Privacy Policy

3E NV/SA (hereinafter ‘we’, ‘us’ and ‘our’) understands the importance of the privacy of the users of its website and the protection of their personal data. This policy sets out how we handle and process your personal data.

1. Scope 

We create and maintain an environment where the users of our website can be confident that their personal data will not be misused. We comply with the laws applicable to data protection such as the Regulation (EU) 2016/679 (also referred to as the General Data Protection Regulation) and the Belgian Data Protection Act. The aforementioned regulations concern the protection of personal data and provide you with rights over the said personal data.

This privacy policy applies when you visit our website https://3e.eu/. The objective of this policy is to indicate what personal data we collect, how we use your personal data after you have visited our website and to assure you that we process your personal data in compliance with the applicable laws.  

The privacy policy applicable to personal data collected and processed within the Careers section of our website accessible at https://3e.eu/careers, including the personal area My Jobsite accessible at jobs.3e.eu/en/myjobsite/logon.aspx, is available at https://jobs.3e.eu/en/disclaimer.aspx.

2. What type of personal data do we collect when you visit our website?

It is not necessary to provide personal data to use most of our website.

We may collect the following categories of personal data and process them for the purposes stated below:

• First name and last name;
• Contact details (email, telephone number);
• Company name;
• Work address;
• Position/role;
• Company profile;
• IP address;
• Product(s)/service(s) of your interest;  
• Region of your interest;
• Nature of your enquiry.

Additional or optional data may be provided by you by filling out forms on our website or when we contact you (by telephone, email or at trade fairs or events).  

With respect to the personal data that we may collect via our website or the devices that you use, these may be:

• Login details (username and password) for the personal/restricted areas of the website;
• Location data (collected via social media or the IP address of your device; GPS signals sent by your mobile device);
• Data collected using cookies, web beacons or from the Internet. These data are automatically collected and can be related to the website that you visited before you navigated to our website, or the website you navigated to after visiting our website. We may also collect data on the website pages you have visited. Please read our cookie policy to find out more on the above;
• Data we obtain from other websites, for example LinkedIn or Twitter.

We may also collect personal data from the public domain to check or update personal data previously collected or to manage or broaden our activities.

3. Why do we collect these data, on what legal basis and for how long we retain them?

We collect the personal data mentioned above to operate our website, to offer better navigation services based on your needs, to get in contact with you. The following table identifies the specific purposes of processing, the legal basis of processing and the retention period of the personal data that we have collected:

4. Will your data be shared?

We may share your personal data with our affiliate and subsidiary companies for internal administrative purposes, or for communication or prospect/customer management purposes.

Based on our legitimate interest, we may also share your personal data with third parties that assist us with our products, services and website. Some examples of third-party activities include the hosting of web servers, data analysis and statistics, and marketing support providers.

The entities mentioned above have access to your personal data but only when this is required to perform their activities. They are not permitted to use your personal data for any other purpose and we remain the data controller with respect to those personal data.

We may also share your personal data with third parties with whom you have asked us to share your personal data, such as social media.

We will not sell or lease your personal data to third parties.  

We may disclose your personal data to enforce our policy, to comply with our legal obligations or in the interest of safety, in the public interest or for the purposes of legal enforcement in any country where we have affiliates or subsidiaries. We may follow up a request from a law enforcement agency, regulatory authority or government agency. We may also disclose personal data for the purposes of current or scheduled court cases or to protect our property, safety, people or other rights and interests.

Should 3E NV/SA be sold or merge with another company, your personal data may be made accessible to the advisor of the party to the potential transaction and transferred to the new company owners. In that case, we will take the appropriate measures to guarantee the integrity and confidentiality of your personal data. The processing of your personal data will be subject to this policy.

5. Transfer of your personal data outside the European Economic Area

For the purposes mentioned above, we may transfer your personal data to third parties, such as our affiliates or subsidiaries and service providers, in third countries (outside the European Economic Area (EEA)). The said transfers of personal data outside the EEA occur subject to appropriate safeguards. Please follow the procedure set out in the next section Your rights as data subject to obtain further information on personal data transfers.

6. Your rights as data subject

Data protection legislation provides various rights for you as data subject with regard to the processing of personal data, to ensure that you have sufficient control over the processing of your personal data.  

a. Right of access/inspection

You are entitled to receive confirmation from us of whether we process your personal data. If we do process your personal data, you are entitled to request access to your personal data and certain information about it.

