Privacy Policy

Notice for users of this website

  1. 'Who we are'
    1. we”, “us” or “our” means First Wave NV, a Belgian company with registered office at B-2550 Kontich, Veldkant 33 A, with a branch office at B-1040 Brussels, Avenue d’Auderghem 346, and known in the Crossroads Bank of Enterprises under number 0552.596.627. We act as controller for the personal data we gather through your use of our website and for the personal data we gather of you in the performance of our services. We shall also act as controller for the personal data we gather from contact persons within your organization.
    2. This Privacy Policy is solely intended to provide you with information in relation to the processing of personal data by First Wave NV (i) through the use of the Website (www.firstwave.be) and (ii) through the use of our services. We ask you to read this Privacy Policy very carefully.
    3. Our Website, www.firstwave.be, is owned and operated by First Wave NV. This Website is hosted by VERSIO.BE(.NL).
    4. Since we are committed to safeguarding your personal data we will explain in this Privacy Policy how we collect, disclose, transfer and use (hereinafter “process”) the personal data that you share with us through the use of our website or our services, and which rights you have regarding your personal data.
    5. We will process your personal data in accordance with 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 (hereinafter the “Privacy law”). This Privacy Policy allows us to be open and transparent, so that you can make meaningful choices about the use of your personal data by First Wave NV.
    6. Our Privacy Policy explains:
      • Which categories of personal data we collect;
      • How we collect and use your personal data;
      • Your rights as a data subject in relation to your personal data;
      • How long we keep your personal data;
      • Who has access to your personal data;
      • ow your personal data will be transferred.
    7. If you have any questions, concerns or complaints regarding this Privacy Policy or our processing of your personal data or you wish to submit a request to exercise your rights as set out in this Privacy Policy, please contact us:
      1. Via e-mail: info@firstwave.be, to the attention of our Privacy Officer;
      2. Via Post: to First Wave NV, to the attention of our Privacy Officer, Veldkant 33A, 2550 Kontich, Belgium.
    8. This Privacy Policy is to be read together with our Cookie Policy. For further information relating to our use of Cookies, we refer you to our Cookie Policy.
    9. We reserve the right to make any changes or amendments to our Privacy Policy. The most recent version of our Privacy Policy will always be available on our Website. Continued use of the Website and/or our services shall imply the acceptance of the modified Privacy Policy. This Privacy Policy was revised last on 01 July 2019.
    10. By using our Website, you give us permission to collect your personal data for the purposes as indicated in this Privacy Policy.
  2. How we use and collect your personal data
    1. “Personal data” is defined as: any information relating to an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.), that can be used to directly or indirectly identify a natural person.
    2. The Personal data we collect, is collected and used for the purposes as listed hereunder:
      • Responding to questions – In case you make use of our phone number, e-mail address or address, then we may use your personal data to respond to your requests via e-mail, phone or post.
      • Performance of services - We process your personal data in the performance of our services or to deliver you the information asked. We also process the personal data that we receive in the performance of our services for customers- and supplier administration in order to augment the quality of our services, to develop our services, to invoice our services and to follow up and collect outstanding invoices.
      • Support of Website - We process your personal data for the purpose of supporting the website and enhancing your user experience, which includes ensuring the security, availability, performance, capacity and health of the Website.
      • Recruitment and selection – When you provide us with your personal data by sending us an e-mail, calling or by sending us a letter, then we will process your personal data in order to invite you for a meeting. We will also process your personal data with regard to a possible recruitment and/or for an outsourcing process.
      • Proposal of business contacts – We will process and transfer personaldata of suppliers to our customers in the performance of the services.
      • Direct marketing / newsletter – If you are a customer of us, we process your personal data for sending you direct marketing messages, proposing golden candidates or sending you our newsletter. In the event you are a potential customer, we will collect your consent in order to process your personal data for sending your direct marketing messages, proposing golden candidates or sending you our newsletter.
