Privacy
1. Introduction
The Shinka IT company (referred to as “Shinka IT”, “we” or “our” below) places great importance on protecting and respecting your privacy.
This Privacy Policy is intended to provide you with transparent information about how we collect, use, and protect the personal data of:
- visitors to our website;
- job applicants;
- employees;
- as well as anyone who interacts with our services.
This policy complies with Regulation (EU) 2016/679 (GDPR) and is part of our Information Security Management System (ISMS).
Use of this website constitutes acceptance of this policy.
2. Data Controller - Data Protection Officer (DPO)
Shinka IT has appointed a Data Protection Officer (DPO): Florence Jonet, HR Manager.
The DPO is responsible for:
- overseeing compliance with the GDPR;
- advising the organization on data protection obligations;
- being involved in activities that impact the processing of personal data;
- participating in the governance of the information security management system (ISMS);
- ensuring the traceability of data protection-related actions.
Rue Toussaint Gerkens, 69 – 4052 Beaufays
Email : rh@shinka.be
Phone : +32 4 228 22 50
3. Categories of data collected
We collect only the data necessary for the purposes described below.
3.1. Data collected via the website
- identification data: last name, first name, email address, phone number, company;
- browsing data: IP address, server logs, website behavior;
- demographic data (if applicable);
- professional data.
3.2. Data collected for HR purposes
3.2.1. Recruitment
- CVs, cover letters;
- contact information and professional background;
- data from LinkedIn or professional platforms;
- interview notes and test results;
- history of interactions.
3.2.2. Employee management
- personal information;
- employment contracts, amendments;
- administrative, financial, and payroll data;
- evaluations, training.
3.2.3. Legal Compliance
- supporting documents: identification documents, diplomas, certificates;
- mandatory employment-related documents.
3.2.4. Relations with HR Service Providers
- contact information, contracts, invoices.
4. Purposes of processing
We use personal data for:
4.1. Website-related activities
- responding to inquiries via the contact form;
- tracking communications;
- sending newsletters (based on consent);
- ensuring system security (logs, anomaly detection).
4.2. Recruitment
- evaluate applications;
- manage recruitment processes;
- search for and shortlist candidates;
- verify identity and qualifications.
4.3. Employee management
- manage employee records;
- handle payroll, benefits, and training;
- manage personnel administration.
4.4. Legal Obligations and Compliance
- comply with legal and regulatory obligations;
- ensure traceability and GDPR compliance;
- manage requests from data subjects.
4.5. Continuous Improvement
- analyze HR processes;
- generate internal statistics (anonymized data).
5. Legal basis for processing
The basis for processing is:
- performance of a contract or pre-contractual measures (recruitment, HR management);
- legal obligations (labor law, accounting, taxation);
- legitimate interests (improving services, handling requests, security);
- consent (newsletter).
6. Access to data and recipients
Personal data is accessible only to authorized individuals:
- HR department;
- management;
- relevant managers;
- IT team (limited access for technical reasons);
- internal staff responsible for managing and maintaining the website, strictly within the scope of their duties.
Data may be shared with contractually bound subcontractors, to the extent necessary for their duties.
No data is shared outside the organization without consent, unless required by law.
All access is subject to control and traceability measures in accordance with the ISMS.
7. International transfers
Data is generally stored within the European Union.
In the event of a transfer to a third country:
- appropriate safeguards are put in place;
- in particular through the European Commission’s standard contractual clauses.
8. Retention periods
Data is retained only for as long as necessary to fulfill the purposes for which it was collected.
8.1. Website
- contact requests: 2 years;
- newsletter: until consent is withdrawn ;
- logs: a period appropriate for system security.
8.2. Recruitment
- unsuccessful candidates: 2 years after last contact;
- interview notes: 2 years;
- sourcing (LinkedIn, CV databases): 2 years;
- interactions: 2 years.
8.3. Administrative and contractual records
- contracts and HR documents: 5 years after contract termination;
- vendor data: 10 years (accounting requirement).
8.4. Employee data
- During the employment relationship;
- then in accordance with legal obligations (payroll, workplace accidents, etc.).
8.5. Statistical data
- Retained in anonymized form;
- Processing at the end of the retention period:
- Deletion;
- Anonymization;
- Legal archiving if required.
9. Data Security and Governance
Shinka IT implements appropriate technical and organizational measures to ensure:
- confidentiality;
- integrity;
- data availability.
Data processing activities are integrated into an ISMS.
Operations related to the management of personal data are documented and traceable through internal records, which enable us to demonstrate compliance with regulatory requirements and internal procedures.
10. Your rights
-
In accordance with the GDPR, you have the following rights:
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restriction of processing;
- the right to object;
- the right to data portability;
All requests are:
- recorded;
- processed;
- tracked in accordance with internal procedures;
11. Exercising Your Rights and Contact Information
For any questions or requests regarding your personal data:
- HR email: rh@shinka.be;
- form: https://www.shinka.be/en/contact
12. Cookies
For more information: Cookie Policy
13. Links to other websites and social media platforms
Our website may occasionally contain links to the websites of our partners or third-party companies. Please note that these websites have their own privacy policies, and we are not responsible for how they use the information collected when you click on these links. We encourage you to review the privacy policies of these websites before providing them with your personal information.
14. Changes to the Privacy Policy
We may occasionally make changes and corrections to this Privacy Policy. If we believe these changes are significant, we will notify you by one (or more) of the following means: (1) by posting the changes on this site, or (2) by sending you an email or message regarding these changes. We will also give you the opportunity to consent to these significant changes. The changes will take effect as soon as they are communicated and you have accepted them; such consent may be implied by your continued use of the site after the changes have taken effect.
However, in the event of a substantial modification to this Privacy Policy, Shinka IT will inform the individuals concerned of the nature of the changes, particularly when personal data is used for new purposes.
This privacy policy is reviewed at least once a year and whenever a significant change occurs in the processing of personal data or in applicable legal and regulatory requirements.
Last review: June 12, 2026.