Charles De Wit Holding



Privacy statement

This privacy statement applies to all companies belonging to the De Wit group (hereinafter “Group De Wit”), in particular: 

Charles De Wit Holding NV 

De Wit Bunkering NV 

Belgian Trading and Bunkering B.V.

Nassau Scheepenodigdheden B.V.

De Wit Transport B.V.


Groep De Wit wishes to deal responsibly with the privacy and personal data of its customers, prospects, suppliers, their employees, its own employees, job applicants and visitors to its website and social media.

This privacy statement describes how we collect, process, store and protect personal data.

What personal data do we collect?

The personal information we collect may include, but is not limited to:

Surname and first name



Telephone and/or mobile number

E-mail address

Date of birth


Job title and employer

Marital status and family composition

Career and training


Financial and fiscal data

Specific requests made by the person concerned

Contractual agreements

IP address

Browser type

Language preference

Posts on the social media applications we run (facebook, instagram, blogs, forums, etc.)

Data on online behaviour and preferences

Audiovisual data

Data relating to the products and services provided

Other relevant information

It is also possible that we collect personal data that are of a so-called “sensitive” nature (special categories of data), such as:

health (e.g. a disability or other specific medical condition that we have to take into account (allergy, …) when the data subject enters our premises or when we organise a business lunch)

Our products, services and website are not directed or tailored to children. Therefore, we do not collect and store personal data from children in an actively intentional manner, except for any of our employees.

The personal data we process always depends on the specific circumstances, for example the nature of the service or product that we are required to provide, the legal obligations to which we are subject, the legitimate interests that we have or the specific permission that you have given us to do so.

From whom we collect personal data

Among other things, we collect personal data from:

our customers, suppliers, business contacts and prospects (or of our contacts with the latter);

from contacts at government agencies and other (public) institutions;

of our employees and job applicants;

visitors to our website and social media;

visitors to our buildings;

family members of our employees.



How do we collect personal data?

We collect personal information in a variety of ways, particularly personal information we receive:

from the individual concerned;

from the employer or client of the person concerned (for example, if our client or supplier is a company and the person concerned is designated by this company as a contact person, from the temporary employment agency that employs our temporary employees);

of other parties (e.g. government agencies, head-hunting offices, etc.);

through the use of our website, social media and other tools;

publicly available information.




Why do we process personal data?

Except in those situations where we process personal data on the basis of consent, we may process personal data for the following purposes and on the basis of the following legal grounds (this is not an exhaustive overview):

Delivery of products or services to our (potential) customers

We process personal data within the framework of the delivery of our products and/or services to our (potential) customers (contract/pre-contractual stage/justified interests). Personal data is processed in the context of the provision of products or services to the data subject itself, to the employer or client of the data subject (e.g. our customers and prospects) or to the data subject’s contracting party (e.g. our customers and prospects).

Compliance with our legal obligations

In some cases, we have a legal obligation to process certain personal data, for example:

As an employer, we are obliged, among other things, to collect certain data (such as the national register number, the marital status and family situation of our employees) and, if necessary, to pass it on to the competent government authorities.


Administrative and financial processing

Based on our legitimate interests and legal obligations, we process personal data within the framework of our own administrative, accounting and corporate law obligations.


Personnel administration and employee recruitment

As part of our personnel administration, we must process data relating to our employees and former employees (contract/legal obligation).

With a view to hiring new employees, we collect personal data from

Personnel administration and recruitment of employees

As part of our personnel administration, we must process data relating to our employees and former employees (contract/legal obligation).

With a view to hiring new employees, we collect personal data from job applicants (contract and, where applicable, consent for data provided to us voluntarily, but without necessity and unsolicited, by the job applicant).

Direct marketing

We have a legitimate interest in processing our customers’ (or our customers’ contacts’) personal data for the purpose of sending, by electronic means, advertising messages, newsletters, invitations to commercial events and the like, provided they relate to similar products and services.

For all other marketing campaigns by electronic means, we always ask the consent of the person concerned.

Finally, we have a legitimate interest in carrying out marketing campaigns by non-electronic means.


Collection of personal data via our website

We have a legitimate interest in processing personal data of the data subjects:

who leave their data on our website in order to fulfil their specific request;

who visit our website within the framework of the management and improvement of our website. In this context, we refer to our cookie policy.


Internal risk analyses, audits and penetration tests

We have a legitimate interest in processing personal data in the context of internal risk analyses, audits and penetration tests, which take place either on our own initiative or on the initiative of any third party who is legally (e.g. the competent data protection authority) or contractually entitled to do so.

To whom do we transfer personal data?

Except with your consent or when necessary for the delivery of our product/service, we do not transfer personal data to commercial partners.

Furthermore, we transfer personal data to our own processors (e.g. the social secretariat, ICT and social media partners, etc.) on the basis of a processing agreement, our other advisors acting as data controllers (e.g. our lawyer, our accountant, etc.), governmental and judicial authorities and inspection services (professional or governmental).

Subject to your consent, if this is necessary for the provision of our services or if we are required to do so by law (e.g. pursuant to an enforceable judgment or ruling), we will not transfer data to recipients located in third countries (non-EU countries).

If for any of the above reasons we need to transfer personal data to a recipient located in a third country, we will comply strictly with the legal obligations associated with such transfer.

How long are personal data stored by us?

We retain personal data as appropriate:

until the end of our liability period after the provision of our products and/or services;

as long as we are legally obliged to retain the personal data;

in the event of a legal dispute, administrative or arbitration procedure, until a final decision has been made within the framework of this procedure, unless we are required by law to retain the personal data for a longer period of time;

in all other cases, for a reasonable and proportionate period of time.


How are your personal data secured?

We have developed a security policy, which is tested and adjusted at regular intervals, as part of which technical and organisational measures have been taken to this end:

raise awareness about the handling of personal data among our employees and other staff and adjust it from time to time (through checks and periodic training courses);

limit access to personal data (both from an organisational and IT point of view);

secure personal data (by means of appropriate IT technical measures, taking into account the state of the art, the associated costs and the risks of processing, such as encryption, anti-virus software, firewalls, transmission via secure connections, etc.);

ensure the accuracy of the data;

guarantee the confidential treatment of personal data;

prevent, detect and remedy data breaches (i.e. accidental or unlawful destruction, loss, alteration, disclosure of or access to the personal data transmitted, stored or otherwise processed), to the extent possible.


What are your rights as a data subject?

As a data subject, whose personal data we process, you have the following rights:

Right to transparency (right to be informed in a clear and comprehensible language


What are your rights as a data subject?

As a data subject, whose personal data we process, you have the following rights:

Right to transparency (right to be informed in a clear and comprehensible language about the processing of your personal data by our offices);

Right of access, correction and deletion of your personal data;

Right to transfer your data in a usual machine-readable format;

Right to withdraw your previously given consent;

Right to request the restriction of the processing or to object to the processing;

Right to complain to the competent data protection authority.

We must point out that these rights are not always absolute, that in certain circumstances we are entitled or even legally obliged to further process your personal data and that therefore we cannot always (fully) fulfil your request. In that case we will inform you about this.

You can exercise these rights free of charge, except in the event of abuse, in which case we are entitled to charge an administration fee to meet your requests.

For all questions relating to the exercise of your rights, please contact us:

(insert contact details)


Amendments to this privacy statement

We have the right at all times to amend this privacy statement in order to bring it into line with (amendments to) the relevant legislation, national and international official positions and court rulings.

You can find the most recent version of this privacy statement on our website at all times.