Privacy policy

In 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

If there are any questions regarding this Privacy Policy you may contact us using the information below.

Villalaan 96
1500 Halle
Phone: +32 2 318 25 00
Company registration number BE 0844.198.918


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’).



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.


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.



The data subject’s right to lodge a complaint with a supervisory authority

If you have a complaint about our use of your information you have a right to complain at the Belgian Authority, Gegevensbeschermingsautoriteit.

You can contact them at:
Drukpersstraat 35, 1000 Brussel
+32 (0)2 274 48 00


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.


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