Privacy Notice & Policy

Privacy Notice & Policy

1. Definitions

Site user(s):  any internet visitor browsing one of the Realdolmen websites including but not limited to employees, candidate employees, existing, future or past clients with or without a login account.

Information system(s): Application software, email software, maintenance tools using and processing non-personal and personal data. This can be digital or physical like printed on paper for temporary use or storage.

Supplier: Processor (third party company, partner company or individual) processing directly or indirectly personal data for the account of Realdolmen, working for Realdolmen based on a supplier agreement with data protection provisions.

Personal data, Processing, Controller, Processor: Please see the official definitions of Article 4 of the GDPR: https://gdpr-info.eu/art-4-gdpr/ 

2. Introduction

Realdolmen’s general website is www.realdolmen.com. When you browse from the general site you can reach other Realdolmen websites that are grouped in four domains: Business websites, e-commerce website (RStore), Jobs website and Education website. Each group of sites collects and processes different personal data. Please find here below the privacy policy details for each of these groups.

With respect to:

Cookies: We use cookies. Please refer to our Cookie policy for more.

Security: We have appropriate physical and electronic security measures in place in our facilities to protect against the loss, misuse or alteration of information that we have collected from you.

We enter into processing agreements with our suppliers to ensure the same level of security and confidentiality of your personal data.

Our IT suppliers process personal data for maintenance purposes of our information systems.

Only Realdolmen’s selected and well-informed employees process your personal data to perform the tasks related to their role, e.g. HR, Sales and Marketing or managing the Education platform.

Remark: On all Realdolmen websites, you will find email addresses to contact us. Please note that we will handle the personal information in your email with the same care as the information you provided in our webforms. We could enter manually these personal data into our Information Systems as if provided via the webforms on one of the four groups of Realdolmen websites. 

3. Your privacy rights:

You have the right to view, correct, delete or transfer your personal data. In addition, you can request to restrict the use of your data or you can object to the use of your data.

If you want to know which personal data Realdolmen processes from you, you can make a request for access.

Does your information appear to be incorrect, incomplete or irrelevant? Then you can make an additional request to have your data modified or completed.

If you have the impression that your data is not properly secured or that there are indications of abuse, please then contact us.

These requests to exercise your privacy rights should be done by filling out the Data Subject Request Webform

In order to ensure that the request for access has been made by you, we ask you to attach a scan of your identity card. In this scan, we ask you to black out your national register number. This is to protect your privacy.

Realdolmen will respond to your request as soon as possible and at the latest within four weeks. If due to circumstances your request is not handled timely or correctly, then you have the opportunity to submit a complaint to the Belgian DPA (Data Protection Authority), previously named Commission for the Protection of Privacy (CPP), at Drukpersstraat 35, 1000 Brussels. 

4. Business websites

(1)    List of the Business websites

(2)    Personal Data

Realdolmen processes the personal data you provide on the business websites for following marketing purposes:

  • Sending our newsletter and / or advertising brochure
  • Call you if requested
  • Inform you about changes to our services and products
  • Allow you to create an account
  • Analyze your interests on the website in order to improve our website and tailor our range of products and services to your preferences.

(3)    Basis of the processing

Any use of personal data must be based on one of the foundations from Article 6 of the General Personal Data Regulation (GDRP). Under this article, it is permitted, among other things, to process personal data:

  • if it is necessary for the legitimate interests of Realdolmen as controller or of a third party.

    This legal basis applies here because it is Realdolmen’s legitimate interest as a commercial company to take marketing actions about its products and services. You can always opt-out from our marketing information systems or manage your preferences. 

(4)    Retention period

We only keep your data for the period required to perform our marketing actions as described above or until your first request for deletion.

(5)    Share with others

The information Realdolmen collects on the forms is not shared with other organizations for commercial purposes.

Realdolmen shares your personal data with the following third parties:

  • Public authorities, if this is necessary to comply with any legal obligation
  • IT suppliers, to support and maintain the websites
  • Web advertising companies  (see our Cookie policy for more information)

With the companies that process your data on our behalf, we conclude a processor agreement to ensure the same level of security and confidentiality of your data. Realdolmen remains responsible for these processing operations.

