Privacy Policy

PRIVACY STATEMENT

We attach great importance to privacy and confirm that all personal data is processed in accordance with both the Belgian law of 30 July 2018 on the protection of natural persons with regard to the General Data Protection Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

We are a dynamic group and our privacy statement is not static. We may therefore adapt this privacy statement to changes that may occur. This privacy statement was last amended on February 7, 2025.

1. Scope

This privacy statement applies to all personal datathat we process.

Personal data is all data that can be traced back toyou as an individual, such as name, telephone number, IP address, customernumber, email address,..

2. Who uses my data?

This statement relates to Gumption NV, with registered office at Satenrozen 10, 2550 Kontich, and with company number 0847.610.843 We will be considered as the data controller with regard to the personal data that we collect in the context of your use of our website.

The full details are:

Gumption NV
Satenrozen 10
2550 Kontich

3. Whom do we use data from?

We process the personal data of everyone who has hadcontact with us or visited our website. These include visitors, customers,prospects, applicants and other contacts.

4. How do we get your data?

We get the data directly from you as soon as you:

• visit our website
• data on our website
• contact us by e.g. email or telephone
• When you register for an event
• if you sign up for our newsletter
• if you apply for a vacancy via our website
• if you download a whitepaper from our website
• …

5. What data do we use about you?

We use both information that you provide to us yourself and information that we collect.

• Identification data, e.g. surname, first name, address, IP address,...
• Contact details: e.g. e-mail address, telephone number,...

We also use cookies to collect information. This is further elaborated in our cookie policy.

5. Legal Bases and Purposes

We only use your personal data for the purpose for which we are allowed to use it.

We rely on the following justifications for the use of your personal data:

• Performance of the agreement: the processing is necessary for the execution of the agreements made.

• Consent: we have obtained your unambiguous and explicit consent to process your personal data.

• Legitimate interest: the processing is necessary for the purposes of the legitimate interests pursued in order to achieve our objectives.

• Information, management and development of customer relationships

We use your data to send a newsletter, to invite you to events,interesting relevant solutions, products or services,... For this we rely onpermission or legitimate interest.

Weprocess the following data, among others:

• Personal details such as name, age,...
• Contact details such as address, telephone number, email address,...
• Interests
• …

We store your data for a maximum of 10 years after a last assignment, contact or business transaction.

• Applications

We use your data in the context of attracting new talent. Forthis, we rely on your permission if you have applied yourself and havetherefore spontaneously provided us with your data. Based on our legitimate interest,we can also maintain a recruitment reserve and contact potential new talentourselves.

We process the following data, among others:

• Personal details such as name, age,...
• Contact details such as address, telephone number, email address,...
• Education
• Career
• Family composition
• Interests
• Working conditions
• ….

Wewill keep your data for a maximum of 5 years after the application if you havenot been retained. If you give us permission to do so, we will keep your datain our recruitment reserve for 3 years.

• Direct marketing

We use your data for direct marketing. The processingis based on legitimate interest.

• Specific purposes

We use your data to contact you ifyou have asked us a question via the contact form. We store your data for amaximum of 1 year and rely on the legal basis of consent or contractualagreements.

7. How long do we keep your data?

We will keep your data for as long as we are required to do soby law and for as long as necessary for the purpose for which we use your data.

If we no longer need to keep your data, we will ensure that itis deleted from our systems or that it can no longer be identified.

After these periods, we may only process your data forstatistical purposes and to handle any complaints or legal matters.

8. Whom do we share your data with?

We share your personal data with othercompanies in the Gumption ecosystem and various third parties if this isnecessary for the execution of the agreement and to comply with any legalobligation. The sharing of this personal data will take place in accordance withall relevant laws and regulations.

We make sure that we limit theinformation to the relevant and necessary information that is necessary toachieve the goal. Your information will not be sold or shared with others formarketing and advertising purposes without your consent.

We process your data within the European Economic Area(EEA).

9. How safe is your data with us?

We have taken measures to secure yourdata both organizationally and technically. We have secured our systems andvarious means of communication to ensure that your data does not end up in thehands of others. We also ensure that your data is only processed and accessibleby people who have received permission from us. When we share your datawith others, they are also obliged to treat it with the same care as we do.

10. Rights

Because we use your personal data, you have various rights.

Right to information
We must explain to you in an understandable and clear way what we do with your data and what rights you have. We do this by means of this privacy statement.

Right of access
You have the right to ask which of your personal data we process, the purposes for which we use it, the retention period,...

Right to rectification
You have the right to ask for your data to be adjusted if it is not (or no longer) correct or incomplete.

Right to object
The right to object can be exercised if the processing is based on legitimate interest as a legal basis, e.g. in the case of direct marketing.

Right to data portability
You can ask us to obtain the personal data in a structured, commonly used and machine-readable format in order to transmit it to another controller without hindrance.

Right to restriction of processing
You may ask us to restrict the use of your data. This means that in certain cases we may only store your data but not use it.

Right to be forgotten
You may ask us to delete the data we have about you. In some cases, we cannot or may not delete your data yet.

Right to lodge a complaint
You can submit a complaint about the way we handle your data. We attach great importance to our relationships and are happy to help you ourselves in the first instance. You can contact us at privacy@gumption.be or per post (Gumption – Privacy, Satenrozen 10, 2550 Kontich).

You also have the right to lodge a complaint with the local data protection authority.
Data from the Belgian Data Protection Authority:

Data Protection Authority
Rue de la Presse 35, 1000 Brussels

+32 (0)2 274 48 00
+32 (0)2 274 48 35
contact@apd-gba.be

Right to object to the processing of your personal data in automated individual decision-making

If your personal data is used in the context of automated individual decision-making and if these decisions have legal effects or other significant consequences, you can request us to stop using your data. If you exercise this right to object, we will stop or restrict the processing unless there are compelling reasons to do so.

How do I apply?
You can contact us at privacy@gumption.be or per post (Gumption – Privacy, Satenrozen 10, 2550 Kontich).

We will process your request or complaint within 1 month. If there are multiple requests or complaints or if your request or complaint is complex, we may need more time. We then have a maximum of 3 months. We will always contact you within 1 month. The processing and the legal basis help determine whether or not we can comply with your request.

We may also ask you to identify yourself. In that case, we request data from you to make sure that you are the right person to whom the personal data belongs.

We also ask you to specify which right you want to exercise and the way in which you want to be kept informed.

11. What are the rules for this Privacy Statement?

Our privacy statement must meet several conditions. These conditions can be found in the General Data Protection Regulation. In addition, the general rules that apply to our privacy statement according to Belgian law apply.

12. What cookies do we use?

You can indicate which of your data we may use. If you have given us permission to personalize your profile based onyour surfing and search behavior, we can set up our website specifically for you so that it becomes easier and more personal to use. We do this with the help of cookies. A cookie is a small text file that is placed on your hardware when you visit our website. For detailed information, please refer to our cookiepolicy.

Questions?

Do you have a question about our privacy statement? Please feel free to contact us by sending an email to privacy@gumption.be. We are happy to help you.