This Privacy Policy (hereinafter: "Privacy Policy") governs the processing of personal data in connection with your visit to our website: http://www.vitrotec.com/ (hereinafter: "Website"), your communication with us via e-mail, telephone, fax and social media ((hereinafter: "Social Media Channels"); e.g. Facebook, LinkedIn, Google+, YouTube, Pinterest, Instagram, Snapchat, Twitter, WhatsApp, Vimeo, etc.).
NOTE 1: If you would like information about how we process personal data through cookies and social plug-ins or other tracking methods, please refer to our Cookie Policy.
1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
Vitrotec SL, Carrer Josep Ros I Ros 3 B, 08740 Sant Andreu de la Barca, Spain (EU), with CIF B58363797, is the entity responsible for your personal data as covered in this Privacy Policy (hereinafter: “Vitrotec”, “we”, “us, “our”.) This Privacy Policy may be changed from time to time, in order to ensure that it remains accurate and in line with legislation. If this happens, you are kindly asked to take note of the changes and to agree with them if you find them acceptable.
1.1 Your personal data are processed by Vitrotec. You can contact us via e-mail at privacy@haerensgroup.com.
1.2 Any notion starting with a capital shall be defined by explicit reference in this Privacy Policy. Where possible given the context, singular words shall be interpreted as also including the plural and vice versa.
1.3 Where reference is made to certain laws or regulations, such reference shall also include any change, replacement or annulment of said laws or regulations, including any related executive decisions.
1.4 Vitrotec reserves the right to modify, change or amend the Privacy Policy at its own discretion and from time to time. Such modification, change or amendment shall be communicated via the Website. If you do not accept the modifications, changes or amendments, you are to inform us by sending an e-mail to privacy@haerensgroup.com. If we do not receive such an e-mail from you within three (3) business days after the changes to the Privacy Policy have been announced on our Website, you will be deemed to have accepted unambiguously all such changes
2. WHICH CATEGORIES OF PERSONAL DATA DO WE PROCESS?
We process following categories of personal data: technical information associated with the device you use, your browsing preferences, basic identity information you provide us with, the content of your communication, the technical details of the communication, your preferences regarding receiving our e-mail communications, publicly available information of your profile, any other personal data you choose to provide to us, your order and the details pertaining to the order itself.
Most of the personal data we process, we receive directly from you. However, from time to time we may receive personal data from third parties.
2.1 Whenever you use our Website and Social Media Channels, we collect:
• technical information associated with the device you use, such as your IP address, browser type, geographical location and operating system;
• information concerning your browsing behavior, such as how long you visit, what links you click on, what pages you visit and how many times you visit a page.
2.2 When you fill out the contact form on our Website, use the chat function or contact us via e-mail, telephone, fax or Social Media Channels, we collect:
• the basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, the company you work for, your function;
• the content of your communication and the technical details of the communication itself (with whom you correspond at our end, date and time, etc.);
• your preferences regarding receiving our e-mail communications, such as newsletters, promotions, advertisements, etc., if you have chosen to receive such communications and you have indicated your preferences in the Preference Center.
• publicly available information of your profile on Social Media Channels;
• any other personal data you choose to provide to us.
2.3 All of the personal data listed above, we receive directly from you. It may happen that we receive additional information about your preferences and surfing behavior from partners such as Google, Facebook, Yandex and AddThis/Oracle. If you require more information about the personal data these parties process about you and make available to others, you are kindly requested to consult their respective privacy policies:
Google: https://www.google.com/intl/en/policies/privacy/
Facebook: https://www.facebook.com/about/privacy/
Yandex: https://yandex.com/legal/privacy/
AddThis/Oracle: http://www.addthis.com/privacy/
3. WHY DO WE PROCESS YOUR PERSONAL INFORMATION?
We process your personal data for several different purposes: to provide, improve and develop services; for marketing purposes; to inform third parties; because we are legally required to do so or to detect if you use our Website, Social Media Channels or other communication channels in any way that may harm Vitrotec or someone else, or is illegal.
3.1 Vitrotec processes your personal data for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of Vitrotec and selected partners.
Unless you are an existing customer who has already purchased similar goods or services from us and who we wish to target with our own marketing material, Vitrotec will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communications channels if you have explicitly consented to receiving such communications, promotions, offerings, newsletters and other advertisements.
3.2 Vitrotec processes your personal data to provide you in a personalized and efficient way with the information, products and services you request via the Website, e-mail, telephone, fax and Social Media Channels.
