Privacy and cookie statement

WageWell Comm.V · Version 1.0 · 3 September 2026
Deep on HR. Clear in delivery.

1. Who we are and what this statement covers

1.1 WageWell Comm.V, with its registered office at Bremstraat 23, 3530 Houthalen-Helchteren, registered with the Crossroads Bank for Enterprises under number 0803.635.694, VAT BE 0803.635.694. For anything relating to this statement or to your personal data, you can reach us at privacy@wagewell.be and on +32 473 37 16 63.

1.2 This statement describes how we handle personal data: on our website wagewell.be, in our dealings with clients, prospects and candidates, and in our day-to-day file management.

1.3 We act in two different capacities. That distinction determines who you should approach with a question.

1.4 As a controller, we ourselves determine why and how we process data. That is the case for visitors to our website, for anyone who contacts us, for our prospects and for the contact persons at our clients and suppliers, for candidates in a recruitment engagement up to the moment they are introduced, and for anyone who applies to us for a job. For all those processing activities we are your point of contact, and the rights set out in chapter 8 apply.

1.5 As a processor, we process personal data on behalf of our client and in accordance with its instructions. That is the case for payroll processing, HR administration and related engagements: the data of our client’s employees remains the responsibility of their employer. In those situations we act on the basis of a data processing agreement as required by article 28 GDPR.

1.6 Are you an employee of an organisation for which we handle payroll processing or HR administration? In that case your employer is the controller, not we. Please address your question or request to your employer. If such a request reaches us directly, we will pass it on to your employer immediately and let you know that we have done so; we will not answer it ourselves, because we have no authority to do so.

1.7 We are not required to appoint a data protection officer and have not done so. All questions about this statement reach us at privacy@wagewell.be.

2. What data we process, why and for how long

The table below is the heart of this statement: for each processing activity it sets out which data is involved, why we process it, on what legal basis and how long we keep it.

Processing activity

Data

Purpose and legal basis

Retention period

Visits to the website

IP address, browser type, pages visited, time of visit, technical log files

Keeping the website secure and working and detecting misuse. Legal basis: our legitimate interest in a secure website

Log files held by our hosting provider: six months at most

Contact form and email

Name, company, email address, telephone number, the nature of your question and your message

Answering your question and following it up. Legal basis: steps taken at your request prior to entering into an agreement, and our legitimate interest in proper follow-up

Two years after the last contact, unless a client relationship results from it

Prospecting and commercial management

Business contact details: name, job title, company, email address, telephone number, notes of conversations

Approaching companies for which our services are relevant, and keeping track of our commercial follow-up in our CRM. Legal basis: our legitimate interest in business-to-business prospecting

Two years after the last meaningful contact

Client relationship and quotations

Contact details and job titles of the contact persons at our clients, correspondence, file documents

Preparing and performing the agreement. Legal basis: performance of the agreement with the organisation, and our legitimate interest in proper file management

The term of the collaboration and ten years thereafter, in line with the limitation period for contractual claims

Invoicing and accounts

Invoicing data and accounting records

Meeting our tax and accounting obligations. Legal basis: legal obligation

Ten years, in accordance with the Belgian retention requirement for accounting and tax records

Newsletter and mailings

Name, company, email address, your areas of interest and whether you open or click a message

Informing you about our services and about developments in payroll and HR. Legal basis: your consent, or our legitimate interest where we write to a business address of a company or to an existing client, within the limits of Book XII of the Belgian Code of Economic Law

Until you unsubscribe or object, and one year thereafter so that we can honour your unsubscription

Recruitment and selection for clients

CV, career and education details, contact details, interview notes, references, salary expectations

Finding, assessing and introducing candidates to the client. Legal basis: your consent to being included in our candidate database and to each introduction to a specific employer

Two years after the last contact, unless you ask us earlier to delete your data

Job applications to WageWell itself

CV, covering letter, contact details, interview notes

Assessing your application. Legal basis: steps taken at your request prior to entering into an agreement

Six months after the procedure is completed, or two years where you give us your consent to keep you in our talent pool

Website statistics

Pseudonymised usage data via Google Analytics 4: pages visited, time spent, device, approximate region, referring source

Understanding how our website is used and improving it. Legal basis: your consent, given through the cookie banner

Fourteen months, the retention period we have set in Google Analytics

2.1 We do not process any special categories of personal data through the website, such as data on health, religion or trade union membership. Data of that kind only arises in files that we handle as a processor for a client, and then under that client’s responsibility and instructions.

2.2 You are never obliged to provide us with data. If you do not, we may be unable to answer your question or to deliver our services. On every form we ask only for what we genuinely need.

3. Where we obtain your data

From you, when you contact us, complete a form, sign up for our mailings or work with us.
From your employer or from our client, when you are a contact person in a file or when we carry out an engagement for your employer.
From publicly available sources, for our business prospecting: company websites, the Crossroads Bank for Enterprises, the trade press, and professional networks such as LinkedIn. From those sources we use only business contact details and the job information you have made public there yourself.
From a partner organisation, in joint recruitment engagements. In that case we record in writing who is responsible for what.

3.1 Where we process data that we did not obtain directly from you, we inform you of this at the first contact, as required by article 14 GDPR.

4. Who we share your data with

We do not sell your data, we do not rent it out and we do not make it available to third parties for commercial purposes. We do engage service providers who process data for us. We have entered into a data processing agreement with each of them.