We will produce a copy of the personal data relating to you in our records upon request. Should you make repeated and disproportionate requests for copies of the said data, we reserve the right to charge you a reasonable fee.

b. Right to rectification

Should you determine that the personal data in our records is incomplete or incorrect, you are entitled to notify us in order for the necessary steps to be taken to complete or rectify the said data.

c. Right to erasure

You are entitled to request that we erase your personal data in certain circumstances. There are certain exceptions where we may not be under the obligation to comply with your request for erasure, for example when retention of your personal data is necessary to comply with legal obligations or in connection with legal claims.

d. Right to restriction of processing

You are entitled to request that we limit the processing of your personal data in certain circumstances, for example for the time necessary for us to establish whether your personal data is accurate.

e. Right to data portability

You are entitled to receive the personal data that you have provided to us in a structured, standard and machine-readable format. You are entitled to request that we transfer the personal data to another data controller (directly from us). This is an option when the processing is based on your consent and the processing is carried out via an automated procedure. ‍

f. Right to object

Where your personal data is processed to pursue our own, or a third party’s, legitimate interests or for direct marketing purposes (including profiling), you remain entitled to object to the said processing. However, we may be entitled to continue processing the said data based on compelling legitimate grounds or in connection with legal claims. ‍

g. Automated individual decision-making, including profiling

You are entitled not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you significantly. There are certain exceptions to this right, for example where the decision is authorised by an applicable law.  

h. Right to withdraw consent

If you have consented to the processing of your personal data for a specific purpose of processing, you are entitled to withdraw your consent by sending us an email at notices@3e.eu.

If you opted in to receiving commercial email messages, newsletters, etc. from us, you can unsubscribe if you change your mind by sending us an email at marketing@3E.eu or by clicking the “Unsubscribe” link or equivalent from the relevant email channel.

i. Right to lodge a complaint with a supervisory authority

In case you consider that the processing of your personal data infringes the General Data Protection Regulation, you have the right to lodge a complaint with the supervisory authority in the European Union Member State where you have your habitual residence or place of work, or of the place of the alleged infringement.

j. Procedure to exercise rights and other provisions

We can request that you verify your identity to ensure that your request is lawful and that we are sending the reply to a person entitled to make such a request and to receive the requested personal data.

Please note that we may refuse access to your personal data or may not be able to grant your request under specific circumstances, when we are entitled to do so under the applicable data protection legislation. ‍

7. Security

We make every effort to guarantee the security of your personal data. We have implemented reasonable technical and organisational measures to guarantee your personal data against accidental or unlawful destruction, loss, modification, unauthorised disclosure and/or unauthorised access to the data transmitted, saved or otherwise processed. Since the Internet is an open network, we cannot guarantee that unauthorised third parties will not be able to circumvent these measures or use your personal data for unauthorised purposes.

8. Third-party websites

This website may include links to third-party websites, services or applications. We will not be held liable for the content of these websites, services or applications, nor for the privacy standards and practices of the corresponding third party. You must read and understand the relevant third-party website, services and privacy/cookie policies before accepting cookies, accessing a website, service or application to ensure that your personal data is sufficiently protected.

9. Amendments to this policy

We may amend or update this policy to ensure that the information on how we process your personal data at that time is accurate. Any updated version of this policy will be available on this same webpage and will take effect upon publication. Please visit this webpage regularly to ensure you remain up to date on how we collect and process personal data, how and under what circumstances we use your personal data and when we share your personal data with third parties. ‍

10. How to contact us

For further information on the collection and processing of your personal data through, or in relation to the use of our website, and to exercise your rights, please contact us at notices@3e.eu.

11. Privacy policy for job application data usage

Types of processed data

• Personal ID information, such as names and addresses;
• Electronic ID information, such as email addresses, mobile phone numbers and cookies;
• Personal details such as age, sex, date of birth, place of birth, marital status, nationality and language;
• Immigration status, such as the existence of a valid work permit for Belgium;
• Psychological descriptions, such as personality, thanks to a psychometric test;
• Academic career;
• Professional qualifications, including professional training and possession of a driving licence;
• Professional experience;
• Affiliation/involvement with professional organisations;
• Publications;
• Information about current employment;
• Information about recruitment;
• Information about the end of employment;
• Career details;
• Information about how work is organised;
• Salary details;
• Appraisal;
• In-job training;
• Images;
• Security information, such as passwords;
• Information about leisure activities and interests.

Applicants are never, in principle, required to disclose so-called sensitive information as defined by the privacy regulation, apart from when it is specifically required by law or authorised by a particular circumstance. This is why when a candidate fills anapplication form or completes a profile or interacts in any way whatsoever with 3E, he/she is generally asked not to provide information of this type, in other words, details revealing your racial or ethnic background, political opinions, religious or philosophical beliefs or membership of a union, as well as genetic or biometric details, information about your health, or information about your sexualactivities or orientation, criminal convictions and offences.

Data collection: Your personal data is collected in different ways.

• Submitting an application

3E processes all the information provided by applicants when they fill in a registration form either in response to a job vacancy or when submitting a spontaneous application.

To complete these registration forms, applicants are invited to provide their contact details (surname, first name, telephone number and email address), as well as send a CV.