The Realdolmen “Business” websites are hosted in the European Union and are maintained by Realdolmen. These Realdolmen “Business” websites also embed a cloud CRM information system with the supplier having entities in Israel and the USA. Israel is on the European Union safe list. For the USA, Realdolmen has the following appropriate safeguards in place, which ensure enforceable rights and effective judicial remedies: the sub-processor in the United States has formally joined the Privacy Shield. The documents that guarantee the adequate safeguards can be requested. 

5: E-commerce website of Realdolmen (RStore)

https://store.realdolmen.com

(1)    Personal Data

Realdolmen processes your personal data for the following purposes:

  • Allow you to create an account
  • Manage your purchase, delivery and payment
    • Realdolmen also processes personal data if we are legally obliged to do so, such as information that we need for our tax declaration
    • To call you if necessary to carry out our services
  • Marketing
    • Sending our newsletter and / or advertising brochure
    • Inform you about changes to our services and products
    • Realdolmen analyzes your interests on the website in order to improve our website and tailor our range of products and services to your preferences.

(2)    Basis of the processing

Any use of personal data must be based on one of the foundations from Article 6 of the General Personal Data Regulation (GDRP). Under this article, it is permitted, among other things, to process personal data:

a)    if it necessary for the implementation of a contract in which you are involved

This legal basis is applicable for the purchase management purposes because: we have to fulfill the obligations of your purchase agreement.

b)    if it is necessary for the legitimate interests of Realdolmen as controller or of a third party

This legal basis is applicable for marketing purposes because: it is Realdolmen’s legitimate interest as a commercial company to take marketing actions about its products and services. You can always opt-out from our marketing information systems or manage your preferences. 

(3)    Retention period

We only keep your data for the period required to perform our marketing actions as described above or until your first request for deletion.

By law, invoices are kept for 10 years.

(4)    Share with others

The information Realdolmen collects on the forms is not shared with other organizations for commercial purposes.

Realdolmen shares your personal data with the following third parties:

  • Public authorities, if this is necessary to comply with any legal obligation
  • IT suppliers, to support and maintain the websites
  • Web advertising companies  (see our Cookie policy for more information)

With the companies that process your data on our behalf, we conclude a processor agreement to ensure the same level of security and confidentiality of your data. Realdolmen remains responsible for these processing operations.

The RStore website is hosted in the European Union. For RStore (MyStore), Realdolmen has an IT maintenance supplier in Sri Lanka. The Standard Contractual Clauses according to Commission Decision C(2010)593 with this company are in the process of being signed.

Realdolmen uses an information system in the cloud (online) for invoicing. The IT supplier supporting this information system is located in India. Realdolmen has therefore following appropriate safeguards, which ensure enforceable rights and effective judicial remedies: Standard Contractual Clauses according to Commission Decision C(2010)593 with this company. The documents that guarantee the adequate safeguards can be requested.

The Realdolmen RStore website also embeds a cloud CRM information system with the supplier having entities in Israel and the USA. Israel is on the European Union safe list. For the USA, Realdolmen has the following appropriate safeguards in place, which ensure enforceable rights and effective judicial remedies: the sub-processor in the United States has formally joined the Privacy Shield. The documents that guarantee the adequate safeguards can be requested.

To perform the contract of shipping your goods and services, contact details and shipping addresses are transferred to suppliers who need this information such as shipping companies or IT equipment manufacturers. Those companies are located in Europe and are obliged to respect the GDPR. 

6: Education website of Realdolmen

https://education.realdolmen.com

(1)    Personal Data

Realdolmen processes your personal data for the following purposes:

  • Manage your purchase, delivery and payment
    • Realdolmen also processes personal data if we are legally obliged to do so, such as information that we need for our tax declaration
    • To call you if necessary to carry out our services
  • Marketing
    • Sending our newsletter and / or advertising brochure
    • Inform you about changes to our services and products
    • Realdolmen analyzes your interests on the website in order to improve our website and tailor our range of products and services to your preferences.

