Privacy Policy

This privacy policy (the “Privacy Policy”) is intended for:

• our potential, current and former staff members;
• our potential suppliers who are natural persons (such as self-employed persons) or the representatives or contact persons of our potential suppliers who are legal persons; and
• visitors to our website and any third parties who follow our business, such as analysts and individuals who have signed up for our newsletters.

This policy does not apply to information processed about legal entities.

You are receiving this Privacy Policy because Vitaminalia BV processes information about you that constitutes “personal data” and Vitaminalia BV is committed to protecting your personal data and privacy.

Vitaminalia BV is responsible for the processing of your personal data, as Vitaminalia BV decides why and how it is processed and thus acts as the “controller”. In this Privacy Policy, the words “we”, “us”, “our” and “our” refer to Vitaminalia BV.

As of May 25, 2018, according to the General Data Protection Regulation (the “AVG”), Vitaminalia BV is subject to and will comply with the revised data protection rules in the European Union and that Privacy Policy is in effect.

In keeping with our commitment to protecting your personal data, we would like to inform and explain to you openly:

• why and how Vitaminalia BV collects, uses and stores your personal data; and
• What your rights and our obligations under that processing are.

1. What personal data do we collect?

We collect basic identifying information about all natural persons with whom we have contact, such as your name, title of address, position, company name, e-mail and/or postal address and landline and/or mobile phone number.

Such information may be provided to us directly by you, communicated to us by the legal entity for which you work (e.g., if you are the contact person your employer has designated as managing relationships with Vitaminalia BV), provided to us by one of our service providers (such as financial institutions or recruitment agencies) or obtained from publicly available sources (such as profiles on social media).

1. Potential, current and former staff members

About potential, current and former employees we may additionally collect the following information:

• additional identifying information (such as date and place of birth, nationality, ID card or passport number and a copy of ID card, emergency contact person);
• family information (such as marital status, number and date of birth of children, family composition and employment status of partner);
• information about your education and experience (such as work and education history, other information from resumes, professional qualifications and experience);
• other data in the context of your recruitment (such as information communicated during the interview, a handwritten text for personality assessment based on your handwriting, notes and comments made during the recruitment process);
• data about your position (such as job title and employee number, immediate supervisor and subordinates, date of hire / promotion / job change, work arrangement, performance evaluations, language skills);
• information about your remuneration (such as salary level and amount, number of years of experience, bonus, shares, options, expense data, insurance and other benefits, pension rights and information about your bank account);
• Social Security data (such as your tax and Social Security status, insurance information, disability, attendance information including periods of illness or career interruption);
• electronic identification data (such as usernames, passwords, IP address, badge number, data on the use of computer tools, online identifiers and cookies, professional email address of Vitaminalia BV and the unique code that identifies each employee’s expense account, audio or visual recordings such as from surveillance cameras or voice messages);
• the information needed to compile the lists of insiders required under Belgian law (according to the template prepared by the FSMA);
• your photograph; and
• more generally, information about the activities you engage in as part of your work at Vitaminalia BV.

2. (Representatives of) suppliers

In addition, we may also collect the following information about (representatives of) suppliers:

• electronic identification data when necessary to provide products or services to our company (such as usernames, access rights, passwords, badge number, IP address, online identifiers and cookies, logs, access and connection times, image or audio recordings such as photos for badges, images from surveillance cameras or voice messages); and
• for natural persons acting as suppliers or service providers: financial information (such as data on bank accounts, bills and invoices) and information about the contract (such as type of agreement, parties and duration).

3. Visitors to our website and any third parties who follow our business, such as analysts and individuals who have signed up for our newsletters.

