At VVA Brussels sprl, avenue des Arts, 10-11, 1210 Brussels, Belgium (VVA), we dedicate significant global resources to ensure compliance with applicable data protection laws. We are committed to comply with any data protection regulations that may apply in processing personal data, including the GDPR.
We may come into possession of your personal data through all kinds of channels.
We may also collect data from other legitimate sources such as third party data aggregators, business and promotional partners, public sources and third party social networks.
The personal data you may actively provide or which we may collect from public sources further to applicable terms (e.g. Linkedin based on your terms with them) or our legitimate interest, include the following :
Passively collected information as regards the use of our website may include :
We take reasonable steps to make sure that the information is accurate, complete, current, relevant and otherwise reliable and not excessive in relation to its intended use. VVA further commits to minimize the amount of personal data collected.
We only use your personal data to the extent permitted by law. Depending on your relationship with us and the channels used to collect personal data, our use of such data will differ.
Use of supplier or customer personal data
If you supply or purchase products or services to or from us, we process your personal data as part of our supplier or customer management, based on the need to perform our contract with you, carry out transactions, process and perform requested services or support and keep sufficient records of the same. Without your personal data, we will not be able to execute the contract.
We also use personal data to perform essential business operations based on our legitimate interest. This includes maintaining and improving the performance of our services, developing new services, aggregate analysis and business intelligence that allow us to make informed business decisions.
Use of visitor personal data
If you visit one of our offices or other locations, we will process your personal data:
Use of personal data of website visitors
When you visit our website, we process your personal data :
During your visit to our website, cookies may be placed in accordance with the cookie section below.
Use of personal data of stakeholders
If you took part to interviews or surveys managed by us or which were contracted out to third parties, we process your personal data based on a contract, your consent or our legitimate interest:
Use of personal data of current and previous partners and experts as a reference for future projects or tenders requiring their skills, based on your consent or our legitimate interest
Use of personal data of job / contract applicants
The provision of your personal data is necessary in order to be able to assess your application or interest and, as the case may be, to offer you a job or to participate to a project or contract. If you apply to us, we will process your personal data as an applicant:
Use of personal data for direct marketing purposes
We may process your personal data to send you relevant newsletters and information regarding services that may be of interest to you, provided you have given us consent if you are not a customer of ours, or on the basis of our legitimate interest if you are.
You can withdraw your consent or unsubscribe from further receipt of direct marketing messages at any time.
In addition to the specific purposes for which we may process your personal data set out in the previous sections, we may also process personal data for:
VVA does not make decisions which produce legal effects concerning you, or similarly significantly affect you solely by automated means and without human involvement, for instance when evaluating certain personal aspects relating to you, such as your performance at work, creditworthiness, reliability or conduct.
We may share your personal data with Third Parties with your consent or as necessary for the performance of a contract to which you are a party or in order to take steps, at your request, prior to entering into a contract.
Parties or entities we may share your personal data with include VVA’s affiliated companies, officials, clients, external contractors we work with or have access to your organization’s personal data, service providers engaged by us to perform certain services such as management of our customer database, website and/or app, processing of orders, cloud services, online payment, providing professional advice, managing risks, health services, pensions, insurance and legal disputes.
In addition to the specific purposes of disclosure set out in this section, we may also share your personal data whenever necessary for compliance with a legal obligation to which we are subject, to comply with a court order, to protect your vital interest as data subject or those of another natural person or for the purpose of any other legitimate interest pursued by VVA or a third party that is not overridden by your fundamental rights and freedoms as data subject.
Certain personal data that you submit or for which you have given your consent for publication through our website or services may be available, via the internet, around the world. VVA cannot prevent the use (or misuse) of such personal data by others.
We may transfer personal data to persons or entities in countries outside the EEA. To ensure that your personal data receives an adequate level of protection, we only transfer your personal data to countries that benefit from an adequacy decision issued by the Commission. If no such decision is available, we may put in place contractual agreements based on the EU Commission’s standard contractual clauses, which seek to ensure that your personal data is treated by those third parties and entities outside the EEA in a way that is consistent with and which respects the EU laws on data protection, including the GDPR.
