1. Purpose of our privacy policy
The privacy policy aims to inform visitors to the INDUSTEEL website and its prospects about the use of their personal data.
This privacy policy intended for users of the INDUSTEEL site is available from the platform.
For information, the ArcelorMittal Group, of which Industeel is part, also has a data protection policy which is available on our website (see link via the cookies policy)
2. Definitions from the GDPR (General Data Protection Regulation)
The following definitions are those taken from the General Data Protection Regulation (GDPR) and the Data Protection Act.
Personal data
Personal data is any information relating to an identified or identifiable natural person. This person can be identified directly (example: first and last name) or indirectly (example: by a telephone number or license plate, an identifier such as the social security number, a postal or email address, but also voice or the image), thanks to a single piece of data or the crossing of several of them (example: a woman living at a given address, born on a given day and member of a given association).
Recipient
The natural or legal person, public authority, service or other body authorized to obtain communication of data recorded in a file or processing due to its functions.
File
A file is a process of data that is organized into a stable and structured set of data. The data in a file is accessible according to specific criteria.
Data controller
The data controller is the legal person (company, municipality, etc.) or natural person who determines the purposes and means of processing, i.e. the objective and the way of achieving it. In practice and in general, this is the legal person embodied by its legal representative.
Subcontractor
The subcontractor is the natural or legal person (company or public body) which processes data on behalf of another organization (“the data controller”), as part of a service or provision.
Treatment
Processing of personal data is an operation, or set of operations, relating to personal data, whatever the process used (collection, recording, organization, conservation, adaptation, modification, extraction, consultation, use, communication by transmission or dissemination or any other form of provision, reconciliation).
Processing of personal data is not necessarily computerized: paper files are also concerned and must be protected under the same conditions.
Data processing must have an objective, a purpose determined prior to data collection and to their exploitation.
3. What is the role of INDUSTEEL?
As part of the management of our website, we act as data controller. In this case, we decide why (purposes) and how (means) your data is used.
A preferred contact for personal data protection can be contacted at the following address: dpo.industeelbelgique@arcelormittal.com for Industeel sites located in Belgium or dpo.industeelfrance@arcelormittal.com for sites located in France.
4. How is your personal data collected?
➢ We collect the personal data that you communicate directly to us:
By responding to our collection forms available on our site, you transmit your personal data to us. This includes your first and last name, the company you work for, your professional telephone number and email.
We also process the data that you communicate to us during our remote (phone call or sales meeting) or physical (meetings, trade fairs, events) exchanges.
The data thus collected by INDUSTEEL is either mandatory or optional. The mandatory nature is identified within each of the forms by an asterisk for each of the fields concerned. When the data is collected orally, we will tell you whether the information is mandatory or optional. All the data that you spontaneously communicate to us are, by definition, optional.
➢ We collect some of your personal data automatically
When you visit the Site, we collect some of your browsing data automatically, others are collected when you give us your consent. For more information, refer to our cookies policy.
➢ We collect some of your personal data indirectly:
This is the case for commercial prospecting activities only. This is professional data:
· From your profiles on the professional social networks you use,
· Publicly accessible (including public contact details contained in open data databases),
· Communicated by partners, third parties or service providers in the context of connections.
This data can be enriched by a service provider who reconstructs the structure of professional email addresses using information available on the internet.
This personal data is used to send you information about our services and our news to the extent that we have considered that this information has a direct link with your professional activity.
