BuzziSpace

Last date of revision: January 03, 2022

1. WHO DOES THIS GDPR PRIVACY STATEMENT APPLY TO?

1.1 The BuzziSpace Group (“BuzziSpace” or “We”) is a furniture and acoustic products manufacturer headquartered in Belgium. We create solutions for happy and healthy workspaces around the world. With a mission to improve wellbeing through human centric design, we seek to provide original acoustic solutions, lighting and furnishings to meet the needs of the modern workplace.

1.2 BuzziSpace is active in four different European countries and in the United States. Our group consists of several companies (“the BuzziSpace Companies”) that process personal data:

• Belgium: BuzziSpace Group nv, BuzziSpace nv, Italielei 8, 2000 Antwerpen, BE
• The Netherlands: BuzziSpace ManuFacture BV, Industrieweg 7A, 5531 AD Bladel, NL
• United States: BuzziSpace Inc, 2880 Ridgewood Park Dr, Winston-Salem, NC 27107, USA

1.3 This GDPR Privacy Statement applies to the processing of personal data:

• by all European BuzziSpace companies, regardless of whether the processing takes place in the Union or not;
• by BuzziSpace Inc, insofar as they process personal data of data subjects who are in the Union in the framework of: 1) the offering of goods or services to such data subjects in the Union; 2) the monitoring of their behaviour as far as their behaviour takes place within the Union.

1.4 All BuzziSpace companies are separate and independent legal entities. Depending on the processing activity in the context of which your personal data are processed, they may be qualified as a separate data controller or a joint controller with one or more of the other BuzziSpace companies. None of the BuzziSpace companies have any liability for the other BuzziSpace companies’ acts or omissions.

1.5 Creating happy, healthy workspaces is about more than what meets the eye. It’s also about trust and feeling safe. In order for you to feel that way, we are committed to protect your privacy and to process your personal data in an open and transparent manner, in particular with respect of the General Data Protection Regulation 2016/679 of 27 April 2016 (“GDPR”).Please follow the links below for further information. Where relevant, we have made a distinction between:

• job applicants seeking a position within one of the European BuzziSpace Companies;
• website visitors and digital platform / app users;
• (contact persons) of suppliers, customers (including dealers, architects etc.) and prospects, or any other individuals whose data are processed in the framework of our business activities (e.g. exhibition visitors, agents, business contacts,...).

2. WHAT IS COVERED BY THIS GDPR PRIVACY STATEMENT?

2.1 With this GDPR Privacy Statement we would like to inform you about why and how we process your personal data when we perform our business activities or when you use our website (“the Site”), apps and digital platforms, who we give that information to, what your rights are and who you can contact for more information or queries.

2.2 When we refer to “the Site”, we mean http://buzzi.space/. When we refer to the apps and digital platforms, we mainly refer to:

• BuzziSpace RT60: our app to measure the reverberation time and to simulate the impact BuzziSpace products would have on your room acoustics;
• pCon: a suite of 3D Interior Design - Space Planning applications. This is not our software, but we process personal data of the subscribers to the BuzziSpace catalogue integrated in this software. For more information about the way pCon (EasternGraphics BV) processes personal data in general, please click on this link: legal notice EasternGraphics BV.
• Configura CET: a suite of 3D Interior Design - Space Planning applications. This is not our software, but we process personal data of the subscribers to the BuzziSpace extension integrated in this software. For more information about the way Configura (Configura Sverige AB) processes personal data in general, please click on this link: Configura Sverige AB Privacy notice.

2.3 Please note that this GDPR Privacy Statement does not contain any detailed information about the cookies and similar technologies used on the Site. For this kind of information, please consult the Cookie Policy.

2.4 The Site may link to other sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices of other websites.

When linking to any such sites, we strongly recommend you to review the Privacy Statements on these sites, before disclosing any personal information.

2.5 Please be aware that, when you visit our pages on Facebook or Instagram, cookies are used by these social media. In this way, we can obtain information - in an anonymised way - about the public that visits our social media pages.

