It goes without saying that we value the protection of your personal data as much as we value you. Of course, we cannot do business with you or carry out our activities without processing (some of) your personal data.
In this privacy notice, we explain what personal data we process, why we do that, how we keep it safe, with whom we share it and so forth.
However, if you feel that this does not answer all your questions, do not hesitate to contact us at firstname.lastname@example.org.
Who are we?
With “we” or “us”, we mean THELMA & CO BV BVBA. Our office is located at Vaartstraat 12, 3000 Leuven and we are registered at the Crossroad Bank of Enterprises under the number 0642.750.803.
We are the controller of your personal data, which means that we are responsible for what happens with your personal data when we process it.
When do we collect and use your personal data?
We collect and use your personal data whenever you:
- use our website
- communicate with us via social media, e-mail, phone, or any other digital communication channel.
- contract and communicate with us as our customer or supplier.
What personal data do we process and why?
When you use our website or communicate with us via social media, e-mail, phone or other digital communication channel, we will collect and use your personal data to:
- allow for the communication between you and us, for which we rely on our legitimate interest to be able to respond to requests, questions or remarks or to contact you proactively for inquiries of whatever kind (e.g. when you use our contact form or contact us via social media, phone or e-mail).
- improve the website’s and social media pages’ content and the overall experience, for which we rely on our own legitimate interest to offer our visitors an interesting online space.
- detect and prevent malware, illegal content and behaviour and other types of misuse, for which we rely on our legitimate interest to keep our online presence safe.
To achieve the above-mentioned purposes, we process the following personal data:
- the basic identity information you provide us with, such as name, e-mail address, postal address and telephone number.
- the content of your communication and the technical details of the communication itself (with whom you correspond at our end, date and time, etc.).
- technical information associated with the device you use, such as your IP address, browser type, geographical location and operating system.
- any other personal data you choose to provide to us.
When we receive an order from you, we will collect and use your personal data to:
- be able to execute and perform our end of the contract and to deliver you the items you purchased or provide you with the services you asked us for. When you as an individual are our customer or supplier, we rely on the necessity of processing your personal data for executing and performing the contract we have with you. However, if you act on behalf of a company or other legal entity, we rely on our legitimate interest to be able to contract with customers and suppliers when processing your personal data.
- do our normal business administration (e.g. invoicing and relationship management), for which we rely on our legitimate interest to manage our business responsibly and professionally.
- defend ourselves in legal proceedings, when it is in our legitimate interest to use your personal data in these proceedings.
The personal data we process for these purposes will always involve your basic identity information such as name, e-mail address, postal or shipping address and telephone number. We may also process other personal data you provide us with, dependent on our contractual relationship with you.
We believe that the above-mentioned purposes for processing your personal data are within anyone’s reasonable expectations. However, for all of the personal data we have collected in the aforementioned circumstances, we wish to make it clear that we will also process your personal data to:
- comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
- inform a third party in the context of a possible merger with, acquisition from/by or demerger by that third party, even if that third party is located outside the EU, in which case we rely on our legitimate interest to engage in corporate transactions.
With whom do we share your personal data?
In principle we will not share your personal data with anyone but with our service providers who help us process your personal data. Anyone who has access to your personal data will always be bound by strict legal or contractual obligations to keep your personal data safe and confidential. This means that only the following recipients will receive your personal data:
- our staff and service providers.
- governmental or judicial authorities insofar we are required to send them your personal data (e.g. tax authority, police or law enforcement).
Since we use service providers outside the EEA for some of our processing activities, your personal data is transferred outside that EEA for those purposes. Rest assured that the necessary measures are in place to safeguard the transfer of your personal data.
How long do we keep your personal data?
Your personal data are only processed for as long as needed to achieve the purposes which are described above or, when we asked for your consent, up until such time where you withdraw your consent. In this page we provide you with the information you need to assess how long we will keep your personal data identifiable.
