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Privacy Policy
Updated November 1, 2019
- Parties and Purpose
NewGen Sourcing | Legal Manager Alexandre Boldireff (hereinafter "NewGen Sourcing" or the "Data Controller")
rue du Coron 98A at 7070 Le Roeulx
BCE / VAT : BE0 741 434 544
Mail: alexandreDOTboldireffATnewgensourcingDOTcom
Telephone: 00 32 493 35 28 70
NewGen Sourcing establishes this Privacy Policy to inform Users of the website hosted at https://newgensourcing.com, (hereinafter the "Site"), in a transparent manner, of the manner in which personal data is collected and processed by NewGen Sourcing.
The term "User" refers to any user, whether a natural or legal person, who visits or interacts in any way with the Site.
As such, NewGen Sourcing determines all technical, legal and organizational means and purposes of processing Users' personal data. To this end, NewGen Sourcing undertakes to take all necessary measures to ensure the processing of personal data in accordance with the Act of 30 July 2018 on the protection of individuals with regard to the processing of personal data (hereinafter the "Act") and the European Regulation of 26 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the "Regulation").
NewGen Sourcing is free to choose any natural or legal person who processes users' personal data at its request and on its behalf (hereinafter the "Subcontractor"). If necessary, NewGen Sourcing undertakes to select a Subcontractor that offers sufficient guarantees regarding the technical and organisational security measures for processing personal data, in accordance with the Act and the Regulations.
- Processing of Personal Data
The use of the Site by Users may result in the communication of personal data. The processing of such data by NewGen Sourcing, in its capacity as Data Controller, or by service providers acting in the name and on behalf of NewGen Sourcing, shall be in accordance with the Law and the Regulations.
Personal data will be processed by NewGen Sourcing in accordance with the purposes set out below via :
- the newsletter registration form,
- the contact form,
- registration in the B2B directory,
- making appointments online,
- the use of cookies,
- Sending questionnaires or surveys relating to the services offered by NewGen Sourcing.
- Purpose of the processing of personal data
In accordance with article 13 of the Regulations, the purposes of the processing of personal data are communicated to the User and are as follows:
- to carry out marketing, sales and promotional information activities,
- sending information and promotions on products and services,
- to produce statistics in order to improve the website, services and products offered,
- allow better identification of users' interests.
- Personal data that may be processed
By visiting and using the Site, the User consents to the collection and processing of the following personal data by NewGen Sourcing in accordance with the terms and principles described in this Privacy Policy:
- any information voluntarily provided by the User by filling out forms or contacting NewGen Sourcing by any means, such as name, mailing address, telephone number, email,
- any information automatically collected in relation to his visits to the site: IP address, browser model, operating system, language used, pages visited, navigation time, etc.
- Consent
By accessing and using the Site, the User declares that he/she is aware of and agrees freely, specifically, knowingly and unambiguously to the processing of personal data concerning him/her. This agreement relates to the content of this Privacy Policy.
Consent is given by the positive act by which the User has ticked the box proposing the Privacy Policy in the hyperlink. This consent is a prerequisite to perform certain operations on the Site or to allow the User to enter into a contractual relationship with NewGen Sourcing. Any contract between NewGen Sourcing and a User regarding the services and goods offered on the Site is subject to the User's acceptance of the Privacy Policy.
The User consents to the data controller processing and collecting, in accordance with the terms and principles contained in this Privacy Policy, personal data provided by the User on the Site or in connection with the services offered by NewGen Sourcing for the purposes set forth above.
The User has the right to withdraw his or her consent at any time. Withdrawal of consent does not affect the lawfulness of the processing based on the consent previously given.
- Storage period of Users' personal data
In accordance with Article 13 §2 of the Regulation and the Law, the Data Controller shall only keep personal data for the time reasonably necessary to allow the fulfilment of the purposes for which they are processed.
This period is in any case less than : 3 years (36 months).
- Recipients of the data and disclosure to third parties
Personal data may be passed on to employees, co-workers, subcontractors or suppliers of NewGen Sourcing who offer adequate data security guarantees and who collaborate with NewGen Sourcing in the marketing of products or the provision of services. They act under the direct authority of NewGen Sourcing and are responsible in particular for collecting, processing or outsourcing such data.
In all cases, the recipients of the data and those to whom the data has been disclosed will comply with the contents of this Privacy Policy. NewGen Sourcing assures that they will process such data only for the intended purposes, in a discreet and secure manner.
In the event that the data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed in advance so that he can express his consent to the use of this personal data.
