Privacy Policy
1. Identity and contact information of the data controller
This privacy policy applies to all personal data processed by Ingenium NV, with its registered office at Nieuwe Sint-Annadreef 23, 8200 Bruges, and company number/VAT BE 0436.815.150, which is the data controller for this website and for the processing activities described below.
The Data Controller attaches great importance to your privacy and therefore processes your personal data in accordance with European Regulation 2016/679 of April 27, 2016, on the protection of natural persons with regard to the processing of personal data (hereinafter “GDPR”), as well as any future or supplementary legislation implementing it, to the extent applicable.
If you have any further questions or comments regarding how we handle your personal data, please feel free to contact us at any time, either by email at info@ingenium.be or by mail at the address listed above.
2. What does “processing personal data” mean?
The processing of personal data (hereinafter “data”) includes any processing of data that can identify you as a natural person. You can read about what data is involved in this Privacy Policy. The term “processing” is very broad and covers, among other things, the collection, storage, and use of your data, or the sharing of your data with third parties.
3. What data do we process?
Below, we explain what personal data we may process about you. Depending on the specific situation, your preferences, and how you contact us, we may not process all of the personal data listed below.
Customers and business contacts
We may process the following data from our customers, clients, architects, contractors, and other business contacts:
- Identification information (last name, first name, job title, organization);
- Contact information (email address, phone number, mailing address);
- Contractual information (agreements, quotes, orders);
- Payment and billing information;
- Project-related communication (emails, memos, reports, plans);
- Contact history (email messages, messages sent via web forms, phone calls);
- Feedback, testimonials, and promotional content (e.g., testimonials, event appearances, photos).
Visitors to our locations
- Footage from security cameras (for monitoring and surveillance of our company buildings);
- Registration information for accessing secure sites (e.g., a copy of an ID card for accessing government or defense infrastructure, if required by law).
Job Applicants
We process the following information about job applicants, depending on what information you choose to provide to us:
- Identification information (last name, first name, date of birth);
- Contact Information;
- Employment-related information (resume, cover letter, diplomas, work experience, preferred office location);
- Results of assessments (abstract reasoning, personality test, motivation test), only at an advanced stage of the selection process;
- Photos, if voluntarily provided.
Website visitors
- Electronic identification and usage data (IP address, browser type, pages visited, time of visit);
- Cookie data (see also our Cookie Policy on the website).
4. For what purposes do we process your data?
We process your data for the purposes described below and do not collect or process any data other than what is necessary for these purposes.
Personal data is processed exclusively within the scope of the company’s activities, specifically for the following purposes:
- Provision of our services: providing consulting and engineering services in the areas of project management, structural engineering, and energy efficiency measures;
- Customer and Business Relationship Management: communication with customers, clients, architects, contractors, and other business contacts;
- Billing and administration: processing payments and complying with accounting obligations;
- Compliance with legal obligations: tax and social security obligations, compliance with security regulations (e.g., access to government or defense sites);
- Marketing and communication: sending newsletters, invitations to events or webinars, and promoting our services via social media (LinkedIn, Facebook, Instagram) and email marketing;
- Recruitment: processing job applications and conducting selection procedures for new employees;
- Human Resources Management: payroll, time tracking, employee evaluations, and training;
- Security: monitoring of our company buildings via camera systems and access control;
- Records Management and Liability: Maintaining project-related communications and documentation in the context of the ten-year liability period in the construction industry;
- Improving our website and services: analyzing website usage via Google Analytics.
5. On what legal grounds do we process your data?
We process your data only to the extent that such processing is based on one of the legal grounds for processing listed in the GDPR, as set forth below.
Legal obligation
We process certain data to comply with legal or regulatory obligations that apply to us, such as tax and accounting obligations, social security obligations, or security regulations governing access to government or defense infrastructure.
Necessary for the performance of the agreement
We process certain data because it is necessary for entering into, performing, or terminating a contract with you as the data subject. For example, to contact you, schedule appointments, respond to a request, or request information in connection with entering into a contractual relationship, as well as to effectively carry out the contractual assignment as part of our core business, in order to provide you with our services or to receive services from you.
Legitimate Interest
We process certain data based on our legitimate interest, which in specific cases outweighs any potential infringement of your rights. For example, to promote our activities to business contacts; to improve the quality of our services; to train employees; and to evaluate and maintain data and statistics related to our activities, in the broadest sense; to retain and use evidence in the context of liability, legal proceedings, or disputes, and for the purpose of archiving our activities; and to ensure security, both online on this website and at our business premises.
Consent
We process certain data based on your consent. For example, to promote activities to potential business contacts; to use certain analytical or marketing cookies; and to post photos containing personal data on our website and social media channels. Data from job applicants will only be retained after the recruitment process with your consent.
6. Source of the data
We have obtained most of the data we process directly from you, through our website, by phone, via email, through contracts, job application forms, or your participation in events and job fairs. As part of our services, we may obtain data about you from third-party service providers (e.g., recruitment agencies), public sources (e.g., KBO), or professional platforms (e.g., LinkedIn).
7. Who do we share your information with?
We do not share your information with third parties, unless it is strictly necessary for the purposes mentioned above, or if we are legally required to do so.