Having sent this data to 3E, applicants may, if they want, sign in to their personal, secure profile to change the information already provided and/or add to their profile by providing other details needed for the purposes described below: professional experience, training, languages spoken, preferred salary, photo etc..

• Telephone and/or video interview

If an applicant chooses to provide the abovementioned information via a registration form and/or a spontaneous application, he/she explicitly agrees that 3E will use these details to contact him/her by telephone and/or email to receive more information about the services offered by 3E and, if he/she would like, to provide more information about his/her professional expectations.

• Recruitment interview

If an applicant agrees to have an interview with 3E, he/she explicitly agrees that 3E can use his/her personal data to invite him/her to this interview and to assess him/her during this interview, including with psychometric tests, as well as to check the references and information provided. The above implies, among other things, that 3E will, if applicable, get in touch with the businesses and/or organisations mentioned by the applicant.

• Purpose of the data treatment

This information is processed by 3E to recruit new employees and to analyze and manage applications. This involves:

- Gathering data via a registration form or an ad hoc application, the applicant’s personal profile, a telephone or even video interview, a face-to-faceinterview, psychometric tests, personality questionnaires etc.;

- Saving this data;

- Viewing this data;

- Checking and analysing this data;

- Producing statistics, market research etc. in order to improve the candidates' experience;

- Proactive communication to applicants of new job vacancies that might meet the professional expectations expressed by the applicants when they filled in a registration form and/or their profile.

It is because the candidate has given his/her permission for this that 3E can process this personal data.

3E needs to collect this data to fulfil the purposes mentioned above.

In fact, if this data is not collected, 3E would not be able, for example, to manage incoming applications correctly. That having been said, as this data processing is based solely on the candidate's consent, he/she is free to withdraw that consent at any time without detracting from the legality of any data processing carried out before this consent is withdrawn.

• Personal data sharing

Candidates’ data is only shared with:

-The candidates themselves;

-Employees of 3E;

-3E subcontractors (for example the hosting company, the recruitment tool

provider) insofar as it is necessary for the fulfilment of their roles or if required by law ;

-The public authorities in circumstances where it isrequired by law.

• Personal data retention period

When an applicant fills in a registration form, submits a spontaneous application and/or completes his/her personal profile, he/she explicitly accepts that his/her data will be kept in a database managed by 3E.

The data is kept as long as is necessary for the recruitment process of the candidate concerned, for the existing job offer(s) for which he/she has expressed interest and during 12 months after the end of the corresponding selection process(es), which allows 3E during this period of time to manage the administrative and legal monitoring of this application, but also to submit to the candidate new job offers that can meet his/her professional expectations. However, in exceptional circumstances, the data may be kept longer if an administrative and legal monitoring demands that it is kept for longer.

The candidates will be informed by email 4 weeks before their data is due to be deleted. Candidates may then, if they want, explicitly ask 3E to keep their data longer, in order to allow 3E to contact them proactively to suggest a job vacancy that might be of interest to them. In this case, the same procedure will be applied before the end of this new period of 12 months, and so on. In the absence of reaction of the candidates at the end of this period of 4 weeks, the data will be automatically and permanently deleted.

• Your rights

Candidates, by connecting to their personal profile, have at any time the right to access, to edit, to correct and to delete their personal data. They are also free to withdraw their consent to the processing of their personal data. This withdrawal will automatically lead to an immediate and irreversible deletion of their personal data.

By sending a dated, signed request (including electronically) by email to ian@3e.eu or by standard post along with proof of ID, any applicant can get a free copy (including electronically) of his/her personal information from 3E, as well as being able to correct or to delete incorrect or incomplete data information, or limit how it is used, within 1 month of receipt of the request. All applicants also have the right to transfer their data. After this deadline of 1 month, if there is no response or reaction from 3E, the candidate can assume that his/her request has been rejected.

If 3E has passed on concerned data to other people, 3E will take all reasonable measures to inform these people of the request to delete any link to this data or any copy or reproduction of it.

If an applicant would like to make a complaint, he/she can do so by contacting the Autorité de Protection des Données // Privacy Commission, rue de la presse, 35, 1000 Brussels, www.privacycommission.be

• Personal data protection

Applicants’ personal data is processed in Belgium and stored in a data centre in the Netherlands. The recruitment tool provider takes appropriate technical and organisational measures to protect applicants’ data, in particular against unauthorised handling and access, and will make every effort to make sure that these measures are as up-to-date as possible, given the state of knowledge, costs for implementation and the nature, scope, context and purposes of the processing as well as the risks for the applicants.

Legislation regarding privacy can sometimes be adapted and improved, so this document is also subject to change. 3E therefore recommends that you consult it regularly if you visit its websites, and will make sure that any changes, modifications and adaptations are clearly marked

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