Party

For what purpose

Where the data is held

Combell

Hosting of wagewell.be and the associated log files

Data centres in the Benelux, within the European Economic Area

Microsoft (Microsoft 365)

Email, calendar, documents and file storage

Storage within Microsoft’s EU Data Boundary; support may involve access from outside the EEA. See chapter 5

Odoo

Our CRM, file and client management, invoicing, the management of recruitment files, and the sending and follow-up of our mailings

Hosting within the European Union

Google (Google Ireland Ltd and Google LLC)

Google Analytics 4 for website statistics, and Google Maps when you load the map on our contact page

Processing partly in the United States. See chapter 5

Our accountant

Accounts, tax returns and annual accounts

Belgium

Our insurer and, where applicable, a legal adviser

Handling a claim or a dispute

Belgium

4.1 In addition, we may disclose data to public authorities where a legal obligation or a court order requires us to do so. We will inform you in advance where the law allows us to.

4.2 Our staff and subcontractors are given access only to what they need for their assignment, and are contractually bound to confidentiality.

5. Transfers outside the European Economic Area

5.1 We prefer to keep your data within the European Economic Area. Our hosting, our CRM and our file storage are set up accordingly.

5.2 For a few services, processing outside the EEA may nonetheless take place: Google Analytics 4 and, where you load it, Google Maps, and to a limited extent the support services of Microsoft.

5.3 For those transfers we rely on two safeguards together. First, the European Commission’s adequacy decision of 10 July 2023 on the EU-US Data Privacy Framework: Google LLC and Microsoft Corporation are certified under that framework, which means that the Commission considers the level of protection there to be equivalent. Second, the European Commission’s standard contractual clauses, which these suppliers include in their processing terms and which continue to apply as an additional safeguard.

5.4 You may ask us for a copy of the safeguards we apply to a specific transfer.

6. Cookies

6.1 A cookie is a small text file that is placed on your computer, tablet or phone when you visit our website. Cookies allow a website to work, to remember your preferences or to measure how it is used. The same rules apply to comparable techniques such as local storage and pixels.

6.2 We only place non-essential cookies once you have given your consent. On your first visit, a banner appears on which refusing is just as easy as accepting and on which you can choose per category. As long as you have not made a choice, only the strictly necessary cookies are placed.

6.3 You can change or withdraw your choice at any time through the Cookie settings link at the bottom of every page. Your choice is recorded on our own website as evidence of consent; that record does not leave our website.

We distinguish four categories.

7. How we protect your data

7.1 We take appropriate technical and organisational measures to protect your data against loss, misuse and unauthorised access. In practical terms: traffic to our website and our systems is encrypted, access to our systems is secured with strong multi-step authentication, access is granted on the basis of what a person needs for their work, and our files are backed up regularly.

7.2 Our staff and subcontractors are bound to confidentiality, including after their assignment has ended.

7.3 No measure offers absolute certainty. If we identify a breach that poses a risk to your rights and freedoms, we report it within seventy-two hours to the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit), and we inform you where the risk is high.

8. Your rights

The GDPR gives you a set of rights. You can exercise them free of charge.

Right

What it means

Access

You may find out what data we process about you and obtain a copy of it

Rectification

You may have inaccurate data corrected and incomplete data completed

Erasure

You may ask us to erase your data, unless we are required by law to keep it or need it to defend a legal claim

Restriction

You may ask us to suspend the processing temporarily, for example while the accuracy of the data is being verified

Objection

You may object to processing based on our legitimate interest, on grounds relating to your particular situation

Objection to direct marketing

You may object to our mailings at any time and without giving reasons. We then stop immediately

Data portability

You may receive the data you provided to us in a commonly used file format, or have it transferred

Withdrawal of consent

Where processing is based on your consent, you may withdraw it at any time. This does not affect what took place beforehand

8.1 You can exercise your rights by sending a message to privacy@wagewell.be or a letter to Bremstraat 23, 3530 Houthalen-Helchteren. We may ask you for proof of identity where we have reasonable doubt, so that we do not disclose data to the wrong person.

8.2 We reply within one month. If your request is complex, or if we receive several requests from you, we may extend that period by two months; we will let you know within the first month if we do.

8.3 We do not take automated decisions producing legal effects for you, and we do not engage in profiling. Assessments of candidates and decisions in files are always made by people.

8.4 Where the data concerned is data we handle as a processor for a client — see article 1.6 — we pass your request on to that client, who decides on it as controller.

8.5 If you are unhappy with the way we handle your data, please tell us first: that is how most matters get resolved. You also always have the right to lodge a complaint with the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit), Drukpersstraat 35, 1000 Brussels, contact@apd-gba.be, +32 (0)2 274 48 00, www.gegevensbeschermingsautoriteit.be. You may also bring the matter before the courts.

9. Links to other websites

9.1 Our website contains links to third-party websites, including our LinkedIn company page. As soon as you follow such a link, the privacy policy and cookie policy of that website apply. We have no control over those websites and accept no responsibility for them.

10. Changes to this statement

10.1 If our working methods, the legislation or the technology behind our website change, we will amend this statement. The current version is always available on wagewell.be, with the version number and date stated at the top.

10.2 Where a change materially affects you, we will inform you actively: through a notice on the website, and by email where we have your address.

10.3 This text is a translation of the Dutch version. In the event of any difference in meaning or interpretation between the language versions, the Dutch text alone prevails.

WageWell Comm.V · Bremstraat 23, 3530 Houthalen-Helchteren · BTW BE 0803.635.694 · wagewell.be

Deep on HR. Clear in delivery.

Privacy and cookie statement

1. Who we are and what this statement covers

2. What data we process, why and for how long

3. Where we obtain your data

4. Who we share your data with

5. Transfers outside the European Economic Area

6. Cookies

Miscellaneous

Usage

Sharing data

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Expiration

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7. How we protect your data

8. Your rights

9. Links to other websites

10. Changes to this statement