consent

For all cookies that are not strictly necessary and non-functional, we will always ask for your explicit consent before placing them. This consent is given by agreeing to the various types of cookies in the cookie banner.

6.1        WHAT ARE YOUR RIGHTS?

• Right of access: You can ask us which personal data we process about you, for which we process it, which categories of personal data we process, with which categories of third parties we share your personal data, the origin of the processed data and – if applicable – what logic we use in the automatic processing of personal data.
• Right to rectification: If information is incorrect, you can ask us to correct it.
• Right to delete your data: If data is not processed lawfully or if your data is no longer necessary for the purpose for which it was collected, you can ask us to delete your data.
• Right to restrict processing: By restricting the processing of your personal data, your personal data can still be kept but its use is limited. When you have requested a processing restriction, we may only store your data. This means that no other transactions can take place with your data.
• Right to object: You have the right to object to the fact that your data is processed if that processing is based on a general interest or the legitimate interest of the person processing your data. Moreover, you can also exercise this right of objection if your personal data are processed for direct marketing purposes. This right of objection also applies to profiling, which forms the basis for processing for direct marketing purposes.
• The right to withdraw consent: If the processing of your personal data is based on consent, you have the right to withdraw your consent at any time.
• The right to transfer data: You have the right to obtain the personal data provided by you in a standard, structured and machine-readable form and you have the right to transfer these personal data to another controller if the processing is based on the legal grounds of consent or contractual relationship.

6.2        HOW CAN YOU EXERCISE YOUR RIGHTS?

You can exercise your rights by sending an e-mail to info@sirus.be .  In order to prevent any unauthorised disclosure of your personal information Sirus may request more information to verify your identity.

Sirus has one month to answer your request. This period will begin when Sirus has received your request and has all the necessary information to fulfil your request. The period of one month can be extended after a notification and explanation of Sirus.

Sirus will provide the requested information free of charge. If requests are unfounded or excessive, in particular because of their repetitive nature, Sirus may charge a reasonable fee or Sirus may refuse the request.

If for any reason you assume that Sirus did not handle your request correctly, you may contact Sirus again and we will work with you to find a solution.

For the sake of completeness, we inform you that if Sirus does not respond to your request, refuses it or if our response does not meet your expectations, you always have the right to file a complaint with the Data Protection Authority (GBA), Drukpersstraat 35, 1000 Brussel, Tel +32 (0)2 274 48 00, or contact@apd-gba.be.

Sirus recognises that the security of personal data is part of data protection. Therefore, Sirus takes appropriate technical and organisational measures to protect your personal data against unauthorised processing or unauthorised access in order to prevent misuse.

Whenever personal data is transferred to a processor outside the European Economic Area (EEA), Sirus will always do so in accordance with the terms of this Privacy Policy and Sirus will follow applicable data protection laws and regulations to ensure adequate safeguards.

Sirus will only keep your personal information for the minimum period necessary to fulfil the purposes set forth in this Privacy Policy unless (i) a longer retention period is required to resolve disputes or (ii) a longer retention period is required by law. Non-personal information may be retained indefinitely for statistical purposes.