- Data Protection Officer (DPO)
The following person is appointed Data Protection Officer (hereafter "DPO"): Alexandre Boldireff.
The role of the DPO is to ensure the proper implementation of national and supranational provisions regarding the collection and processing of personal data.
The DPO can be contacted as follows: alexandreDOTboldireffATnewgensourcingDOTcom
- Users' Rights
At any time, the User may exercise his rights by sending a message by e-mail to the following address: alexandreDOTboldireffATnewgensourcingDOTcom, or a letter by post, enclosing a copy of his identity card to the following address: rue du Coron 98A, 7070 Le Roeulx (Belgium).
a. Right of access
In accordance with Article 15 of the Rules, NewGen Sourcing guarantees the User's right of access to his personal data. The User has the right to obtain access to said personal data as well as the following information:
- the purposes of the processing,
- the categories of personal data concerned,
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations,
- where possible, the envisaged period of retention of personal data or, where that is not possible, the criteria used to determine that period,
- the existence of automated decision making, including profiling, as referred to in Article 22(1) and (4) of the Regulation, and, at least in such cases, relevant information about the underlying logic and the importance and intended consequences of the processing for the data subject.
The Controller may require the payment of reasonable charges based on administrative costs for any additional copies requested by the User.
Where the User submits such a request electronically (e.g. via e-mail address), the information is provided in a commonly used electronic form, unless the User requests otherwise.
A copy of the User's data will be communicated to the User no later than one month after receipt of the request.
b. Right of rectification
NewGen Sourcing guarantees the user's right to correct and delete personal data.
In accordance with Article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User first makes the necessary changes himself/herself from his/her user/other account, unless these changes cannot be made independently, in which case they can be requested from NewGen Sourcing.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data have been communicated of any rectification of the personal data, unless such communication proves impossible or requires disproportionate efforts. The Controller shall provide the data subject with information about these recipients if so requested by the data subject.
c. Right of erasure
The User has the right to obtain the deletion of his/her personal data as soon as possible in the cases listed in Article 17 of the Regulation.
Where the Controller has made the personal data public and is required to erase them pursuant to the previous paragraph, the Controller, taking into account the available technologies and the costs of implementation, shall take reasonable steps, including technical measures, to inform other controllers who process such personal data that the data subject has requested the erasure by those controllers of any link to such personal data, or any copy or reproduction thereof.
The two preceding paragraphs shall not apply to the extent that such processing is necessary :
- for the exercise of the right to freedom of expression and information,
- in order to comply with a legal obligation requiring processing in accordance with Union law or the law of the Member State to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller,
- the establishment, exercise or defence of legal rights.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data have been disclosed of any erasure of personal data or any restriction on the processing operation carried out, unless such notification proves impossible or involves a disproportionate effort. The controller shall provide the data subject with information about these recipients if the data subject so requests.
d. Right to limit the processing
The User has the right to obtain the limitation of the processing of his/her personal data in the cases listed in article 19 of the Regulations.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom the personal data have been communicated of any limitation of the processing carried out, unless such communication proves impossible or involves a disproportionate effort. The Controller shall provide the data subject with information about these recipients if he or she so requests.
e. Right of data portability
In accordance with Article 20 of the Rules, Users have the right to receive from NewGen Sourcing their personal data in a structured, commonly used and machine-readable format. Users have the right to pass on such data to another controller without NewGen Sourcing obstructing it in the cases provided for in the Regulation.
Where Users exercise their right to data portability under the previous paragraph, they have the right to have personal data transmitted directly from one controller to another, where technically possible.
The exercise of the right of data portability shall be without prejudice to the right of erasure. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
The right of data portability shall not prejudice the rights and freedoms of third parties.
f. Right of opposition and automated individual decision making
The User has at any time the right to object to the processing of his personal data due to his particular situation, including the automation of data by NewGen Sourcing. In accordance with Article 21 of the Regulations, NewGen Sourcing will no longer process personal data, unless there are legitimate and compelling reasons for the processing that prevail over the interests and rights and freedoms of the User, or for the establishment, exercise or defense of legal rights.
Where personal data is processed for the purposes of canvassing, the User has the right to object at any time to the processing of his personal data for such canvassing purposes, including profiling insofar as it is related to such canvassing.
Where the data subject objects to the processing for canvassing purposes, the personal data shall no longer be processed for such purposes.
g. Right of complaint
The User has the right to lodge a complaint regarding the processing of his personal data by NewGen Sourcing with the Data Protection Authority, competent for the Belgian territory. Further information can be found on the website:
https://www.autoriteprotectiondonnees.be.
