Personal data protection policy (GDPR)

Last updated December 18, 2023.

By using some of our services, contracting with us, and / or accepting our terms and conditions, you agree to be bound without reservation by this Privacy Policy.

Introduction

As a customer or visitor to our website, we want to inform you about respect of your rights and allow you to control what happens to your personal data, in accordance with GDPR 2016/679 of April 27, 2016 relating to the protection of natural persons with regard to the processing of personal data (hereinafter, the “GDPR”).

The purpose of this Privacy Policy (hereinafter, the “Privacy Policy” or the “Policy”) is therefore to inform all the natural persons concerned (hereinafter referred to as “you ”or “your ”), on the way in which E.W.G (hereinafter referred to as “we ”or “our / our ”) collects and uses personal data in the context of its activities and on means available to the natural person to control such use.

1. Scope of this Privacy Policy

The notion of personal data (hereinafter, “Personal Data” or “Data”) refers to any information relating to an identified or identifiable natural person. A person is “identifiable” when he can be identified, directly or indirectly, in particular by reference to one or more elements which are specific to him.

To avoid any misunderstanding, this Privacy Policy only applies in the context of our relationships with natural persons.

2. Who is responsible for your data

The persons in charge of processing your data is E.W.G, whose registered office is at Rue de la Gare 20, 6001 Charleroi – Belgium registered under the VAT company number BE 0889.076.561 and contactable by email info@ewg-europe.com or by phone on +32 (0)71/11.92.20 during store opening hours.

3. Who is protected by this Privacy Policy?

This Privacy Policy only applies to Personal Data that we process as data controller, in relation to our services, to visitors to our website https://www.controle-visuel.com/ (hereinafter, the “Site”).

4. What do we mean by “processing of Personal Data”?

By “processing of Personal Data”, we mean any processing of data that can identify you as a natural person, namely:

  • Your first and last name
  • Your address for the delivery and / or invoicing of your orders for items sold by E.W.G
  • Your phone number
  • Your email address
  • Your IP address, the name of cookies stored in your browser and your user account security information (but we don’t know your secure password).

By “processing” we mean the collection, recording, organization, conservation, updating, modification, consultation, use, archiving, erasure or permanent destruction of this data.

5. What personal data can we process?

5.1. Personal Data that you share with us

We collect the Data that you send us as part of our activities, following the use of or subscription to our Services, the placing of an order, the subscription to a newsletter, the sending of a contact, the creation of a user account or simply voluntarily. This can be done by telephone, by written post or electronic means (for example, when you send us a letter, an e-mail), by placing an order or completing an online contact form on the site.

5.2. Personal data of non-clients

Via various channels, for example contests, promotions / actions, our website or social networks, we may collect Personal Data about people who are not (yet) customers in order to offer these people the most relevant offer possible of our Services. In this context, we guarantee your right to information and we impose it contractually – insofar as it is applicable – with your possible authorization required by law on third parties who would collect your data (for us) in this context.

6. For what purposes do we use this Personal Data?

6.1. Proportional treatment

We process personal data for different types of purposes. In each case, we only process the data which is essential to achieve the intended purpose of the processing. Thus, we use Personal Data when necessary:

  • in connection with the preparation, execution or termination of our services;
  • to comply with the legal or regulatory provisions to which we are subject; and or
  • to defend our legitimate interests, in which case we always take care to maintain a balance between these interests and respect for your privacy, in particular if you are a minor.

If the processing of your Personal Data is not essential for one of these three purposes, we always ask for your authorization to be able to process this data.

6.2. Our processing activities

More specifically, we collect personal data for the following purposes:

  • execution and management of contracts and customers, namely their administration, including accounting and tax, order management, contract monitoring and invoicing, responding to customer requests (including through the online contact form);
  • carrying out studies, statistics, maintenance and continuous improvement of our products, services, website, as well as personalization, creation of user profiles, optimization of general, commercial and marketing strategies, including the creation and management of user accounts, loyalty programs, targeted promotions, and others;
  • navigation, user-friendliness and optimization of the website, its functionality and space reserved for holders of user accounts;
  • prospecting (direct marketing), such as sending advertisements, newsletters and information, invitations, in a targeted and / or non-targeted manner, by electronic means, sms, social networks and / or post, both on offers, promotions and / or activities of the company, with your consent and / or in the legitimate interest of the Company to promote its services to its customers;
  • securing our products, services, website, and other applications;
  • compliance with all legislation applicable to our company;

7. How do we protect your Personal Data?

7.1. Our technical and organizational measures

We do everything to protect your personal data and your confidentiality against destruction, loss, unintentional modification, damage, accidental or unauthorized access or other unauthorized processing of Personal Data.

Our employees have been trained to properly manage confidential data. In addition, we apply various technical measures to protect your personal data against unauthorized access and use, loss or theft, namely: password protection, hard drive encryption software, firewall, antivirus , detection of intrusions and anomalies and access controls for our employees. In the event of a data leak with adverse consequences for your Personal Data, you are personally notified as a customer in the circumstances provided for by law.

Data management and storage software are continuously updated.

