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Privacy statement for business partners
The EU General Data Protection Regulation (GDPR) entered into force on 25 May 2018.
Therefore, with this privacy statement, we wish to seize the opportunity to inform you about our practices with regard to the processing of your personal data.
Data controller
The data controller is the natural or legal person determining the purposes and means of the processing of your personal data.
In the context of this policy, the data controller is Sumitomo Bakelite Europe NV, with registered offices at 3600 Genk, Henry Fordlaan, 80 (SBE NV or We).
Data subjects
This privacy statement applies to all business partners of SBE NV, be it natural persons or collaborators of legal persons, and specifically to:
Purposes of processing and data processed
We only process your personal data in the context of our business relationship and we do not use it for other purposes.
Purpose | Legal basis |
|---|---|
Administration of orders placed with suppliers and of services requested to subcontractors | Necessity for the performance of contracts with suppliers and subcontractors |
Administration of orders from clients and the delivery of products | Necessity for the performance of contracts concluded with clients |
Administration of services provided to clients | Necessity for the performance of contracts concluded with clients |
Financial management of our business relationships | Necessity for the performance of the contract concluded with clients, suppliers and subcontractors Statutory obligations SBE NV’s legitimate interest to effectively manage its finances |
Intra-group reporting | SBE NV’s legitimate interest to ensure qualitative reporting on commercial activities and business relationships within the Group of Sumitomo Bakelite Co., Ltd. |
Risk management and compliance | Compliance with statutory obligations SBE NV’s legitimate interest to manage risk and compliance |
Arrangements for business meetings or other events | Necessity for (potential) pre-contractual measures Necessity for the performance of the contract concluded with clients, suppliers and subcontractors Legitimate interest to enter into or perform a contract with the client’s, supplier’s or subcontractor’s employer or contract party (when the latter is not an individual) |
Arrangements for business meetings or other events including meals |
|
In exceptional circumstances, management of potential disputes which may arise from our business relationships | Statutory obligations Necessity for the performance of the contract concluded with clients, suppliers and subcontractors |
Typically, the personal data we hold about you will include the following:
We do not conduct profiling activities nor take automatic decisions on that basis. Data we process about you will usually be obtained from yourself or from other companies of the Group of Sumitomo Bakelite Co., Ltd.
Retention of your personal data
Generally speaking, your personal data will be retained as long as necessary for the fulfilment of the above purposes. In most cases, this will result in us keeping most of your personal data for a period of 10 years, which may however be extended in the event of litigation.
Transfer of your personal data
To achieve better quality or efficiency in the processing of your personal data, we may enter into contracts with third parties to carry out said processing on our behalf and only according to our instructions. Client data can for example be transferred to transport companies charged with ensuring delivery of the products. Service providers to whom your personal data are transferred, are bound by specific agreements and are required to keep your data securely.
In addition, as part of our compliance with statutory obligations, we may share your personal data with custom authorities.
Additionally, disputes and other incidents may lead us, in exceptional circumstances, to share personal data about you with police and other law enforcement bodies.
In the context of internal reporting within the Group of Sumitomo Bakelite Co., Ltd. (i.e. the group to which Vyncolit belongs), your personal data may also be shared with other group companies.
If and to the extent your employer would be subject to a potential sale, your personal data may also be shared with potential acquirers as part of routine pre-acquisition due diligence processes.
Cross-border transfers of personal data
The technical processing and transmission of your personal data (whether within the Group of Sumitomo Bakelite Co., Ltd.or through third parties) may involve transmissions over various networks, including the transfer of your personal data to other countries.
That may also constitute a transfer to third countries outside the European Economic Area that do not provide an adequate level of personal data protection. In that case, SBE NV shall take appropriate safety measures in order to ensure that your personal data are sufficiently protected (for example by concluding standard contractual clauses concerning the transfer of personal data).
Currently, such transfers take place in the framework of SBE NV’s reseller business within the Group of Sumitomo Bakelite Co., Ltd., with offices currently located in Japan and the United States of America.
Your rights
You have the right to request access to your personal data, and its correction in the event of inaccuracies. You also have the right to request erasure of your personal data when such data is no longer relevant. Although you may request that your personal data be deleted at any time, we may have to retain certain personal data for contract performance purposes or in order to comply with statutory retention obligations.
In addition, you have the right to object to the processing of your personal data in relation to justified personal circumstances and to request the restriction of the processing in specific circumstances.
Finally, note that you have the right to receive the personal data you have provided to us, in a structured, commonly used and machine-readable format (data portability).
When the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time.
Contact information
If you have any questions or concerns about this statement, any concerns about your personal data being processed as outlined above, or would like to exercise the rights outlined above, please contact us through sending an email at HRGenk@sumibe.eu, which is the single point of contact.
Data Protection Authority
Finally, please note you have the right to lodge a complaint with respect to the processing of your personal data with the Belgian Data Protection authority, the contact details of which are:
Data Protection Authority
Drukpersstraat 35
1000 Brussels
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