Where necessary, we engage external service providers (processors) to support our operational purposes, such as the management of our websites and IT systems. These external service providers may, where applicable, carry out certain data processing activities on our behalf. We will only share your data with these external service providers to the extent necessary for the specific purpose. They are not permitted to use the data for any other purposes. Furthermore, these service providers are contractually obligated to ensure the confidentiality of your data through a “data processing agreement” entered into with them.
Specifically, this means that we share your data—to the extent it is relevant to your situation—with the following third parties for the following purposes, with these third parties acting as data processors on our behalf in certain cases:
- Postal services, transportation, and delivery companies, if we need to send you something by mail;
- Payment service providers, if we receive payments from you, or vice versa;
- External representatives and consultants, or any other parties involved in connection with our primary or secondary activities;
- The processors who assist us with IT matters in the operation of our organization, with a view to ensuring secure and efficient digital data management within our organization;
- Government agencies, judicial authorities, and members of regulated professions such as accountants and attorneys, for the purpose of complying with our legal obligations and defending our interests, to the extent required.
8. How long do we retain your data?
We do not retain your data longer than is necessary for the purpose for which it was collected or is being processed. Since the period for which data may be retained depends on the purposes for which it was collected, the retention period may vary in each situation. In some cases, specific laws may require us to retain the data for a certain period. Our retention periods are always based on legal requirements and a balance between your rights and expectations and what is useful and necessary to fulfill the purposes. Once the retention period has expired, your data will be deleted or anonymized.
Our main retention periods are:
- Client and project data (including project communications): 10 years after the project is completed (10-year liability period in the construction industry)
- Accounting and tax records: 7 years (legal requirement)
- Contractual documents: 10 years after the termination of the agreement
- Data on unsuccessful applicants: Until the end of the hiring process, unless consent was given for longer retention
- Security camera footage: Up to 30 days, unless an incident warrants longer retention
- Marketing Information: As long as you do not unsubscribe or withdraw your consent
- Cookie data (analytics/marketing): In accordance with the Cookie Policy on our website
9. Where do we store your data, and how is it protected?
We implement appropriate technical and organizational security measures to prevent, within the scope of our activities, the destruction, loss, falsification, alteration, unauthorized access, or unlawful disclosure to third parties of this data, as well as any other unauthorized processing of this data.
In addition, we also ensure that the processors we engage implement appropriate security measures to minimize the risk of incidents as much as possible.
The data we process remains within the European Economic Area (EEA) at all times.
If your data is processed outside the European Economic Area (EEA) when you use specific services or software tools, this will occur exclusively in or to countries that the European Commission has confirmed provide an adequate level of protection for your data, or measures will be taken to ensure the lawful processing of your data in these third countries.
10. What are your rights?
You have various rights regarding the data we process about you. If you wish to exercise any of the following rights, please contact our GDPR Officer using the contact information provided under the first section of this Privacy Policy.
Right to Access and Copy
You have the right to access your data and receive a copy of it. This right also includes the ability to request further information regarding the processing of your data, including the categories of data being processed and the purposes for which this is done.
Right to Amendment or Correction
You have the right to have your information corrected if you believe that the information we have is incorrect.
Right to Data Erasure (Right to Be Forgotten)
You have the right to request that we delete your data without undue delay. However, we will not always be able to comply with such a request, including when we still need the data in connection with an ongoing agreement, or when we are legally required to retain certain data for a specific period of time.
Right to Restriction of Processing
You have the right to restrict the processing of your data. This means that processing will be temporarily suspended until, for example, the accuracy of the data has been verified.
Right to Withdraw Your Consent
If the processing is based on your consent, you have the right to withdraw that consent at any time by contacting us. For marketing messages you receive from us via email based on your consent, you can easily withdraw your consent by clicking the unsubscribe link at the bottom of such a message.
Right to Object
You have the right to object to the processing of your data based on legitimate interests. This must be done on the basis of specific reasons related to your situation. You may also object to the use of your data for direct marketing purposes. Marketing messages sent by email will always include an opt-out option.
Right to Portability
You have the right to receive, in electronic form, the data you have provided to us with your consent or in fulfillment of a contract. This makes it easy to transfer that data to another organization. You also have the right to request that we transfer your data directly to another organization, if this is technically feasible.
Right to file a complaint with your supervisory authority
If you believe that we are processing your data in an improper manner, you always have the right to file a complaint with your data protection supervisory authority.
Belgian Data Protection Authority (GBA)
35 Drukpersstraat
1000 Brussels
contact@apd-gba.be
11. How can you exercise your rights?
You can exercise your rights by contacting us, either by email at info@ingenium.be or by mail at Nieuwe Sint-Annadreef 23, 8200 Bruges, provided you include a copy of the front of your ID card or another document that can be used to identify you. The copy will be used solely to verify your identity in accordance with the GDPR.
12. Changes
We reserve the right to amend this Privacy Policy. The most recent version is always available on our website. The date on which this Privacy Policy was last amended is listed at the top. In the event of a substantial change to the Privacy Policy, we will, if possible, directly notify the individuals who may be affected.