The number of E.W.G employees having access to your personal information is limited and our employees are carefully selected. They only have access to your Personal Data to the extent that they need this information to properly perform their tasks.

7.2. Where is your Personal Data stored

Your Personal Data is stored on computer servers located at the place of our head office and on the hosting of the E.W.G websites, at Combell in Belgium.

8. On what legal basis do we collect and process your Personal Data?

Personal Data is collected with your consent as well as by virtue of the execution of the contractual relationship that we are binding with you, or, where applicable, on the basis of the agreement given by any person having completed one or more forms appearing on the site.

When said processing is not necessary for this contractual performance, it is then based on the legitimate interests of E.W.G as a professional, in particular that of information and monitoring of your files, management and prevention fraud, ensure efficiency to perform our contracts, provide our Services and comply with our legal obligations, identify the means allowing us to improve services to our customers, protect our commercial, financial and economic interests.

9. Do we sell your Data to third parties or do we pass your Data on?

9.1. Data transfers

We don’t sell any of the Personal Data to third parties. We also don’t transfer them to third parties, except (if):

  • This is necessary for the proper performance of the E.W.G Services. We may be required to transmit certain personal data to third parties processing the data in the name and on behalf of E.W.G (such as a database manager, an advertising agency, or any other service provider), to stakeholders in your contract (such as suppliers, subcontractors as part of the performance of the Services), etc.

Your Data is only transmitted for the sole purpose of achieving the purpose (s) declared by E.W.G. Said Data is then transmitted to third parties for the sole purpose of carrying out the mission delegated to them by E.W.G.

  • There is a legal obligation, particularly in the fight against money laundering.
  • There is a legitimate interest for E.W.G or the third party concerned.

We will only transmit your personal data if your interest or your fundamental rights and freedoms don’t prevail and you will always be informed in full transparency (except in the case of legal exceptions). Thus, your personal data may, for example, be transmitted to partners, collection offices and legal service providers, as well as to partners with whom we collaborate within the framework of a specific action.

9.2. International processing of your Personal Data

Insofar as and if the Personal Data are processed outside the European Union, we ensure by contractual or other measures that these data enjoy an appropriate level of protection there, comparable to the protection they would enjoy in the European Union in accordance with European regulations.

10. Security measures in the event of subcontracting

When Data processing must be carried out on our behalf, E.W.G only uses subcontractors who provide sufficient guarantees as to the implementation of appropriate technical and organizational measures such as processing meets the requirements of this Policy and guarantees the protection of your rights.

11. How do you determine which Personal Data we may use for general information purposes and how?

11.1. E.W.G privacy settings

You have the possibility to determine the confidentiality parameters of your Personal Data, by contacting us or via your personal user account available on our Site.

While technically you have the ability to determine the purposes for which we can collect and process your Data, in order to avoid any misunderstanding, we would like to point out that this limitation must nevertheless be assessed in the light of our legal obligations as well as the need to perform the Services of E.W.G.

11.2. Unsubscribe from marketing communications

If you do not / no longer wish to receive any form of commercial communication, you have the right to oppose, at any time, without reason, in whole or in part, to the use by E.W.G of your Data of a personal nature for direct marketing purposes. To do this, all you need to do is contact us:

  • Either online, via your user account, or at the foot of the commercial notifications sent to you, by clicking on the “unsubscribe” link and / or by modifying your “preferences”;
  • Or by email to the address info@ewg-europe.com.

Please note: the fact that you no longer wish to receive communications of this type from us obviously does not prejudice our right to contact you electronically as part of the performance of the Services or if the law requires us to do so.

12. How long do we keep your Personal Data?

We cannot keep your Personal Data beyond the time necessary to achieve the purpose of the initial collection. The retention period may therefore differ depending on the intended purpose:

  • Compliance with our legal obligations: to meet our accounting and tax obligations, we are, for example, required to keep your billing data for a maximum of 7 years;
  • Legal necessity: to keep certain data (in particular your contract, your invoices and your correspondence concerning complaints on this subject) as proof in the event of litigation, up to a maximum of 10 years after the termination of the E.W.G Services.

However, these archived data have very limited access.

At the end of the applicable retention periods, the Personal Data is deleted or made anonymous.

13. What are your privacy rights and how can you exercise them?

13.1. Overview of your privacy rights

Your right of access

You have the right to ask us at any time whether or not we are processing your Personal Data and, if we are processing it, to consult this Data and to receive additional information concerning:

  • the purposes for which we process them;
  • the categories of personal data concerned;
  • the recipients or categories of recipients (in particular recipients in third countries);
  • if possible, the retention period or, if this is not possible, the criteria for determining this period;
  • the existence of your confidentiality rights;
  • the right to lodge a complaint with the supervisory authority;
  • what information we have about the source of the data if we obtain personal data from a third party; and
  • the existence of an automatic decision-making process.

You also have the right to obtain a free copy of the processed data, in understandable form.

Your right to rectify your personal data

You have the right to have incomplete, erroneous, inadequate or old Personal Data corrected immediately, either online through your user account by making the necessary changes yourself, or by contacting the e-mail address directly next info@ewg-europe.com.

