Privacy Statement

Hybridge attaches great importance to your privacy and careful handling of your personal data. We therefore make every effort to explain to you in clear and plain language with this privacy statement what personal data we collect from you, what we use it for and what your rights are in this regard.

This version of this privacy notice (version: 3.0) is dated as of 11/10/2022.

1. Table of contents

  1. Table of contents
  2. Who are we?
  3. Scope
  4. Why and how do we process your personal data
    1. Using our website
    2. Contact via website
    3. Customer relationship management (incl. prospecting new customers)
    4. Sending of newsletters
    5. Organisation of events
    6. Recruitment and selection
    7. Management of supplier relationships (incl. prospecting new suppliers)
    8. Making appointments
    9. Chatbot
    10. Purchases in our webshop
    11. Extra
  5. Sharing personal data with third parties
  6. Transfer of personal data outside the EEA
  7. How long do we keep your personal data?
  8. Automated individual decision-making
  9. What are your rights and how can you exercise them?
    1. Right of access
    2. Right of improvement
    3. Right to restrict processing
    4. Right to data portability
    5. Right to object
    6. Right to data erasure (right to oblivion)
    7. Right to withdraw your consent
    8. Right to oppose the processing of your personal data in automated individual decision-making
  10. Who can I turn to with further questions or any complaints around privacy?
  11. Amendments to the privacy statement
 

2. Who are we?

“We”, “We”, “us” or “our” means Hybridge with registered office at Veldkant 33a in 2550 Kontich and with company number BE0784822050.

If you have any questions, comments or complaints regarding this privacy statement or the processing of your personal data or wish to exercise any of your rights, please contact us by e-mail at dpo@cronos.be.

3. Scope

This privacy statement applies to this website, our direct marketing activities and the general organisation of Hybridge.

4. Why and how do we process your personal data?

If you visit our website and/or are in contact with us, it is possible that certain personal data may be processed. Below you will find more information on the different processing activities that may apply to you.

4.1. Using our website

When you visit our website, we may process personal data using online techniques such as cookies, trackers, scripts and similar technologies (hereinafter referred to as ‘cookies’). These may include (1) essential cookies that are strictly necessary to send a message via an electronic communications network, to ensure the security of our website or to store information about the provision of a service expressly requested by you; (2) functional cookies that further shape your use of our website; (3) analytical cookies to measure and analyse your use of our website; (4) marketing cookies to deliver (personalised) advertisements to you; and (5) other third-party cookies that we allow on our website.

More information on this can be found in our cookie statement.

4.2. Contact via website

Consent – Contact forms are available on our website to get in touch with us. You can also reach us by email or phone at any time. We process this personal data to process your contact request but have no visibility or control over any other personal data you may communicate to us via the open fields. We ask you not to include any confidential or sensitive data.

This processing is done on the basis of your consent. Please know that you can withdraw it at any time. This withdrawal does not affect the lawfulness of the processing that took place before the withdrawal of your consent.

  • What personal data do we process?
    • Identification and contact details
  • Other details as may be spontaneously communicated in the contact form:
    • Occupational data
    • Personal details
  • How do we obtain this personal data? Directly from you when filling in our contact form
  • How long do we keep them? To be archived up to 1 year after the contact request has been completed plus the archiving period of related communications (such as emails)
  • With whom may we share this personal data (other than affiliated and associated companies)? Processors (such as, for example, our hosting partner) that we rely on for the purposes of our website, contact or relationship management
  • Do these activities involve automated individual decision-making? No 
  • Do these activities involve transfers outside the EEA? No

4.3. Customer relationship management (incl. prospecting new customers)

Justified interest – Hybridge is always looking for new customers, actively establishing new contacts for this purpose and building relationships with existing customers. As part of this, your personal data will be processed (e.g. to invite you to other forms of communication, an event…)

This processing is done on the basis of the legitimate interest of Hybridge. You can always object to this according to the conditions described under ‘right to object’ in the section ‘What are your rights and how to exercise them’.

