Sodexo Belgium SA (hereinafter referred to as “Sodexo”) builds strong and lasting relationships with its clients, partners, consumers and employees, based on mutual trust: ensuring the security and confidentiality of their personal data is an absolute priority for SODEXO.
Sodexo complies with all Belgian and European regulations and legislation on the protection of personal data.
- Each user remains in control of his or her data. They are processed in a transparent, confidential and secure manner.
- Sodexo is committed to a continuous approach to the protection of its users' data, in compliance with the General Data Protection Regulation (EU) of 27 April 2016 (hereafter referred to as the "GDPR").
- Sodexo has a team dedicated to the protection of personal data, consisting of a Group Data Protection Officer declared to the CNIL and a network of contact points dedicated to the protection of personal data (called the “Local Data Privacy Contact”).
Object of the present policy
Sodexo attaches great importance to the protection of your Personal Data.
We have developed this policy to inform you of the conditions under which we collect, process, use and protect your Personal Data. Please read this policy carefully so that you are aware of what categories of Personal Data we collect and process, how we use them and with whom we may share them. This policy also describes your rights and how you can contact us to exercise them or to ask any questions you may have about your Personal Data.
This policy may be amended, supplemented or updated in order to comply with legal, regulatory, case law and technical developments. However, your Personal Data will always be processed in accordance with the policy in force at the time of collection, unless a mandatory legal requirement provides otherwise and is retroactive.
Identity and details of the controller
The Personal Data Controller is: Sodexo Belgium SA, a company duly incorporated and organised in accordance with the laws of Belgium, registered with the Crossroads Bank Enterprises under number BE 0407.246.778 and having its registered office at 15 Boulevard de la Plaine, 1050 Ixelles, Belgium.
“Personal Data” any information relating to a natural person who is identified or can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to that person.
“we” or “our” Sodexo Belgium SA (hereinafter referred to as “Sodexo”).
“you” any user of or visitor to the Website (being a Web App).
“Website” the Modern Recipe website available at the address https://modernrecipe.be
Collection and origin of personal data
We may collect your Personal Data directly (in particular via the collection forms available on our Website) or indirectly (in particular via our service providers and/or technologies on our Website).
We undertake to obtain your consent and/or to allow you to object to the use of your data for certain purposes, as soon as this is necessary.
Types of personal data which we collect and use
We may collect and process the following types of Personal Data in particular:
- the information you provide by completing the forms on the Website, in particular for the purposes of requesting information, registering and personalising your account (e.g. title, surname, first name, e-mail address, telephone number),
- the information you provide for authentication, connection and internet browsing purposes (e.g. identifiers, password, IP address, cookies, etc.),
- the information you provide for the purposes of managing and paying for an order or service (e.g. food preferences, bank transaction details, order delivery address etc.),
- the information relating to your online order (e.g. details of your consumption, prices and identification of the place of collection of the order),
- the information you provide through posts, comments or other content you post on the Website.
Unless indicated as optional, the Personal Data to be provided are mandatory and their absence will not allow your request to be taken into account.
Personal data which we collect automatically
We collect certain information automatically when you visit the Website in order to personalise and enhance your experience. We collect this information in a variety of ways, including:
A “cookie” is a small information file sent to your browser when you are on our Website and stored on your terminal. This file includes information such as the domain name, the Internet service provider, the operating system, and the date and time of the user's access. Cookies do not damage your terminal in any way.
Cookies are not used to determine the identity of an individual visiting our Website. Cookies allow us to determine your geographical location and language of display in order to improve your navigation. They also allow us to process information about your visit to the Website, such as the pages consulted and the searches carried out, in order to improve the content of the Website, to follow your interests and to offer you the most suitable content.
If you do not wish to receive cookies from our Website, you can configure your browser. Each browser has a different configuration for managing your choices. This is described in the help menu of your browser, which will tell you how to change your cookie preferences.
However, we recommend that you do not disable our cookies. Please bear in mind that if you block, turn off, or reject our cookies, some pages of our Website may not display properly or you may not be able to use some of the services offered to you. In this case, we decline all liability for the consequences linked to the degraded functioning of our services resulting from the impossibility for us to record or consult the cookies necessary for their functioning and which you would have refused or deleted.