    3. We collect the following different categories of personal data:
      • Contact data: We collect contact data about you. We receive this information directly from you when you communicate this to us, for example by sending us an e-mail. Please do not provide us with any sensitive information, such as health information, information pertaining to criminal convictions, or credit card/account numbers. This is information that is provided directly by you.
      • Identification data: as a professional customer or supplier we process the coordinates of the contact person(s) within your organization as well as the coordinates of the partners in your case, in particular: name, first name, address, e-mail address, phone number, cellphone number, VAT-number, enterprise number, education, title and job description.
      • Financial data: when you use our services, we process the identification- and bank account numbers as well as credit card numbers or debit card numbers. We also process the amounts already paid or that you still have to pay. Finally, we process all the data regarding your solvability.
      • Usage data: We collect personal data regarding your activities on our website: IP address, device ID and type (serial number, hardware type, version, etc.), referral source, language settings, browser type, operating system, geographical location, length of visit, page views, or information about the timing, frequency, pattern or other details of your service use. This information may be aggregated and used to help us provide more useful information regarding the use of our website. In the event the usage data is completely anonymized (and can therefore not be traced back to you as an individual), this will not be considered personal data for the purpose of this Privacy Policy. This is personal data that is automatically collected through your use of the website.
      • Direct Marketing, golden candidates and newsletter: We collect the following personal data for sending you direct marketing messages, proposing golden candidates or sending you our newsletter: e-mail address, name, address and phone number.
    4. The legal basis for the processing of your contact data is “performance of the agreement”. We need the personal data in order to respond to questions and e-mails we receive from you.
    5. In the performance of our services and with regard to our suppliers, we process the identification data and financial data based on the legal basis “necessary for the performance of the agreement”. We need the identification data to deliver invoices, to include the invoices in our accounting and for our customer and supplier administration.
    6. The contact data that we process when you contact us by using our phone number, address, e-mail address as well as the usage data that we aggregate from your use of our Website are based on the legal ground “legitimate interest”. For example, we have a legitimate interest to respond to your questions or to react on your comments and to make your Website experience as pleasant and save as possible. It is also possible that we keep identification data after the performance of the agreement, such as your CV, based on the legal ground “legitimate interest”. For example, we have a legitimate interest to keep your identification data for potential future opportunities. By all means we aim for a balance between our legitimate interest and your privacy.
    7. When you are an existing customer of us, we process your personal data for direct marketing purposes, proposing golden candidates and sending you the newsletter based on the legal ground “legitimate interest”.
      When you are a potential customer of us, we will process your personal data for direct marketing purposes, proposing golden candidates and sending you the newsletter based on the legal ground “consent”. In this case, you will at all times, have the right to withdraw your consent. This will, however, not affect the lawfulness of any processing done prior to the withdrawal of consent.
    8. For the avoidance of doubt, your personal data will solely be used for the purposes as set out in this clause.
  3. Your rights
    This article lists your principal rights under data protection law. We have tried to summarize them for you in a clear and legible way.
    To exercise any of your rights, please send us a written request in accordance with article 1.7. of this Privacy Policy. We will respond to your request without undue delay, but in any event within one month of the receipt of the request. In the event of an extension of the term to respond or in the event we do not take action on your request, we will notify you.
    1. The right to access
      • You have the right to confirmation as to whether or not we process your personal data and, in the event we do so, you have the right to access such personal data, together with certain additional information that you also find listed in this Privacy Policy.
      • You have the right to receive from us a copy of your personal data we have in our possession, provided that this does not adversely affect the rights and freedoms of others. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies.
    2. The right to rectification
      • If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed.
    3. The right to erasure (right to be forgotten)
      • In some circumstances, you have the right to the erasure of your personal data without undue delay.
