First of all, we are pleased that you are interested in Ottho CommV's products and services.

In this privacy statement, we inform you about how Personal Data is processed by us.

We may ask you to share certain Personal Data with us, including but not limited to your first name, last name and e-mail address (identifying information). Certain specific obligations may require you to provide us with additional data, such as payment and billing information.

We collect only the Personal Data necessary to inform you about our products and services, to perform a contract with you, and to contact you.

We base this on the contract processing grounds, legal obligation, our legitimate interest and, in some cases, your consent (see also Article 2).

The processing of your Personal Data is subject to this Privacy Statement. For questions and/or comments, please contact info@ottho.be.

Article 1 - Definitions

"Ottho CommV", trading under the name "OTTHO", a limited liability company under Belgian law, with its registered office at 2640 Mortsel (Belgium), Eduard Arenstraat 41 and registered in the Crossroads Bank for Enterprises with enterprise number 0798.114.317.

"Personal data" has the meaning defined in the General Data Protection Regulation 2016/679, which includes any information by which a natural person (also known as "data subject" or "data subject") is identified or can be identified.

"Controller" has the meaning defined in the General Data Protection Regulation 2016/679. Ottho CommV will be qualified as the Controller who determines the purposes and means of processing your Personal Data.

"Affiliated Company" means a company that is affiliated with Ottho CommV to the extent that it meets the conditions of an "affiliated company" within the meaning of Article 1:20 of the Belgian Companies and Associations Code.

"Processor" has the meaning as defined in the General Data Protection Regulation 2016/679, which processes Personal Data on behalf/on the instructions of the Controller.

"Website" means Ottho CommV's website: www.ottho.be

Article 2 - Processing purposes and legal grounds.

Customer information

As part of our services and operations, we collect and process the identity and contact data of our customers and clients, their staff and employees. The purposes for this processing are the performance of agreements with our clients, customer management, accounting and direct marketing activities such as sending promotional or commercial information. The legal grounds are the performance of the agreement, the fulfillment of legal and regulatory obligations (in particular accounting laws), our legitimate interest and, in some cases, your consent. 

Details of suppliers and subcontractors

We collect and process the identity and contact data of our suppliers and subcontractors, as well as their subcontractor(s), if any, their staff and employees. The purposes of this processing are the performance of the agreement, management of the suppliers/subcontractors and accounting. The legal grounds are the performance of the contract, the fulfillment of legal and regulatory obligations (in particular accounting laws) and/or our legitimate interest.

Staff data

We process the Personal Data of our employees as part of our personnel management and payroll processes.

Applicant data

We process applicants' identity and contact information as well as work history and other data commonly indicated on a curriculum vitae when they provide us with this information. The Personal Data are processed to investigate their eligibility for a job with us based on our legitimate interest.

If we wish to retain their Personal Data longer after the relevant vacancy has been filled, we will notify them and ask their permission to do so.

Other data

Besides the data of customers, suppliers/subcontractors, staff and job applicants, we also process Personal Data of others, such as potential new customers/prospects, useful contacts within our industry, network contacts, etc. This is done through our Website or through other channels. The purposes of this processing are in the interest of our operations, direct marketing and public relations. The legal basis is our legitimate interest, the performance of a contract and, in some cases, your consent. 

Very specifically, we may use the Personal Data we collect for the following purposes: 

(i) To provide you with information regarding our products and services;

(ii) to provide you with our products and services and to perform any agreements;

(iii) to process and handle possible complaints or requests;

(iv) to process your application;

(v) to help us evaluate, correct or improve the Website and all related Ottho CommV products and services;

(vi) for direct marketing purposes;

(vii) For internal reasons, including corporate records and archival purposes. 

Article 3 - The confidentiality of your Personal Data.

Whenever you provide Personal Data to us, we will treat that information in accordance with the provisions of this Privacy Statement and the legal obligations in the context of processing Personal Data, including the General Data Protection Regulation (GDPR) 2016/679.

We implement appropriate measures and procedures to secure and protect the Personal Data we collect. In this way, we are committed, to the extent reasonably expected, to preventing unlawful processing of Personal Data and accidental loss or destruction of your Personal Data.

We seek to optimize the security of your Personal Data by restricting access to your Personal Data to those with a need-to-know basis (e.g., only Ottho CommV and its employees, associates, Affiliates or subcontractors who need your Personal Data for the purposes described in Section 2 will have access to the data).

Article 4 - How do we collect your Personal Data and how long is it kept?

Collection of your Personal Information.

We collect your Personal Data - without being exhaustive - in the following cases:

(i) When you enter into an (employment) agreement with us;

(ii) when you complete the contact form provided on the Website;

(iii) when you communicate with us through the Facebook Messenger link provided on the Website (using your Facebook profile);

(iv) When you sign up on the Website to receive our newsletter;

(v) when you call, email or correspond with us in any way other than through the Website.

We avoid the collection of Personal Data that is not relevant to the purposes set forth in Article 2.

We may combine the Personal Data we collect with information provided to us by third parties.

 Retaining your data

The Personal Data will be kept and processed by us for a period necessary in function of the purposes of processing.

Customer data and data of suppliers or subcontractors will in any case be deleted from our systems after a period of 7 (seven) years after the termination of the agreement, except in the case of an ongoing dispute for which the Personal Data is still necessary. 

Personnel Personal Data will be deleted immediately after the termination of the employment relationship, except with respect to Personal Data that we are required to retain for a longer period of time based on specific legislation or in the case of an ongoing dispute for which the Personal Data is still necessary.