Realdolmen only collects, stores or uses your personal information for giving trainings. The personal data you fill in the forms of the education website is collected in Realdolmen’s proprietary Education information system where Realdolmen’s Education center employees manage the trainers, the training participants, courses and participants’ feedbacks. The trainers have access to the list of participants to their course. Your personal data is only used to plan and conduct the trainings. Your evaluation of the trainer is available anonymously or identifiable (your choice) to the trainers. Where relevant, the presence of employees to a training are communicated back to the contact person (usually human resources) of the employer.

(2)    Basis of the processing

Any use of personal data must be based on one of the foundations from Article 6 of the General Personal Data Regulation (GDRP). Under this article, it is permitted, among other things, to process personal data:

a)    if it is necessary for the implementation of a contract in which you are involved

This legal basis is applicable for the purchase management purposes because: we have to fulfill the obligations of the purchase agreement that you have with us.

b)    if it is necessary for the legitimate interests of Realdolmen as controller or of a third party

This legal basis is applicable for the marketing purposes because: it is Realdolmen’s legitimate interest as a commercial company to take marketing actions about its products and services. You can always opt-out from our marketing information systems or manage your preferences. 

(3)    Retention period

We only keep your data for the period required to perform our marketing actions as described above or until your first request for deletion.

By law, invoices are kept for 10 years.

(4)    Share with others

The information Realdolmen collects on the forms is not shared with other organizations for commercial purposes.

Realdolmen shares your personal data with the following third parties:

  • Public authorities, if this is necessary to comply with any legal obligation
  • IT suppliers, to support and maintain the websites
  • Web advertising companies  (see our Cookie policy for more information)

With the companies that process your data on our behalf, we conclude a processor agreement to ensure the same level of security and confidentiality of your data. Realdolmen remains responsible for these processing operations.

Realdolmen uses cloud storage for the Education information system. It is hosted in the European Union and the IT maintenance team is located in Europe and the USA. Realdolmen has the following appropriate safeguards in place, which ensure enforceable rights and effective judicial remedies: the sub-processor in the United States has formally joined the Privacy Shield. The documents that guarantee the adequate safeguards can be requested.

The trainers at Realdolmen are requested not to keep a copy of the list of participants of a Realdolmen training. 

7: Jobs website of Realdolmen

http://jobs.realdolmen.com

(1)    Personal Data

Realdolmen processes your personal data for the following purposes:

  • Process your job application
  • To call you if necessary to ask more information or make appointments
  • Realdolmen analyzes your interests on the website in order to improve our website.

Realdolmen stores your CV and documents provided by you when you applied.

Realdolmen only collects, stores or uses your personal information for executing the processes of reviewing candidates’ application to job offers. The personal data contained in the documents and CV provided will remain within the HR team and are transmitted when necessary to managers or team members of the divisions who could recruit you.

(2)    Basis of the processing

We process your personal data because you have given us your consent
This basis applies here because: you have given us your consent when selecting “I agree” on the site when filling in your contact details and sending us your CV.

(3)    Retention period

We keep your personal data until 4 weeks after the job recruitment procedure has been closed or 1 year after your consent was given. A yearly consent will be asked if Realdolmen intends to continue storing your personal data.

(4)    Share with others

The information Realdolmen collects on the forms is not shared with other organizations for commercial purposes.

Realdolmen shares your personal data with the following third parties:

  • IT suppliers, to support and maintain the websites
  • Web advertising companies  (see our Cookie policy for more information)

With the companies that process your data on our behalf, we conclude a processor agreement to ensure the same level of security and confidentiality of your data. Realdolmen remains responsible for these processing operations.

The Realdolmen Jobs website is hosted in the European Union and managed by an IT supplier established in the UK and Germany. This IT supplier is only processing your data “indirectly” i.e. for maintenance of the entire database without specific consulting of personal data.


Laws and technologies on the Internet change quickly, Realdolmen reserves the right to modify this Privacy Notice & Policy when required. This is version RD-PNP-15-07-2018 valid in NL, FR and EN from 15/07/2018 to the next version’s date.