  • What personal data do we process?
    • Identification and contact details
    • Other details as may have been raised during further contacts:
      • Occupational data
      • Leisure activities and interests
      • Personal details
  • How do we obtain this personal data? Directly from you through customer relationship management
  • How long do we keep them? Up to 7 years after completion of a last order or contact
  • With whom may we share this personal data (other than affiliated and associated companies)? Processors (such as, for example, our CRM platform) that we use in the context of our website, contact or relationship management
  • Do these activities involve automated individual decision-making?  No
  • Do these activities involve transfers outside the EEA? No

4.4. Sending of newsletters

Consent – On our website, you can subscribe to our newsletter. We process this personal data to then contact you when a new newsletter is available for you.

This processing is done on the basis of your consent. You have the option of withdrawing the given consent at any time without prejudice to the lawfulness of the data processing up to the time the withdrawal took place. Specifically, this means that your consent remains valid for all previous newsletters, but you will no longer receive newsletters.

  • What personal data do we process? Identification and contact data 
  • How do we obtain this personal data? Directly from you when you register
  • How long do we keep them? As long as consent is not withdrawn
  • With whom may we share this personal data (other than affiliated and associated companies)? Processors (such as, for example, our email platform) that we rely on for the purposes of our website or newsletter delivery
  • Do these activities involve automated individual decision-making? No
  • Do these activities involve transfers outside the EEA? No

4.5. Organisation of events

Consent – When you register for one of our events, personal data is processed for the processing of your registration and the organisation of the event.

This processing is done on the basis of your consent. You have the possibility of withdrawing the given consent at any time without prejudice to the lawfulness of the data processing up to the time the withdrawal took place. Specifically, this means that your consent remains valid for all previous events in which you have already participated, but you will no longer be invited to future events.

  • What personal data do we process?
    • Identification and contact details
    • Other data as possibly communicated spontaneously:
      • Occupational data
      • Leisure activities and interests
      • Personal details
      • Allergies or dietary requirements
  • How do we obtain this personal data? Directly from you when you register
  • How long do we keep them? We keep personal data about your participation for up to 1 year after the event takes place.
  • With whom may we share this personal data (other than affiliated and associated companies)? Processors (e.g. event companies, catering, etc. ) that we rely on to help organise and shape the event. 
  • Do these activities involve automated individual decision-making? No
  • Do these activities involve transfers outside the EEA? No

4.6. Recruitment and selection

Consent for (spontaneous) applications and maintenance of a recruitment reserve -Justified interest for active recruitment -.

When you (spontaneously) apply for a position at Hybridge, Hybridge processes personal data about you. We do this in function of recruiting and selecting employees for open or future vacancies. This processing (including the creation of a recruitment reserve) is done on the basis of your consent. You have the option of withdrawing the consent given at any time without prejudice to the lawfulness of the data processing up to the time the withdrawal took place.

When Hybridge itself actively recruits, Hybridge processes personal data about you. This is only done on the basis of data publicly available about you (e.g. on platforms such as LinkedIn and Google) or data provided to us by third parties.  This processing is based on the legitimate interest of Hybridge. You can always object to this in accordance with the conditions as described under ‘Right to object’ in the chapter ‘What are your rights and how can you exercise them’.

Finally, we declare our legitimate interest in passing on your personal data to our affiliated and associated companies as part of our recruitment process. We always do this with a view to finding a suitable assignment for you. You can always object to this according to the conditions as described under ‘Right to object’ in the chapter ‘What are your rights and how can you exercise them’.

  • What personal data do we process?
    • Identification and contact details
    • Other details as may be listed on your CV:
      • Personal characteristics
      • Social contacts
      • Psychological data (cfr. a description of your personality or character)
      • Family composition
      • Leisure activities and interests
      • Academic curriculum
      • Professional competence
      • Professional experience
      • Membership/participation in professional organisations
      • Current employment
      • Career
      • Business records (cfr. (partial) disability)
      • Current salary
      • Current fringe benefits
      • Row register number
  • How do we obtain this personal data?
    • (Spontaneous) application: directly from you on your application
    • Active recruitment: through third parties such as public platforms or intermediaries
  • How long do we keep them?  
    • For non-rejected applicants: we keep personal data on your application for up to 1 year after application.
    • For applicants within our recruitment reserve: as long as consent is not withdrawn and for up to 3 years after application.
  • With whom may we share this personal data (other than affiliated and associated companies)?
    • Processors (e.g. recruitment agencies) we use to recruit and select
  • Do these activities involve automated individual decision-making? No
  • Do these activities involve transfers outside the EEA? No