3.3 Vitrotec processes 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.
Your personal data may be transferred upon Vitrotec’s own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website, our Social Media Channels or other communication with us.
3.4 Vitrotec may be required to collect and transfer your personal data to the financial institution or payment service provider to allow your financial institution and the payment service provider to comply with their legal obligations, such as obligations under applicable anti-money laundering and counter-terrorism financing legislation.
3.5 Vitrotec processes your personal data to perform statistical analyses so that we may improve our Website, products and services or develop new products and services.
3.6 Vitrotec may process your personal data for informing any 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.
3.7 Vitrotec may process your personal data for the preservation of the legitimate interests of Vitrotec, its partners or a third party if and when your registration with or use of the Website, Social Media Channels or other communication channels can be considered (a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Website, Social Media Channels or other communication channels, (c) a danger to the Website, Social Media Channels or other communication channels or any of Vitrotec’s or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.
3.8 Vitrotec may process your personal data for the organization of trainings and for carrying out certification.
4. WHAT MAKES THE PROCESSING OF YOUR PERSONAL DATA LEGITIMATE?
The law requires us to state precisely which legal basis we use to process your personal data. We may process your personal data because you have given your consent to do so, it is necessary for performing the agreement between you and us, we are obliged to do so by legislation or it is in our legal interest to process your personal data.
4.1 For processing your personal data for the purposes outlined in clause 3.1 and 3.2, Vitrotec as the responsible party asks for your consent.
4.2 The processing of your personal data for the purposes outlined in clauses 3.3 and 3.4 is necessary to allow Vitrotec to comply with its legal obligations
4.3 The processing of your personal data for the purposes outlined in clauses 3.5, 3.6 and 3.7 is necessary for the purpose of the legitimate interests of the Vitrotec, which are:
• continuous improvements to Vitrotec’s Website, Social Media Channels, products and services to ensure that you have the best experience possible;
• keeping our Website, Social Media Channels, products and services safe from misuse and illegal activity;
• marketing and promotion of our products, services, brands an overall successful commercialization of our products and services.
5. WHO RECEIVES YOUR PERSONAL DATA?
Our general approach is that we do not share your personal with third parties unless you consent to it. However, sometimes it is unavoidable that third parties receive your personal data. Social media providers, financial institutions, payment service providers, cloud providers, service providers that help us with the maintenance of our Website, and entities within Haerens Group may receive and process your personal data in some circumstances.
5.1 Vitrotec does not send your personal data in an identifiable manner to any third party without your explicit permission to do so. You understand, however, that if you use our Social Media Channels, your personal data is also processed by the social media providers.
5.2 Vitrotec relies on third party processors to provide you the Website, as well as to process your personal data on our behalf. These third party processors are only allowed to process your personal data on behalf of Vitrotec upon explicit written instruction of Vitrotec. Vitrotec warrants that all third party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.
5.3 Vitrotec may share your personal data with other entities within Haerens Group. However, we will ensure that all Haerens Group entities will take due care that all processing of your personal data is in line with what is set out in this Privacy Policy.
6. DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EEA?
Yes, we transfer your personal data outside the EEA (i.e. the European Economic Area, consisting of the EU and Norway, Liechtenstein and Iceland). Parties to whom we transfer your personal data are entities in Haerens Group and foreign service providers. It goes without saying that your personal data are safe when we send your personal data to countries outside the EEA.
6.1 Vitrotec processes your personal data first and foremost within the EEA. However, in order to process your personal data for the purposes outlined in article 3 above, we may also transfer your personal data to other entities within Haerens Group or to third parties who process on our behalf which are located outside the EEA. Each entity outside the EEA that processes your personal data shall be bound to observe adequate safeguards with regard to the processing of your personal data. Such safeguards will be the consequence of:
• the recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
• of a contractual arrangement between Vitrotec and that entity. All Haerens Group entities are parties to a contractual arrangement based on the EC’s Standard Contractual Clauses (controller-to-controller) (Commission Decision C(2004)5721
6.2 Vitrotec may transfer anonymized and/or aggregated data to organizations outside of the EEA. Should such transfer take place, Vitrotec will ensure that there are safeguards in place to ensure the safety and integrity of your data as well as all rights with respect to personal data you might enjoy under applicable mandatory law.
