Article 1 - Identify and applicability
BT Solutions, with its registered office at Ter Stratenweg 2, 2520 Ranst, Belgium, and accessible via btsbelgium.com and info@btsbelgium.com, is the data controller within the meaning of the General Data Protection Regulation (GDPR).
This privacy policy applies to all processing of personal data within our organization, including but not limited to:
- Our website and digital communication
- Customer and supplier management
- Project execution and operations
- HR and personnel management
- IT systems and security
- Legal and contractual obligations
Article 2 – Categories of Data Subjects, Data, and Sources
We process personal data of:
- Customers and prospects
- Suppliers and subcontractors
- Employees and applicants
- Shareholders and directors
- Website visitors
The processed personal data may include:
- Identification data: Name, address, VAT number, national register number (if legally required)
- Contact details: Email address, phone number
- Financial data: Billing details, bank account numbers
- Commercial information: Contractual and commercial agreements, quotes
- HR and recruitment data: Payroll data, resumes, cover letters, and evaluations
- Technical documentation: Technical project data and drawings
- IT data: Log data, access data, IP address, browser and device characteristics, cookie data
Obtained via third parties (Indirect collection): For our recruitment purposes, we do not only collect data directly, but we also receive profile and application data via external recruitment, job, and social media platforms.
We exclusively process data that is necessary for the purposes described below (data minimization).
Article 3 – Purposes and Legal Bases for Processing
We process personal data solely on the basis of the valid legal grounds set out in Article 6 of the GDPR:
3.1 Contractual Necessity (Art. 6.1.b GDPR) For the preparation, conclusion, and proper execution of agreements with you.
- Applications: Customer and project management, quote management, billing, supplier management, and the drafting and execution of HR and employment contracts.
3.2 Legal Obligation (Art. 6.1.c GDPR) For compliance with legal obligations to which BT Solutions is subject.
- Applications: Tax and accounting obligations, social security administration (NSSO/RSZ, Dimona, A1 documents), labor and occupational safety legislation, and corporate law obligations (such as the shareholder register).
3.3 Legitimate Interest (Art. 6.1.f GDPR) For the pursuit of our legitimate business interests, provided that the impact on your privacy remains limited and following a careful balancing of interests. Data subjects have the right to object to these processing activities at any time.
- Applications: IT security and network management, logging and fraud prevention, internal administration and reporting, relationship management with existing customers and suppliers, and quality and process optimization.
3.4 Consent (Art. 6.1.a GDPR) If no other legal basis applies. Given consent can be withdrawn at any time and without giving any reason.
- Applications: Marketing communication to non-customers, use of specific visual material of employees for external communication, and optional communication or newsletter subscriptions.
Article 4 – Website Use, Cookies, and Marketing Tools
When using our website, we process the following data: IP address, browser and device data, visited pages, referrer URLs, and cookie data.
This processing is done for the functioning of the website, security, statistical analysis, and the optimization of our services. In doing so, we use the following categories of technologies:
- Targeted Advertising & Social Media: We use tracking pixels and cookies from external advertising networks and social media platforms to measure the effectiveness of our campaigns and to show you relevant advertisements on external platforms.
- B2B Lead Generation: To measure and optimize the business use of our website, we use external lead generation software. This software exclusively shows us public company data based on the IP addresses of our business visitors.
We use cookies and similar technologies. Non-essential cookies (for analysis and marketing) are only placed after you have given explicit consent via our cookie banner. More specific information about the exact technologies, parties, and your preferences can be consulted in our cookie policy or via the cookie settings on the website.
Article 5 – IT Systems, Security, and Storage
BT Solutions implements appropriate technical and organizational measures to protect personal data against loss, misuse, or unauthorized access. We use, among other things:
- Odoo for centralized business and project management
- Microsoft 365 / OneDrive for document storage and communication
- Secured internal networks and strict access control
- Encryption and Multi-Factor Authentication (MFA) where relevant
- Secured backups and proactive logging
Article 6 – Processors and Third Parties
BT Solutions collaborates with carefully selected processors and partners who process personal data on our behalf or with whom we share data. These categories include, among others:
- IT, cloud, and software providers
- Communication and administrative service providers (such as payroll and accounting partners)
- External advertising networks and analytics partners
- External recruitment and job platforms
All processors acting on our behalf are contractually bound via a Data Processing Agreement (DPA) in accordance with Article 28 of the GDPR. An up-to-date list of sub-processors is available internally and can be provided upon simple request.
Article 7 - International Transfers
If personal data is transferred outside the European Economic Area (EEA), this is done exclusively under one of the following legal safeguards:
- An adequacy decision by the European Commission, or
- Standard Contractual Clauses (SCCs), and/or
- Additional technical and organizational measures such as encryption and access restriction.
We actively strive to keep data processing within the EEA as much as possible.
Article 8 - Retention Periods
Personal data is not kept longer than strictly necessary for the realization of the purposes. Indicative retention periods:
- Accounting and tax documents: 7 to 10 years (in accordance with legal Belgian retention periods)
- Customer and supplier files: 7 years after the last interaction or contract termination
- HR and personnel files: Up to 5 years after termination of employment (or legally longer if required for social inspection)
- Applications: Up to 12 months after the completion of the procedure
- IT log files: 6 to 24 months
- Website and tracking data: Up to 24 months
Article 9 - Data Transfer
Personal data is only shared with third parties if:
- This is necessary for the execution of an agreement with you
- We are legally obliged to do so
- This is necessary for a legitimate interest with appropriate safeguards
Under no circumstances will personal data be sold or commercially rented to third parties.
Article 10 – Rights of Data Subjects
As a data subject, you have various legal rights regarding your personal data:
- Right of access and copy
- Right to rectification (correction)
- Right to erasure ("right to be forgotten", if legally permitted)
- Right to restriction of processing
- Right to object (especially for processing based on legitimate interest)
- Right to data portability
- Right to withdraw your given consent at any time
Requests to exercise your rights can be directed to info@btsbelgium.com or privacy@btsbelgium.com. We will respond to this within 1 month of receipt in accordance with the GDPR guidelines.
Article 11 - Complaints
If you have any questions or complaints about the way we handle your personal data, we kindly request you to contact us directly first. In addition, you always have the legal right to file a complaint with the supervisory authority. In Belgium, this is the Data Protection Authority (GBA/APD): www.gegevensbeschermingsautoriteit.be
Article 12 - Amendments
BT Solutions reserves the right to unilaterally amend this privacy policy to stay up-to-date with changing legislation or business processes. The most recent, applicable version is always available via our website. ww.gegevensbeschermingsautoriteit.be