Privacy Policy

PRIVACY POLICY

1. INTRODUCTION

Act&Sorb BV, referred to in this Policy as “Inventinc.”, “we”, “us” and “our” respects your privacy. Whether you deal with Inventinc as a customer, a consumer, a member of the general public, etc., you are entitled to the protection of your Personal Data.

In this General Privacy and Data Protection Policy (“this Policy”) we describe how we collect your Personal Data and why we collect it, what we do with your Personal Data, with whom we share it, how we protect it, and the choices you can make about your Personal Data.

This Policy applies to the processing of your Personal Data in the framework of various services, tools, applications, our website www.inventinc.be (“Website”), portals, marketing actions, (online) sales promotions, etc. that are provided or operated by us or on our behalf.

We recommend you carefully read this entire Policy to ensure you are fully informed. If you accept the provisions of this Policy, you are agreeing to us processing your Personal Data in the ways that are set out in this Policy.

2. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

The legal entity which is responsible for the processing of your Personal Data and acts as data controller is:

Act&Sorb BV
Geleenlaan 31
3600 Genk
Belgium
BE 0652 775 158

3. WHO CAN YOU CONTACT IN CASE YOU HAVE QUESTIONS OR REQUESTS?

For any questions, requests or complaints concerning this Policy or to exercise your rights, as described in this Policy, you may contact us at:

· Via our online contact form

· Or via e-mail: privacy@inventinc.be

4. WHICH PERSONAL DATA DO WE PROCESS

The Personal Data that we may process can be either in the context of (i) when you visit our Website or (ii) when you engage with us in relation to our business and (iii) when you apply for a job opening.

The Personal Data that we may process about you when you visit our Website is the following:

· Personal Data you provide us voluntarily through our Website (via our contact form). The information that we

may collect could include your surname, name, email address, phone number, company, information pertinent
to fulfilling our business to you and any other information you may voluntarily provide us.

·        Personal Data that we may collect automatically, such as your IP-address, device type, browser-type,
     geographic location (country or city), other technical information and how you interact on our Website.
   This allows us to improve the quality and relevance of our Website.

The Personal Data that we may process when you engage with us in relation to our business is the following:

· Basic information (e.g. name, company, role/position);

· Contact information (e.g. address, email address, telephone/mobile number);

· Financial information (e.g. payment related information);

· Any other information which you provide to us for the purpose of our business.

The Personal Data that we may process when you apply for a job opening is the following:

· Basic information (e.g. name, current role/position, CV, identification documents, educational history);

· Contact information (e.g. address, email address, telephone/mobile number);

· HR related information (e.g. employment history, references, salary);

· Any other information which you provide to us in the framework of the recruitment process.

We usually collect Personal Data directly from you when you apply for a job opening with us, but may also collect Personal Data about you from third parties, such as professional recruiting firms, your references, prior employers and Sibelco employees with whom you have interviewed, but also from publicly available resources online (e.g. LinkedIn). Your Personal Data may be passed to the relevant hiring managers and persons involved in the recruiting process.

Whenever we require any additional Personal Data (not described above), we will clearly inform you the reasons why you are asked to provide it at that point that you are asked to provide said Personal Data.

5. LEGAL GROUNDS OF PROCESSING PERSONAL DATA

The legal basis for which we process your Personal Data described above depends on the applicable Personal Data and the specific context in which we process it.

Please note that in accordance with applicable data protection law, your Personal Data can be processed if:

·        you have given us your consent for the purposes of the Processing (as described in the privacy notice related
     to that particular Processing). For the avoidance of doubt, you will always have the right to withdraw your
     consent at any time; or

· it is necessary for the performance of a contract to which you are a party; or

· with such Processing, we pursue a legitimate interest that is not outbalanced by your privacy rights.
Such legitimate interest will be duly communicated to you at the relevant time; or

· it is required by law.

6. FOR WHICH PURPOSES WE PROCESS YOUR PERSONAL DATA

We will only process your Personal Data for specified, explicit and legitimate purposes and we will not process your Personal Data further in a way that is incompatible with those purposes.

Such purpose can be the execution of an order you have placed, the improvement of your visit on one of our Websites or portals, the improvement of our products and services more generally, the offering of services or applications, marketing communications and actions, etc.