To keep your data up to date, we kindly ask you to inform us of any changes, such as moving, changing your e-mail address or changing your identity card.

Your right to erasure of data (the “right to be forgotten”)

You have the right, in the following cases, to have your Personal Data erased / deleted:

  • your Personal Data are no longer necessary to achieve the purposes for which they were collected or otherwise processed by E.W.G ;
  • you have withdrawn your consent to the processing and there is no other legal basis for the processing on the part of E.W.G ;
  • you have validly exercised your right of opposition and there is no other legal basis for the processing on the part of E.W.G which prevails;
  • your Personal Data has been the subject of unlawful processing;
  • your Personal Data must be erased to meet a legal obligation;
  • your Personal Data was collected while you were still a minor.
  • Please take into account that we cannot always delete all the Personal Data requested, for example when their processing is essential for the establishment, exercise or defense of legal claims or because we are legally obliged to do so. We will provide you with more information on this in our response to your request.

Your right to restrict processing

You have the right to obtain the restriction of the processing of your Personal Data if one of the following applies:

  • you dispute the accuracy of this Personal Data: their use is then limited for a period allowing E.W.G to check the accuracy of the Data;
  • the processing of your Data is unlawful: instead of requesting the deletion of your Data, you request that their use be limited;
  • E.W.G no longer needs your Data for the initial purposes of the processing, but you need it for the establishment, exercise or defense of legal claims: instead of requesting the deletion of the Data, their use is limited to the establishment, exercise or defense of legal claims;
  • as long as no decision has been taken concerning the exercise of your right to object to processing, you request the limitation of the use of your Personal Data.

Your right to the portability of Personal Data

You have the right to “retrieve” your Personal Data, for example to be able to change service provider more easily. This is only possible for Personal Data that you yourself have provided to E.W.G, on the basis of an authorization or the Service entrusted to E.W.G. In all other cases, therefore, you cannot benefit from this right (for example, when the processing of your data occurs on the basis of a legal obligation).

Two aspects are linked to this right:

  • you can ask E.W.G to recover the Personal Data concerned in a structured, commonly used and machine-readable format; and
  • you can ask E.W.G to directly transmit the Personal Data concerned to another controller. In this context, you are personally responsible for the accuracy and security of the (e-mail) address you provide for the transfer. E.W.G has the right to refuse your request if the transfer is technically impossible.

Your right to object to the processing of your Personal Data

You have the right, by virtue of your particular situation, to object to the processing of your Personal Data when the processing falls within the framework of the legitimate interest of E.W.G or within the framework of the interest general. E.W.G will suspend the processing of your Personal Data, unless E.W.G can demonstrate that there are legitimate and compelling reasons for the processing which prevail over yours or if the processing of Personal Data is related to the establishment, exercise or defense of legal claims (for example, the lodging of an application before a court).

Your right to withdraw your consent

You can withdraw your consent to the processing of your Personal Data at any time. The withdrawal of your consent does not affect the validity of the processing operations prior to the withdrawal.

13.2. In practice

How can I exercise my privacy rights?

You can send us an e-mail at info@ewg-europe.com. In order to exercise your right of access and to prevent any unlawful publication of your Personal Data, we must verify your identity. In case of doubt or imprecision, we will first ask you for additional information (preferably a copy of the front of your identity card).

Are there any fees?

You can exercise your confidentiality rights free of charge, unless your request is manifestly unfounded or exaggerated, in particular because of its repetitive nature. In this case, we have the right and the choice – in accordance with the legislation relating to the protection of privacy – (i) to charge you a reasonable compensation (taking into account the administrative costs associated with providing the information or the communication requested and the costs associated with taking the requested actions), or (ii) to refuse to act on your request.

In what format will I receive a response?

If you submit your request electronically, the information will be transmitted electronically if possible, unless your request states otherwise. In any case, we will send you a concise, transparent, understandable and easily accessible answer.

When will I receive a response?

We react as quickly as possible to your request, and in any case within one month of receiving your request. Depending on the complexity of the requests and their number, this period may be extended by two months, if necessary. In the event of an extension of the deadline, we will inform you within one month of receiving the request.

What can I do if E.W.G does not respond to my request?

We will always inform you, in our response, about the possibility of lodging a complaint with the supervisory authority and of appealing to the judge.

14. Ask questions to E.W.G

For more information on this Privacy Policy or for any complaint regarding the processing of your Personal Data, you can contact us at the e-mail address info@ewg-europe.com or by phone on +32 (0)71/11.92.20 during store opening hours.

15. Stay informed of adaptations.

E.W.G may modify this Privacy Policy from time to time, for example in the context of market developments and new processing activities of E.W.G.

In such cases, we will spontaneously notify you of any changes to this Policy and / or (new) processing activities.

16. Supervisory authority.

For complaints relating to the processing of your personal data, you can contact the Data Protection Authority, rue de la Presse 35, 1000 Brussels / +32 (0) 2 274 48 00 / contact@apd-gba.be / www.autoriteprotectiondonnees.be.