1. Who we are:
The data controller responsible for the processing of your data is Delphi Genetics SA, having its registered offices at Rue Antoine de Saint-Exupéry 5, 6041 Gosselies (Charleroi), Belgium ("Delphi Genetics" or "we").
As data controller, we respect your right to privacy and will only process your personal data in accordance with applicable data protection laws and as described in this policy. Applicable data protection laws include (i) the General Data Protection Regulation (Regulation 2016/679) (“GDPR”); and (ii) all other existing or new applicable laws relating to or impacting on the processing of personal data of a living person and privacy.
2. What data does Delphi Genetics collect?
We collect and process your personal data only for the purposes set out in this Policy.
Delphi Genetics may process the following categories of personal data about you, depending on the categories of data subjects to which you belong:
2.1 For contact persons of prospect/client and supplier/vendor of Delphi Genetics
|Contact person of Prospect/Client/Supplier/Vendor||Source|
|Contact details e.g. name, company address||Either (i) directly from you, or (ii) from your employer (i.e. Delphi Genetics' client/prospect/supplier or vendor) or (iii) from publicly available sources such as LinkedIn|
|Communications, e.g. e-mails|
|Company (employer) and professional title|
2.2 For job applicants
|Contact details e.g. name, address, phone number||Either (i) directly from you or (ii) from third-party headhunters|
|E-mail address||Either (i) directly from you or (ii) from third-party headhunters|
|Communications, e.g. e-mails||From you|
|CV, references||Either (i) directly from you or (ii) from third-party headhunters|
|Assessment forms, background check||From you|
|Interview notes||Either (i) directly from you or (ii) from third-party headhunters|
3. On which legal basis and for what purposes do we process your data?
We always process your personal data on the basis of and within the boundaries of the legal bases as those are laid down under applicable law. We also ensure to limit the processing of your personal data to what is strictly necessary for the achievement and performance of these purposes.
3.1 Performance of our legal or contractual duties
We may process your personal data where this is necessary for the performance of our legal duties, such as our tax or accounting obligations, our fight against fraud or for performing any other legal obligation, including abiding by or enforcing an order from a court or from a governmental body or authority.
We may also process your personal data for the performance of our contractual obligations towards you or in order to take steps at your request. For example:
- We process job candidates' personal data for the purposes of the recruitment process and the evaluation of your application, including the further follow-up, such as interview, background check, etc;
- We process client's contact person's personal data for the purposes of the administration of the client relationship, the organisation of meetings or to reply to your requests or other enquiries;
- We process supplier's contact person's personal data for the purposes of the administration of the supplier relationship, performing obligations or enforcing rights in relation to the contractual relationship or to reply to your requests or other enquiries.
3.2 Legitimate interests of Delphi Genetics
When not strictly necessary for any of the abovementioned reasons, Delphi Genetics may also process your personal data for other purposes, falling under the achievement and the realisation of its legitimate interests. In such a case, however, Delphi Genetics maintains a fair balance between the need to process your data and the preservation of your rights and freedoms, including the protection of your privacy. Whenever this is the case, Delphi Genetics will keep you informed about what type of legitimate interest we are pursuing and provide you with transparent information about the processing operations and your rights.
Against this background, we may process your personal data to support Delphi Genetics' position in disputes and legal proceedings. We may also process your personal data as contact person of a client or prospect to run day to day operations or send you further information from Delphi Genetics.
4. How do we share your personal data and who do we share it with?
We will not sell, rent or otherwise disclose your personal data to any third party, except as described in this policy.
- Third party processors
We may provide your personal data to contractually bound third-party companies and external service providers (referred to as "processors") which process personal data on our behalf for the purposes set out above. These parties are required to process such information based on our instructions and in accordance with this policy.
The third party providers to whom we may disclose your personal data are our IT services providers, including e.g. Microsoft Outlook 365.
- Compliance with laws and legal proceedings
We may disclose your personal data where:
- we are required to do so by applicable law, by a governmental body or by a law enforcement agency;
- to establish or exercise our legal rights or defend against legal claims;
5. How long do we keep your personal data?
We will not store your personal data beyond the time necessary for the performance of the purposes for which the data is processed. We will hold your personal data as long as it is necessary to comply with our legal obligations (including bookkeeping, and tax obligations) or to resolve disputes and/or enforce our agreements.
In particular, we will store your personal data for no longer than:
- 2 years for rejected job applicants' personal data;
- 3 years for prospects' personal data (i.e. after the last contact);
- 10 years after expiry of the contract if you are a contact person of a client or supplier.
6. International transfers
In connection with the abovementioned purposes, we try to avoid as much as possible the transfer of personal data that we collect from you to third party data processors located outside the European Economic Area.
When we transfer personal data that we collect from you to third party data processors located in countries that are outside of the European Economic Area and which do not offer an adequate level of protection, we ensure the use of appropriate data transfer tools such as the entering into of the standard contractual clauses issued by the European Commission.
We take appropriate technical and organisational measures to safeguard the personal data that you provide to us against unauthorized or unlawful processing and against accidental destruction, loss or damage.
8. Your rights
You have the following rights as a data subject:
- the right to access to personal data that we hold about you;
- the right to ask us to update or correct any out-of-date or incorrect personal data that we hold about you;
- the right to erasure where the conditions of article 17 of the GDPR have been met;
- the right to restriction of processing where the conditions of article 18 of the GDPR have been met;
- the right to data portability insofar the conditions of article 20 GDPR apply to you;
- the right to object to processing of personal data concerning you, insofar the conditions under article 21 GDPR have been met; and
- the right to opt out of any direct marketing communications that we may send you.
You can exercise these rights at any given time by emailing us at email@example.com.
You also have the right to lodge a complaint with the competent supervisory authority.