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Privacy Policy

BEL Europe GmbH (“BEL Europe GmbH”) may have occasion to collect and process Personal Data (as defined below). This Privacy Policy (this “Policy”) applies to the processing of Personal Data concerning data subjects in the European Economic Area (“EEA”) in accordance with the General Data Protection Regulation (the “GDPR”).

1. Personal Data
In this Policy, Personal Data means any data relating to an identified or identifiable natural person (“Personal Data”).  BEL Europe GmbH may acquire and process below Personal Data of a natural person in the EEA, directly from the data subject or indirectly from the company that such data subject belongs to.

(1) Personal Data of employees of BEL Europe GmbH
· Identification data (which may include name, address, date of birth, age, telephone number, fax number, email address, academic background, marital status, passport, driver’s license, nationality, job title)
· Gender
· National ID number
· Educational and professional qualifications and classifications
· Previous employment, resumes
· Performance appraisals
· Work experience
· Employment, severance, and agreements including non-disclosure agreements
· Compensation and benefits to data subjects.
· Photograph
· Other Personal Data required pursuant to statutory provisions

(2) Personal Data of employees of clients of BEL Europe GmbH and clients of BEL Europe GmbH
· Phone number, fax number, e-mail address, job title
· Other Personal Data required pursuant to statutory provisions

2. Use of Personal Data
BEL Europe GmbH acquires and processes Personal Data for the following purposes:
· Providing services to relevant clients;
· Legitimate business interests, such as undertaking business research and analysis or managing the operation of the business;
· Public relations, such as responding to inquiries;
· Engaging in marketing and business development activities in relation to the services. This may include sending client newsletters, marketing communications and other information that may be of interest to them;
· Defense of certain rights or interests;
· Compliance with legal and regulatory obligations that BEL Europe GmbH has to discharge;
· Managing clients, credit exposure, contracts, and exports;
· Recruiting activity;
· Personnel management of employees and officers;
· Administration of employee and officer benefits and compensation;
· Executing and performing employment or consignment contract between BEL Europe GmbH and employees/officers; and
· Administration of whistle-blowing

BEL Europe GmbH relies on the following legal grounds to process Personal Data:
· The data subject’s consent expressly given to process his/her Personal Data in such manner. The data subject may withdraw his/her consent to this processing at any time; however, this will not affect the lawfulness of any processing carried out before withdrawal of the consent;
· Entering into a contract with a data subject or performing obligations under a contract with a data subject;
· Legitimate interests, some examples of which are given above; and
· Compliance with applicable laws or regulations

3. Disclosure to Third Parties
BEL Europe GmbH may supply or disclose Personal Data, without the data subjects’ prior consent, to BEL Europe GmbH’s group companies and other third parties that are BEL Europe GmbH’s service assignees. BEL Europe GmbH may also supply or disclose Personal Data to third parties when it is necessary for some other justifiable reason permitted by the laws and regulations.

4. Cross-Border Transfer
Personal Data may be transferred to entities in countries or jurisdictions outside the EEA, such as Japan, if required for the purposes as described above. Please note that such countries or jurisdictions may not have the same data protection laws as the EEA and will not afford many of the rights conferred upon data subjects in the EEA. BEL Europe GmbH will ensure that any such international transfers are made subject to appropriate and suitable safeguards as required by the GDPR or other relevant laws. When doing so, BEL Europe GmbH will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of Personal Data.

5. Retention of Personal Data
BEL Europe GmbH will retain Personal Data for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law.

6. Rights of Data Subjects
Data subjects have the right to access, request correction of, request deletion of, request the limitation of processing of, object to the processing of, and request the data portability of their Personal Data retained by BEL Europe GmbH. When BEL Europe GmbH receives a request based on the right specified above, BEL Europe GmbH shall conduct any necessary investigation without delay and provide data subjects or nominated third parties with Personal Data or respond to such rights without delay.

While there will not generally be any detrimental effects for the data subjects if they fail to provide their Personal Data, BEL Europe GmbH may need to collect Personal Data to process data subjects’ instructions or perform contracts with them. In such case, BEL Europe GmbH may have to cancel the engagement or contract such data subjects have with BEL Europe GmbH, and will notify them thereof at that time.

7. Right to Lodge Complaint with Data Protection Authority
Data subjects have the right to lodge a complaint with the local data protection authority if they have a complaint with regard to BEL Europe GmbH’s processing of their Personal Data.

8. Contact
For any questions about this Policy, BEL Europe GmbH’s privacy practices or your rights described in “Section 6. Rights of Data Subjects”, please contact us at the following:

[E-mail address] info@bel-europe.com

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BEL Europe GmbH.

   

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