Privacy Policy

Last modified on 9 June 2017.

First of all, we are excited that you are interested in Spencer (the “Application”). We undertake and ensure the protection of your Personal Data when you are using the Application.

To use the Application you will need to log in with your company credentials. As you log in, the Application will obtain certain Personal Data. This may include, but is not limited to, your first name, last name, e-mail address, department, job title, office location, phone number, etc. (the “Personal Data”).

If you do not wish to share any Personal Data with RECNEPS and your Employer, you will not be able to use the Application and we suggest you do not log in.

This privacy policy describes how we use the Personal Data you provide us with whilst using the Application. In case you have questions or remarks concerning this policy, we invite you to contact us at support@spencer.co.

By using the Application, you are deemed to have approved the use of your Personal Data in accordance with this privacy policy.

1. Definitions

“Affiliated Company” means a company that is connected to the Employer or RECNEPS, such as, for example but not limited to, their subsidiary companies.

“Application” means custom software consisting of an intelligent cloud layer that connects to existing enterprise solutions to unify fragmented processes, in the form of a user-friendly application called “SPENCER”.

“Employer” means the company you are working for, controller of the Personal Data you provide us with and licensee of the Spencer application.

“RECNEPS” means NV RECNEPS with its registered office situated at 2000 Antwerp, Kammenstraat 18 and registered in the Belgian Crossroad Bank for Enterprises with number 0667.513.616, processor of the Personal Data you provide us with and licensor of the Spencer application.

“Personal Data” means all information, currently in the possession of the Employer, allowing the identification of an individual. Such as, without being exhaustive, your name, telephone number, e-mail address, company id.

2. The confidentiality of your Personal Data

Every time you as a user submit Personal Data, we shall handle this information in accordance with the stipulations of this privacy policy and any legal obligations applicable to the processing of Personal Data.

We undertake and ensure to protect your Personal Data protected accordance with any and all applicable laws, as well as with the undertakings laid down in this privacy policy. We shall establish appropriate procedures to secure and protect the data we collect via the Application or via electronic correspondence.

In this way, we undertake to prevent illegal processing of Personal Data and unintentional loss or liquidation of your Personal Data. Despite these precautions, we cannot guarantee that your Personal Data is protected when it gets displayed or reported in another way via unsecured means.

We optimize the security of your Personal Data by limiting the access to your Personal Data to persons on a “need-to-know” basis (for example: only Employer or RECNEPS employees or associates who need your data for the purposes as described here below shall receive permission to access the data).

3. Bron van de persoonsgegevens

3.1. Het HA verwerkt naast de persoonsgegevens die zij rechtstreeks van jou verkrijgt, ook persoonsgegevens die afkomstig zijn van een andere bron, namelijk Active directory (Directory service van Microsoft waarin onze gebruikersaccounts worden beheerd), Oracle Internet Directory (Directory service van Oracle waarin onze gebruikersaccounts voor interne en externe toepassingen worden beheerd), Sesam en Apollo

4. How do we collect your Personal Data?

We collect your Personal Data as follows:

• When you log in to the Application;
• When you change your profile data afterwards;
• When you access and use the Application;
• When you file a complaint or ask for information;
• When you call or mail us or correspond with us via another way than the Application;
• When you share Personal Data with us voluntarily in any other way.

We can combine the Personal Data we collect via the Application with information which you provide us in another way or which third parties deliver to us. We can retain this information in a combined database or in several separate databases.

We will store and process your Personal Data no longer than necessary for the desired purpose, as listed below, or for the period as determined in an eventual agreement or by law.

We shall delete or correct Personal Data on your (written) request, if you provide us with a copy of your ID card in accordance with the provisions of section 6 below.

We avoid the collection of Personal Data which are not relevant for the purposes set out in section 4.

5. To whom do we report your Personal Data?

We will not provide your Personal Data to third parties without your permission, except:

• To Affiliated Companies;

• When these data are necessary to permit employees, agents, subcontractors, suppliers or commercial partners to provide a service or accomplish a task in the framework of the product agreement between RECNEPS and the Employer (including providing marketing support, accomplish market research or providing customer services);

• If it is necessary to pursue our legitimate interests or if this is required by law.

As a user you acknowledge that all information published in the Application is made available to you by your Employer and should be treated confidentially. Should your Employer allow you to publish information in the Application, you acknowledge that that information, might become visible to other persons within the organisation of your Employer. Taking this into consideration it is important that you use your common sense and take precautionary measures concerning the information you place on the Application and you acknowledge to know and agree that the concerning information will be published in such a way that other users within the organisation of your Employer have access to it.

Every distribution of your Personal Data to one of the third parties mentioned in the list above, is in accordance with the stipulations of the privacy legislation and Belgian privacy laws and regulations. We ascertain that stipulations are foreseen to make sure that third parties cannot use your Personal Data for other purposes than and according to the purposes mentioned in section 4, and that these third parties have assembled the necessary security measures.

We will have agreements in place with the aforementioned third parties in order to ensure the security of the data.

If we report your Personal Data to an Affiliated Company or to third parties with registered offices outside the EEA, we shall not share these Personal Data until measures are taken to ensure that your Personal Data has the same level of protection as within the EEA.

We shall take all necessary precautionary measures to assure that our employees and associates who have access to Personal Data will process these Personal Data exclusively in accordance with this policy and our obligations under the privacy regulations.

6. Access to and correction of your Personal Data

By virtue of both Belgian and European legislation concerning data protection, you have the right to ask us for details concerning the Personal Data we can access and make corrections if necessary, or to have them deleted all together.

If you wish to do this, you can send an e-mail to the following address support@spencer.co.

You can also consult the public register for automated data processing by sending a mail to commission@privacycommission.be or by sending a written request to the Privacy Commission, situated at Drukpersstraat 35, 1000 Brussels.

We kindly ask you to help to make sure that the Personal Data in our records are as accurate and up-to-date as possible. If you believe that the Personal Data submitted to us are incorrect or incomplete, please notify our customer service as described above. We will correct or adapt your Personal Data as soon as possible.

7. Third Party Links

The Application may contain links to other websites which are not controlled by us. Although we will do our utmost to make sure that the links on the Application lead exclusively to websites which share our safety and confidentiality standards, we are not responsible for the protection and confidentiality of data, among which Personal Data, which you submit on other websites after you have left the Application. Before submitting personal information on other sites we recommend that you proceed carefully and consult the privacy statement which applies on the website concerned.

8. Cookies

We might use “cookies” whenever you make use of the Application. A “cookie” is information that is sent via the server to your internet browser or application and that is stored on the hard drive of your device. Cookies can help us to identify your device whenever you use the Application. That way we can make the Application more user friendly and offer you a personalized service. You can decide to refuse the use of cookies if your internet browser or application provides this as an option, but said refusal could impact the use of the Application severely.