You will be informed whenever we intend to transfer your personal data outside the EEA, the existence of an adequacy decision or the appropriate safeguards and how to obtain a copy of them or where they have been made available prior to such transfer taking place.
VVA shall not store personal data that we process for any purpose for longer than is necessary for that purpose as may be detailed in our data processing register. After expiration of that period, the personal data are routinely deleted, unless retention is necessary (i) to ensure compliance with a legal obligation to which VVA is subject, (ii) to protect your vital interests or the vital interests of another natural person, or (iii) for the purpose of any other legitimate interest pursued by VVA or a third party that is not overridden by your fundamental rights and freedoms as data subject.
VVA takes reasonable and appropriate measures to maintain the confidentiality and integrity, prevent the unauthorized use or disclosure, of personal data and to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction.
We maintain a system of appropriate administrative, physical and technical safeguards to secure such information. We have made contractual arrangement with our third party service providers which require them to take appropriate security measures to ensure the confidentiality and security of your personal data and process your personal data for specified purposes only and in accordance with our instructions and comply with applicable privacy laws.
We take reasonable steps to make sure that the information is accurate, complete, current and otherwise reliable with regard to its intended use. However, VVA expects that you will provide VVA with updated personal data as necessary as described in section 10.
There are different types of cookies which may be distinguished on the basis of their origin, function and lifetime:
More information on all aspects of cookies can be found on www.allaboutcookies.org.
An overview of the cookies most commonly used by VVA is given below:
Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. Instructions for blocking or deleting cookies can be found in each browser’s privacy or help documentation. Certain features of VVA’s website and services depend on cookies. Please be aware that if you choose to block or delete cookies, you may have to manually adjust settings and preferences controlled by those cookies every time you visit and some services and functionalities may not work. If you use different devices to access a website, you will need to ensure that each browser of each device is set to your cookie preference.
VVA web pages may also contain electronic images know as web beacons. These are miniature, single-pixel graphics or gifs that we use to help deliver cookies on our websites, understand the behaviour of visitors of our website or count website visitors. More information on web beacons can be found on http://www.allaboutcookies.org/web-beacons/. We may also include tracking pixels in e-mails to determine whether an e-mail was opened and acted upon, enable log file recording and analysis. The data so collected may be used by VVA in order to optimize the shipping of the newsletter, as well as to adapt the content of future mailings even better to your interests.
With both cookies and web beacon technology, the information that we collect is anonymous and not personally identifiable. Cookies and web beacons cannot retrieve any other data from a hard drive or obtain an email address.
Under the GDPR you have a number of rights with regard to your personal data. You have the right to:
You may file your request by sending an e-mail to contact_Brussels@vva.it or reach out to us in writing at VVA, Kunstlaan 11, 1210, Sint-Joost-ten-Node. Responses to requests shall normally be made within one month of receipt, however this may be extended by up to two months if the request is complex and/or numerous requests are made. If such additional time is required, we will inform you of the same.
Without prejudice to your rights to lodge a complaint with the competent data protection authority, we encourage you to approach us directly if, in connection with your personal data, you consider that there is an infringement of the applicable data protection laws. To do so, you can either send an e-mail to contact_Brussels@vva.it or reach out to us in writing at VVA, Kunstlaan 11, 1210, Sint-Joost-ten-Node.
We will investigate the complaint and respond to it as soon as possible and within one month of the sending of the acknowledgement of receipt. If the complaint is particularly complex, we will provide you with an estimate of when the response, which will in any event not be later than two (2) months of the sending of the acknowledgement of receipt. If the complaint is upheld, VVA commits to take appropriate remedial measures as necessary to resolve the complaint.
If you are not satisfied with our response, you can lodge a complaint with the competent data protection authority.
Last updated : 15 August 2018