This policy contains the guidelines that Dovesco NV and Dovesco MV Comm.V. (together with their respective legal successors hereinafter referred to as “Dovesco”), apply in processing personal data, in accordance with the objectives and obligations arising from the General Data Protection Regulation, i.e. Regulation (EU) 2016/679 of 27 April 2016 of the European Parliament and of the Council 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 (‘GDPR’).
Dovesco MV Comm.V., with registered office at B-9052 Zwijnaarde, Nederzwijnaarde 2, registered in the register of legal entities in Ghent under number 685.601.641, and with VAT number BE0685.601.641, acts as processor of personal data.
Dovesco confirms that it complies with the current legislation, namely the European General Data Protection Regulation of 27 April 2016 referred to above.
- “Personal data”: all information about an identified or identifiable natural person (“the data subject”). A natural person is regarded as identifiable if he or she can be identified directly or indirectly, in particular by means of an identifier such as a name, an identification number, location data, an online identifier or one or more elements characterising the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
- “Processing”: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- “Controller”: a natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- “Processor”: a natural or legal person which processes personal data on behalf of the Controller.
- “Sub-processor”: the subcontractor appointed by the Processor to carry out part of the processing on behalf of the Controller.
- “Personal data breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed, also known as a “data leak” ;
- “GDPR”: The General Data Protection Regulation, i.e. Regulation (EU) 2016/679 of 27 April 2016 of the European Parliament and of the Council 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.
3. Processing of personal data
Below is a list of personal data which are processed and the purposes for which Dovesco processes them as well as Dovesco’s basis for doing so.
- In connection with Dovesco’s investment activities and management, the following personal data are processed:
- Your surname and first name
- Your address
- Your telephone number
- Your email address
The above data are processed with a view to duly perform our investment activities and management in the ordinary course of business.
Dovesco justifies the processing of personal data in this case on the basis of the legitimate interest that Dovesco has received your express and prior consent to that effect.
- In connection with your accessing and use of our website, the following personal data will be processed:
- Your IP address
- Your browsing behaviour
Dovesco processes the above data with a view to optimising the content and functioning of the website, in accordance with the needs of the visitor.
Dovesco justifies this processing of personal data on the basis of the legitimate interest that Dovesco has in offering a readily accessible, understandable, appropriate, comprehensive and relevant website.
- In connection with the sending electronically or by post of newsletters, deal announcements and invitations to events, the following personal data are processed:
- Your surname and first name
- Your address
- Your email address
The above data are processed with a view to personalising our newsletters, deal announcements and invitations.
Dovesco relies on your express and prior consent for the processing of personal data in this case.
- In connection with the compilation and analysis of anonymised statistics, the following personal data are processed:
- The sequence of pages you visit on the website
- The number of times you visit our website
Processing for statistical purposes is carried out using coded data, from which the identity of the data subject cannot be traced.
The legal basis on which Dovesco justifies this processing is the company’s legitimate interest in continually subjecting its website to evaluation and improvement.
Dovesco undertakes not to process your personal data for any purpose other than the purposes mentioned above, unless you give Dovesco express prior permission to do so. Dovesco guarantees that your personal data will not be retained if Dovesco no longer requires them for the execution of our investment activities and management, or if it is no longer subject to a statutory retention obligation.
4. Retention period
Your personal data processed by Dovesco are stored as long as is necessary for the duly execution of our investment activities and management, in accordance with the legal, regulatory and internal requirements in this respect. If you wish to erase your personal data from our systems, you can simply make a request to us in this respect as provided for below.
As a data subject whose personal data are processed, you have a number of rights with regard to the processing operations carried out by Dovesco.
To exercise these rights, you should contact Dovesco’s legal department, accessible via email (GDPR@dovesco.com).
Dovesco is obliged to respond to this request within a period of one month. You will only receive a response within the set period if you send your request for the exercise of your rights using the above-mentioned procedure.
You have the following rights:
- Right of inspection and access
You have the right to access your personal data and the right to check how they are being used. You may obtain a free copy of your available personal data at any time by simply making a request to this effect, including proof of your identity by attaching a copy of your identity card to your request.
- Right to correction, erasure and restriction
Except for those personal data that must be processed because of a legal obligation, you may indicate which personal data may not be processed at all or may only be processed for a limited number of processing operations. In addition, you may request that personal data which you do not wish to be processed in whole or in part, be deleted. You may also ask to check and, if necessary, correct your personal data.
- Right to object, automated decisions and profiling
You may oppose the processing of your personal data at any time if your objection is based on serious and legitimate reasons. If you wish to oppose the use of your personal data for direct marketing purposes, you do not have to give any reasons for this.
The processing of personal data by Dovesco is not carried out on the basis of automated decisions; in other words it is not carried out without human intervention.
Dovesco does not engage profiling on the basis of the available personal data.
- Right to withdraw consent
If the processing of your personal data is based on consent you have given, you may withdraw this consent at any time.
Under the conditions stipulated in the GDPR, you have the right to obtain your personal data in a structured, commonly used and machine-readable form. You may ask Dovesco to transfer your data in this way to another Controller.
If you believe that your rights as a data subject are being infringed by or during the processing of your personal data, you have the right to make a complaint to the Data Protection Supervisor (the Commission for the Protection of Privacy, Drukpersstraat 35, 1000 Brussels, email: firstname.lastname@example.org, tel. +32 (0)2 274 48 00, fax +32 (0)2 274 48 35), without prejudice to any other possibility of initiating a judicial review or seeking a judicial remedy.
6. Transfer to third parties
Dovesco undertakes not to sell, rent, distribute or otherwise disclose your personal data to third parties, unless the communication is made to the third party under a legal obligation. In exceptional cases, mandatory laws oblige Dovesco to transfer your personal data to the competent government authorities. Likewise, a court order may require Dovesco to communicate personal data to people authorised by the order to inspect the personal data concerned.
Dovesco makes an exception to its non-disclosure undertaking in the event of a partial or complete reorganisation or a transfer of the company’s business operations. In such cases, your personal data will be conveyed along with the business operations to the third parties involved in the transfer and in the confidential negotiations prior to the transfer.
As far as possible, Dovesco will inform you of the transfer to the aforementioned third parties.
7. Security and confidentiality
Dovesco guarantees that the processing of your personal data takes place in an appropriate, correct and secure manner. If you wish, you will be informed in a transparent manner about the processing procedures and the technical and organisational measures taken to prevent any loss, falsification or unlawful alteration of or unlawful access to your personal data.
Dovesco reserves the right to change this policy.
If substantial adjustments are made, Dovesco will take all reasonable measures to notify you before the changes take effect.