Privacy policy

Privacy policy

BATMAN cares about your privacy and treats personal data with the strictest confidentiality and always in accordance with the applicable legislation.

The purpose of this privacy policy is to provide you with transparent information about the data we collect, the purpose, the way we use it, with whom we share it and the rights you have regarding the processing of such data.

This privacy policy is applicable when you use our website, social media or communicate with us via phone, e-mail or other digital communication channel.

It is important to read this privacy policy carefully. If you have any further questions, please do not hesitate to contact us at info@wearebatman.be.

1. Who is responsible for the processing of your personal data?

BATMAN Ltd, that has its registered office at Gijmelsesteenweg 81, 3200 Aarschot and is registered in the Crossroads Bank for Enterprises under the number BE 0650 548 910 (hereinafter ‘BATMAN’ or ‘we’) is responsible for the processing of personal data as described in this privacy policy.  If you have any questions, please do not hesitate to contact us at info@wearebatman.be.

2. How do we collect your personal data?

BATMAN Ltd is a young, ambitious content management company in Leuven. This may require the handling of personal data of individuals involved in these activities and hence BATMAN Ltd collects personal data in several ways from a number of sources.

BATMAN Ltd may collect your personal data in the following ways:

  • directly from your verbal or written input;
  • indirectly through third parties acting on behalf of you (e.g. affiliated partners providing details of their representatives);

We collect and use your personal data whenever you:

  • use our website or social media or communicate with us via e-mail, phone or any other digital communication channel (e.g. through the use of cookies); This information is collected using various technologies which includes saving cookies to your computer or device
  • leave us your business card when we have the pleasure of meeting you in person;
  • contract and communicate with us as our customer or supplier;
  • apply for one of our vacancies.

3. What personal data do we process about you and what do we use it for?

When you use our website, social media or communicate with us via phone, e-mail or other digital communication channel, we will collect and use your personal data to:

  1. allow for the communication between you and us, for which we rely on our legitimate interest to be able to respond to requests, questions or remarks or to contact you proactively for inquiries of whatever kind (e.g. when you respond to a blog, use our contact form or contact us via social media, phone or e-mail);
  2. improve the website’s and social media pages’ content and the overall experience, for which we rely on our own legitimate interest to offer our visitors an interesting online space;
  3. detect and prevent malware, illegal content and behavior and other types of misuse, for which we rely on our legitimate interest to keep our online presence safe.

To achieve the above-mentioned purposes, we process the following personal data:

  1. the basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, the company you work for, your function;
  2. the content of your communication and the technical details of the communication itself (with whom you correspond at our end, date and time, etc.);
  3. technical information associated with the device you use, such as your IP address, browser type, geographical location and operating system;
  4. information concerning your browsing behavior, such as how long you visit, what links you click on, what pages you visit and how many times you visit a page.
  5. any other personal data you choose to provide to us.

When you leave us your business card, we collect and digitally register the personal data which are written on that card for normal business relationship management purposes. We thus rely on our legitimate interest to process these personal data, which is to be able to build up our network of contacts.

If we enter into a contract, either as a customer or as a supplier, we will collect and use your personal data to:

  1. be able to execute and perform our end of the contract. When you as an individual are our customer or supplier, we rely on the necessity of processing your personal data for executing and performing the contract we have with you. However, if you act on behalf of a company or other legal entity, we rely on our legitimate interest to be able to contract with customers and suppliers when processing your personal data;
  2. do our normal business administration (e.g. invoicing and relationship management), for which we rely on our legitimate interest to manage our business responsibly and professionally;
  3. defend ourselves in legal proceedings, when it is in our legitimate interest to use your personal data in these proceedings.

The personal data we process for these purposes will always involve your basic identity information such as name, e-mail address, postal address, telephone number, the company you work for and your function. We may also process other personal data you provide us with, dependent on our contractual relationship with you.

When you apply for one of our vacancies, we will collect and use your personal data to:

  1. assess your application, for which we rely on the necessity of processing your personal data in order to come to a potential agreement with you;
  2. defend ourselves in legal proceedings, when it is in our legitimate interest to use your personal data in these proceedings.
  3. keep you in our recruitment reserve, for which we will ask your consent;

The personal data we process when you apply with us, are:

  1. your basic identity information such as name, e-mail address, postal address and telephone number;
  2. any other personal data you have chosen to include in your application.
  3. information you have included in your resumé and cover letter;
  4. information you have made publicly available on social media;

4. How long do we keep your personal data?

We will retain your personal data for as long as this is necessary to achieve the purposes set out as described above. We will remove your personal data from our database as soon as we no longer need them to achieve these purposes or when you validly exercise the right to erase your personal data.

All personal data we collect through our interactions with you via the website, social media, phone, e-mail and other digital communication channels we keep for as long as required to communicate with you, but also to keep an historical archive of our communications. This allows us to revert back to earlier communications if you return to us with new questions, request, remarks or other input.