        Those circumstances include:
        1. The personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed;
        2. You withdraw your consent, and no other lawful ground exists;
        3. The processing is for direct marketing purposes;
        4. The personal data have been unlawfully processed; or,
        5. Erasure is necessary for compliance with EU law or Belgian law.
      • There are certain exclusions to the right to erasure. Those exclusions include where processing is necessary,
        1. for exercising the right of freedom of expression and information;
        2. for compliance with a legal obligation; or,
        3. for the establishment, exercise or defense of legal claims.
    4. The right to restrict processing
      • You have the right to restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes), if:
        1. You contest the accuracy of the personal data (and only for as long as it takes to verify that accuracy)
        2. The processing is unlawful and you request restriction (as opposed to exercising the right to erasure)
        3. We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; or,
        4. You have objected to processing, pending the verification of that objection.
      • In addition to our right to store your personal data, we may still otherwise process it but only:
        1. with your consent;
        2. for the establishment, exercise or defense of legal claims;
        3. for the protection of the rights of another natural or legal person; or,
        4. for reasons of important public interest.
      • We will inform you before we lift the restriction of processing.
    5. The right to data portability
      • To the extent that the legal basis for our processing of your personal data is consent, and such processing is carriedout by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
      • You also have the right to have your personal data transferred directly to another company, if this is technically possible, and/or to store your personal data for further personal use on a private device.
    6. The right to object to processing
      • You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
        1. The performance of a task carried out in the public interest or in the exercise of any official authority vested in us;
        2. The purposes of the legitimate interests pursued by us or by a third party.
      • If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
      • You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
    7. The right to complain to a supervisory authority
      • If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
        In Belgium, you can submit a complaint to the Data Protection Authority, Rue de la Presse 35, 1000 Brussels, (contact@apd-gba.be, tel: +32 (0) 2 274 48 00, fax: +32 (0) 2 274 48 35).
  4. Retention of your data and deletion
    1. Your personal information will not be kept for longer than is necessary for a specific purpose.
    2. In the event you withdraw your consent or you object to our use of your personal data, and such objection is successful, we will remove your personal data from our databases. Please note that we will retain the personal data necessary to ensure your preferences are respected in the future.
    3. The foregoing will, however, not prevent us from retaining any personal data if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.
  5. Providing your personal data to others
    1. In order to provide you with our Website, we work with service providers to process and store your personal data. We use the following service providers:
      • Hosting provider: Versio.be (.nl)
      • Website operator: First Wave NV & kmo:city
    2. If you are a client of ours, we may provide your personal data to the suppliers we have contracted or intend to contract in order to provide you with our services. Those suppliers may have access to your personal data in the performance of their assignments. They may never process your personal data for their own purposes.
    3. If you are a supplier of ours, we may provide your personal data to our clients for the purpose of suggesting you as a supplier or in the course of delivering the services.
    4. We may disclose your personal data to affiliated companies of First Wave NV. These affiliated companies shall only process your personal data in accordance with this Privacy Policy.
    5. We may also disclose your personal data in the event such disclosure is required or necessary in order to fulfil a legal obligation. We may also disclose personal data in order to protect your vital interests or the vital interest of another natural person.
    6. As such, we do not disclose your personal data to our social media partners. We do, however, make use of LinkedIn’s social media plugin to direct you to our social media channel and to allow you to interact with our content. In the event you click on the link, LinkedIn may collect personal data about you and may link this information to your existing profile on LinkedIn.
    7. We are not responsible for the use of your personal data by LinkedIn. In such case, LinkedIn will act as controller. For your information, on the following link (http://linkedin.com/legal/privacy-policy), you will find more information on how LinkedIn may process your personal data. The content thereof can change from time to time.
  6. International transfers
    1. We will transfer your personal data outside of the European Economic Area, because of the use we make of third parties for the purposes described in this Privacy Policy.
    2. We will ensure that any transfer of personal data to countries outside of the European Economic Area will take place pursuant to the appropriate safeguards.
    3. You hereby authorize us to transfer your personal data outside the European Economic Area.