4.7. Management of supplier relationships (incl. prospecting new suppliers)

Justified interest – Hybridge cooperates with suppliers, actively establishing new contacts for this purpose and building relationships with existing suppliers. As part of this, personal data of employees at our suppliers (e.g. account managers) are processed.

This processing is done on the basis of the legitimate interest of Hybridge. You can always object to this according to the conditions described under ‘right to object’ in the section ‘What are your rights and how to exercise them’.

  • What personal data do we process?
    • Identification and contact details
    • Other details as may have been raised during further contacts:
      • Occupational data
      • Leisure activities and interests
      • Personal details
  • How do we obtain this personal data? Directly from you through customer relationship management
  • How long do we keep them? Up to 7 years after completion of a last order or contact
  • With whom may we share this personal data (other than affiliated and associated companies)? Processors (such as, for example, our CRM platform) that we use in the context of our relationship management
  • Do these activities involve automated individual decision-making?  No
  • Do these activities involve transfers outside the EEA? No

4.8. Making appointments

Consent – On our website, you can book appointments through our online appointment maker. As part of this, we process your personal data to organise and handle the appointment.

This processing is done on the basis of your consent. You have the option of withdrawing the given consent at any time without prejudice to the lawfulness of the data processing up to the time the withdrawal took place. Specifically, this means that your consent remains valid for all appointments previously made online and you no longer book appointments via the online appointment maker.

  • What personal data do we process?
    • Identification and contact details
    • Occupational data
  • How do we obtain this personal data? Directly from you when scheduling the appointment
  • How long do we keep them? To be archived up to 1 year after the contact request has been completed plus the archiving period of related communications (such as emails)
  • With whom may we share this personal data (other than affiliated and associated companies)? Processors (such as, for example, our hosting partner) that we rely on to get the arrangements organised
  • Do these activities involve automated individual decision-making? No
  • Do these activities involve transfers outside the EEA? No

4.9. Chatbot

Consent – On our website, you can ask your questions to and chat with our chatbot. As part of this, we process your personal data to enable communication.

This processing is done on the basis of your consent. You have the option of withdrawing the given consent at any time without prejudice to the lawfulness of the data processing up to the time the withdrawal took place. Specifically, this means that your consent remains valid for all previous conversations and you no longer engage in conversations with the chatbot.

  • What personal data do we process?
    • Identification and contact details
    • Other details as may have come up during the interview
  • How do we obtain this personal data? Directly from you through the conversation you have with the chatbot
  • How long do we keep them? Until the moment you close the conversation plus the archiving period of related communications (such as e-mails) to be archived
  • With whom may we share this personal data (other than affiliated and associated companies)? Processors (such as, for example, our hosting partner) that we rely on to keep the chatbot available
  • Do these activities involve automated individual decision-making?  No
  • Do these activities involve transfers outside the EEA? No

4.10. Purchases in our webshop

Execution of an agreement – You can make digital purchases on our website. We process your personal data to complete your purchase (including arranging payment) and deliver the product/service to you.

This processing is done because it is necessary for the performance of the agreement.

  • What personal data do we process?
    • Identification and contact details
    • Financial identification data
    • Financial transactions
  • How do we obtain this personal data? Directly from you during the purchase process
  • How long do we keep them? We retain personal data for the duration of the processing and fulfilment of your order. Data that we are required to store in accordance with legal obligations, statutes or contractual retention requirements will be restricted rather than deleted to avoid being used for other purposes.
  • With whom may we share this personal data (other than affiliated and associated companies)? Processors we use to complete your purchase and deliver the product/service to you.
  • Do these activities involve automated individual decision-making? No
  • Do these activities involve transfers outside the EEA? No

4.11. Extra

Legal basis – explanation

  • What personal data do we process?
  • How do we obtain this personal data?
  • How long do we keep them?
  • With whom may we share this personal data?
  • Do these activities involve automated individual decision-making?
  • Do these activities involve transfers outside the EEA?