For more informations about why and how your personal data are processed in this respect, we refer to the privacy and cookie policies of both Facebook and Instagram:

• cookie policy Facebook: https://www.facebook.com/policies/cookies/
• privacy policy Facebook: https://www.facebook.com/about/privacy/
• cookie policy Instagram: https://help.instagram.com/1896641480634370
• privacy policy Instagram: https://help.instagram.com/402411646841720

3. WHY WE USE YOUR DATA

3.1 I AM A WEBSITE VISITOR OR A DIGITIAL PLATFORM / APP USER

3.1.1 We only process your personal data for legitimate business reasons. These purposes include, but are not limited to:

• providing the (online) services;
• communication and management of contacts
• dealing with enquiries, requests and complaints (e.g. sent via the contact form on the Site);
• advertising and (direct) marketing;
• system logs and gathering statistics about the use of the Site / platform / app;
• maintenance;
• improving performance and design of the Site / platform / app.

3.2 I am (a contact person of) a supplier, a customer (including dealers, architects etc.), a prospect or any other individual whose personal data are processed (e.g. an exhibition visitor, an agent, a business contact etc.)

3.2.1 We only process your personal data for legitimate business reasons. These purposes include, but are not limited to:

• respecting our legal obligations;
• customer and supplier management;
• follow-up of exhibitions;
• order and supply management;
• invoicing and accounting;
• the provision of information on our company, services and activities;
• the good organisation of our services;
• (direct) marketing and sales;
• dealing with enquiries, requests and complaints;
• dispute management;
• public relations and press contacts;
• statistics and market research;
• security.

3.3 I AM A JOB APPLICANT

3.3.1 The purpose for processing your personal data is to register your application for a job with us and, if this application leads to start our selection procedure, make a profile of you, meaning that we will process all the necessary data that is required for us to assess your job application in view of a potential recruitment. This assessment can also include an assessment by a third party.

3.3.2 In case of positive assessment and decision to hire, we will also process your personal data to prepare an employment contract. In case of a decision not to hire you, we will retain your personal data for a period of time as well (see “Data Retention”) in order to be able to contact you if any future job opportunities would seem to match your profile and to safeguard our interests.

4. THE LEGAL GROUNDS FOR PROCESSING YOUR DATA

4.1 I AM A WEBSITE VISITOR OR A DIGITAL PLATFORM / APP USER

4.1.1 When we process your data because you use the services offered on the Site, an app or a platform, we will mainly do this because it is necessary to fulfil our (contractual) obligations or, if we are not in a direct contractual relationship with you, for the purposes of our legitimate interests.

4.1.2 When you send a message via the online contact form on the Site, your personal data will in principle be processed for the purposes of our legitimate interests (namely the interest to handle all enquiries, requests and complaints sent via this form in the best possible way).

Before relying on legitimate interests, we will always determine case by case whether our interests are not overridden by your interests, fundamental rights and freedoms.

4.1.3 If we have the legal obligation to obtain your free, informed, specific and unambiguous consent to process your personal data for certain purposes (e.g. specific direct marketing ), we will only process your data for such purposes to the extent that we have obtained such consent from you.

4.2 I AM (A CONTACT PERSON OF) A SUPPLIER, A CUSTOMER (INCLUDING DEALERS, ARCHITECTS ETC.), A PROSPECT OR ANY OTHER INDIVIDUAL WHOSE PERSONAL DATA ARE PROCESSED (E.G. AN EXHIBITION VISITOR, AN AGENT, A BUSINESS CONTACT ETC.)

4.2.1 We process your personal data for the purposes mentioned above:

• when necessary for the performance of contracts to which you are party or in order to take steps at your request prior to entering into a contract;
• when necessary for compliance with our legal obligations;
• for the purposes of the legitimate interests of BuzziSpace and/or of a third party, including (but not limited to) our business activities, customer and supplier management etc. In this respect, we will always determine case by case whether our interests are not overridden by your interests, fundamental rights and freedoms.

4.2.2 If we have the legal obligation to obtain your free, informed, specific and unambiguous consent to process your personal data for certain purposes (e.g. specific direct marketing or market research activities), we will only process your data for such purposes to the extent that we have obtained such consent from you.

Please note that if you are an existing customer, your e-mail address might be added to our mailing list for e-mail messages containing information of commercial or promotional nature regarding similar products and services.

4.3 I AM A JOB APPLICANT

4.3.1 The professing of your data for the purposes mentioned above is necessary in order to take steps prior to entering into an employment contract and is in our legitimate interests, i.e. the interest to assess and evaluate you before deciding on making an offer of employment, which is, according to us, also in your interests.