7. WHAT ARE THE QUALITY ASSURANCES WITH REGARD TO YOUR PERSONAL DATA?
We will not process more personal data than we need for the purposes we have communicated to you. Additionally, we will only process your personal data for as long as needed to achieve the purposes we have communicated to you or up until such time where you withdraw your consent for processing them and no other legal ground applies that allows us to proceed in processing your personal data. We also guarantee to keep your personal data safe.
Note that the withdrawal of your given consent may imply that you cannot longer use the whole or part of the Website, Social Media Channels and other communication channels.
We also make profiles about you based on preferences, surfing behavior and purchases so that we may better target our marketing activities.
In the Preference Center you can change your preferences regarding receiving marketing materials.
7.1 Vitrotec does its utmost best to process only those personal data which are necessary to achieve the purposes listed under article 3.
7.2 Your personal data are only processed for as long as needed to achieve the purposes listed under article 3 of this Privacy Policy or up until such time where you withdraw your consent for processing them. Note that withdrawal of consent may imply that you can no longer use the whole or part of the Website, Social Media Channels and other communication channels. Vitrotec will de-identify your personal data when they are no longer necessary for the purposes outlined in article 3, unless there is:
• an overriding interest of Haerens Group, your financial institution, the payment service provider, or any other third party in keeping your personal data identifiable;
• a legal or regulatory obligation or a judicial or administrative order that prevents Vitrotec from de-identifying them.
7.3 You understand that an essential aspect of our marketing efforts pertains to making our marketing materials more relevant to you. This means that Vitrotec builds a profile of you based on relevant characteristics as outlined in article 2 and then uses this profile to provide you with communications, promotions, offerings, newsletters and other advertisements about products and services that may interest you.
7.4 Vitrotec will take the appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access by personnel of Vitrotec or its third party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only which can never be guaranteed.
7.5 If you are registered to receive communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communications channels, you can change your preferences for receiving such communications, promotions, offerings, newsletters and other advertisements by surfing to our preference center (“Preference Center”). The link to our Preference Center will be made available in each e-mail or other person-to-person communication we send you.
8. WHAT ARE YOUR RIGHTS UNDER THIS PRIVACY POLICY?
As a data subject, you have several rights vis-à-vis the processing of your personal data. These rights are the right of access, the right to rectification, the right to withdraw your earlier given consent, the right to erasure, the right to oppose the processing of personal data and the right that you receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.
If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to privacy@haerensgroup.com.
8.1 You have the right to request access to all personal data processed by Vitrotec pertaining to you. Vitrotec reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to Vitrotec.
8.2 You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.
8.3 You have the right to withdraw your earlier given consent for processing your personal data, in which case clause 6.2 will apply.
8.4 You have the right to request that personal data pertaining to you be deleted if they are no longer required in light of the purposes outlined in article 3 or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by Vitrotec against:
• overriding interests of Haerens Group, your financial institution, the payment service provider or any other third party;
• legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
Instead of deletion you can also ask that Vitrotec limits the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes listed under article 3 but you need them to defend yourself in judicial proceedings.
8.5 You have the right to oppose the processing of personal data if you are able to proof that there are serious and justified reasons connected with his particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.
8.6 You have the right to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.
8.7 If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to privacy@haerensgroup.com. An e-mail requesting to exercise a right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, Vitrotec may ask you for your signed confirmation and proof of identity.
Vitrotec will promptly inform you of having received this request. If the request proves valid, Vitrotec shall honour it 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 Vitrotec, you may always contact Vitrotec via the e-mail address listed in this clause 8.7. If you remain unsatisfied with Vitrotec’s response, you are free to file a complaint with the competent data protection authority, i.e. the Belgian Data Protection Authority. For more information, visit http://www.privacycommission.be
This cookie policy (“Cookie Policy”) governs the use of cookies and social media plugins on the Vitrotec website (https://www.vitrotec.com/, hereinafter: the “Website”). Cookies are small text files which are stored on a device’s hard drive and which contain certain information and sometimes personal data. Social media plugins are small pieces of software developed and provided by social media service providers (i.e. Facebook, LinkedIn, Google+, YouTube, Pinterest, Instagram, Snapchat, Twitter, WhatsApp and Vimeo), which add social media integration when built into the Website.
NOTE 1: If you want general information on how we process your personal data other than the processing through cookies and social media plug-ins, including in relation to your communication with us via e-mail, telephone, fax and social media, please refer to our Privacy Policy.
By continuing to use the Website or by clicking on “Yes, I Agree” after having been informed of our use of cookies and social media plugins, you acknowledge that you have read this Cookie Policy carefully and that you agree with it without reservation. You may at all times change your cookie preferences through the cookie settings.