5. Sharing personal data with third parties

When you visit our website or use our products and services as a customer we may use third parties, such as partners, affiliated and associated companies and suppliers to whom we transfer your personal data as part of this process. These third parties help us provide, support, develop and understand the use of our products and services and provide services such as hosting, customer and technical support, marketing, analytics, content delivery and/or execution of online payment(s), among others.

In addition, we may also share data (including personal data) with third parties as part of a reorganisation, restructuring, merger, sale or other transfer of business assets. We share information provided by you, automatically collected information and information from others with these third parties to the extent necessary to enable them to provide their services or support. In the activities described above, we indicate for each activity the categories of third parties, other than affiliated and associated companies, with which we share your personal data.

Furthermore, we may have to provide access to your data or transfer your data because of a legal obligation. This to authorities, government agencies or other third parties.

Finally, we may pass on your data if this becomes necessary in the context of your vital interest.

6. Transfer of personal data outside the EEA

Hybridge always tries to limit the transfer of personal data to third parties outside the European Economic Area (“EEA”).

If this should nevertheless be the case, in this situation we will ensure as soon as possible that this transfer is brought into line with the AVG (by, among other things, the presence of an adequacy decision in the country concerned or the establishment of an appropriate alternative, additional measures if necessary, etc.).

We refer to the section “Why and how do we process your personal data?”) for specific transfers.

7. How long do we keep your personal data?

We will not retain your personal data for longer than strictly necessary to fulfil the purposes for which the personal data were collected or according to the legal obligation imposed on us. We refer to the section “Why and how do we process your personal data?”) for the specific retention period.

8. Automated individual decision-making

European data protection legislation (GDPR/AVG) imposes certain conditions on organisations when they make decisions about individuals solely on the basis of processing operations that are fully automated, including profiling, and when these decisions have legal effects or other significant consequences. Hybridge does not engage in this type of decision-making.

9. What are your rights and how can you exercise them?

Hybridge considers it important that you always retain control over the processing of your personal data. Below you will find more information on the various rights you have and can invoke in relation to the processing of your personal data:

Depending on the processing and the legal basis of that processing, certain conditions or restrictions may be attached to the exercise of the rights below.

To exercise the above rights, or information about them, please contact dpo@cronos.be. We will then also provide more information if there are certain modalities linked to your request. Furthermore, we may request additional information to verify your identity so that your personal data is not erroneously deleted or shared with someone who is not entitled to it. We will endeavour to respond to your request without unreasonable delay, but in any event within a period of one month from receipt of your request. If we cannot respond within one month and wish to extend the deadline, or if we will not act on the request, we will notify you.

9.1. Right of access:

Where we process your personal data, you have the right to access your personal data, as well as certain additional information as described in this privacy notice. You have the right to receive from us a copy of the personal data we hold, provided this does not adversely affect the rights and freedoms of others. The first copy will be provided to you free of charge, but in the event of repeated requests, we reserve the right to charge a reasonable fee.

9.2. Right of improvement:

If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information corrected or, given the purposes of the processing – completed.

9.3. Right to restrict processing:

You have the right to have the processing of your personal data restricted. This means that the personal data may only be stored by us and used only for limited purposes. This right applies if any of the following situations occur: 

  • You dispute the accuracy of the personal data, for a period of time that allows us to verify the accuracy of the personal data; 
  • The processing is unlawful but you oppose the erasure of the personal data and request instead that its use be restricted;
  • We no longer need your personal data for the processing purposes described above but you need it for the establishment, exercise or support of a legal claim; or,
  • You have objected to processing and asked us to restrict processing pending the answer to whether our interests outweigh yours. 

In addition to our right to store your personal data, we can still process it, but only: 

  • With your permission; 
  • For bringing, exercising or defending legal action; 
  • To protect the rights of another natural or legal person; or
  • For reasons of public interest. 

