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PRIVACY POLICY EXTERNAL (customers and suppliers)

1. General

VALUE TRADING processes personal data in the course of its activities.

Personal data should be understood as any information about an identified or identifiable person.

Processing should be interpreted broadly and is an operation or set of operations involving personal data or a set of personal data, whether or not carried out by automated processes, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of data.

As VALUE TRADING values and respects the privacy and security of personal data, these personal data are processed only in accordance with (i) the Regulation (EU) 2016/679 of the European 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, better known as the General Data Protection Regulation (GDG) or the General Data Protection Regulation (GDPR), as well as with (ii) all applicable national regulations.

The present privacy policy aims to provide you with transparent information regarding:

(a) The controller of your personal data
(b) The purposes for which your personal data are processed
(c) The period for which the personal data will be stored
(d)Your rights in relation to such processing
(e)Our obligations in relation to this processing



2. The controller of your personal data

BV VALUE TRADING, registered in the Crossroads Bank for Enterprises under the number 0713.776.775, with its registered office in 2018 Antwerp, Jacob Jacobsstraat 58, is the controller of your personal data.

This means that VALUE TRADING determines the purposes and means of processing personal data.

VALUE TRADING does this in its capacity as the company with which you have a contractual relationship (directly or indirectly) as a client or supplier, or whose website you visit.


3. The purposes for which your personal data are processed

How? VALUE TRADING collects personal data through (i) agreements you conclude (directly or indirectly) with us, (ii) voluntary provision of this by the data subject (whether or not through contact forms), (iii) through the use of our website and social media.

What? The personal data collected by VALUE TRADING are identification data, financial details, national register number, image recordings, audio recordings (telephone conversations), academic curriculum, professional experience, all data required to determine a money laundering risk profile.

Why? Personal data is always collected and processed by VALUE TRADING for one or more specific purposes. The purposes for which VALUE TRADING processes personal data are as follows: (i) to execute the contracts concluded with it, (ii) to comply with applicable legal obligations, (iii) for marketing purposes (which you may oppose at any time), (iv) to improve our services, as well as (v) in the context of its recruitment policy (job applicants).

Consequence of not providing it? The provision of personal data is a necessary condition for the conclusion of a contract or the use of VALUE TRADING’s applications. If the required personal data are not provided, a contract cannot be concluded or access to the applications cannot be provided.


4. The period for which personal data will be stored

Your personal data will be kept for as long as is necessary to achieve the purpose for which it was collected, in line with the legal, regulatory and internal requirements in this regard, and no longer than 5 years after the end of the contractual relationship (with the exception of invoicing which is kept for 7 years, and documentation required in the context of a warranty settlement which is kept for 10 years). Present provision obviously does not affect your rights as shown infra sub. 5.


5. Your rights in relation to this processing

Right to withdraw consent: You always have the right to withdraw your consent as described infra sub. 6 to withdraw it. Of course, this does not affect the lawfulness of the processing prior to such withdrawal.

Right of access: You always have the right to obtain confirmation from VALUE TRADING as to whether or not your personal data is being processed, as well as to inspect it.

Right of rectification: You always have the right to obtain from VALUE TRADING rectification of incorrect personal data without delay.

Right to data erasure: You have the right to obtain from VALUE TRADING the erasure of personal data without unreasonable delay in the following cases: (i) the personal data are no longer necessary for the purposes for which they were collected, (ii) the consent on which the processing is based is withdrawn, (iii) you object to the processing which is justified by the public or a legitimate interest, or which is done for the purpose of direct marketing, (iv) the personal data have been processed unlawfully, (v) the personal data must be erased to comply with a legal obligation, (vi) the data have been obtained in connection with an offer of information society services to a child.

Right to restriction of processing: You also have the right to restrict processing in a number of limited situations, notably (i) when the accuracy of the personal data is disputed, and this for a period enabling the controller to check the accuracy of the personal data, (ii) when the processing is unlawful and the data subject objects to the erasure of the personal data, (iii) when VALUE TRADING no longer needs the personal data for the purposes of processing, but the data subject needs them for the establishment, exercise or substantiation of a legal claim, (iv) when the data subject has objected to the processing.

Right to data portability: You have the right under certain circumstances to obtain your personal data in a structured, common and machine-readable form, and to transfer it to another controller.

Right to object to marketing purposes: You have the right to oppose the use of your personal data for direct marketing purposes at any time.


6. Our obligations in relation to such processing

Principles of processing: VALUE TRADING will always process personal data through the following principles: (i) in a manner which is lawful, proper, and transparent in relation to the data subject, (ii) for specified, explicit and legitimate purposes, (iii) relevant and limited to what is necessary for the purposes for which they are processed, (iv) the data will be accurate and, where necessary, updated, (v) will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed, (vi) all appropriate technical or organisational measures will be taken to ensure that personal data will be processed in a manner that ensures adequate security and that they are protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage.

Lawfulness of processing: VALUE TRADING is entitled to process personal data only if one of the following conditions is met: (i) you have given your express consent, (ii) processing is necessary for the execution of a contract to which you are (directly or indirectly) a party, (iii) processing is part of a legal obligation of VALUE TRADING, (iv) processing is necessary to protect your vital interests or those of other natural persons, (v) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, or (vi) processing is necessary for the protection of the legitimate interests of the controller (except where such interests are overridden by the interests of the data subject).

Sharing of personal data: Your personal data is only accessible within VALUE TRADING by the employees and associates who need to have access to it as part of their duties. These employees and associates are bound by strict internal rules regarding the processing of personal data. When VALUE TRADING makes use of external parties for the purpose of processing personal data, only those that provide adequate guarantees so that the processing complies with legal requirements and your rights are guaranteed. Your personal data may be transferred to the following categories of recipients: group companies, insurers and insurance brokers, banks (in the context of their compliance), external accountants, IT suppliers, marketing companies, delivery companies. Your data may also be transferred to police forces / judicial authorities in the context of a conducted investigation.


7. In conclusion

The present privacy policy may be modified at any time in the future, and you will always be notified in advance of any future changes or modifications.
We have tried to provide you with transparent information on your rights and VALUE TRADING’s obligations with regard to the processing of personal data. If, however, you still have doubts, would like further information or have questions, we will be happy to help you.

To contact us or to exercise your rights regarding data protection, please send an e-mail to compliance@valuetrading.eu or a letter to VALUE TRADING attn. the privacy officer, Jacob Jacobsstraat 58, 2018 Antwerp. When you exercise your rights, your letter or e-mail must be accompanied by a copy of your identity card or passport so that your identity can be verified.

Should you have any complaints and/or suggestions regarding the way we process your personal data, we would be pleased to hear from you. VALUE TRADING attaches great importance to guaranteeing your rights. We also inform you that you always have the right to lodge a complaint with the supervisory authority, i.e. the data protection authority.