All personal data we collect in the context of a contractual relationship with you or the organization you represent, we will keep for the duration of the contractual relationship and at least until 7 years thereafter.

Should you wish to know how long your personal data will be kept for specific processes, please contact us at info@wearebatman.be.

5. Whom do we share personal data with and how do we protect your personal data?

We do not sell, trade, or rent your personal data to others.

We shall not disclose your personal data to third parties, unless it is necessary in the context of providing online services. In this respect, your personal data may be disclosed to software providers, cloud partners, payment partners and business partners.

If it is necessary that we disclose your personal data to third parties in this context, the third party in question is required to use your personal data in accordance with the provisions of this privacy policy. We have concluded data processing agreements with the third parties concerned, which contain the necessary guarantees regarding confidentiality and privacy compliance of your personal data.

Notwithstanding the foregoing, it is however possible that we disclose your personal data to the competent authorities (i) if we are obliged to do so under law or under legal proceedings and (ii) to safeguard and defend our rights.

In certain limited cases, we may transfer personal data to third countries. However any transfer of personal data outside the European Economic Area (EAA) to a recipient in a country which does not fall under the adequacy decision enacted by the European Commission, shall be governed by the provisions of a data transfer agreement, which shall contain (i) the standard contractual clauses issued by the European Commission, or (II) any other mechanism pursuant to privacy legislation, or any other regulations pertaining to the procession of personal data.

6. What are your rights?

6.1 Right of access

You have the right to request information on the data we hold about you from us at any time. This information includes, but is not limited to, the categories of data we process, the purposes for which it is processed, the source of the data if not collected directly from you, and, if applicable, the recipients with whom we have shared your data. You can obtain a copy of your data from us free of charge. If you require additional copies, we reserve the right to charge you for these copies.

6.2 Right to rectification

You have the right to request that we rectify inaccurate data relating to you. We will take appropriate steps to keep the data we store and process on an ongoing basis accurate, complete and current, based on the most up-to-date information available.

6.3 Right to erasure

You have the right to request that we erase your data, as long as the legal requirements for this are satisfied. This may be the case if:

  • the data is no longer required for the purposes for which it was collected or otherwise processed;
  • you withdraw the consent on which data processing is based, and there is no other legal basis for processing;
  • you lodge an objection to the processing of your data and there are no legitimate reasons for processing, or you object to data processing for direct marketing purposes;
  • the data was processed unlawfully;

and provided that processing is not required:

  • to ensure compliance with a legal obligation that requires us to process your data;
  • especially with regard to statutory retention periods;
  • to establish, exercise or defend legal claims.

6.4 Right to restriction of processing

You have the right to request that we restrict processing of your data if:

  • you dispute the accuracy of the data – in which case processing may be restricted during the time it takes to verify the accuracy of the data;
  • processing is unlawful, and you reject erasure of your data, requesting that its usage be restricted instead;
  • we no longer need your data, but you need it to establish, exercise or defend your rights;
  • you have lodged an objection to its processing, as long as it is not certain that our legitimate reasons outweigh yours.

6.5 Right to object

You have the right to object to the processing of your data at any time for reasons that arise from your particular situation, as long as data processing is based on your consent, on our legitimate interests or those of a third party. In this case, we will cease to process your data. This does not apply if we can show that there are compelling legitimate grounds for processing that outweigh your interests, or if we need your data for the establishment, exercise or defense of legal claims.

6.6 Right to data portability

You have the right to request that we transfer your data – if technically possible – to another responsible party. However, you may only enforce this right if data processing is based on your consent or is necessary for the performance of a contract. Rather than receiving a copy of your data, you may also ask us to submit the data directly to another responsible party specified by you.

6.7 Right to withdraw your consent

You have the right to withdraw your consent at any time, for example if you have given your consent for direct marketing.

7. How can you exercise your rights?

If you wish to exercise one of the above rights, you can send a written request by letter to Gijmelsesteenweg 81, 3200 Aarschot or by email to info@wearebatman.be. We promise you an answer as soon as possible.

We make every effort to comply with all requests within one month. However, this period may be extended for reasons relating to the specific right or complexity of your request.

8. Right to file a complaint

Please note that you always have the right to lodge a complaint with the competent supervisory authority and to seek judicial remedy in relation with the processing of your personal data.

For Belgium this is the Data Protection Authority, which can be reached by mail at Rue de la Presse 35, 1000 Brussels, and by email at the following address: contact@apd-gba.be.

For other countries of the EU you can find the list of data protection supervisory authorities here: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

9. Revisions to our Privacy Policy

We reserve the right to revise this privacy policy or any part of it from time to time, in particular to comply with all new applicable laws and/or regulations, the recommendations of the Authorities and the decisions of the courts in this area.

Please review the policy periodically for changes.

June 17th, 2020