The purpose of each Processing of your Personal Data will be clearly defined at the relevant time.

7. HOW LONG DO WE KEEP YOUR PERSONAL DATA

We will keep your Personal Data in a manner consistent with applicable data protection law. We will only keep your Personal Data for as long as necessary for the purposes for which we process your Personal Data or to comply with the law. For information on how long certain Personal Data is likely to be kept before being removed from our systems and databases, please contact us.

8. PROTECTING YOUR PERSONAL DATA

We have a set of technical and organizational security measures in place to protect your Personal Data against unlawful or unauthorized access or use, as well as against accidental loss or damage to their integrity. They have been designed taking into account our IT infrastructure, the potential impact on your privacy and the costs involved and in accordance with current industry standards and practice.

Your Personal Data will only be processed by a third party Data Processor if that Data Processor agrees to comply with those technical and organizational data security measures.

9. DISCLOSURE OF PERSONAL DATA

Depending on the purposes for which we collect your Personal Data, we may disclose it to the following categories of recipients, who will then process your Personal Data only within the framework of these purposes:

a) Within our organization: our authorized staff members; and/or companies within Act&Sorb BV;

b) Third party business partners:

· Advertising, marketing and promotional agencies: to help us deliver and analyse the effectiveness of our
advertising campaigns and promotions;

·        Service providers of Inventinc. : companies that provide services for or on behalf of Inventinc,
     for the purposes of providing such services (for example, Inventinc may share your Personal Data with
   external providers of IT related services);

c) Other third parties:

· when required by law or as lawfully necessary to protect Inventinc.:

o to comply with the law, requests from authorities, court orders, legal procedures, obligations related to the
reporting and filing of information with authorities, etc.;

o to verify or enforce compliance with Inventinc. policies and agreements; and

o   to protect the rights, property or safety of Inventinc. and/or its customers;
   o   in connection with corporate transactions: in the context of a transfer or divestiture of all or a portion of its
business, or otherwise in connection with a merger, consolidation, change in control, reorganisation or
   liquidation of all or part of Inventinc. business.

Please be aware that third party recipients listed under points b) and c) above – especially service providers who may offer products and services to you through Inventinc. services or applications or via their own channels – may separately collect Personal Data from you. In such case, these third parties are solely responsible for the control of such Personal Data and your dealings with them will fall under their terms and conditions.

10. TRANSFERS OUTSIDE THE EEA

Your Personal Data may be transferred to recipients which may be outside the EEA, and may be processed by us and these recipients outside the EEA. In connection with any transfer of your Personal Data to countries outside the EEA that do not generally offer the same level of data protection as in the EEA, Inventinc. will implement appropriate specific measures to ensure an adequate level of protection of your Personal Data.

These measures can for instance consist of agreeing with these recipients on binding contractual clauses guaranteeing such adequate level of protection.

11. YOUR CHOICES AND YOUR RIGHTS

We want to be as transparent as possible with you, so that you can make meaningful choices about how you want us to use your Personal Data:

· If you wish to access, correct, update or request deletion (except in some cases, for example, to prove a
transaction or when required by law) of your Personal Data you can do so at any time by contacting us;

· If you wish to object to the processing of your Personal Data, restrict the processing of your Personal Data or
request portability of your Personal Data you can do so at any time bycontacting us;

·        If you wish to object to the use of your Personal Data for direct marketing purpose (if you prefer, you can also
     indicate to us through which channel and how frequently you prefer to be contacted by us) we send to you at
     any time. You can do so by using the “unsubscribe” link in the marketing e-mail we send you. To opt-out of other
   forms of marketing purposes you can do so at any time by contacting us;

· You may withdraw your consent at any time to the continued Processing of the Personal Data that you have
provided to us by contacting us;

· You have the right to file a complaint against the Data Controller with a data protection authority about our
Processing of Personal Data (See Data Protection Authority Examples).

12. LEGAL INFORMATION

The requirements of this Policy supplement, and do not replace, any other requirements existing under applicable data protection law. In case of contradiction between what is written in this Policy and requirements in applicable data protection law, applicable data protection law will have priority.