Privacy policy with respect to the processing of personal data belonging to the customer and the user of the website
ETAP Lighting International NV (hereinafter referred to as ‘we’, ‘us’ or ‘our’) is conscious of the fact that that the privacy and protection of the personal data belonging to our customers and visitors to our website is important. In this policy we explain how we handle your personal data and how we process this data.
Area of application
ETAP Lighting International NV, with head office in B-2390 Malle, 130 Antwerpsesteenweg and company number 0424 980 655 is the administrator for this website. We act as data controller when we process our customers’ and website users’ personal data.
We feel it is important to create and to maintain an environment in which our customers can be assured that their information is not misused. We comply with the applicable data protection legislation, such as the General Data Protection Regulation no. 2016/679 (AVG or GDPR) and national data protection legislation. This legislation involves the protection of your personal data and grants you rights with respect to said personal data.
The aim of this policy is to show which personal data we collect and how we use your data after you have visited our website and to reassure you that we handle your data correctly.
Which personal data do we collect?
You do not have to provide us with your personal data to be able to use the majority of our website.
For the purposes listed below, we may collect and process the following categories of personal data:
- Name, title, address
- Contact details (e-mail, phone)
- Company and position
You can also provide additional/optional information if you complete forms on our website or if we are in contact with you (by telephone, via e-mail, at trade fairs or during events).
In addition, we can also collect and process information, which we receive through our website or through the devices you use. This may involve:
- Location data (location data collected through social media or IP addresses for your device; GPS signals sent by a mobile device).
- Information from cookies, web beacons or through the Internet. This information is collected automatically and may involve the website you have visited before going to ours or the website you will visit after ours. We may also collect information on the pages you visit on our website, your IP addresses, the type of browser, the access time and operating system. You will find more about how we use cookies in our cookie policy.
- Data we receive from other websites, for example when you ask us to link us to your Facebook account.
We may also collect publicly available information to verify information we have previously collected and to manage and expand our business.
Why do we collect this information and what legal grounds do we use?
We collect the aforementioned information to have an idea of your needs and to provide you with better service, and more particularly for the following purposes:
|
Purpose |
Personal data |
Legal grounds |
Retention period |
|
Direct Marketing (customers) |
Name and contact details (e-mail) |
Legitimate interest
|
1 year after end of commercial relationship |
|
Direct Marketing (prospects) |
Name and contact details (e-mail) |
Permission |
1 year |
|
Customer management |
Name and contact details (e-mail, phone) Position Business address |
- Necessary for the fulfilment of the agreement - Legitimate interest |
10 years after end of commercial relationship |
How do we use and share your data?
We may share your personal data with:
- Companies that belong to the group and/or with subsidiaries; or
- With every third-party you have requested us to share your personal data with, such as Facebook or other social media if you have asked us to link your account.
Based on our legitimate interest, we may also share your personal data with third parties that assist us with our products and services. A few examples of activities by third parties include the hosting of Web servers, data analysis, marketing support and customer service providers. These companies will have access to your personal data, but only when strictly necessary to carry out their activities. They are not allowed to use your data for other purposes.
Your personal data will not be sold or rented to third parties.
We may disclose your personal data to enforce our policy, to comply with our legal obligations or in the interest of security, public interest or law enforcement in each country in which we have entities or subsidiaries. This enables us to respond to a request from a law enforcement agency or regulatory or governmental body. We may also disclose data as part of actual or suggested lawsuits or to protect our property, safety, people and other rights and interests.
In the event that ETAP Lighting International NV is sold or merges with another company, your data will be disclosed to the advisor of a potential buyer and will be passed on to the company’s new owners. In that case we will take the necessary measures to ensure the integrity and confidentiality of your personal data. The use of your personal data will nonetheless still be subject to this policy.
Transfer of your personal data outside the European Economic Area
We may pass on your personal data to third parties located in countries outside the European Economic Area (EER)), such as the United Kingdom. This transfer of data outside the EEA is lawful if the recipient of the data is located in a country that provides an adequate level of protection following an Adequacy Decision by the European Commission. It is possible that some of these countries do not have equivalent legislation on data protection to safeguard the use of your personal data. In this case we have investigated whether suitable precautionary measures as within the EU are possible, for example, by establishing standard contract provisions. In specific cases we will ask your prior permission to transfer your personal data outside the EER. For further information on the transfer of data you can follow the process described in the article Rights of the data subject.
Data subject’s rights
Data protection legislation includes several rights on the part of the data subject with respect to the processing of personal data so that the data subject continues to have sufficient control over the processing of their personal data.