4.3.2 In case of a decision not to hire you, it is also in our legitimate interests to retain your personal data for a period of time (see “Data Retention”) for any future job opportunities that would match your profile

5. YOUR RIGHTS

5.1 You have several rights concerning the information we hold about you. We would like to inform you that you have the right to:

• obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
• ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
• ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data if you believe that there is no (longer a) lawful ground for us to process it;
• withdraw consent to our processing of your personal data (to the extent such processing is based on consent);
• receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
• object to our processing of your personal data for which we use legitimate interest as a legal basis, in which case we will cease the processing unless we have compelling legitimate grounds for the processing.

You have also the right to object at any time to the processing of personal data for direct marketing. If you do not want to continue receiving any direct marketing from us, you can contact us (see below) or click on the unsubscribe function in any such communication. In that event, the personal data shall no longer be processed for such purposes.

5.2 In order to exercise any of your rights, you can send us a request, indicating the right you wish to exercise by e-mailing us at privacy@buzzi.space.

You may also use these contact details if you wish to make a complaint to us relating to your privacy.

5.3 If you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us.

6. HOW WE OBTAIN DATA

6.1 I AM A WEBSITE VISITOR OR A DIGITAL PLATFORM / APP USER

6.1.1 We may obtain your personal data when you use the Site, an app or a digital platform. The data may be freely provided by the user (e.g. via the contact form on the Site), or collected automatically (e.g. usage data).

6.1.2 Unless specified otherwise, all data requested by us are mandatory and failure to provide this data may make it impossible for us to provide our (online) services. In case where we specifically state that some data is not mandatory, you are free not to communicate this data without consequences to the availability or the functioning of the (online) services.

6.1.3 We may collect data through the use of cookies or similar technologies. For more information about this, please consult our Cookie Policy.

6.2 I AM (A CONTACT PERSON OF) A SUPPLIER, A CUSTOMER (INCLUDING DEALERS, ARCHITECTS ETC.), A PROSPECT OR ANY OTHER INDIVIDUAL WHOSE PERSONAL DATA ARE PROCESSED (E.G. AN EXHIBITION VISITOR, AN AGENT, A BUSINESS CONTACT ETC.)

6.2.1 We may obtain you personal data in the framework of the execution of our business activities.

6.2.2 We may obtain such personal data because you give them to us (e.g. by contacting us, by completing online forms, by giving us your business cards on exhibitions ...), because others give them to us (e.g. your employer, exhibition organisations, or other third parties that we use in the framework of our business activities) or because they are publicly available.

6.2.3 When we obtain personal data from external parties, we make reasonable efforts to enter into contractual clauses with these parties obliging them to respect the data protection legislation. This can be done by obliging this party to provide you with all necessary information or - if necessary - to obtain your consent for processing the personal data as described in this GDPR Privacy Statement.

6.3 I AM A JOB APPLICANT

6.3.1 In first instance, we will obtain your personal data because you give them to us in the framework of your application. During the application process, we may also generate personal data ourselves (e.g. assessment reports) or obtain them from others (e.g. references mentioned in your CV).

7. DATA WE COLLECT

7.1 I AM A WEBSITE VISITOR OR A DIGITAL PLATFORM / APP USER

7.1.1 When we process your data because you use the services offered on the Site, an app or a platform, it may concern - depending on the specific situation - the following data:

• Identification data (e.g. name, e-mail address, country of residence, ...);
• electronic identification data (e.g. IP addresses, browser type, cookie identifiers, ...);
• data about how you interact with us (e.g. when you contact us,) and other similar information;
• data about the use of the Site / digital platform / app;

7.1.2 Please find below an overview of the main personal data we collect through the services offered on the Site:

• Contact form: When completing the contact form on the Site, you might be asked to provide us with the following information: your message, company name, country, e-mail address, first name and last name.
• Mailing list or newsletter: By registering on the mailing list or for the newsletter, your e-mail address will be added to our contact list of those who may receive e-mail messages containing information of commercial or promotional nature concerning BuzziSpace. In this context, you might be asked to provide us with the following information: company name, country, e-mail address, first name, last name and profession.

We may also collect data through the use of cookies or similar technologies. For more information about this, please consult our Cookie Policy.