5. For what purpose and for how long do we use your personal data?
The table below summarizes all the processing for which INDUSTEEL may use your personal data. Certain processing operations are only valid in the case of our commercial prospecting activities.
| Treatement Name | Purposes | Legal bases | Concerned data | Duration of the retention |
| Website management | • Technical administration of the Site (maintenance, accommodation); • Securing the Site; • Improvement of the user experience and interactivity of the site (links to social networks); • Production of audience and service usage statistics. | Legitimate interest: manage the showcase site and make it available to secure manner; • Consent for third-party cookies. | Legitimate interest: manage the showcase site and the make available to secure manner; • Consent for third-party cookies.. | 13 months |
| Website forms | Process your request and provide you with information | Legitimate interest: managing interactions with the public (customers and prospects) and allow us to respond to requests addressed to us | • Identity data and contact ; • Data relating to professional life.. | 3 years from last contact in active base then archived at probationary title for 5 years |
| Prospecting management | • Contacting prospects to offer goods and services | • Legitimate interest: promote the activity and services to professionals concerned; • Consent for third-party cookies (LinkedIn) | • Identity data and of contact ; • Data relating to professional life | 3 years from last contact in base active then archived at probationary title for 5 years |
6. Who is your personal data intended for?
➢ Within INDUSTEEL (internal recipients)
Depending on the subject of your request, your personal data is processed by employees of the following INDUSTEEL services:
– Commercial
– Communication
– HR
– Environment
In all cases, only the data strictly necessary for carrying out the processing in question are transmitted only to employees authorized to know it due to their functions. All persons likely to have access to your Personal Data are subject to an obligation of confidentiality.
➢ Transfers outside INDUSTEEL (external recipients)
Several categories of third parties referred to below may have access to your personal data (service providers, partners, suppliers, distributors, subcontractors). Only strictly necessary personal data is transmitted to them for the purpose(s) pursued by the envisaged processing.
· Our IT subcontractors:
§ In charge of the administration and maintenance of the Site,
§ Provision of analysis and advertising tools,
· Companies providing third-party cookies to which you give your consent for their installation (see cookie policy).
· Exceptionally, the competent authorities (administrative, judicial, police) due to a legal obligation or to guarantee the rights, property or safety of INDUSTEEL.
We ensure that in terms of Personal Data, our subcontractors contractually undertake to implement a level of protection equivalent to ours and that they are, in any case, compliant with the Regulations.
➢ The use of your data by third-party platforms
Our site may contain links to other sites over which we have no control. We encourage our users to read the privacy policies of the websites and applications with which they may interact.
➢ Transfer outside the EU
The personal data you provide to us via contact forms is intended for services located in the EU. However, depending on the evolution of commercial exchanges, your data may be communicated to our Industeel commercial agencies located outside the EU.
This data transfer will comply with regulations because the ArcelorMittal Group has Binding Corporate Rules (BCR) in accordance with Article 47 of the GDPR. And Industeel adheres to these BCRs as a subsidiary of the ArcelorMittal Group.
7. What are your rights regarding your personal data?
7.1 Right of access
You have the right to obtain confirmation from INDUSTEEL that personal data concerning you are or are not being processed. In the event that the data is processed, you have a right of access to this data and the following information:
· The purposes of the processing;
· The categories of personal data concerned;
· The recipients or categories of recipients to whom the data have been communicated or will be communicated;
· The planned retention period of the data if this is possible, or when this is not possible, the criteria used to determine this duration;
· The right to request from INDUSTEEL the rectification or erasure of data concerning you, the limitation of processing or the right to object to processing;
· The right to lodge a complaint with the CNIL or the APD;
· Where personal data is not collected from you directly, any information available about the source;
· The existence of automated decision-making, including profiling and, at least in such cases, meaningful information regarding the underlying logic, as well as the significance and intended consequences of such processing for you.
Finally, when personal data is transferred to a third country or an international organization, you have the right to be informed of the appropriate guarantees regarding the transfer.
We will provide you, upon request, with a copy of the data being processed.
If you request a copy of the data by email, INDUSTEEL will provide it in commonly used electronic form unless you request otherwise.
Finally, the right to obtain a copy of personal data must not infringe the rights and freedoms of others.
7.2 Right of rectification
You can ask INDUSTEEL to rectify any data that is inaccurate, as soon as possible. You also have the option of having incomplete personal data concerning you completed, including by providing an additional declaration.