Complaints can be submitted to the following addresses:
Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Phone + 32 2 274 48 00
Fax + 32 2 274 48 35
E-mail: contact@apd-gba.be
The User may also file a complaint with the Court of First Instance of his domicile.
- Cookies
The Site uses cookies to distinguish Users of the Site. This helps to provide Users with a better browsing experience and an improved Site and content. The objectives and modalities of cookies are contained in this article.
a. General principles
A "Cookie" is a file that is temporarily or permanently deposited on the User's hard disk when consulting the Website, with a view to later connection. Thanks to cookies, the server recognises the User's computer.
Cookies may also be installed by third parties with whom NewGen Sourcing collaborates.
Some of the cookies used by NewGen Sourcing are necessary for the proper functioning of the Website, others are used to improve the User's experience.
The User may personalize or disable cookies by setting up his browser.
By using the Website, the User expressly agrees to the management of cookies as described in this article.
b. Type of cookies and purposes
Different types of cookies are used by NewGen Sourcing on the Site:
- Technical cookies: they are necessary for the operation of the Website, allow the communication of the data entered and are intended to facilitate the User's navigation.
- Cookies for statistical and audience measurement: these cookies enable the recognition of the User and are used to count the number of Users of the Website over a certain period of time. Since they also indicate browsing behaviour, they are an effective means of improving the User's browsing, by displaying proposals and offers that may be of interest to the User. They also allow NewGen Sourcing to identify possible bugs on the Website and to correct them.
- Functional Cookies: These cookies facilitate the use of the Website by retaining certain choices entered (for example, user name or language).
- Tracking cookies: NewGen Sourcing uses tracking cookies via Google Analytics to measure the interaction of Users with the content of the Website and to produce anonymous statistics. These statistics enable NewGen Sourcing to improve the Website. Google supports the explanation of these cookies at http://www.google.nl/intl/en_uk/policies/privacy/.
c. Cookie retention period
Cookies are kept for the time necessary to accomplish the purpose for which they were created. The cookies that may be stored on the User's hard drive and their retention period are as follows: 13 months
d. Cookie management
- If the User does not want the Website to place cookies on his/her hard disk, it is easy for him/her to manage or delete them by modifying the parameters of his/her browser. Browser programming also allows the User to receive a notice or notification as soon as a Website uses cookies and thus decide whether to accept or reject them.
- If the User deactivates certain cookies, the User accepts that the Website may not function optimally. Certain parts of the Website may therefore not be usable, or may only be partially usable.
- If the User wishes to manage and/or delete certain cookies in this way, he or she can do so by using the following link(s), for Users with a browser:
- Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
- Microsoft Edge: http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq
- Chromium: https://support.google.com/accounts/answer/61416?hl=fr
- Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
- Safari: https://support.apple.com/kb/ph21411?locale=fr_CA
- If the User does not want Google Analytics cookies to be used, he is invited to set his browser to this effect on the following website: http://tools.google.com/dlpage/gaoptout.
- Limitation of liability of the Data Controller
The Website may contain links to other websites owned by third parties not related to NewGen Sourcing. NewGen Sourcing is not responsible for the content of these sites and their compliance with the Law and Regulations.
The holder of parental authority must give his or her express consent for a minor under 16 years of age to disclose personal information or data on the website. NewGen Sourcing strongly advises persons exercising parental authority over minors to promote responsible and secure use of the Internet. The Data Controller cannot be held responsible for collecting and processing personal information and data from minors under the age of 16 whose consent is not effectively covered by that of their legal parents or for data - in particular concerning age - entered by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he/she is under 16 years of age.
NewGen Sourcing is not responsible for the loss, corruption or theft of personal data caused in particular by the presence of viruses or as a result of computer attacks.
- Security
The Data Controller implements organisational and technical measures to guarantee an appropriate level of security for the processing and collection of data. These security measures depend on the costs of implementation in relation to the nature, context and purposes of the processing of personal data.
The Data Controller uses standard encryption technologies within the IT sector when transferring or collecting data on the Site.
- Modification of the Privacy Policy
NewGen Sourcing reserves the right to modify this Privacy Policy to comply with legal obligations. The user is therefore advised to regularly review the Privacy Policy for changes and adaptations. Any such modification will be posted on the Site or emailed to you for your review.
- Applicable law and jurisdiction
This Privacy Policy is governed exclusively by Belgian law. Any dispute will be brought before the courts of the judicial district of the registered office of NewGen Sourcing.
- Contact
For any question or complaint relating to this Privacy Policy, the User may contact the Data Controller via the following address: alexandreDOTboldireffATnewgensourcingDOTcom
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