Before we lift the restriction on processing your personal data, you will be informed.

9.4. Right to data portability:

If the processing of your personal data is based on your consent, and the processing is carried out through automated processes, you have the right to receive a copy of your personal data in a structured, common and machine-readable form. You also have the right, where technically possible, to have your personal data transmitted directly by us to a third party. This right does not apply where this would infringe the rights and freedoms of others.

9.5. Right to object:

You have the right to object to the processing of your personal data in the activities described above. In the latter case, this is only possible if the activity is related to (1) the performance of a task in the public interest or in the exercise of a task in the exercise of public authority conferred on us or (2) the protection of our legitimate interests or those of a third party. 

If you object to the processing of your personal data, we will no longer process the personal data unless we can demonstrate legitimate interests for processing that outweigh your interests, fundamental rights and freedoms. 

If your personal data are processed for direct marketing purposes, regardless of whether this is initial or further processing, you have the right to object to such processing at any time and free of charge, including in the case of profiling insofar as it relates to direct marketing. If you raise such an objection, we will stop processing your personal data for this purpose.

9.6. Right to data erasure (right to oblivion):

You have the right to request us to delete your personal data. This means that the personal data must be deleted by us without unreasonable delay. This right applies if any of the following situations occur: 

 

  • Personal data are no longer needed for the purposes for which they were collected or otherwise processed; 
  • You withdraw your consent on which the processing is based, and there is no other legal basis for processing your personal data; 
  • Your personal data has been unlawfully processed; 
  • Erasure of your personal data is necessary to comply with European or Belgian law; 

If you ask us to delete your personal data, we will delete the personal data unless one of the following situations (exceptions) occurs: 

  • The processing is in the context of exercising the right to freedom of expression and information; 
  • Erasure is not an issue given public health reasons; 
  • Erasure is out of the question given the need for archiving in the public interest, or statistical purposes; 
  • There is a legal obligation to retain the data; or,
  • Erasure is not an issue given the institution, exercise or substantiation of an action. 

9.7. Right to withdraw your consent:

If you have given your consent to certain processing of your personal data, you can withdraw it at any time. We try to make withdrawing your consent as easy as possible and, as far as possible, as simple as giving your consent.

9.8. Right to oppose the processing of your personal data in automated individual decision-making:

If your personal data is used in the context of automated individual decision-making and if these decisions have legal effects or other significant consequences, you can ask us to stop using your data. If you oppose such processing, we will stop or restrict processing unless there are compelling reasons to do so.

10. Who can I turn to with further questions or any complaints around privacy?

If after reading this privacy statement you have further questions or comments regarding the collection and processing of your personal data, you can always contact us at the following e-mail address: dpo@cronos.be.

In addition, you have the right to submit any comments and observations or complaints to the supervisory authority responsible for data protection. You can do this in the EU member state where you reside, the place where you work or the place where the alleged breach took place. In Belgium, you can complain to the Data Protection Authority:

Data protection authority
 Rue du Printing Press 35, 1000 Brussels
 +32 (0)2 274 48 00
 www.gegevensbeschermingsautoriteit.be/burger/acties/klacht-indienen
 www. data-protection-authority.be

As we attach great importance to our mutual relationship, we ask that you always contact us first so that we can work out a solution to whatever is at the root of your complaint.

11. Amendments to the privacy statement

Our organisation and therefore our website are a dynamic and innovative environment. This privacy statement may be modified if our services or applicable legislation so require. This means that we are constantly looking to provide a better service tailored to you. It is possible that there will be new applications whereby we will collect or process your personal data in a different way. Naturally, we will inform you when there are important changes to this privacy statement, and we will ask your permission if necessary.

The following three forces are driving the adoption of Hybrid IT:

  • an enterprise’s need to maintain centralized control of data & applications for security purposes
  • the cost-effectiveness of cloud services (provided they are JIT (Just In Time))
  • and the desire for an IT department to respond as quickly as possible to rapidly changing business needs through the adoption of serverless/PAAS/SAAS solutions.
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