Personal data of job applicants will be deleted after the relevant vacancy has been filled or after a period of 2 (two) years after consent has been obtained to notify applicants about future job opportunities.

Other data will not be kept longer than a period of 2 (two) years after the last meaningful contact with you, except in the case of an explicit consent to keep this data longer.

Article 5 - Transfer of Personal Data.

We will not transfer Personal Data to third parties located outside the European Economic Area, except to subcontractors or associates who have undertaken to comply with the European Commission's Standard Contractual Clauses and thereby provide an adequate level of security for the processing of Personal Data.

We will further not transfer Personal Data to other parties located within the European Economic Area except with your consent, unless:

(i) the transfer is necessary to permit employees, agents or subcontractors to provide a service or perform a task on our behalf that is necessary for the performance of the agreement we have with you or within the scope of our legitimate interest (including but not limited to providing marketing support, to conduct market research or provide customer service);

(ii) this is required by law.

Any transfer of Personal Data to a recipient as listed above is in accordance with the provisions of the General Data Protection Regulation 2016/679.  

We ensure that measures are taken so that the recipients cannot use the Personal Data for purposes other than those exhaustively listed in Article 2 and that the recipients have taken sufficient technical and organizational measures to protect these data.

In order to ensure the security of Personal Data, we will always enter into a processor agreement with the aforementioned recipients of Personal Data. 

We will take all necessary precautions to ensure that employees and associates who have access to Personal Data process it only in accordance with this Privacy Notice and the legal obligations under the General Data Protection Regulation 2016/679.

Article 6 - Rights of the data subject.

Pursuant to both Belgian and European legislation on the protection of Personal Data, you have the rights described below. If you wish to exercise these rights, you should send us a written request accompanied by a copy of the front of your identity card to info@ottho.be.

We will inform you of the action that will be taken within 1 (one) month of receiving the request. This period may be extended to a maximum of 3 (three) months, in which case you will be informed of the reasons for this delay within 1 (one) month from the original request.

The right to access Personal Data

You have the right to instruct us to disclose any Personal Data we hold about you, provided that the rights of other data subjects are not affected.

The right to rectification of Personal Data.

We kindly ask you to ensure that the Personal Data in our database is as accurate and complete as possible. If you believe that the information provided to us is incorrect or incomplete, please inform us as described above. We will then correct or supplement your Personal Data as soon as possible.

Right to erase Personal Data
You have the right to erase your Personal Data without undue delay in the following cases:

(i) if it is no longer necessary to retain the Personal Data in relation to the purposes for which it was
collected or otherwise processed;

(ii) in case of withdrawal of consent for consent-based processing;

(iii) processing intended for direct marketing; and

(iv) if the Personal Data was processed unlawfully.

However, there are certain general exclusions to the right to erasure. Those general exclusions include cases where processing is necessary:  

(i) for exercising the right to freedom of expression and information;

(ii) for compliance with a legal obligation; or

(iii) for bringing, exercising or defending legal claims.

Right to restrict processing of Personal Data
In the following cases, you have the right to restrict the processing of your Personal Data:

(i) for challenging the accuracy of your Personal Data;

(ii) where the processing is unlawful, but you do not want the Personal Data to be deleted; or

(iii) if you object to the processing of your Personal Data, pending verification of that objection.

If processing is restricted on this basis, we may continue to store your Personal Data. However, we will only process the data with your express consent for the establishment, exercise or defense of legal claims, to protect the rights of another natural or legal person or for reasons of substantial public interest.

The right to object

You have the right to object to our processing of your Personal Data in the following cases:

(i) if we process your Personal Data for direct marketing purposes (including profiling for these
purposes) based on our legitimate interest; and

(ii) because of your specific situation (your particular personal circumstances).

The right to data portability ("data portability")

 If you wish to exercise your right to data transfer, we will transfer the Personal Data in a structured, common and machine-readable form to a data controller of your choice.

The right to withdraw consent

To the extent that the legal basis for our processing of your Personal Data is your consent, you have the right to withdraw this consent at any time. However, this withdrawal will not affect the lawfulness of the processing that took place before the withdrawal.

The right to complain to a supervisory authority

You may contact the Data Protection Authority at any time by sending an e-mail to contact@apd-gba.be or by sending a written request to the Data Protection Authority, located at 1000 Brussels (Belgium), Press Street 35.

Article 7 - Referral to third parties

The Website may contain links to other websites not operated by us, such as Facebook, Instagram and Soundcloud. While we make every effort to ensure that the links lead only to websites that have corresponding security and confidentiality standards, we are in no way responsible for the protection and confidentiality of Personal Data, including the data you provide on other websites, after you leave the Website.

We emphasize to be careful and always consult the privacy statement applicable to the website in question before providing personal data on other websites.

Article 8 - Modifications 

We have the right to modify this privacy statement at any time by posting a new version of it on our Website.
We encourage you to check the Website on a regular basis to verify your agreement to any changes to this privacy statement.

In any event, you will be notified by email of any changes to this privacy statement to the extent we have your email address.

Article 9 - Cookies

Ottho CommV uses "cookies" each time you use the Website. A "cookie" is information sent through the server to your device and stored on the device's hard drive. Cookies help Ottho CommV recognize your device when you use the Website. This enables Ottho CommV to make the processing more user-friendly and to provide you with a personalized service.