7.2 I AM (A CONTACT PERSON OF) A SUPPLIER, A CUSTOMER (INCLUDING DEALERS, ARCHITECTS ETC.), A PROSPECT OR ANY OTHER INDIVIDUAL WHOSE PERSONAL DATA ARE PROCESSED (E.G. AN EXHIBITION VISITOR, AN AGENT, A BUSINESS CONTACT ETC.)

7.2.1 The personal data that we collect or obtain may, among other things, include:

• Identification data (e.g. name, address (private/work), phone number (private / work), e-mail address (private / work), country of residence), national identification number, passports etc.
• electronic identification data (e.g. IP addresses, browser type, cookie identifiers, ...);
• personal characteristics (e.g. age, gender, date of birth, place of birth, nationality, language, family composition, etc.);
• financial specifics (e.g. bank account number, creditworthiness...);
• life style and social circumstances;
• family circumstances (e.g. marital status);
• employment and educational data (e.g. organisation you work for, job title, current responsibilities, projects, qualifications, trainings, work scheme...);
• data about which products and services you order;
• data about how you interact with us (e.g. when you contact us, when you visit us at exhibitions etc.) and other similar information

7.3 I AM A JOB APPLICANT OR A DIGITAL PLATFORM / APP USER

7.3.1 For the purposes referred to here above, the processing of personal data will include the following:

• standard data related to your identity (surname, name(s), address…);
• personal data (date and place of birth, nationality, gender, phone number, email address, hobbies and interests, …);
• your picture if you provide it to us knowingly and voluntarily;
• data with regard to your professional experience (profile, data on previous employers, termination of last employments and work carried out, special projects, …), including reference checks if you have provided us with references in your CV;
• data with regard to your education (diploma’s, certificates, internships, special trainings, …)
• language skills;
• if applicable, whether you possess a permit of working and/or reside in the European Economic Area (EEA);
• any other personal data that you present us with as part of your application, related to the exercise of the role;
• digital assessment through the internet (social media presence), insofar as this presence is open for us to see;
• any other personal data (than mentioned above) that require processing by virtue of the law.

You are not required to provide us with these data. However, not doing so might adversely affect your chances of being hired.

8. COOKIES

8.1 For detailed information about the cookies and similar technologies used on the Site, please consult the Cookie Policy. Please also note that the Site does not support “Do Not Track” settings at browser level.

9. DISCLOSURES

9.1 I AM A WEBSITE VISITOR

OR

I AM (A CONTACT PERSON OF) A SUPPLIER, A CUSTOMER (INCLUDING DEALERS, ARCHITECTS ETC.), A PROSPECT OR ANY OTHER INDIVIDUAL WHOSE PERSONAL DATA ARE PROCESSED (E.G. AN EXHIBITION VISITOR, AN AGENT, A BUSINESS CONTACT ETC.)

9.1.1 We may disclose your personal data to affiliated companies, third parties that provide services to us that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “Why we use your data” section above. The following external parties may for instance be involved:

• external service providers we rely on for various business services;
• law enforcement authorities in accordance with the relevant legislation
• external professional advisors (e.g. attorneys or consultants of the company).

If our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.

With respect to internal data transfers, the BuzziSpace Companies have concluded an intra-group agreement that sets out the obligations and restrictions that apply between these companies. You can always contact us in order to obtain an extract of the provisions which are relevant to you.

9.1.2 Please note that, in the framework of our business activities, some of the recipients of your personal data referenced above may be based in countries outside of the European Economic Area whose laws may not provide the same level of data protection.

With respect to possible transfers to our Company in the United States (BuzziSpace Inc), the BuzziSpace Companies have concluded standard contractual clauses in the sense of article 46 (c) of the GDPR. You can always contact us in order to obtain more information about this. Moreover, in case of other transfers outside of the EEA, BuzziSpace will take - where necessary - appropriate safeguards such as EU standard contractual clauses.

9.1.3 We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.

9.2 I AM A JOB APPLICANT

9.2.1 HR and your envisaged hierarchic superior(s) will have access to your personal data on a strict ‘need-to-know’ basis for the purposes described above.

9.2.2 We do not pass on your information to any other third party, with the possible exception of assessments centres etc. or any other third party in case it is relevant for the recruitment process. The confidentiality of your personal data will be guaranteed.

