Privacy Notice
Our Privacy Notice
Last modified: Fri 23 May 2025.
First of all, we are excited that you are interested in our products and services. This privacy statement describes how we use the Personal Data you provide us with.
We may ask you to share certain Personal Data with us, including but not limited to your first name, last name and e-mail address (identification data). For certain specific obligations you may be required to provide us with additional data, such as billing or payment data.
We only collect Personal Data that is necessary to inform you about our products and services, to execute an agreement with you and to contact you.
For this purpose, we base ourselves on the processing grounds of the agreement, the legal obligation, our legitimate interest and, in some cases, your consent (see also section 2).
The processing of your Personal Data is subject to this privacy statement. For questions and/or comments, please contact privacy@novemberfive.co.
By providing your Personal Data, you are deemed to have acknowledged the use of your Personal Data in accordance with this privacy statement.Article 1: Definitions
"Affiliated Company" means any company that is affiliated to November Five insofar as it meets the conditions for an "affiliated company" as set out in article 1:20 of the Belgian Companies Code.
"Controller" has the meaning as defined in the General Data Protection Regulation 2016/679. November Five will be qualified as the Controller, which determines the purposes and means of the processing of Personal Data.
"November Five" is the tradename/company name of November Five BV, a limited liability company organized and existing under the laws of Belgium, having its registered office at 2000 Antwerp (Belgium), Scheldestraat 11 and registered in the Register of Companies under number 0820.822.413.
"Personal Data" has the meaning as defined in the General Data Protection Regulation 2016/679, which is any information relating to an identified or identifiable natural person (also called the "data subject").
"Processor" has the meaning as defined in the General Data Protection Regulation 2016/679, which processes Personal Data on behalf of the Controller.
"Website" means the website of November Five: (www.novemberfive.co).
Article 2: Purposes and legal grounds
Client data
In relation to providing our products and services and our activities we collect and process the identification and contact data of our clients, their employees, associates and appointees. The data may be processed for the purposes of execution of the agreement with our clients, client management, accounting and direct marketing activities. The legal grounds for this processing are the execution of an agreement, compliance with a legal obligation, our legitimate interest and, in some cases, your consent.
Data of suppliers and subcontractors
We collect and process the identification and contact data of our suppliers and subcontractors. The legal grounds for this processing are the execution of an agreement, compliance with a legal obligation and/or our legitimate interest.
Data of employees
The data of our employees may be processed for the purposes of staff management and payroll administration. The legal grounds for this processing are the execution of an agreement and compliance with legal obligations.
Data of applicants
We process the identification and contact data, as well as the work history and other data of applicants. The Personal Data is processed to determine whether you qualify for a job with us on the ground of our legitimate interest.
Other data
We also process Personal Data of others, such as possible new clients/prospects, useful contacts within our sector, network contacts, expert contacts, etc. The legal grounds for this processing are our legitimate interest, the execution of an agreement and, in some cases, your explicit consent.Article 3: The confidentiality of your Personal Data
Every time you submit Personal Data, we shall handle this information in accordance with the stipulations of this privacy statement and the legal obligations within the scope of the processing of Personal Data, including the General Data Protection Regulation (GDPR) 2016/679.
We establish reasonable measures and procedures to secure and protect the Personal Data we collect. We seek to optimize the security of your Personal Data by limiting the access to persons on a "need-to-know" basis.
Article 4: How do we collect your Personal Data and for how long is it kept?
Collection of data
We collect your Personal Data when you submit it via the Website, when you enter into an agreement with us, when you apply for a position, or when you contact us.
Retention of data
Client data and supplier data will be removed 7 years after the termination of the agreement. Employee data will be removed 5 years after the termination of employment. Applicant data will be removed after the vacancy has been filled or 2 years after obtaining consent. Other data will not be stored longer than 2 years after the last useful contact.
Article 5: Transfer of Personal Data
We will not transfer Personal Data to third parties outside the European Economic Area, except to subcontractors or associates who retain the Personal Data in accordance with the European Commission's Standard Contractual Clauses. We will not transfer Personal Data inside the EEA without your permission, except when necessary for Affiliated Companies or required by applicable laws.
Article 6: Rights of the data subject
By virtue of Belgian and European legislation concerning data protection, you have the right of access to your Personal Data, the right to withdraw consent, and the right to complain to a supervisory authority. To exercise these rights, send a written request and a copy of your ID to privacy@novemberfive.co. You can file a complaint with the Data Protection Authority at contact@apd-gba.be.
Article 7: Third-party links
The Website may contain links to other websites which are not controlled by us. We are not responsible for the protection and confidentiality of data you submit on other websites.
Article 8: Amendments
We have the right to change this privacy statement at any time by publishing a new version on our Website.
Article 9: Cookies
We use "cookies" each time you visit the Website. The following cookies may be used: Necessary cookies (essential for basic functioning), Analytics cookies (e.g., Snitcher), and Marketing cookies (e.g., LinkedIn Insight Tag). We manage cookie deployment and user consent through Cookiebot. You can modify or withdraw your consent at any time through the cookie settings available on our Website.