In addition, about visitors to our website and any third parties who follow our business, such as analysts and individuals who have signed up for our newsletters, we may also collect the following information:

• electronic identification data (such as fields in the http header, IP address, browser identification data, hardware and software location information if available);
• information about your browser and device (such as Internet access provider, type and version of your browser, operating system and platform, screen resolution, manufacturer and model of your device);
• Information you provide when you sign up for one or more newsletters (such as address, profile and interest in one or more newsletters);
• data collected through cookies, website code and web beacons from the sender of our newsletters (such as language preferences and website usage data, such as the pages you visited, in what order you visited them and how long you viewed them); and
• for analysts following our company, their estimates and any related opinions, forecasts or predictions.

To the extent permitted or required by law, we may also process sensitive data, such as union membership or health information. Vitaminalia BV does so only when strictly necessary for the relevant purposes stated in Section 4 below or to comply with a legal obligation and, where appropriate, provided that it has obtained your prior consent to do so. In this case, the data will only be viewed and processed under the responsibility of a representative of Vitaminalia BV bound by a duty of confidentiality.

When personal data is collected (e.g., in forms), we always state whether providing that data is mandatory (e.g., with an asterisk) and the consequences of refusing to provide the requested data.

We may also collect your national registration number or national identification number, but only process such data if and when required by law.

2. When do we collect personal data?

Vitaminalia BV collects personal data:

• When natural persons apply for a position with an entity of Vitaminalia BV;
• when employees have contact with Vitaminalia BV, its personnel, its computer facilities and other systems;
• When Vitaminalia BV has contact with former employees;
• When Vitaminalia BV has contact with (the representatives of) our current/potential suppliers;
• When individuals visit our website or subscribe to our newsletters; and
• When we receive questions from analysts.

3. On what legal basis and for what purposes do we process personal data?
   1. Legal basis for processing

We may not process personal data if we do not have a valid legal basis for doing so. Accordingly, we only process personal data if:

• we have obtained your prior consent to do so;
• the processing is necessary to fulfill our contractual obligations to you or to take action at your request prior to entering into a contract;
• the processing is necessary to comply with our legal or regulatory obligations;
• the processing is necessary to protect your vital interests or the vital interests of another natural person; or
• the processing is necessary for the legitimate interest of Vitaminalia BV and your interests or fundamental rights and freedoms are not overridden.

Note that when we process your personal data under the latter legal basis, we always strive to balance our legitimate interest and your privacy. Examples of such “legitimate interest” include:

• To take advantage of cost-effective services (e.g., we may choose to use certain vendor platforms);
• to prevent fraud or criminal activity and to protect the security of our computer systems, architecture and networks; and
• to meet our corporate social responsibility goals.

1. Purposes of processing

We always process your personal data for a specific purpose and process only the personal data relevant to achieving that purpose. In particular, we process personal data for any of the following purposes:

• Potential, current and former staff members

Of potential, current and former staff members, we process personal data for the purpose of:

• recruitment activities;
• personnel administration (including to organize work, manage tasks, benefits, expenses and absences, conduct career and background checks, compile and keep employee lists up-to-date and arrange travel);
• payroll administration (including for managing salaries and other contractual benefits, salary and pay scale reviews, other benefits such as stock options, stock awards and bonuses, pensions and savings plans, family member benefits and professional expenses);
• performance reviews (such as evaluations, promotions, career and succession planning, and personnel and talent management);
• monitoring the activities of employees in the workplace, including compliance with policies and applicable health and safety regulations;
• disciplinary actions and internal complaints regarding violence, workplace bullying or unwelcome (sexual) behavior;
• responses to official inquiries from an appropriate governmental or judicial authority; and
• compliance with laws and regulations and reporting (such as compliance with our policy documents and legal requirements, withholding of withholding taxes and insurance premiums, management of alleged instances of misconduct or fraud, conducting audits and defense in litigation);
• the continuity of business operations;
• Mergers and acquisitions involving our company; and
• any other purpose imposed by law or governmental authority.

1. (Representatives of) suppliers
   • performing tasks to prepare or execute contracts;
   • monitoring activities in our facilities, including compliance with policies and applicable health and safety regulations;
   • the management of our information technology assets, including infrastructure management and business continuity; and
   • billing.