1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
Vitrotec SL, Carrer Josep Ros I Ros 3 B, 08740 Sant Andreu de la Barca, Spain (EU), with CIF B58363797, is the entity responsible for your personal data as covered in this Cookie Policy (hereinafter: “Vitrotec”, “we”, “us”, “our”.) This Cookie Policy may be changed from time to time, in order to ensure that it remains accurate and in line with legislation. If this happens, you are kindly asked to take note of the changes and to agree with them if you find them acceptable.
1.1 Your personal data are processed by Vitrotec. You can contact us via e-mail at privacy@haerensgroup.com.
1.2 Any notion starting with a capital shall be defined by explicit reference in this Cookie Policy. Where possible given the context, singular words shall be interpreted as also including the plural and vice versa.
1.3 Where reference is made to certain laws or regulations, such reference shall also include any change, replacement or annulment of said laws or regulations, including any related executive decisions.
1.4 Vitrotec reserves the right to modify, change or amend the Cookie Policy at its own discretion and from time to time. Such modification, change or amendment shall be communicated via the Website. If you do not accept the modifications, changes or amendments, you are to inform us by sending an e-mail to privacy@haerensgroup.com. If we do not receive such an e-mail from you within three (3) business days after the changes to the Cookie Policy have been announced on our Website, you will be deemed to have accepted unambiguously all such changes.
2. COOKIES
We place a number of cookies when you visit our Website. These cookies are divided in 3 groups of cookies: functional cookies; analytical and statistical cookies; advertising and social media cookies. You may at all times withdraw your consent with Vitrotec’s use of cookies.
2.1 You can avoid cookies being placed by configuring your browser as such. Guidelines on how to do this, can be found here:
• Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
• Microsoft Edge: http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq;
• Chrome: https://support.google.com/chrome/answer/95647?hl=en;
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;
• Safari: https://support.apple.com/en-euro/guide/safari/sfri11471/mac.
However, not allowing cookies when visiting the Website may cause certain or all features of the website to stop working properly.
2.2 When you visit the Website, Vitrotec places a number of cookies. Most data pertaining to these cookies, their placement and use allow to identify you, and Vitrotec uses them to gain insight in how you and other visitors use the Website by gathering statistical and usage data, enabling Vitrotec to provide a better user experience on the Website.
Vitrotec knows about the following cookies being used on the Website:
• Functional cookies:
o Name cookie: “_livechat” and several session cookies (livechatinc.com)
Lifespan: Up to 37 months
Purpose: These cookies are required to offer you our live chat option.
o Name cookie: “vuid” (vimeo.com)
Lifespan: 2 years
Purpose: This cookie is used to offer you the video functionality on our website but is also used by vimeo.com for analytical purposes. For more information on how Vimeo uses your personal data, please visit https://vimeo.com/cookie_policy.
• Analytical and statistical cookies
o Name cookie: “_ga”, “_gid”, “_utma”, “_utmz”, “_utmc” and “utmb” (Google Analytics)
Lifespan: Up to 2 years
Purpose: Vitrotec uses Google Analytics cookies to determine how you and other visitors use our Website as well as some of the third party services (e.g. Vimeo) on our Website.
o Name cookie: “yabs-sid”, “yp” and “i” (Yandex Metrica)
Lifespan: Up to 10 years
Purpose: Vitrotec uses Yandex Metrica cookies to determine how you and other visitors are using our Website, which Vitrotec can then use to improve its services.
o Name cookie: “hashedEmail”
Lifespan: Up to 2 years
Purpose: Vitrotec uses the cookie to determine how you and other users use our Website, which Vitrotec can then use to improve its services.
o Name cookie: “_hjIncludedInSample” (Hotjar)
Session cookie
Purpose: Vitrotec uses the Hotjar cookie also for determining how you and other users use our Website and specifically to let Vitrotec know whether that visitor is included in the sample which is used to generate funnels.
