At SPARKI, we respect the privacy of our customers, suppliers, website users and contacts, and we are committed to keeping all your personal data secure.
This Privacy Policy explains how we use the personal data that SPARKI collects or generates in connection with our website and our services.
The list below sets out what is covered by this Privacy Policy, and you can click on the titles below to go to a specific section.
1. BACKGROUND
SPARKI BV, with registered office at Borsbeeksebrug 34, 2600 Antwerp (hereinafter referred to as ‘Sparki’, “we” or ‘us’), collects and uses certain Personal Data as a data controller within the meaning of the General Data Protection Regulation (GDPR). Sparki is responsible for ensuring that it uses such Personal Data in accordance with data protection legislation, including but not limited to the GDPR and the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.
‘Personal data’, “processing” or ‘controller’ in the context of this Privacy Policy have the meanings given to them in the GDPR.
Please note that this Privacy Policy may be updated from time to time due to the implementation of new technologies and/or changes in legislation. We will inform you in an appropriate manner when the Privacy Policy is updated.
2. THE TYPES OF PERSONAL DATA WE COLLECT AND PROCESS
Some services offered by Sparki on its website require us to obtain Personal Data about you in order to perform the services for which we have been appointed. In connection with the services available on this website, we will collect and process the following Personal Data about you:
Personal data that you provide to Sparki. This includes information about you that you provide to us (for example, via the contact form on the website). The nature of the services you request or the questions you ask determine the type of Personal Data we may ask for, e.g.:
Contact details, such as first name, last name, company name, (professional) email address, delivery address, country;
Any information you wish to share with us (whether or not via our websites) that may be considered Personal Data, including but not limited to questions, comments, complaints, orders, etc.;
Information about your professional background when you submit an application in the career section of the website.
Personal data that we collect or generate about you. This includes:
When you visit the Sparki website, cookies are used to collect technical information about the services you use and how you use them. For more information about the cookies Sparki uses, please consult the Cookie Policy;
If you or your company are customers of Sparki, all Personal Data relating to the services or products you or your company have requested and our interactions with you or your company.
3. HOW WE USE YOUR PERSONAL DATA
3.1 We may store and process your Personal Data for the following purposes:
to respond to your request for information via our contact form on the website;
for the management and administration of our activities;
to gain insight into your needs and interests;
for the ongoing evaluation and improvement of the information on or the functioning and security of the Sparki websites;
to assess and manage your customer relationship with us, where applicable;
to offer our customers and prospects Sparki services and products;
to process your job application;
to comply with applicable laws, rules and regulations, and internal policies and procedures, and to assess compliance with them; and/or
for the administration and maintenance of databases in which Personal Data is stored.
3.2 When we use Personal Data, we ensure that the use is in accordance with applicable law, is based on a valid legal basis, and that the law permits and/or requires us to use Personal Data for various reasons. These include when:
we are required to do so in order to fulfil our contractual obligations to our customers, suppliers and candidates for employment at Sparki;
we have obtained your consent;
we have legal and regulatory obligations that we must comply with;
we must do so in order to establish, exercise or defend our legal rights, or in the context of legal proceedings;
the use of your Personal Data as described is necessary for our legitimate business interests, such as: o enabling us to manage and administer the operation of our business effectively and efficiently; o managing the proper functioning of our website; o enforcing compliance with internal policies and procedures; and o promoting our services and products.
4. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
4.1 We may share your Personal Data within Sparki. We will take steps to ensure that the Personal Data is only accessible to Sparki employees who need it to perform their duties for the purposes described in this Privacy Policy.
4.2 We may also share your Personal Data outside Sparki with the following persons:
with our business partners; these may be intermediaries who have introduced you to us or through whom you have requested services or products from Sparki. Personal data will only be passed on to a business partner who is contractually obliged to comply with applicable data protection obligations and the relevant legislation on privacy and confidentiality;
with third-party agents and contractors for the purpose of providing services to us (e.g. Sparki’s accountants, professional advisors, IT and communications suppliers, and legal advisors). These third parties will be subject to the necessary data protection obligations and will only use your Personal Data as described in this Privacy Policy;
to the extent required by law, for example if we need to disclose your Personal Data to comply with a legal obligation (including, but not limited to, to comply with tax reporting and regulatory disclosure obligations), or to establish, exercise or defend our legal rights.
5. INTERNATIONAL TRANSFERS OF PERSONAL DATA
5.1 Some Personal Data may occasionally be stored on servers outside the EEA.
5.2 When we transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner that complies with legal requirements. With regard to data transferred outside the EEA, this may be done in one of the following ways:
the country to which we send the data may have been approved by the European Commission as a country that guarantees an adequate level of protection for Personal Data;
the recipient may have signed an agreement based on ‘standard contractual clauses’ approved by the European Commission, under which they are obliged to protect your Personal Data; or
in other circumstances, the law may allow us to transfer your Personal Data outside Europe in other ways.
5.3 You can obtain further details about the protection of your Personal Data when it is transferred outside the EEA (including a copy of the standard data protection clauses we have agreed with recipients of your Personal Data) by contacting us as described in section 9 below.
6. HOW WE PROTECT YOUR PERSONAL DATA
6.1 We have extensive controls in place to maintain the security of our information and information systems. The information we handle is protected with safeguards that are commensurate with the sensitivity of the information involved. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal data is collected, processed or stored is restricted to authorised employees.
6.2 As a condition of employment, Sparki employees and staff are required to comply with all applicable laws and regulations, including data protection legislation. Access to Personal Data is restricted to those employees and staff who need it to perform their duties.
7. HOW LONG WE STORE YOUR PERSONAL DATA
7.1 How long we retain your Personal Data will vary and will be determined by the following criteria:
the purpose for which we use them – Sparki must retain the data for as long as necessary for that purpose; and
legal obligations – laws or regulations may specify a minimum period during which we must retain your Personal Data.
7.2 We will no longer process your Personal Data if you withdraw your consent and there is no other valid basis for processing your Personal Data. We will delete your Personal Data if we have not been in contact with you for five years. We will delete the Personal Data of our customers ten years after the end of our contractual relationship. We will delete the Personal Data of unsuccessful candidates for a job at Sparki after one year.
8. YOUR RIGHTS
8.1 You have a number of rights in relation to the Personal Data we hold about you. These rights include:
the right to obtain information about the processing of your Personal Data and to access the Personal Data we hold about you;
where you have actively given us consent to process your Personal Data, the right to withdraw your consent at any time;
in certain circumstances, the right to receive certain Personal Data in a structured, commonly used and machine-readable format and/or to request us to transfer this data to a third party where technically feasible (‘data portability’). Please note that this right only applies to Personal Data that you have provided to us;
the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances in which you ask us to erase your Personal Data, but we are legally entitled to retain it;
the right to request that we restrict our processing of your Personal Data in certain circumstances. Again, there may be circumstances in which you request us to restrict our processing of your Personal Data, but we are legally entitled to refuse that request; and
the right to lodge a complaint with the data protection authority (details of which are provided below) if you believe that any of your rights have been infringed by us.
8.2 You can exercise your rights by contacting us using the details in the ‘Contact us’ section below.
8.2 You can obtain more information about your rights by contacting a competent data protection authority. In Belgium, this is the Data Protection Authority, Drukpersstraat 35, 1000 Brussels, or by searching their website www.gegevensbeschermingsautoriteit.be.
9. CONTACT US
If you have any questions or concerns about the processing of your Personal Data by Sparki or about this Privacy Policy, or to exercise the above rights, please contact us using the following contact information:
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