• Visitors to our website and any third parties who follow our business, such as analysts and individuals who have signed up for our newsletters.

Of visitors to Vitaminalia BV’s website and all third parties who follow our company, such as analysts and individuals who have signed up for our newsletters, we process personal data in order to:

• manage and improve our website (including to identify server problems, optimize traffic, and integrate and optimize web pages where appropriate);
• measure the use of our website (including by compiling statistics on traffic or collecting information on the behavior of visitors and the pages they visit);
• improve and personalize your experience and better tailor website content to your needs (including by remembering your selections and preferences using cookies);
• Periodically send newsletters and promotional emails about our portfolio and information that you or your company may find of interest using the email address you have provided to us (if you choose to do so);
• Analyze the success of email campaigns and improve the sending of emails to better communicate with our subscribers;
• detect and prevent fraud, breaches and other potential abuses of our website; and
• To communicate analyst estimates to third parties on the Vitaminalia BV website.

1. General

In addition to the above specific purposes, we also process all personal data collected for the following general purposes:

• To keep contact information (such as business cards);
• To manage and organize the relationship between Vitaminalia BV and its stakeholders;
• To manage our computing resources, including infrastructure management and business continuity;
• to safeguard the Company’s economic interests and ensure compliance with laws, regulations and reporting requirements (such as compliance with our policy documents and legal requirements, the withholding of taxes and fees, the management of alleged instances of misconduct or fraud, the conduct of audits and the defense in litigation);
• To comply with all legal obligations imposed in the context of Vitaminalia BV’s activities;
• To answer official questions from any governmental or judicial authority authorized to do so;
• For archiving and preservation purposes; and
• to manage mergers and acquisitions involving our company.

4. How do we protect personal data?

We have taken appropriate technical and organizational measures to ensure the security and confidentiality of your personal data. Those measures take into account:

• the state of the art;
• implementation costs;
• the nature of the data;
• and risk of processing.

Their purpose is to protect your personal data against accidental or unlawful destruction, accidental loss, unlawful disclosure or access and other unauthorized forms of processing.

In addition, in handling your personal data, we ensure that:

• we only collect and process personal data that is adequate, relevant and limited to what is necessary for the above purposes; and
• keep your personal data current and accurate.

For that purpose, we may ask you to confirm the personal data we hold about you. You are also requested to inform us spontaneously when your personal circumstances change so that we can update your personal data.

5. Who has access to personal data and with whom are they shared?
   1. Transfer to third parties

We may transfer personal data to or provide access to third parties outside Vitaminalia BV for the purposes set forth in Section 3.2 above, to the extent that they need such data or access to carry out the assignments they have received from us. Such third parties include:

• third parties who process personal data, such as the administrator of our payroll administration, our suppliers of (computer) systems, website designers and hosting providers, payment service providers, banks, insurance companies and pension funds, social security authorities and social secretariat, event organizers (e.g. for shareholders’ meetings), e-mail service providers, providers of database and cloud services and consultants;
• any third party to whom we transfer or assign any part of our rights or obligations under any relevant agreement;
• our advisors and outside counsel in connection with the sale or transfer of any part of our business or its assets; and
• any national and/or international regulatory, enforcement or exchange bodies or courts where applicable law or regulation requires us to do so or they request it.

In accordance with applicable law, the above third parties are contractually obligated to protect the confidentiality and security of your personal data.

1. Transfer outside the European Economic Area

Personal data that Vitaminalia BV transfers may also be processed in a country outside the European Economic Area (“EEA”), which consists of EU member states, Iceland, Liechtenstein and Norway. Non-EEA countries may not offer the same level of protection of personal data as EEA countries. Therefore, if your personal data is transferred outside the EEA, we will implement appropriate safeguards to ensure that such transfer is made in accordance with applicable data protection rules. You can obtain more information about this and a copy of the safeguards in question by exercising your rights as set out below.

