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  1. Definitions

    • Personal data : all information about an identified or identifiable natural person. An identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more elements characteristic of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

    • VACA : VACA cv recognized as SO, with registered office at 8400 Ostend, Zeedijk 330, registered in the Crossroads Bank for Enterprises under number BE 0461.255.289, RPR Gent, Ostend Department;Tel: +32 (0)78 156 100E-mail :

    • Processing : an operation or a set of operations relating to personal data or a set of personal data, whether or not carried out via automated procedures, such as collecting, recording, organising, structuring, storing, updating or changing, retrieving, consulting, use, provide by transmission, dissemination or otherwise make available, align or combine, shield, erase or destroy data.

  2. Object

    • This Privacy Policy contains the terms and conditions that apply to the processing of the personal data that you provide to VACA.

  3. What personal data does VACA keep?
    The following personal data is kept:

    • Identification data (name, address, telephone number, ...)

    • Financial details

    • Personal characteristics (age, gender, marital status, ...)

    • Physical data (size, weight, ...)

    • Family composition

    • Education and training

    • Occupation and position

    • Image recordings (camera surveillance)

    • National register number/social security identification number

    • Membership of a trade union, trade union or similar group (with the explicit consent of the person concerned)

  4. For what purposes are your personal data used?
    Your personal data is kept for the following purposes:

    • Execution or conclusion of (an) agreement(s)

    • direct marketing

    • Relationship management (customers (CRM) and/or suppliers)

    • HR

    • Website and/or application(s)

    • E-commerce

  5. What does VACA do with your personal data?

    • VACA takes the protection of your privacy and personal data seriously. It has therefore already taken all the initiatives it deems necessary to comply with the current privacy legislation, in particular the Act of 8 December 1992 on the protection of privacy with regard to the processing of personal data" (hereinafter referred to as the "Privacy Act"). its implementing decrees, their amendments and as recently updated and to be amended pursuant to the General Data Protection Regulation* (hereinafter referred to as “GDPR”)

      • *Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)

    • VACA undertakes to follow this legal framework and, where necessary, to take additional measures and to implement adjustments as a result of its updating. The personal data requested by VACA are therefore always limited to those data that we deem necessary and sufficient for the correct performance of our services. We strive to ensure that the personal data processed by us is correct and that it is updated in the event of changes. Your data will always be kept for a specific period of time, depending on our services and/or the legal requirements that VACA must comply with. Finally, we guarantee adequate protection (including by means of encryption) against unauthorized or unlawful processing and against accidental loss, destruction or damage to your personal data, depending on the state of the art and the sensitivity of the data concerned.

  6. Lawfulness of processing (Opt-In)

    1. VACA will only process your personal data if you give your permission for this with regard to one or more specific purposes mentioned above, if the processing of your personal data is necessary for the execution of the services you request from VACA (processing in the context of the execution of an agreement), or when VACA can invoke a legitimate interest in doing so, provided that your interests or fundamental rights and freedoms do not prevail. For direct marketing purposes (facebook/instagram/googleads), VACA will always ask for your explicit permission for the use of your personal data. requests. Your subscription to the newsletter and cognizance of the privacy policy are sufficient for this. Notwithstanding your consent, you have the right to object at any time to the processing of your personal data for direct marketing purposes.

    2. If you change your mind after opting in, you can withdraw your consent to the further processing of your personal data at any time by contacting us at or by sending your request to the following address: VACA cv recognized as so - Zeedijk 330 - B8400 Ostend.

  7. Your rights

    1. VACA strives for transparency regarding the processing of your personal data. When VACA processes your personal data, you can request us to be informed about this in a concise and clear manner. In that case, you have the right to request VACA to inspect, rectify or delete your personal data, or to restrict the processing concerning you. You can also object to the processing of your personal data and you have a right to data portability.

    2. Right of access

      • the processing purposes

      • the categories of personal data concerned

      • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations

      • if possible, the period for which the personal data is expected to be stored, or if that is not possible, the criteria for determining that period

      • where we did not obtain your personal data directly from you: the available information about the source of your personal data. If you request more than one copy, we reserve the right to charge an administrative fee.

      • When we process your personal data, you have the right to inspect this data and you can also request the following information from us:

    3. Right to improvement.
      If you determine that the personal data processed by us is incorrect or incomplete, you can request us to make the necessary improvements or additions.


    4. Right to be forgotten

      • Your personal data are no longer necessary for the purposes for which they were collected or otherwise processed by VACA

      • You withdraw your consent to the processing of your personal data and there is no other legal basis on which VACA can process your personal data

      • You object to the processing of your personal data due to a situation specific to you, unless VACA invokes compelling legitimate grounds for the processing that outweigh your interests, rights and freedoms or that are related to the establishment, exercise or defense of a legal claim

      • Your personal data has been unlawfully processed

      • Your personal data must be erased to comply with a legal obligation resting on VACA.

      • You have the right to require VACA to delete the personal data we process about you, but only in one of the following cases:

    5. Right to restriction of processing

      • When you dispute the accuracy of your personal data, for a period that allows VACA to verify the accuracy of your personal data

      • The processing would take place unlawfully, but you do not want your personal data to be deleted

      • VACA no longer needs your personal data for the processing purposes, but you need it yourself for the establishment, exercise or defense of legal claims

      • You object to the processing of your personal data due to a situation specific to you, pending the answer to the question whether VACA's legitimate grounds override your interests, rights and freedoms or are related to the establishment, exercise or substantiation of a legal claim.

