PRIVACY POLICY SMT BELGIUM AND SMT LUXEMBOURG

The present document constitutes the privacy policy (the “Privacy Policy”) of SMT
Belgium, with registered office at Woluwelaan 9, 1800 Vilvoorde, Belgium, company
number 0434.815.960, and of her sister company, SMT Luxmbourg, with registered
office at Um Woeller, L-4410 Soleuvre, Grand-Duchy of Luxemburg, with company
number B 50.456 (hereafter jointly « SMT »).
This Privacy Policy informs the visitor of the website https://www.smt.network/belux/ (the
“Website”), operated by SMT, about how SMT processes the personal data collected or
communicated by the visitor via the Website, and about how SMT processes the
personal data collected or communicated by a person who contacted SMT spontaneous
and directly (via e-mail or other).
1. Generalities
1.1. SMT is the controller of the personal data mentioned above and looks after the
respect of the Regulation (EU) 2016/679 of the European Parliament and of the Council
of 27 April 2016 on the protection of natural persons with regard to the processing of the
personal data and on the free movement of such data (the “GDPR”) or of any other rule
of Community law or Member State laws related to the protection of personal data, in
particular related to confidentiality and security of data.
1.2. The Website may contain links to other websites. This Privacy Policy is only
applicable for this Website. If the visitor visits other websites, SMT recommends him to
read the privacy policy of the other websites.
1.3. SMT reserves the right to adapt this Privacy Policy. The visitor shall regularly consult
the applicable Privacy Policy at the moment he visits the Website.
2. Process of your personal data by SMT
2.1. SMT collects and processes your personal data when you visit the Website or
because you disclose them (for example, via the contact form, contact form to apply for
a job, or via an e-mail), or just because you use the Website.
2.2. The purposes of data processing: the processing of your personal data is based on
different legal basis’s depending on the circumstances.
1. When the visitor visits the Website: the legitimate interests of SMT (article 6.1.f of
GDPR), in particular in order to improve our Website, the products and services offered,
and, sometimes the consent of the data subject (article 6.1.a of GDPR);
2. When the visitor enters himself his details in a contact form and/or writes an email to
SMT via the Website and/or contacts SMT directly via e-mail (or in another way): the
legitimate interests of SMT (article 6.1.f of GDPR) and the consent of the data subject
(article 6.1.a of GDPR);
3. When the visitor applies for a job through the Website (webpage “spontaneous
application”) (or directly via e-mail (or other)): in order to take steps prior to entering into
a contract (article 6.1.b of GDPR), the consent of the data subject (article 6.1.a of GDPR),
the compliance, by SMT, with a legal obligation (article 6.1.c of GDPR), the pursue by
SMT of her legitimate interests (the normal course of business) (article 6.1.f of GDPR).
2.3 Collected data: depending on your use of the Website, SMT could potentially process
following data:
Personal identification data (name, surname, address), electronic identification data
(email address, phone number, cookies); personal details (date of birth, place of birth,
gender, marital status, nationality and language knowledge), a valid work permit in
Belgium or Luxemburg; academic background; publications, information about the actual
job, information about the recruitment, information about the end of the actual job;
information about the career; information about the organization of work, remuneration
data; assessments; pictures; data about security (like login and password); data about
the hobbies and interests; data about your company; etc.
SMT does not request any special categories of personal data via the Website. Special
categories of personal data include e.g. information about race or ethnic group, political
preference, religious or philosophical beliefs, trade union membership, genetic data,
biometric data for the purpose of uniquely identifying a natural person, data concerning
health or data concerning a natural person's sex life or sexual orientation. We dissuade
you from furnishing this type of particular personal data. Should you, however, supply
such information for whatever reason, we assume that you explicitly grant SMT
permission to process this information.
2.4. Scope of purpose : when you use the Website, or when you fill in a form online, SMT
collects and processes your personal data for the following purposes:
- to manage its Website and to manage its (potential) clients;
- to manage the applications;
- to inform about new jobs.
2.5. The recipients: SMT may, if necessary to fulfil the purposes, use suppliers (for
example, IT infrastructures, foreign servers), who could process personal data on
instruction of SMT and on SMT’s behalf.
Furthermore, SMT could share your data with other companies of the SMT group all
around the world, depending on the circumstances, in order to ensure effective follow-
up of the received applications, or in order to provide services to a prospect. In any case,
it will communicate the applications it received to companies of the SMT group
concerned by the application, and it will communicate the demand received from a
prospect to the concerned company of the group.
When SMT uses suppliers, or transfers data to companies of its group, SMT commits
that appropriate measures are in place in order to protect the confidentiality of the data
and to guarantee their integrity and, when the suppliers are based outside the EEA, to
ensure an adequate level of data protection (for example, by the execution of ad hoc
stipulations).
In the case this is prescribed by law, or justified in the concrete circumstances, SMT is
likely to communicate your personal data to the authorities in charge with the compliance
with the rules (for example, the compliance with the rules on the protection of personal
data, and more generally, the compliance with the laws (for example communication to
the police)).
2.6. Right to withdraw your consent: When the processing is based on your
consent, you have the right to withdraw your consent at any time, for free, by
writing an email at the following address: avg.be@smt.network (Belgium) or
avg.lu@smt.network (Luxembourg).
2.7. Right to request access, rectification, erasure, right to oppose and right of data
portability: In any case, you have the right to access your data and to rectify them if they
are incorrect or incomplete, to obtain their erasure or limitation or, in cases specified by
law, to oppose against the processing of your data. Furthermore, you have the right to
receive the data that concerns you in a structured, commonly used and machinereadable format and have the right to transmit those data to another controller (right to
data portability). To exercise these rights, you can send, for free, an email to following
address: avg.be@smt.network (Belgium) or avg.lu@smt.network (Luxembourg).
2.8. Duration of the data retention: Your data will be retained by entitled persons for:
- 6 months as of the collection of the data, in the case of data collected to manage the
Website and/or to improve the service by using the Website and/or by submitting a
question via a contact form or directly;
- When a candidate fills in a registration form, sends a spontaneous application and/or
completes his personal profile, his personal data will be conserved in a data base,
managed by SMT, at least during the time it will be necessary to examine his candidature
and during the recruitment process, and maximum during 2 years as of the
communication of the candidature for the data processed for recruitment purposes.
2.9. Complaints: You can lodge a complaint with the :
- Belgian control authority: Authority of data protection (Drukpersstraat 35, 1000
Brussels – contact@apd-gba.be); or
- Luxembourger control authority: National Commission for Data Protection ((1,
avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette -
https://cnpd.public.lu/fr/support/contact/).
3. Cookies
3.1. SMT uses cookies on its Website, i.e. small information files that are transferred to
the visitor’s computer hard drive and which is saved temporarily or definitively on the
visitor’s computer, by the server of a website, via the navigator. This information makes
it possible to simplify, complete or personalize the use of the Website.
3.2. Insofar the cookies contain personal data, the visitor has the right to invoke his rights
under the GDPR.
3. Contact
If you have any questions and/or complaints, please contact SMT at the following
address:
- SMT Belgium: Woluwelaan 9, 1800 Vilvoorde, Belgium or by email at following
address: avg.be@smt.network ; or
- SMT Luxemburg: Um Woeller, L-4410 Soleuvre, Grand-Duchy of Luxemburg or
by email at following address: avg.lu@smt.network