7.3. Right to erasure
You have the right to erasure of your personal data as soon as possible when one of the following reasons applies:
· The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
· You withdraw your consent on which the processing is based and there is no other legal basis for the processing in question. Withdrawal of consent applies for the future;
· You exercise your right to object and there is no overriding legitimate reason for the processing;
· Personal data has been the subject of unlawful processing;
· Personal data must be erased to comply with a legal obligation;
· Personal data was optional.
You are informed that the right to erasure may not apply if processing is necessary:
· To comply with a legal obligation,
· To establish, exercise or defend legal rights.
7.4. Right to restriction of processing
You may request restriction of processing of your personal data where one of the following applies:
· A verification of your data is necessary after a dispute on your part regarding the accuracy of your personal data;
· The processing is unlawful and you object to the erasure of your personal data and demand the limitation of their use;
· INDUSTEEL no longer needs the personal data concerning you for processing but the data is necessary for you to establish, exercise or defend legal rights;
· You have opposed the processing and INDUSTEEL verifies whether the legitimate reasons pursued by it prevail over your legitimate reasons.
7.5. Right to portability
You may request to receive the personal data you have provided to INDUSTEEL in a structured, commonly used and machine-readable format when, cumulatively:
· Processing is based on consent or a contract;
· Processing is carried out using automated processes.
As part of the exercise of this right, you have the right to obtain from INDUSTEEL that your personal data be transmitted directly by INDUSTEEL to another data controller when this is technically possible.
The right to portability must not infringe the rights and freedoms of third parties. 6.6. Right to object
Pursuant to the right to object, you have the right to object at any time, for reasons relating to your particular situation, to the processing of personal data based on the legitimate interests of INDUSTEEL.
INDUSTEEL will no longer process your personal data unless it demonstrates that legitimate and compelling grounds for the processing exist and prevail over your interests and your rights and freedoms or for the establishment, exercise or defense of your legal rights.
You have the right to object at any time to the processing of your personal data for prospecting purposes. You can do this completely free of charge.
7.7. Regarding consent
You can withdraw your consent for processing based on this legal basis at any time.
This withdrawal of consent has no impact on the legality of processing of Personal Data carried out on the basis of your consent before its withdrawal.
Please also note that Personal Data whose processing is required to respond to your requests or provide the requested services are systematically marked with an asterisk on the collection form. Without this information, INDUSTEEL will not be able to respond to your requests or provide the products or services requested.
7.8. Fate of personal data after death
In application of the law, you have the right to define your directives relating to the conservation, erasure and communication of your personal data in the event of death.
You can communicate your instructions to us or register them with a certified digital trusted third party. You can designate the person of your choice who will be responsible for carrying out your instructions. Otherwise, it will be your heirs.
8. How to exercise your rights?
8.1. Conditions for exercising rights
You can send your requests:
· By email to the address dpo.industeelbelgique@arcelormittal.com for Industeel sites located in Belgium or dpo.industeelfrance@arcelormittal.com for sites located in France.
If the information communicated as part of your request does not allow INDUSTEEL to identify you with certainty, we may ask you for additional information allowing you to be identified with certainty.
8.2. Response time
INDUSTEEL has one (1) month to respond to you from receipt of your request. This period may be extended by two months due to the complexity of your request and the number of requests made to it; if necessary, you will be informed at the latest within one (1) month following your request.
Concerning commercial offers sent electronically, you have the option of unsubscribing at any time by clicking on the hyperlink available in each of the emails sent by INDUSTEEL.
You also have the right to lodge a complaint with the CNIL, the supervisory authority (www.cnil.fr):
CNIL – Complaints Department – 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07
Or submit a complaint to the APD (Data Protection Authority): www.autoriteprotectiondonnees.be
APD – Take action/submit a complaint – Rue de la Presse, 35 – 1000 BRUSSELS
9. Policy Change
This privacy policy may be subject to change.
Date this privacy policy was updated: May 15, 2024