Policies
its everyday business operations Korys Investments NV makes use of a variety of data about identifiable individuals.
In collecting and using this data, the organisation is subject to a variety of legislation controlling how such activities may be carried out and the safeguards that must be put in place to protect it.
The purpose of this policy is to set out the relevant legislation and to describe the steps Korys Investments NV is taking to ensure that it complies with it.
This control applies to all systems, people and processes that constitute the organisation’s information systems, including board members, directors, employees, suppliers and other third parties who have access to Korys Investments NV systems.
Identity and contact details of the controller and, where applicable, of the controller’s representative
Link to relevant data protection legislation
The General Data Protection Regulation (GDPR) is one of the most significant pieces of legislation affecting the way that Korys Investments NV carries out its information processing activities.
The GDPR has been integrated in Belgium through the ‘Data Protection Act’ of July 30, 2018.
Significant fines are applicable if a breach is deemed to have occurred under the GDPR, which is designed to protect the personal data of citizens of the European Union. It is Korys Investments NV’s policy to ensure that our compliance with the GDPR and other relevant legislation is clear and demonstrable at all times.
Definitions and principles
Personal data is defined as:
any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one 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 factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
‘processing’ means:
any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
‘controller’ means:
the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
There are a number of fundamental principles upon which the GDPR is based.
These are as follows:
1. Personal data shall be:
(a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
2. The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).
Statement
Korys Investments NV will ensure that it complies with all of these principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems.
The purposes and legal basis of the processing
There are six alternative ways in which the lawfulness of a specific case of processing of personal data may be established under the GDPR. It is Korys Investments NV policy to identify the appropriate basis for processing and to document it, in accordance with the Regulation.
|
Activity Processing purpose |
Source Data Subject | Category of personal data | Legal basis | Receivers | Retention period |
| Contactform | visitors website | Identification records | Legitimate interest | website operator: internal Korys | 2 years after last contact |
| Cookies | visitors website | Identification records | Consent | website operator: internal Korys | 2 years after last contact |
We do not use the information you provide to make any automated decisions that might affect you.
Regarding the recipients, or categories of recipients, of the data, if any
We will not share your information with any third parties for the purposes of direct marketing.
We share your information in order to meet the above mentioned purposes. All staff involved in handling personal data understand their responsibilities for following good data protection practice.
We use processors who are third parties who provide elements of services for us. We have contracts in place with our processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Give details of any planned transfers of personal data to a third country or international organisation
The data subject also has rights under the GDPR. These consist of the right to be informed, the right of access, the right to rectification, the right to erasure, the right to restrict processing, the right to data portability, the right to object and rights in relation to automated decision making and profiling. Each of these rights are supported by appropriate procedures within the company of client that allow the required action to be taken within the timescales stated in the GDPR. These timescales are shown below
| Data Subject Request | Timescale |
| The right to be informed | When data is collected (if supplied by data subject) or within one month (if not supplied by data subject) |
| The right of access | One month |
| The right to rectification | One month |
| The right to erasure | Without undue delay |
| The right to restrict processing | Without undue delay |
| The right to data portability | One month |
| The right to object | On receipt of objection |
| Rights in relation to automated decision making and profiling. | Not specified |
Each basis of lawful processing creates relevant rights of the data subject, as shown below:
| Right of the data subject | Basis of lawful processing | |||||
| Consent | Contractual | Legal Obligation | Vital interests | Public interest | Legitimate interest | |
| Withdraw consent | Yes | No | No | No | No | No |
| Be informed | Yes | Yes | Yes | Yes | Yes | Yes |
| Access | Yes | Yes | Yes | Yes | Yes | Yes |
| Rectification | Yes | Yes | Yes | Yes | Yes | Yes |
| Erasure | Yes | No | No | No | No | Yes |
| Restrict processing | Yes | Yes | Yes | Yes | Yes | Yes |
| Data portability | Yes | Yes | No | No | No | No |
| Object | N/A | No | No | No | Yes | Yes |
| Automated decision making and profiling | N/A | No | No | Yes | Yes | Yes |
Describe the data subject’s rights to access, rectification, erasure and portability of the personal data
By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
To submit a request regarding your personal data by email, post or telephone, please use the following contact information .
Describe the data subject’s rights to restriction of, or objection to, processing of their personal data
The data subject has the right to object to processing that is based on the following legal justifications:
- For the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
- For the purposes of the legitimate interests of the controller
Once an objection has been made, Korys Investments NV must justify the grounds on which the processing is based and suspend processing until this is done. Where the personal data is used for direct marketing we have no choice but to no longer process the data.