• Advertising and social media cookies
o Name cookie: “fr” (facebook.com)
Lifespan: 90 days
Purpose: This cookie is used for advertising purposes and allows us and Facebook to track your surfing behavior across different websites in order to provide you with more relevant and personalized advertisements. More information on Facebook’s use of the “fr”-cookie can be found here: https://www.facebook.com/policies/cookies/. We also use the Facebook Connect feature, which is Facebook’s single sign-on solution. If you choose to use your Facebook account to sign on, we will receive personal data from Facebook.
o Name cookie: “SEUNCY” (semasio.net)
Lifespan: 6 months
Purpose: The integration of the cookie of Semasio also allows us and Semasio to offer you more relevant and personalized content and advertisements by tracking which websites you visit. More information can be found here: http://www.semasio.com/privacy-policy/
o Name cookie: “di2”, “uid”, “vc”, “uvc” and “loc” (addthis.com)
Timespan: 13 months up to 2 years
Purpose: The integration of the cookies of AddThis allows us and AddThis to offer you more relevant and personalized content and advertisements by tracking which websites you visit. More information can be found here: https://www.oracle.com/legal/privacy/privacy-policy.html
o Name cookie: “bkdc” and “bkdu” (bluekai.com)
Lifespan: 6 months
Purpose: The integration of the cookies of Bluekai also allow us and Bluekai to offer you more relevant and personalized content and advertisements by tracking which websites you visit. More information can be found here: https://www.oracle.com/legal/privacy/privacy-policy.html
o Name cookie: “TapAd_TS” and “TapAd_DID” (tapad.com)
Lifespan: 2 months
Purpose: The integration of the cookies of Tapad also allow us and Tapad to offer you more relevant and personalized content and advertisements by tracking which websites you visit. More information can be found here: https://www.tapad.com/privacy.
o Name cookie: “_mkto_trk” (Marketo)
Lifespan: 2 years
Purpose: The integration of the cookies of Marketo allow Vitrotec to offer you more relevant and personalized content and advertisements by tracking what you do on our Website.
o Name cookie: “IDE” and “DSID” (doubleclick.net)
Lifespan: Up to 25 days
Purpose: These cookies are used to show you more relevant advertisements. For more information, please visit: https://policies.google.com/technologies/types.
2.3 You may at all times withdraw your consent with Vitrotec’s use of cookies. To exercise this right, it suffices to delete the cookies, which have been placed on your device. To do so, you are kindly asked to refer to the appropriate instructions of your browser manufacturer, as listed above.
3. WHY DO WE PROCESS YOUR PERSONAL DATA?
We process your personal data through cookies for several different purposes: to improve our Website and the experiences and services we offer; to show advertisements; to provide information to third parties and to keep the web experiences we offer, our Website, you and us safe.
3.1 Vitrotec processes your personal data to offer you more personalized content and advertisements and perform statistical analyses so that we may improve our Website, advertisements, products and services or develop new products and services.
3.2 Vitrotec may process your personal data for informing any 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.
3.3 Vitrotec may also process your personal data for the preservation of the legitimate interests of Vitrotec, its partners or a third party if and when your registration with or use of the Website can be considered (a) a violation of this Cookie Policy or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Website or to any of Vitrotec’s or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (c) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.
3.4 Your personal data may be transferred to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your use of the Website.
4. WHAT MAKES THE PROCESSING OF YOUR PERSONAL DATA LEGITIMATE?
The law requires us to state precisely which legal basis we use to process your personal data. We may process your personal data because you have given your consent to do so, because the law obliges us to do so or because it is in our or a third party’s legitimate interest.
4.1 For processing your personal data for the purposes outlined in clause 3.1 and 3.2 of this Cookie Policy, Vitrotec as the responsible party asks for your consent. Vitrotec obtains your consent through the cookie banner. By clicking on this banner affirmatively and continuing to use the Website, you acknowledge that you have read this Cookie Policy carefully and that you agree with it without reservation.
4.2 The processing of your personal data for the purposes outlined in clause 3.3 of this Cookie Policy is also necessary for the purpose of the legitimate interests of Vitrotec, which are: keeping our Website, Social Media Channels, products and services safe from misuse and illegal activity.
4.3 The processing of your personal data for the purposes outlined in clause 3.4 is necessary to allow Vitrotec to comply with its legal obligations.
5. WHO RECEIVES YOUR PERSONAL DATA?
Our general approach is that we do not share your personal with third parties, unless you consent to it. However, sometimes it is unavoidable that third parties receive your personal data. Service providers which help us to provide the Website to you and entities within Haerens Group may receive and process your personal data in certain circumstances.
5.1 Vitrotec relies on third party processors to provide you the Website as well as to process your personal data on our behalf. These third party processors are only allowed to process your personal data on behalf of Vitrotec upon explicit written instruction of Vitrotec. Vitrotec warrants that all third party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.