To receive personal data about you that you have provided to a processor in a structured, standardised and machine-readable format and to transfer such data to another processor.
You have the following rights:
Right of access/inspection
You have the right to have us confirm whether we have processed your personal data or not. If yes, you can request to access your personal data.
We will inform you of the following if they are not yet included in this policy:
- Processing purposes
- Relevant categories of personal data
- Recipients or categories of recipients to whom personal data is provided
- Transfer to recipients in third countries or international organisations
- Where possible, the period during which the personal data is expected to be stored, or if not possible, the criteria to determine said period
- That you have rights with respect to your personal data as summed up in this section
- If we have not received your personal data from you, all available information on the source of said data
- the existence of automated decision-making, including profiling, and useful information on the underlying logic in such decision-making and the significance and expected consequences of such processing for the data subject
We will provide you with a copy of the personal data we have available, if you so request. Should you repeatedly and disproportionally ask for additional copies, we will charge a reasonable fee.
Right to rectification
Should you notice that we have incorrect or incomplete personal data about you, you always have the right to report it to us so that we can improve or complete this data.
Right to erasure
You can also ask us to delete your personal data if the processing does not comply with data protection legislation within the boundaries of the law.
Right to restrict processing
You can request to restrict processing if:
- The accuracy of the personal data is questioned and for the period to check accuracy.
- The processing is unlawful and you do not want us to delete the data.
- We no longer need the data, but you ask not to remove it as it is required for the execution or underpinning of a legal claim.
- Objection is raised against the processing, pending the explanation of legitimate interests that outweigh your interests.
Right to data portability
You also have the right to receive the personal data you have provided to us in a structured, standard and machine-readable format. You have the right to transfer this personal data (directly us) to another processor. This is possible if the processing is based on your consent and on an automated process.
Right to object
If your personal data is processed for direct marketing purposes (including profiling), you can always object to said processing.
You can also object to the processing due to a specific situation involving the data subject. The organisation will stop the processing, unless the organisation provides compelling legitimate grounds for the processing, which outweigh the interests of the data subject or which are related to the exercise or underpinning of legal claims.
Automated individual decision-making
The data subject is entitled not to be subjected to a decision based exclusively on automatic processing, including profiling, which has legal consequences for them or which otherwise significantly affect them, such as evaluating personal aspects with respect to the performance of work, reliability, creditworthiness, etc.
This right not to be subjected to such automated decision-making does not apply if the decision is allowed by a compelling legal provision.
The data subject will not be able to invoke this right if the decision is required for the creation or performance of the agreement between the data subject and the organisation or is based on the data subject’s express consent. In these last two cases, the data subject is entitled to human intervention by someone within the organisation and to share their point of view and to challenge the automated decision.
Right to withdraw consent
Should you have granted us permission to process your data for a specific purpose, you can withdraw said permission at any time by sending us an e-mail or through your account.
If during registration on the website you have opted to receive newsletters and/or mailings from us, you can opt out at any time should you change your mind.
Process to exercise your rights and other provisions
We may ask you to verify your identity to ensure that your request is legitimate and that we provide the answer to the person who is entitled to send one of the aforementioned requests and receive the information.
Please take into account that we, in specific circumstances provided by law, may refuse access to your information or decline your request, if we are entitled to do so by virtue of applicable data protection legislation.
Should you wish further information on the processing of your personal data or should you wish to exercise your rights, please contact us at info@etaplighting.com.
You have the right to file a complaint with the competent supervisory authority (on data protection). For Belgium this is the data protection authority, located at 35 rue de la Presse, 1000 Brussels (contact@apd-gba.be).
Safety
We endeavour to ensure the safety of your data. We have taken reasonable technical and organisational measures to secure your personal data against accidental or unlawful destruction, loss, changes, unauthorised granting of unauthorised access to the transferred, stored or otherwise processed data. However, you must take into account that the Internet is an open system and that we are unable to guarantee that it is impossible for unauthorised third parties to circumvent such measures or to use your personal data for inappropriate purposes.
This website may contain links to third-party websites. We are not liable for the content of said websites and are not responsible for the standards and practices with respect to privacy on the part of such third parties. Make sure to read and understand the relevant privacy policy of those third parties and their websites before accepting their cookies and going to their website to make sure that your personal data is sufficiently protected.
Amendment to this policy
ETAP Lighting International NV may amend and update this policy periodically to ensure that it reflects how we process your personal data at any given time. The updated version of this policy will be posted on the same webpage and will take effect immediately upon publication. Please return to this webpage regularly to ensure that you are always aware of the information we collect and process, how and under what circumstances your data is used and in what cases we share your data with third parties.
January 2021