Privacy

1. Who is responsible for your personal data?

European Energy Pooling BV (“EEP”, “we”, “us” or “our”) is responsible for the personal data processed for the purposes described in this policy.

You can contact us at:

European Energy Pooling BV
Company number: BE 0833.491.108
Merestraat 131
9300 Aalst, Belgium
Email: contact@eep.energy
Telephone: +32 (0)53 89 63 10

This policy covers our website, business enquiries, professional communications, newsletter subscriptions and recruitment enquiries. Additional privacy information may apply to particular services or processes.

2. What personal data do we process?

Depending on your interaction with us, we may process:

• Contact and professional details: your name, business email address, telephone number, company, position and business sector.
• Enquiries and correspondence: information you provide through a contact form, email, telephone call, meeting or other professional exchange.
• Business relationship information: your role within a customer, supplier or partner organisation and records of relevant communications.
• Subscription preferences: your newsletter preferences, consent records and unsubscribe requests.
• Recruitment information: your CV, professional background and information you provide when applying for a role.
• Technical information: IP address, browser and device information, access logs and, where permitted, information about your interaction with the website.

We obtain information directly from you and, where relevant, from your colleagues, professional introductions or publicly available business sources. Where we obtain personal data indirectly, we provide the information required by applicable data protection law.

Please only provide information relevant to your enquiry. Avoid including sensitive personal data in general contact forms.

3. Why do we use your personal data?

Responding to enquiries

We use your contact details and message to answer questions, discuss your requirements and follow up on your request.

For professional enquiries made on behalf of an organisation, we rely on our legitimate interest in communicating with prospective customers and business partners. Where you personally request steps towards a contract with us, we process the necessary information to take those steps.

Managing business relationships

We use professional contact details and correspondence to maintain customer, supplier and partner relationships and coordinate our activities.

We rely on our legitimate interest in managing these relationships, on contractual necessity where you are personally a party to a contract, and on legal obligations where applicable.

Sending newsletters and marketing communications

Where you subscribe, we use your contact details to send the updates you have requested, based on your consent.

You can unsubscribe at any time using the link in the communication or by contacting us. Sending a general enquiry does not automatically subscribe you to marketing communications.

Considering applications

When you apply for a role, we use your information to assess your application and communicate with you about the recruitment process.

We rely on steps taken at your request before potentially entering into an employment contract and, where appropriate, our legitimate interest in assessing candidates. Keeping your application for unrelated future vacancies requires a separate basis, which we will explain to you.

Operating and protecting the website

We process necessary technical information to deliver the website, maintain its security, diagnose faults and prevent misuse. We rely on our legitimate interest in providing a secure and reliable website.

Optional analytics or tracking technologies are subject to the choices described in our Cookie Policy.

Meeting legal requirements

We may process information to comply with applicable legal obligations, respond to lawful requests from authorities, and establish, exercise or defend legal claims.

Where we rely on legitimate interests, we assess the necessity of the processing and balance those interests against your rights and reasonable expectations.

4. Contact forms and HubSpot

Our website contact forms are connected to HubSpot, which we use to manage enquiries and professional relationships.

When you submit a form, the information you provide is recorded in our customer relationship management system and made available to the EEP team members responsible for handling your request.

Processing your enquiry is separate from optional website tracking and newsletter subscriptions. Optional tracking requires the relevant permission where applicable, and marketing consent is requested separately.

Fields marked as required are needed to handle your request. You can choose whether to complete optional fields. If necessary information is missing, we may be unable to respond fully.

5. Who receives your personal data?

Access is limited to people and organisations that need the information for the purposes described in this policy. Depending on the circumstances, these may include:

• Authorised EEP personnel.
• Website hosting, maintenance, IT and security providers.
• HubSpot and other providers supporting our communications and relationship management.
• Professional advisers where necessary.
• Public authorities or other parties where disclosure is legally required or necessary for legal claims.

Where a provider processes personal data on our behalf, we require appropriate contractual safeguards and instructions.

6. International transfers

Some service providers or their support teams may process personal data outside the European Economic Area.

Where this happens, transfers must be supported by an applicable adequacy decision or appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, together with supplementary measures where necessary.

You can contact us for information about the safeguards applicable to your personal data and how to obtain a copy.

7. How long do we keep your information?

We retain personal data for the period needed for its purpose, taking account of applicable legal requirements and the need to establish, exercise or defend legal claims.

The criteria depend on the information concerned:

• Enquiries: whether the request has been resolved and whether further relevant correspondence or a business relationship is reasonably expected.
• Business contacts: whether the professional relationship remains active and whether the information is still accurate and relevant.
• Recruitment information: the duration of the recruitment process and any justified period needed to address questions or claims afterwards.
• Newsletter information: the duration of your subscription. After an unsubscribe request, we may keep a minimal suppression record to respect your choice.
• Security logs: the period needed to identify and investigate incidents and protect our systems.
• Cookie information: the periods stated in the cookie overview and the applicable service configuration.

Information retained for legal requirements or claims is limited to what is necessary for those purposes.

8. How do we protect personal data?

We apply technical and organisational measures appropriate to the nature of the information and the risks involved. These include access restrictions and measures to protect systems and information against unauthorised access, loss and misuse.

No system can eliminate every security risk. If you suspect an issue involving your personal data, please contact us promptly.

9. Your rights

Subject to the conditions in applicable law, you can request access to your personal data, correction of inaccurate information, deletion, restriction of processing, or a portable copy of information you have provided where portability applies.

You can object to processing based on legitimate interests. You can object to direct marketing at any time.

Where processing relies on consent, you can withdraw it at any time. Withdrawal does not affect processing lawfully carried out before that withdrawal.

To exercise your rights, email contact@eep.energy. We may ask for proportionate information to verify your identity. We normally respond within one month. If a lawful extension is necessary, we will explain the reason within that month.

You may lodge a complaint with the Belgian Data Protection Authority at www.dataprotectionauthority.be, or another competent supervisory authority. You do not have to contact us first.

10. Cookies and updates

Our Cookie Policy provides further information about cookies, similar technologies and preference controls.

We may update this policy when our processing activities or applicable requirements change. Where required, we will bring material changes to your attention or request fresh consent.