5.2 Vitrotec may share your personal data with other entities within the Haerens Group of companies. However, we will ensure that all Haerens Group entities will take due care that all processing of your personal data is in line with what is set out in this Cookie Policy.
5.3 Vitrotec does not send your personal data in an identifiable manner to any third party without your explicit permission to do so. However, Vitrotec may send anonymized and/or aggregated data to other organizations that may use those data for improving products and services as well as tailor the marketing, displaying and selling of those goods and services.
6. DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EEA?
Yes, we transfer your personal data outside the EEA (i.e. the European Economic Area, consisting of the EU and Norway, Liechtenstein and Iceland). Parties to whom we transfer our personal data are entities within Haerens Group and foreign service providers. It goes without saying that your personal data are safe when we send your personal data to countries outside the EEA.
6.1 Vitrotec processes your personal data first and foremost within the EEA. However, in order to process your personal data for the purposes outlined in article 3 above, we may also transfer your personal data to other entities within Haerens Group or to third parties who process on our behalf which are located outside the EEA. Each entity outside the EEA that processes your personal data shall be bound to observe adequate safeguards with regard to the processing of your personal data. Such safeguards will be the consequence of:
the recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
of a contractual arrangement between Vitrotec and that entity. All Haerens Group entities are parties to a contractual arrangement based on the EC’s Standard Contractual Clauses (controller-to-controller) (Commission Decision C(2004)5721).
6.2 Vitrotec may transfer anonymized and/or aggregated data to organizations outside of the EEA. Should such transfer take place, Vitrotec will ensure that there are safeguards in place to ensure the safety and integrity of your data as well as all rights with respect to personal data you might enjoy under applicable mandatory law.
7. WHAT ARE THE QUALITY ASSURANCES WITH REGARD TO YOUR PERSONAL DATA?
We will not process more personal data than we need for the purposes we have communicated to you. Additionally, we will only process your personal data for as long as needed to achieve the purposes we have communicated to you or up until such time where you withdraw your consent for processing them and no other legal ground applies that allows us to proceed in processing your personal data. We also guarantee to keep your personal data safe.
7.1 Vitrotec does its utmost best to process only those personal data which are necessary to achieve the purposes listed under article 3.
7.2 Your personal data are only processed for as long as needed to achieve the purposes listed under article 3 of this Cookie Policy or up until such time where you withdraw your consent for processing them. Note that withdrawal of consent may imply that you can no longer use the whole or part of the Website. Vitrotec will de-identify your personal data when they are no longer necessary for the purposes outlined in article 3, unless there is:
o an overriding interest of Haerens Group, the payment service provider, or any other third party in keeping your personal data identifiable;
o a legal or regulatory obligation or a judicial or administrative order that prevents Vitrotec from de-identifying them.
7.3 Vitrotec will take the appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access by personnel of Vitrotec or its third party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only which can never be guaranteed.
8. WHAT ARE YOUR RIGHTS UNDER THIS COOKIE POLICY?
As a data subject, you have several rights vis-à-vis the processing of your personal data. These rights are the right of access, the right to rectification, the right to withdraw your earlier given consent, the right to erasure, the right to oppose the processing of personal data and the right that you receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.
If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to privacy@haerensgroup.com.
8.1 You have the right to request access to all personal data processed by Vitrotec pertaining to you. Vitrotec reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to Vitrotec.
8.2 You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.
8.3 You have the right to withdraw your earlier given consent for processing your personal data.
8.4 You have the right to request that personal data pertaining to you be deleted, if they are no longer required in light of the purposes outlined in article 3 or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by Vitrotec against:
o overriding interests of the Haerens Group, your financial institution, the payment service provider or any other third party;
o legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
Instead of deletion you can also ask that Vitrotec limits the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes listed under article 3 but you need them to defend yourself in judicial proceedings.
8.5 You have the right to oppose the processing of personal data if you are able to proof that there are serious and justified reasons connected with his particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.
8.6 You have the right to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.
8.7 If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to privacy@haerensgroup.com. An e-mail requesting to exercise a right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, Vitrotec may ask you for your signed confirmation and proof of identity.
Vitrotec will promptly inform you of having received this request. If the request proves valid, Vitrotec shall honour it 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 Vitrotec, you may always contact Vitrotec via the e-mail address listed in this clause 8.7. If you remain unsatisfied with Vitrotec’s response, you are free to file a complaint with the competent data protection authority, i.e. the Belgian Data Protection Authority. For more information, visit http://www.privacycommission.be.