      • A restriction of your personal data will result in it being marked by VACA with the aim of limiting its processing in the future. In certain cases, you can request VACA to restrict the processing of your personal data, in particular:

    6. Right to portability of your personal data

      • The processing of the personal data is based on your consent or the processing is necessary for the execution of the agreement

      • The processing is carried out via automated processes. Both the aforementioned conditions must be met. If this is not the case, you are not entitled to transferability.

      • In certain cases, you have the right to obtain the personal data concerning you, which you have provided to VACA, in a structured, commonly used and machine-readable form, and you have the right to transfer that data to another controller. This concerns the following cases: Finally, the right to portability must not affect the rights and freedoms of others (e.g. if the data concerns more than one data subject). VACA reserves the right to refuse transferability if it believes that doing so will infringe the rights and freedoms of others.

  8. Security of your personal data

    1. Taking into account the state of the art, the implementation costs, as well as the nature, scope, context, processing purposes and the risks to your rights and freedoms varying in likelihood and seriousness, VACA ensures that it has taken the necessary security measures – and updates from time to time – to ensure a level of security appropriate to the risk. Where relevant, the measures taken by VACA may include:

      • the pseudonymization and encryption of your personal data

      • the ability to ensure the confidentiality, integrity and availability of its processing systems and services on an ongoing basis

      • the possibility to restore the availability of and access to the personal data in a timely manner in the event of an incident

      • Establishing a procedure to periodically test, assess and evaluate the effectiveness of technical and organizational security measures for processing.

        • Where VACA itself is responsible for the storage of your personal data, this is done on its own secure servers.

    2. VACA guarantees that it has also taken adequate measures to ensure that any natural person acting under its authority or under the authority of the processor and in the performance of his/her function or assignment for VACA or the processor, has access to your personal data, will only be processed on behalf of VACA, unless he/she would be obliged to do so on the basis of a legal provision.

  9. Notification of infringements

    1. VACA is legally obliged to report a breach of your personal data to the supervisory authority without undue delay and, if possible, no later than 72 hours after becoming aware of it. For Belgium, this supervisory authority is the Commission for the Protection of Personal Data. Privacy (hereinafter referred to as “Privacy Commission”), with registered office at 1000 Brussels, Hoogstraat 139 (Tel: +32(0)2/213.85.40; Fax: +32(0)2/213.85.65; E-mail: commission@
      The Privacy Commission is an independent body that monitors the protection of privacy in the processing of personal data.


    2. Where appropriate, and where the breach is likely to pose a high risk to your rights and freedoms, VACA undertakes to notify you of the breach of your personal data as well, unless one of the following conditions is met:

      • VACA has taken appropriate technical and organizational protection measures that make your personal data incomprehensible to unauthorized persons (encryption, pseudonymization, etc.) and these measures have been applied to your personal data to which the infringement relates

      • VACA has taken the necessary steps following the discovery of the breach to ensure that the breach is no longer likely to pose a high risk to your rights and freedoms

      • the communication would require a disproportionate effort. In that case, VACA will instead make a public announcement or take a similar measure on the basis of which you will be informed equally effectively.

  10. Processing by third parties

    1. It is possible that VACA is dependent on the services of third parties for the correct performance of its services. In that regard, VACA guarantees that it has concluded an agreement with its direct subcontractors for the processing of personal data (hereinafter referred to as the “Processing Agreement”), has obtained at least a written guarantee from this third party that they act at all times in accordance with the applicable privacy legislation, in in particular the Privacy Act and the AVG. By means of a Processor Agreement, these third parties undertake, when they process your personal data in the context of an assignment outsourced to them by VACA, to act in full compliance with the applicable privacy legislation, in particular the Privacy Act and the AVG.10.2.

    2. VACA may rely on certain third-party service providers that have their own privacy policies regarding the information we are required to provide to them for your purchase-related transactions, such as payment gateways and other payment transaction processors. Read the privacy policies of these service providers so that you understand how your personal data is handled by these providers. Please note in particular that certain providers may be located in a jurisdiction other than Belgium or the European Union or may have facilities there. When you choose to proceed with a transaction involving the services of a third-party service provider, your information may be subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. For example, if you are in Canada and your transaction is processed by a payment gateway located in the United States, your personal information used in completing that transaction may be disclosed under United States law, including the Patriot Act.

  11. Change

    1. VACA reserves the right to change this Privacy Policy without prior individual notice. Please therefore regularly check this policy.

  12. Complaints and comments

    1. If you have a complaint or comment about this Privacy Policy or the processing of your personal data, or if you discover a breach of the processing of your personal data, please contact VACA in the first instance. This can be done by sending an email to or by sending your complaint to the following address: VACA cv recognized as so - Zeedijk 330 - B8400 Ostend. VACA undertakes to deal with your complaint expeditiously, but it has sovereignty over its validity.

    2. If you wish, you can also address your complaint to the Privacy Commission (Tel: +32(0)2/213.85.40; Fax: +32(0)2/213.85.65; E-mail: commission@privacycommission .be).

  13. Applicable law and competent court

    1. Applicable law
      This Privacy Policy is subject to Belgian law.

    2. Competent court
      The courts of the judicial district of Ghent, Ghent division, are competent to take cognizance of any dispute that may arise between VACA and the data subject whose personal data are processed by or on behalf of VACA.

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