Describe the data subject’s rights to withdraw consent at any time (if applicable)
The data subject has the right to withdraw consent where the basis for processing of their personal data is that of consent (i.e. the processing is not based on a different justification allowed by the GDPR such as contractual or legal obligation).
Before excluding the data subject’s personal data from processing, it must be confirmed that consent is indeed the basis of the processing. If not, then the request may be rejected on the grounds that the processing does not require the data subject’s consent. Otherwise, the request should be allowed.
In many cases, the giving and withdrawal of consent will be available electronically i.e. online, and this procedure will not be required.
Where consent involves a child (defined in Belgium by the age of – 13 years old)) the giving or withdrawal must be authorised by the holder of parental responsibility over the child.
Will the personal data be subject to automated processing, including profiling? If so describe the logic and potential consequences involved
The data subject has the right to not be the subject of automated decision-making where the decision has a significant effect on them, and can insist on human intervention where appropriate. The data subject also has the right to express their point of view and contest decisions
There are exceptions to this right, which are if the decision:
- Is necessary for a contract
- Is authorised by law
- Is based on the data subject’s explicit consent
In assessing these types of request, a judgement needs to be made about whether the above exceptions apply in the particular case in question.
COMPLAINTS/CHANGE OF POLICY/ADRESSING COMPLIANCE
The data subject’s right to lodge a complaint with a supervisory authority
Addressing compliance
The following actions are undertaken to ensure that Korys Investments NV complies at all times with the accountability principle of the GDPR:
- The legal basis for processing personal data is clear and unambiguous
- A Data Protection Officer is appointed with specific responsibility for data protection in the organisation (if required)
- All staff involved in handling personal data understand their responsibilities for following good data protection practice
- Training in data protection has been provided to all staff
- Rules regarding consent are followed
- Routes are available to data subjects wishing to exercise their rights regarding personal data and such enquiries are handled effectively
- Regular reviews of procedures involving personal data are carried out
- Privacy by design is adopted for all new or changed systems and processes
- The following documentation of processing activities is recorded:
- Organisation name and relevant details
- Purposes of the personal data processing
- Categories of individuals and personal data processed
- Categories of personal data recipients
- Agreements and mechanisms for transfers of personal data to non-EU countries including details of controls in place
- Personal data retention schedules
- Relevant technical and organisational controls in place
These actions are reviewed on a regular basis as part of the management process concerned with data protection.
Updates to this privacy policy
We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we haven’t previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.
Cookie policy
Read the dedicated page for the cookie policy.
Cookie Policy
We use a range of different technologies on our web site, some of which are controlled by ourselves (first party) and some of which are controlled by other organisations (third party).
These technologies include (but are not limited to) cookies, scripts, fonts and images;
some of which are considered as necessary for us to be able to deliver the web site to you and others which we use to enhance our understanding of how you use our web site; to assist in our marketing activities and other purposes as explained below.
Under European law we are required to obtain your consent for any use of these technologies which is not considered as necessary, as well as provide you with clear
information as to what these technologies do; and the third parties we work with.
What technologies do we use?
Cookies
Cookies are small files containing specific information relating to your use of our web site – such as login credentials; items in a shopping cart; and tracking identifiers.
Cookies are set by our web server and the web servers of the third parties we deploy on our web site; and can be read , updated or deleted by those same servers, each time you visit our web site, based on the type of cookie it is.
Cookies which are only related to a single session (a single visit to our web site) are deleted automatically when you close your web browser – these are typically considered as necessary for us to deliver the web site to you.
Other cookies (such as tracking cookies or authentication cookies) are often saved for an extended period of time from days to years.
Some cookies can impact your fundamental rights to Privacy and Data Protection and as such, require your consent before they can be accessed or stored on your device. Because of this, we limit our use of cookies as explained below.
Who sets them?
First party cookies are stored and accessed by our web server; third party cookies are stored and accessed by other organisations, such as analytics providers and advertisers.
How we use cookies
Cookies on our website are used for a variety of different purposes, but generally
speaking their use breaks down into the following categories:
- Strictly Necessary Cookies: These are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
- Analytical/Performance Cookies: These cookies are set by our analytics providers and allow us to record certain information about you, such as the pages you visit on our web site; how many times you visit our web site; and links you might click on.
Furthermore when you connect to our analytics provider in order for them to set the cookie – they may also collect other information about you such as you geographical location; your IP address; what type of device you are using and various information about the device. This information can be used to create a unique fingerprint to help further identify you on other web sites you might visit and can be used to create a profile of your online activities and interests. - Marketing Cookies: Cookies set by our marketing providers are used for the purpose of tracking your online activities to create a profile and give us a better understanding of your interests.