6. How do we use cookies and other similar technologies on our websites?

A cookie is a text file that may be stored on your device when you visit our website. It contains information that is collected on your device and sent to the website on each subsequent visit to remember your actions and preferences.

Vitaminalia BV uses cookies to remember your language preferences and to make using the website easier for you. It also uses Google Analytics to administer the website (among other things, to measure website usage and compile statistics) and to customize and improve the website.

Note that you can change your browser’s settings to alert you when you receive cookies. If you do not wish to receive cookies, you can also disable cookies completely by activating the relevant setting of your browser. Note that if you decide to reject all cookies, some parts of the website may not be accessible to you or may not work properly. Finally, you can also delete already stored cookies.

More information on managing cookies on your device can be found in the help function of your browser or at https://www.aboutcookies.org, which contains extensive information on how to change settings in a wide range of browsers (external link).

7. How long do we keep your data?

We retain personal data only for as long as necessary to fulfill the purpose for which it was collected or to comply with any legal, regulatory or internal requirements.

We retain candidate data collected for recruitment purposes for up to two years. Data on employees is kept for as long as they are employed by the company, unless legal or regulatory requirements impose a longer or shorter retention period.

Data in connection with contracts will be kept for as long as your contract (or your company’s contract) with us runs, plus the period until the legal claims arising from the contract expire, unless legal or regulatory requirements impose a longer or shorter retention period.

Personal data collected and processed in the context of a dispute shall be deleted (i) as soon as an amicable settlement is reached, (ii) as soon as a final judgment is rendered, or (iii) when the claim is time-barred.

When the above retention periods expire, your personal data will be deleted from our systems.

However, if individuals wish to have their personal data removed from our databases, they may submit a request to that effect as described in Section 8, which we will evaluate as set forth below.

8. What are your rights and how can you exercise them?
   1. Your rights

You have the right to review the personal data that Vitaminalia BV processes about you pursuant to this policy. If you believe that any information we hold about you is inaccurate or incomplete, you may also request that it be corrected. Vitaminalia BV will correct such information as soon as possible.

You also have the right to:

• request that your personal data be deleted;
• request that the processing of your personal data be restricted;
• withdraw your consent where Vitaminalia BV has obtained your consent to the processing of personal data (without such withdrawal affecting the lawfulness of the processing prior to the withdrawal);
• Object to the processing of your personal data for direct marketing purposes; or
• object to the processing of your personal data for other purposes in certain cases where Vitaminalia BV processes your personal data on a legal basis other than your consent.

Vitaminalia BV will review and implement such requests, withdrawals or objections in accordance with applicable data protection rules.

Moreover, you also have the right to data portability. That is the right to obtain the personal data you have provided to Vitaminalia BV in a structured, common and machine-readable form and to request that such personal data be forwarded to a third party, without being interfered with by Vitaminalia BV and provided that your own duty of confidentiality is observed.

1. Exercise of your rights

If you have any questions or wish to exercise the above rights, please send an e-mail to info@vitaminalia.be or send a letter to the attention of Vitaminalia BV, Broekstraat 78a, 9220 Hamme with a scan of your identity card for identification purposes, it being understood that we will only use such data to verify your identity and will not retain the scan after such verification is completed. When providing us with such a scan, please ensure that you make your photograph and national registration number or similar number unrecognizable on the scan.

If you are dissatisfied with how we process your personal data, please send an e-mail to info@vitaminalia.be or send a letter to the attention of Vitaminalia BV, Broekstraat 78a, 9220 Hamme with Then we will investigate your complaint.

In addition to the above rights, you always have the right to lodge a complaint with the competent data protection authorities.

9. Adjustments to this policy

This policy is subject to change. Any future changes or additions to the processing of personal data as described in this policy that affect you will be communicated to you through an appropriate channel depending on how we typically communicate with you.

(1) Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation or “AVG”).