9.2.3 In principle, we do not transfer your personal data to recipients located in countries outside of the European Economic Area whose laws may not provide the same level of data protection. However, if you would apply for a job in the United States, we will transfer your application to the hiring manager in the United States. We consider this transfer is necessary for the implementation of pre-contractual measures taken at your request.

10. SECURITY OF YOUR DATA

10.1 We employ strict technical and organisational (security) measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage both online and offline.

These measures include:

• training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
• administrative and technical controls to restrict access to personal data on a ‘need to know’ basis (passwords, authorization systems, digital certificates);
• technological security measures, including back-ups, fire walls, encryption and anti-virus software;
• physical security measures, such as locking buildings and cabinets. .

10.2 Although we use appropriate security measures once we have received your personal data, the transmission of data - especially over the internet (including by e-mail) - is never completely secure. We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.

We limit access to your personal information to those who we believe reasonably need to come into contact with that information in order to carry out their jobs.

11. DATA RETENTION

11.1 I AM A WEBSITE VISITOR OR A DIGITAL PLATFORM / APP USER

11.1.1 Your personal data will not be retained longer than necessary for the purposes described above.

11.1.2 As a general rule, personal data obtained through the (online) services we offer are stored for a period of 10 years.

11.1.3 Depending on the specific situation and the applicable national legislation, we may however retain your personal data for a longer period. This will in particular be the case if any of the following periods is longer : (i) as long as is necessary for our daily business; (ii) any retention period that is required by law; or (iii) the end of the period in which litigation or investigations might arise.

11.2 I AM (A CONTACT PERSON OF) A SUPPLIER, A CUSTOMER (INCLUDING DEALERS, ARCHITECTS ETC.), A PROSPECT OR ANY OTHER INDIVIDUAL WHOSE PERSONAL DATA ARE PROCESSED (E.G. AN EXHIBITION VISITOR, AN AGENT, A BUSINESS CONTACT ETC.)

11.2.1 Your personal data will not be retained longer than necessary for the purposes described above.

As a general rule, records in the framework of our business activities that may contain personal data (e.g. contracts, orders, correspondence etc.) are stored for a period of 10 years.

11.2.2 Personal data processed for direct marketing purposes, are however stored for a period of 5 years as from the last contact with the individual concerned. If you have become a customer during this period, we may however retain your personal data for a longer period, namely 10 years as from the delivery of the products or services, or as from the latest contact with BuzziSpace (if this contact would take place at a later date).

11.2.3 Depending on the specific situation and the applicable national legislation, we may however retain your personal data for a longer period. This will in particular be the case if any of the following periods is longer : (i) as long as is necessary for our daily business; (ii) any retention period that is required by law; or (iii) the end of the period in which litigation or investigations might arise.

11.3 I AM A JOB APPLICANT

11.3.1 We will only hold your personal data for as long as it is necessary for the purposes described above. If the recruitment does not result in an employment relationship, your personal data will in principle be retained for a maximum period of one year after the end of the job application procedure for the purposes described above.

11.3.2 Depending on the specific situation and the applicable national legislation in the future country of employment, personal data may be retained for other periods than mentioned above. For instance, if the future country of employment is the Netherlands and the recruitment does not result in an employment relationship, your personal data will be retained for a maximum period of 4 weeks. With your consent, we will however retain your data for a period of one year for the purposes described above.

12. AUTOMATED DECISION-MAKING

12.1 Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.

12.2 As a rule, your personal data will not be used for automated decision-making. We do not base any decisions about you solely on automated processing of your personal data.

13. HOW TO CONTACT US?

13.1 We hope that this GDPR Privacy Statement helps you understand, and feel more confident about, the way we process your data. If you have any further queries about this GDPR Privacy Statement and this Site in general, please contact us at privacy@buzzi.space.

14. CHANGES TO THIS GDPR PRIVACY STATEMENT

14.1 We may modify or amend this GDPR Privacy Statement from time to time. Any changes we may make to this GDPR Privacy Statement in the future will be posted on this page. To let you know when we make changes to this GDPR Privacy Statement, we will amend the revision date at the top of this page. The new modified or amended GDPR Privacy Statement will apply from that revision date. Please check back periodically to see changes and additions.

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