Non-essential cookies
Used for other business purposes which are not considered necessary to deliver the website to you.
| Name | Provider | Goal | Expiry period | Type |
| pll_language | korys.be | Determines the user’s preferred language and sets the language (if possible) accordingly. | 1 year | HTTP |
| GPS | youtube.com | Records a unique ID on mobile devices to enable tracking based on geographic GPS location. | 1 day | HTTP |
| IDE | doubleclick.net | Used by Google DoubleClick to record and report the website user’s actions after viewing or clicking on any of the advertiser’s advertisements for the purpose of measuring the effectiveness of an advertisement and to present targeted advertisements to the user. | 1 year | HTTP |
| NID | google.com | Records a unique ID that identifies a returning user device. | 6 months | HTTP |
| PREF | youtube.com | Records a unique ID used by Google to track statistics about how visitors use YouTube videos on different websites. | 8 months | HTTP |
| test_cookie | doubleclick.net | Used to check whether the user’s browser supports cookies. | 1 day | HTTP |
| VISITOR_INFO1_LIVE | youtube.com | Tries to estimate user bandwidth on pages with embedded YouTube videos. | 179 days | HTTP |
| YSC | youtube.com | Records a unique ID to keep track of which videos from YouTube the user has seen. | Session | HTTP |
| yt-player-bandwidth | youtube.com | Used to determine the optimal video quality based on the device and the user’s network settings. | Continuous | HTML |
| yt-player-headers-readable | youtube.com | Used to determine the optimal video quality based on the device and the user’s network settings. | Continuous | HTML |
Your choices regarding these technologies
Essential technologies will be placed in your web browser without your prior consent.
These are being used to maintain the functionality of the Site. Any non-essential technologies, will only be placed in your web-browser with your prior consent.
Changes to this Policy
We may revise this Policy on occasion. If we make any material changes to the way we intend to use web technologies, we will prominently be posting the changes on our website.
How to contact us
Should you have any queries regarding this Notice or how your information is collected, used and stored, please visit our Privacy Policy or contact .
Whistleblowing policy
Purpose of the policy
Korys, as defined in Article 3 of this policy, aims to foster an ethical corporate culture while adhering to applicable laws.
To detect any violations of integrity, a whistleblower mechanism is established. This policy outlines the whistleblower mechanism, including the internal reporting channel, and provides essential information on external reports to designated authorities and disclosures.
Additionally, the policy explains the protections available to whistleblowers under European and national legislation.
Definition of whistleblowing
Whistleblowing involves the reporting by employees of Korys or external parties as described in article 3 (e.g., suppliers, portfolio companies etc.) of dangerous, illegal, unfair or abusive behavior within Korys business activities, protecting the reporter from retaliation. This reporter is referred to as the whistleblower.
Scope of application
Any person who has obtained information about a breach within Korys, which means all legal entities affiliated with Korys NV, whose registered office is established in 1500 Halle, Villalaan 96, in a work-related context may make a report.
This may contain:
- Employees;
- Self-employed persons;
- Shareholders and persons belonging to the administrative, management or supervisory body of Korys, including non-executive members;
- Temporary workers, job students, volunteers and paid or unpaid trainees;
Korys contractors, subcontractors and suppliers, as well as anyone working under their supervision and direction; - …
The mechanism is also open to persons whose working relationship has ended or is yet to begin, if they report information about violations obtained during the now-terminated working relationship or during the recruitment process or other pre-contractual negotiations.
Additionally, if a breach is reported concerning financial services, products and markets, or in the area of money laundering and terrorist financing prevention, the reporter may also be protected even if this information was obtained outside a work-related context.
Speak up
Korys is committed to fostering an ethical company culture where unethical or abusive behavior is not tolerated. Employees are encouraged to report any such breaches or suspected breaches, even if they involve board members or executives, or if the information pertains to the company’s trade secrets.
Types of misconduct to report
A reporter may inform Korys of any dangerous, illegal, abusive, or immoral activities for which the Korys is responsible. Reports can be made while such activities are ongoing, after they have occurred, or if they are anticipated in the future.
Whistleblowers may be protected when reporting violations or reasonable suspicions of the following matters:
a) consumer protection;
b) product safety and product compliance;
c) public health;
d) transport safety;
e) protection of the environment;
f) food and feed safety, animal health and animal welfare;
g) protection of privacy and personal data, and security of network and information systems;
h) tax fraud;
i) social fraud;
j) public procurement;
k) financial services, products and markets, prevention of money laundering and terrorist financing;
l) radiation protection and nuclear safety;
m) damage to the financial interests of the EU as referred to in Article 325 TFEU;
n) the internal market as referred to in Article 26(2) TFEU, including competition and state aid.
In considering whether certain conduct should be reported, the following questions could provide important guidance:
• Could this conduct be viewed as dishonest, unethical or unlawful?