Finally, by clicking on the icons dedicated to the social networks Twitter, Facebook, Linkedin and so on, appearing on our Website, and if you have accepted the deposit of cookies by continuing your navigation on the Website, the social networks concerned may also deposit cookies on your terminals (computer, tablet, mobile phone). These types of cookies are only deposited on your terminals if you consent to them, by continuing your browsing on the Website. However, at any time, you can withdraw your consent to the deposit of these types of cookies by these social networks.
An IP address is a unique identifier which some electronic devices use to identify themselves and communicate with each other over the Internet. When you visit the Website, we may use the IP address of the device you use to connect to the Website. We use this information to determine the general physical location of the device and to understand the geographic region from which visitors come to the Website.
The Website uses Google Analytics to generate statistical reports. These reports tell us, for example, how many users have visited the Website, which pages have been visited, and from which geographical region from which users come to the Website. Information collected through the use of statistics may, for example, include your IP address, the website from which you arrived at our Website and the type of device you are using. Your IP address is masked on our systems and will only be used as necessary to troubleshoot technical problems, to administer the Website and to understand the preferences of its visitors. Information about traffic on the Website is available only to authorised personnel. We do not use any of this information to identify visitors and we do not share it with third parties.
You can click on the icons for the social networks Twitter, Facebook, Linkedin and so on used on our Website.
Social networks help to improve the friendliness of the Website and help to promote it through sharing. Video sharing services allow us to enrich our Website with video content and increase its visibility.
When you click on these icons, we may have access to personal information which you have indicated as public and accessible from your profiles on the relevant social networks. However, we do not create or use any database independent of these social networks from the personal information you may post on them, and we will not process any of your personal data in this way.
If you do not want us to have access to the personal information published on the public area of your social profiles or accounts, you should use the means made available by the social networks concerned to limit access to such data.
Purposes for which we use personal data
|No||Purpose of processing||Legal basis||Data retention period|
|1||To manage and process requests for the creation and management of Website accounts||The conduct and management of our contractual relationship with you and/or our client (your employer)||Up to 12 months from the last activity or deletion of the account by us or its user|
|2||To provide the services ordered on the Website||The conduct and management of our contractual relationship with you and/or our client (your employer)||Up to 5 years from the last activity or the end of our contractual relationship with your employer|
|3||To respond to your requests, such as for information or research||The conduct and management of our contractual relationship with you and/or our client (your employer)
Our legitimate interest in improving the quality and operational excellence of the services we offer you
|Up to 12 months from the last contact|
|4||To enable you to consult your balance and/or your history, your consumption||The conduct and management of our contractual relationship with you and/or our client (your employer)||Until your account is deleted|
|5||To provide you with offers for our products and services and/or those of our partners||Our legitimate interest in improving the quality and operational excellence of the services we offer you
Your consent to receive offers from our partners
|Up to 3 years from the date of collection of the data or the last contact from you|
|6||To conduct surveys||Our legitimate interest in improving the quality and operational excellence of the services we offer you||Up to 12 months from the last contact|
|7||To personalise and improve your experience on our Website||Our legitimate interest in improving the quality and operational excellence of the services we offer you||Up to 12 months from the last contact|
|8||To conserve your credit card data by our secure payment provider in order to facilitate your future transactions on the Website||Your consent||Until you withdraw your consent and/or the validity of the credit card data expires|
|9||To conserve data on your receipts and/or consumption for tax or accounting purposes||The fulfilment of certain legal obligations||Up to 10 years|
Within the context of the provision of certain services (e.g. payment, meal delivery, etc.), the Website may redirect you to mobile applications and/or to websites managed by third parties (hereinafter referred to as the “Platforms”). These services are provided to you by our partners (e.g. Mollie BV for payment transactions made on the Website etc.) and are governed by their separate privacy policies. Our partners are responsible for collecting and processing any Personal Data which you submit or provide to them in order to benefit from their services. They are also responsible for creating and administering the account(s) which allow you to access their Platforms. To this end, some of your Personal Data such as your name, first name and e-mail address may be communicated to them for the purpose of creating such account(s). If you have any questions about the conditions under which your Personal Data is collected and processed by our partners and to know in particular what your rights are (access, rectification etc.) and how to exercise them, please consult the privacy policies available on their Platforms.
Legal basis for the processing of personal data
We process your Personal Data within the context of the conduct and management of our contractual relationship with you, our legitimate interest in improving the quality and operational excellence of the services we provide to you, or to fulfil certain regulatory obligations.
Your data may also be processed on the basis of your prior consent in the event that you are asked for it in certain situations.
