Privacy notice — Shareholders

WDP commits itself to protect and respect your privacy and the privacy of everyone (employees and contractors) who is employed by you. Every reference in this privacy declaration to you — as being the tenant of WDP — or your personal data, has to be read as every person who is employed by you. 

This Privacy Notice describes the basis on which we will process all personal data that we collect from you or that you provide to us. You can find more information on our views and practices regarding your Personal Data and how we will use it in the Internal Data Protection Policy. 

In this Privacy Notice, the terms WDP, we or us refer to Warehouses De Pauw NV with company number 0417.199.869, established at Blakebergen 15, 1861 Wolvertem, Belgium. 

1. Data that we collect about you

We may collect and process the following data about you: name, telephone number, address, e‑mail address, nationality, bank account number, etc. 

In any case, the data we collect about you will be stored, used and protected pursuant to: 

  • the Belgian Act of 30 July 2018 relating to the protection of natural persons with regard to the processing of personal data; and 
  • Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), and all corresponding or equivalent national legislation or regulations in Belgium; 

as in force and applicable and as amended, completed or replaced from time to time (hereinafter jointly referred to as Data Protection Legislation”). 

2. Use of your information

We may use your information for the following purposes: preparation and management of attendance and voting procedures for shareholders’ meetings, analysis of the database of WDP shareholders and WDP’s participations, management of the register of registered shareholders and for sending notices, fulfilment of our contractual obligations towards our shareholders, payment of dividends and any other form of distributions to shareholders, live streaming of the image/​vote of certain shareholders who are physically present at a shareholders’ meeting, IT support, fraud prevention, dispute management, etc. 

3. Legal base

Your data is collected and processed on the following legal grounds: 

  • if this is necessary for the execution of the agreement we have with you (e.g. we have to store your contact details for the execution of the agreement with you as a shareholder); 
  • if this is necessary to comply with a legal obligation applicable to us (e.g. we have to store certain personal data to comply with our legal obligations to prepare for our shareholders’ meetings) 
  • if this is necessary for the protection of our legitimate interests, insofar as your fundamental rights and freedoms do not outweigh these interests (e.g. analysis of our shareholder database); 
  • where you have consented, for example where you have agreed to participate voluntarily in a survey of WDP shareholders; 
  • when the processing is necessary to safeguard your vital interests or those of another (natural) person. 

4. Communication of your data

In accordance with the purposes outlined above, we may share your data with: 

  • our branches/​other entities within the WDP Group; 
  • the authorities (including judiciary services and the police); 
  • banks and insurers; 
  • our professional advisors, such as lawyers; 
  • our suppliers of IT-related services, such as SAP; 
  • our suppliers of marketing-related services; 
  • our commercial partners, such as event organisations; 
  • if we are obliged to make your data available or share it in order to comply with a legal obligation or protect the rights, property or security of the WDP Group, our clients or others. This also covers exchanging data with the authorities (including judiciary services and the police) in the event of a cyber security incident, for example. 

5. Transfer of your data 

We may transfer your data to a destination outside the European Economic Area (EEA) if this is adequate (i) for achieving one of the purposes explained in clause 2 and/​or (ii) for making your data available to a third party in line with Article 4 of this Privacy Notice. 

If your data is transferred outside the EEA, we shall ensure that your data is protected using the following security mechanisms: 

  • the laws of the country to which your data is transferred, ensuring an appropriate level of data protection (Article 45 of the GDPR); or 
  • the transfer falls under the data protection clauses approved by the European Commission (Article 46(2) of the GDPR); or 
  • an approved data transfer agreement (Article 46(3) of the GDPR); data protection clauses adopted by the Belgian Data Protection Authority (Article 46(2) of the GDPR). 

If you would like more information about the transfer of your data outside the EEA and/​or the security mechanisms implemented (including the means through which you can receive a copy of said data), please contact us using the contact details included below in Article 10

6. Your rights

You have certain rights with regard to the data we store about you. These rights may be exercised by contacting us as outlined below: 

  • you have the right to access the data we store about you – this is because we wish you to be informed of the data we hold about you, and to enable you to verify whether we process your data in accordance with the applicable legislation and regulations relating to data protection; 
  • in certain circumstances, you have the right to block or cancel any further use of your data. If the processing is restricted in this way, we may still store your data but no longer use it; 
  • if your data is inaccurate or incomplete, you have the right to request your data be corrected; 
  • in certain circumstances, you have the right to request that your data be deleted or removed from our systems; 
  • you have the right to submit a complaint to your national data protection authority regarding the manner in which we deal with or process your data; 
  • if our processing of your personal data is specifically based on your consent, you have the right to withdraw this consent at any time. This includes, among others, your right to withdraw your consent for the use of your data for direct marketing purposes; 
  • insofar as the processing is carried out using automated means and if the processing is based on (i) the employee’s consent or (ii) the need for executing a contract, you have the right to receive from us your data in a structured, commonly used and machine-readable format so that you can reuse this data for your own purposes and for various services. 

You also have the right to object to certain types of processing, including processing for direct marketing purposes. 

Please note, however, that we may need to store certain data for legal or administrative purposes, for example (such as maintaining accounts). 

For all requests mentioned above, send us an e‑mail with the subject line Request relating to data privacy” and attach a copy of your identity card or another form of ID (such as a driving licence). By doing so, you will help us to prevent unauthorised access to your data and prevent your data from being amended or deleted. We will respond to your request as soon as possible and in any case within 30 working days of receipt. Should we, after receiving your request, need more than one month to respond to your request, we will contact you to inform you of this. Furthermore, you have the right to submit a complaint to your national data protection authority regarding the manner in which we deal with or process your request. 

7. Retention of your data

The data we hold on you will be stored in a manner that is in line with the applicable Data Protection Legislation. Under no circumstances will your data be stored for longer than necessary so as to achieve the purposes as set out in this Privacy Notice, unless: 

  • the processing of your data is required in relation to a current or potential dispute (for example, we need such data to take or defend against legal action), in which case we shall store your data until the end of such a dispute; and/​or 
  • the retention is essential for us to fulfil a legal or regulatory obligation (for tax purposes or publication obligations, for example), in which case we shall store your data for as long as is required by this obligation

8. What happens if you do not provide us with the requested data or if you ask us to stop the processing of your data?

Our option to fulfil our obligations arising from our agreement with you or the applicable legal obligations incumbent on you sometimes depends on the option to have access to and make use of certain data about you. If you therefore fail to provide us with the requested data or if you ask us to stop the processing of your data, this may involve us failing to meet one or more legal or contractual obligations. 

9. Automated decision-making

We will not use your data for any automated decision-making based on your data. 

10. Contact details

Questions, comments and requests relating to this Privacy Notice (including your privacy rights as mentioned above) should be sent to: 


Attn. Privacy advisor 

Blakebergen 15

BE-1861 Wolvertem 

[email protected](link sends e‑mail)privacy [at] wdp​.eu ?subject=Privacy%20request”>