As a general rule, we will de-identify your personal data when they are no longer necessary for the purposes outlined above or when the retention period as explained in this page has expired. However, we cannot de-identify your personal data if there is a legal or regulatory obligation or a judicial or administrative order that prevents us from de-identifying them.
All personal data we collect through our interactions with you via our website, social media, phone, e-mail and other digital communication channels we keep for as long as required to communicate with you, but also to keep an historical archive of our communications. This allows us to revert back to earlier communications if you return to us with new questions, request, remarks or other input.
All personal data we collect in the context of a contractual relationship with you or the organization you represent, we will keep for the duration of the contractual relationship and at least until 10 years thereafter.
How do we keep your personal data safe?
We can ensure you that we have taken steps to ensure that all personal data processed by us are kept safe. These steps include processing only the personal data required for achieving the purposes we have communicated to you. We have also taken technical and organizational measures to secure our infrastructure, systems, applications, premises and processes.
What are your rights?
When we collect and use your personal data, you enjoy a number of rights which you can exercise in the manner described below. Please be aware that whenever you wish to exercise a right, we will ask you for a proof of identity. We do this to avoid any data breach on our hands.
You have the right to access your personal data, which means that you can ask us to provide you information regarding the personal data we have about you. You can even ask for a copy of your personal data. However, note that you must specify for which processing activities you would like to have access to your personal data. If you make the same request repeatedly, clearly causing us nuisance, we are allowed to refuse granting you these subsequent requests or charge an administrative fee covering the expenses. We can also refuse granting you a right to access your personal data, or only grant it partially, if such access would risk disproportional detriment to the rights and freedoms of others, including ours.
You have the right to ask that we correct your personal data if you can show that the personal data we process about you are incorrect, incomplete or outdated. Please specify the context in which we use your personal data (e.g. to send you newsletters or to respond to a request), so that we may assess your request swiftly and accurately.
You can ask that we delete your personal data, if these personal data are no longer needed for the purposes for which we collected them in the first place, if our collection of them was illegitimate or if you have successfully exercised your right to withdraw your consent or your right to object to the processing of your personal data. When one of these circumstances applies, we will immediately delete your personal data unless the law, regulatory obligations or administrative or judicial orders prohibit us to delete your personal data.
You can ask that we restrict the processing of your personal data:
- during the time we are assessing your request for correction of your personal data;
- we no longer need your personal data, but you require them for the establishment, exercise or defence of a legal claim;
- when such processing was unlawful but you prefer restriction to erasure;
- during the time we are assessing your objection to the processing of your personal data.
When we process your personal data on the basis of our own interests, i.e. you have not given us your consent and we do not need them for the execution or performance of an agreement nor to comply with legal obligations, you have the right to oppose our processing of your personal data. When our interest relates to direct marketing, we will grant you your request immediately. For other interests, e.g. our security interests, we will ask you to describe your specific circumstances giving rise to request. We then need to balance your circumstances against our interests. If this balancing exercise results in your circumstances outweighing our interests, we will cease processing your personal data.
When we have collected your personal data on the basis of your consent or because they were necessary for the execution or the performance of an agreement with you, you have the right to obtain a copy from us in a structured, commonly used and machine-readable format. However, this right only applies to personal data you have provided to us.
If you would like to exercise any of these rights, we ask that you send us an e-mail. You can reach us at email@example.com. Rest assured that we will not interpret an e-mail from you requesting to exercise a right as your consent with any processing of your personal data beyond what is required for handling your request.
A request should clearly state and specify which right you wish to exercise. Always indicate the context in which we have obtained your personal data so that we may handle your request swiftly and diligently. Your request should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. We will promptly inform you of having received this request. If the request proves valid, we will notify you as soon as reasonably possible and at the latest thirty (30) days after having received the request.
If you have any complaint regarding the processing of your personal data by us, you may always contact us via email at firstname.lastname@example.org. If you remain unsatisfied with our response, you may file a complaint with the competent data protection authority, i.e. the Belgian data protection authority (https://www.dataprotectionauthority.be/).