Communication of personal data
The security and confidentiality of your data is of great importance to us. For that reason, we restrict access to your Personal Data to those members of our employees who need to know that information in order to process your request or to provide you with the requested service.
We do not disclose your Personal Data to unauthorised third parties. We may, however, share your data with entities of the Sodexo group and authorised service providers (e.g. technical providers (hosting, maintenance), consultants etc.) which we use to provide our services. We do not authorise these service providers to use or disclose your Data except to the extent necessary to provide the services on our behalf or to comply with legal obligations. In addition, we may share Personal Data about you (i) if we are required to do so by law or legal process, (ii) in response to a request from public authorities or other government officials, or (iii) if we believe that disclosing such data is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity.
Data retention period
We will keep your Personal Data for no longer than is necessary for the purposes for which it is collected and processed, extended, where appropriate, by the periods of applicable legal or regulatory requirements.
Sensitive personal data
As a general rule, we do not collect Sensitive Personal Data through our Website. “Sensitive Personal Data” is considered to be any information concerning racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, health data, or data concerning the sex life or sexual orientation of an individual. This definition also includes Personal Data relating to criminal convictions and offences.
Personal data and minors
The Website is intended for people of legal age who are capable of entering into obligations in accordance with the legislation of the country in which you are located.
Users under the age of 16 or those who are otherwise incapable must obtain the prior consent of their legal guardian before entering their data on the Website.
The age of 16 may be lowered to 13 depending on the local legislation of your habitual residence.
Transfers of personal data
Considering the international nature of the Sodexo group, your Personal Data may be transferred to internal or external recipients authorised to provide services on our behalf which may be located in countries outside the European Union or the European Economic Area which do not offer an adequate level of protection of Personal Data.
In order to guarantee the security and confidentiality of Personal Data transferred in this way, we take all necessary steps to ensure that such data is adequately protected, such as signing the European Commission's Standard Contractual Clauses or any other equivalent mechanism.
Sodexo is committed to facilitating the exercise of your rights in accordance with the applicable regulations. You will find below a table summarising the various rights available to you:
|RIGHT OF ACCESS AND RECTIFICATION||You may request a copy of the Personal Data we hold about you. You may also request that inaccurate Personal Data be corrected or that incomplete Personal Data be completed.|
|RIGHT TO DELETION / RIGHT TO BE FORGOTTEN||
Your right to be forgotten allows your Personal Data to be deleted when:
|RIGHT TO LIMITATION OF PROCESSING||
You can request that the Processing is limited when:
|RIGHT TO DATA PORTABILITY||
Where applicable, you may request the portability of your Personal Data provided to Sodexo in a structured, commonly used and machine-readable format, and have the right to transmit such Personal Data to another Data Controller without Sodexo's interference, when:
|RIGHT OF OBJECTION||You have the right to object to (“opt-out” of) the Processing of your Personal Data (including profiling or marketing communications). Where we Process your Personal Data on the basis of your consent, you may withdraw your consent at any time.|
|RIGHT NOT TO BE THE SUBJECT OF AUTOMATED DECISIONS||You have the right not to be subject to a decision based exclusively on automated processing, including profiling, which produces legal effects concerning you or which affects you in a similar significant manner.|
|RIGHT TO MAKE A COMPLAINT||You may choose to make a complaint to the supervisory authority in the country where you are ordinarily resident, where you work, or in the country where a violation is alleged to have occurred. You also have the right to take legal action in the courts of the country in which the Sodexo entity has a place of business or in the country where you are ordinarily resident.|
To exercise these rights, please complete the form on this link: Privacy Web Form (onetrust.com). You may also send your Request to your Local Data Privacy Contact at email@example.com and/or to the Group Data Protection Officer at firstname.lastname@example.org.
We implement all technical and organisational measures to ensure the security and confidentiality of the processing of Personal Data.
In this respect, we take all the necessary precautions, with regard to the nature of the Personal Data and the risks presented by the processing, in order to protect the security of the data and, in particular, to prevent them from being distorted, damaged or accessed by unauthorised third parties (physical protection of the premises, authentication procedures with personal and secure access via confidential identifiers and passwords, logging of connections, encryption of certain data and so on).
Links to other websites
If you have subscribed to certain services through our Website and do not wish to receive future emails, please visit the unsubscribe page for the subscription for which you have signed up.
How to contact us
If you have any questions or comments regarding this policy, please feel free to contact the Local Data Privacy Contact at the following address: email@example.com.
Last update: 8 July 2021