Introduction

Europochette NV and its subsidiaries (collectively ‘Europochette Group NV we, us or our’) values your privacy and are committed to protecting your personal data in accordance with applicable privacy laws.

This Europochette NV Web Privacy Policy (the “Web Privacy Policy”), explains how we collect and use your personal data. Personal data means any information relating to an identified or identifiable natural person; one who can be identified, directly or indirectly, by reference to an identifier such as name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Acceptance of the Policy

The use of this Website is subject to this Web Privacy Policy. By providing personal data to us, you understand and agree to the collection, processing, international transfer and use of such information as set forth in this Web Privacy Policy. Where required by applicable law we will ask your explicit consent. As this Web Privacy Policy can be modified at any moment without prior notice, you are advised to regularly consult this Web Privacy Policy.

Data controller

The data controller which is responsible for the processing of any personal data through this Website is Europochette NV. Data controller means Europochette NV which, along or jointly with others, determines the purposes and means of the processing of personal data.

Categories of Personal Data Collected

We collect personal data in a variety of ways through our normal business activities both online and offline. This includes, for example when you contact us via the contact form, enter into agreements or communicate with us, or visit and use websites. We also receive personal information from our customers in order to perform services on their behalf.

The categories of personal data we may collect and process includes:

  • contact Information that allows us to communicate with you, such as your name, job title, and prefix, mailing address, telephone numbers, email address or other addresses that allow us to send you messages, company information and registration information you provide on our website;
  • relationship information that helps us do business with you, such as the types of products and services that may interest you, contact and product preferences, languages, creditworthiness, marketing preferences and demographic data;
  • transactional information about how you interact with us, including purchases, inquiries, customer account information, order and contract information, delivery details, billing and financial data, details for taxes, transaction and correspondence history, and information about how you use and interact with our websites; and
  • security and compliance Information that helps us to secure our interests, including information for conflict checks, fraud prevention and internal verification, as well as information necessary for the security of our premises, such as visual recordings.

Purposes of Processing

Europochette NV, as well as its subsidiaries with whom we share your personal data, use your personal data for the following purposes:

  • website improvement: maintaining, customizing and improving the Website;
  • managing our relationship: managing our ongoing relationship with you, including interacting with you, fulfilling your orders and requests, and providing other services related to your requests;
  • marketing: promotional offers regarding Europochette® products and services; and
  • business needs: managing our business needs, such as payment processing and account management, product development, contract management, corporate governance, audit, and legal compliance.

Legal ground

We may collect and process your personal data based on the following legal grounds:

  • your consent;
  • the performance of a contract with you;
  • the legitimate interests of Europochette NV which are our usual business activities.

Data sharing

In connection with the purposes described above in Section 5, we may need to share your personal data with third parties, so-called ‘recipients’:

  • third parties: we may use third parties to provide or perform services and functions on our behalf. We may make personal data available to these third parties, to perform these services and functions. Any processing of that personal data will be on our instructions and compatible with the original purposes;
  • legal obligations: we may also make personal data concerning individuals available to public or judicial authorities, law enforcement personnel and agencies as required by law, including to meet national security or law enforcement requirements, and including to agencies and courts in the countries where we operate. Where permitted by law, we may also disclose such information to third parties (including legal counsel) when necessary for the establishment, exercise or defense of legal claims or to otherwise enforce our rights, protect our property or the rights, property or safety of others, or as needed to support external audit, compliance and corporate governance functions;
  • mergers & acquisitions: personal data may be transferred to a party acquiring all or part of the equity or assets of Europochette NV or its business operations in the event of a sale, merger, liquidation, dissolution, or other;
  • affiliates: we may also transfer and share personal data to our affiliates in compliance with applicable law.

Retention

We may retain your personal data no longer than necessary for the purposes for which they were collected or as required by applicable law.

Transfer outside of the European Economic Area (“EEA”)

Europochette NV may transfer your personal data to entities (recipients) located in countries outside of the EEA, which do not offer adequate protection of personal data. In such cases, we take measures to ensure that your personal information receives an adequate level of protection.

Security

We apply appropriate technical, physical and organizational measures that are reasonably designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and against other unlawful forms of processing. Access to personal data is restricted to authorized recipients on a need-to know basis. We maintain a comprehensive information security program that is proportionate to the risks associated with the processing. The program is continuously adapted to mitigate operational risks and to protect personal information, taking into account industry-accepted practices.

Data subject rights

You have the right to request from Europochette NV access to and rectification or erasure of personal data or restriction of processing concerning you or to object to the processing as well as the right to data portability. You may also have the right to lodge a complaint with a supervisory authority. To exercise your rights please contact us via quality@europochette.be

Consent

By providing personal information to us, you understand and agree to the collection, processing, international transfer and use of such personal data as set forth in this Privacy Policy. Where required by applicable law we may ask your explicit consent. You may always object to the use of your personal data for direct marketing purposes or withdraw any consent previously granted for a specific purpose, free of charge by clicking on relevant links on our websites, following the directions contained in an email or by contacting us via contact us via quality@europochette.be

Cookies

To keep our Website running smoothly, we might store small files on your computer which provide us with useful information (so-called ‘cookies’). You can opt out of the advantages of these cookies by adjusting your browser’s cookies preferences.

Europochette NV may use one or more of the following types of cookies:

  • Necessary cookies

Necessary cookies are required for the operation of the Website. These cookies are essential to make the Website work correctly. They include cookies that remember previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies do not identify you as an individual. If you do not accept necessary cookies, it may affect the performance of the Website or parts of it.

  • Functionality cookies

Functionality cookies are used to recognize you when you return to the Website and to remember the choices you made to enable Europochette NV to personalize its content to you. The information the functionality cookies collect may include personally identifiable information that you have disclosed. If you do not accept functionality cookies, it may affect the performance and functionality of the Website and may restrict access to its content.

  • Analytical/Performance cookies

Analytical/Performance cookies allow Europochette NV to recognize and count the number of visitors and help Europochette NV understand how visitors interact with the Website by providing information about, among others, the areas visited, the time spent on the Website and any issues encountered. This helps Europochette NV to improve the way the Website works. Performance cookies do not identify you as an individual. All data is collected and aggregated anonymously.

You can change your browser settings to block or notify you when you receive a cookie, delete cookies or browse our website using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our websites may not function properly if you do not accept cookies or these technologies.

We may also use Google Analytics on our website to collect information about your online activity on our websites, such as the web pages you visit, the links you click, and the searches you conduct on our websites. We may use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come to the site from and the pages they visited. The information generated by those cookies and your current IP-address will be transmitted by your browser to and will be stored by Google on servers in the United States and other countries. Google will use this information on our behalf for the purpose of evaluating your use of our website as described above. The IP address collected through Google Analytics will not be associated with any other data held by Google. For more information about the information gathered using Google Analytics please visit http://www.google.com/intl/en/analytics/privacyoverview.html. You can prevent these cookies by selecting the appropriate settings on your browser. If you do this you may not be able to use the full functionality of our websites. You may download and install the Google Analytics Opt-out Browser Add-on available here: http://tools.google.com/dlpage/gaoptout. Changes to the Policy

Europochette NV may change this Web Privacy Policy at any time. Any changes to this Web Privacy Policy will become effective when we make the revised Policy available through the Website. Your continued use of the Website following such changes means that you accept the revised Web Privacy Policy.

Contact

If you have any comments or questions, please do not hesitate to contact us via quality@europochette.be

Version

May 25th, 2018