• Could this conduct potentially impact the company to a significant extent?
• Could this conduct affect the company’s reputation with its customers, business providers, employees or other stakeholders?
• Could this conduct hurt other people?
Should the answer to any of these questions be ‘yes’, and the information pertains to any of the matters specified in this Article, the whistleblower is required to report the violation as per the stipulations in this Policy.
If the report does not pertain to any of the aforementioned matters, the whistleblowing policy is not applicable. For issues related to psychosocial matters and personal wellbeing or others matters you deem necessary to report within Korys, please refer to the HR manager Dietske.Devillé@korys.be, the internal prevention advisor Tine.Bigaré@korys.be, one of our board members or the external prevention advisor .
To act in good faith
When making a report, the whistleblower must always act in good faith, ensuring that the report is based on reasonable grounds.
A whistleblower does not lose protection simply because a report made in good faith is later found to be false or unfounded. However, protection is not extended to those who knowingly report false or unsubstantiated information or who make a report with an improper motive, such as to defame or harm others. In such cases, Korys may disregard the report and take appropriate disciplinary and/or legal action against the reporter.
A reporter acting in bad faith may be guilty of slander and defamation, offenses for which Belgian criminal law provides sanctions. Victims of such malicious reports are also entitled to seek compensation.
Reporting procedure
Reporting through internal reporting channel
Korys has an internal reporting channel. Reports can be submitted via email to .
The report must be sufficiently detailed and documented. It must contain at least the following information:
• The name of the reporter;
• A detailed description of the event being reported;
• The date and place of the event;
• The names and positions of the persons involved in the event, or information that allows identification;
• The names and contact information of other persons who witnessed the event, or who can confirm the event;
• Any other information about similar events.
When reporting a breach, Korys does not require whistleblowers to collect evidence, but rather to provide a detailed description to facilitate the investigation.
Whistleblowers have the option to remain anonymous and can submit their reports through the appropriate external channels if they prefer anonymity.
Handling of the report
Report confirmation
Reports are directed to the Whistleblowing Manager, who comprises the Korys Paralegal and Finance Manager. Within 7 (seven) calendar days of receiving the report, the whistleblower will receive a confirmation of receipt, indicating that the report has been entered into the report register.
Investigation
The report will be carefully investigated in compliance with the principles of confidentiality and impartiality. The Whistleblowing Manager is responsible for following up the report carefully and investigating it. He/she will maintain further communication with the whistleblower and request additional information from the reporter if necessary.
Feedback
Within a reasonable time and no later than 3 (three) months from the Confirmation Receipt, the whistleblower will receive feedback from the Whistleblowing Manager on the report.
Records/file retention
Reports submitted are kept strictly confidential. Only the Whistleblowing Manager will have access to the identity of the whistleblower and any third parties mentioned in the report. The Whistleblowing Manager will maintain this confidentiality. However, they may disclose certain non-personal information to ensure proper feedback.
Any processing of the report will be done in accordance with the General Data Protection Regulation. These reports will remain in the register for the duration of the contractual relationship or professional cooperation between the whistleblower and Korys.
Reporting through external reporting channel
Reports can also be submitted via an external reporting channel to the Federal Ombudsman or the appropriate authorities. While internal reporting is an option, external reporting is encouraged in the following situations:
• It is not possible to effectively report the breach through the internal reporting procedure.
• The reporter fears retaliation through the internal reporting procedure.
• European or national laws require the notifier to report to designated national authorities.
Designated authorities have set up independent and autonomous channels for receiving and processing information about violations. These external channels allow for both written and oral reports. Oral reporting can be conducted via telephone or other voice messaging systems, and upon the whistleblower’s request, through a physical meeting within a reasonable time.
No retaliation
Korys unequivocally prohibits any form of retaliation against whistleblowers who submit reports in good faith based on this policy. Any acts of retaliation, as well as threats or attempts of retaliation, are strictly forbidden. Whistleblowers are encouraged to report any instances of retaliation or attempted retaliation to the Whistleblowing Manager.
Protective measures
Whistleblowers are granted the following protections against retaliation:
• Absolute immunity from liability for the act of reporting or disclosing information, and partial immunity from liability for the act of obtaining or accessing information.
• An out-of-court protection mechanism involving a reasoned complaint to the Federal Ombudsman in instances of retaliation or threats thereof.
• For employees, the right to request reinstatement under identical conditions.
• The right to appeal and pursue compensation in cases of reprisals.
Approval, amendments and entry into force
This Policy has been issued and approved the Partners who are responsible for the adequacy and appropriate overall implementation of the Policy.
Additions, revisions, amendments and abolishment of this Policy are to be approved by the Partners. This Policy has entered into force upon its adoption by Partners on 01 January 2025.
