PRIVACY POLICY- WOLFERS
1. Who we are
The website www.wolfers.be (hereafter: the “Website”) is an initiative of:
SA WOLFERS 1812 (hereafter: “Wolfers” and “We”)
Boulevard de Waterloo, 1
1000 BRUSSELS
BELGIUM
VAT BE0432.111.541
(+32) 2 513 6150
Feel free to contact us should you have further questions or remarks. We promise to reply soon!
2. Why this privacy policy?
Every person who relies on our services (hereafter: the “Customer” of “Data subject”) will in most cases disclose a certain amount of personal data. The personal data is information which allows Wolfers to identify you as a natural person, regardless of whether we actually do this. You are identifiable as soon as it is possible to create a direct or indirect link between one or more data and you as a natural person.
We only use and process your personal data in accordance with the GDPR and any replacement legislation, or any similar regulation under any applicable law, and any regulatory requirements or codes of practice governing the use, storage or transmission of personal data. Every reference in this Privacy Policy to the ‘GDPR’ is a reference to the Regulation of 27 April 2016 on the Protection of Natural Persons with regard to the Processing of Personal Data and on the Free Movement of such Data (General Data Protection Regulation).
Through this Privacy Policy, every User of the Website of Customer of our services is informed of the processing activities Wolfers may carry out with his or her personal data. Wolfers reserves the right to modify this Privacy Policy at all times. Every substantial change will be clearly communicated towards the User. We advise you to consult this document regularly.
3. Who is responsible for the processing of personal data?
3.1. Controller
Wolfers is responsible for the processing and decides alone or in cooperation with others which personal data is being collected as well as the purposes and the technical and organisational means with regard to the processing of this personal data.
Wolfers has taken appropriate technical and organizational measures to protect the personal data of its Visitors and Customers. Wolfers uses various adequate security technologies and procedures to protect your personal data against unauthorized access, use or disclosure. Wolfers ensures that your personal data is stored safely in a controlled environment.
3.2. Processor(s)
Wolfers does not use any data processors. Wolfers is free in the future to rely on data processors. A processor is the natural or legal person who processes your personal data upon request and on behalf of the data controller. The processor is required to ensure the security and confidentiality of the data. The processor shall always act on the instructions of the data controller.
If we decide to use data processors, we will make the necessary contractual arrangements with the aforementioned data processors to ensure that they apply the highest privacy standards. In any event, data processors shall be required to ensure the security and confidentiality of the personal data.
As a resident of the European Economic Area, a transfer of your personal data outside the European Economic Area (EEA) can only take place to countries that the Data Protection Authority in Belgium has found to provide the same adequate level of protection or, if this is not the case, to the extent that Wolfers has made the necessary contractual arrangements, taking into account the standard provisions as imposed by the Data Protection Authority in Belgium, to ensure that your personal information receives an adequate level of protection.
4. On what legal grounds is your personal data processed?
In accordance with the GDPR we process personal data on the following legal grounds:
- On the basis of the execution of the contract agreed upon with the Customer or the execution of pre-contractual steps taken at the request of the Data Subject; or
- On the basis of compliance with legal or regulatory provisions with regard to the management of the contractual relationship with the Customer, invoicing in particular;
- On the basis of our legitimate interest in responding to information requests from Visitors and Customers;
- On the basis of our legitimate interest in sending promotional offers (direct marketing) to our Customers;
- On the basis of the explicit consent to send promotional offers (direct marketing) to Visitors.
5. Which personal data is processed?
Wolfers commits to only collect and process your personal data in a way that is adequate, relevant and limited to what is necessary for the purposes for which they are processed.
How much and what personal information Wolfers collects about you depends on your use of the Website and/or of our services. The following categories of personal data are processed by Wolfers:
- Personal data (gender, age, name, first name, address, login details);
- Contact details (telephone number and e-mail address);
- Financial identification data (bank details);
This personal data is collected when you visit our Website and, in particular, when you fill out and submit our contact form.
6. For which purposes is your personal data used?
The processing of your personal data is essential for the proper functioning of the Website and the provision of associated services. The collection of personal data becomes more extensive as the User makes more intensive use of our Website and our online services.
Wolfers commits to solely process your personal data for the following purposes:
- Customer management: customer administration, order management, deliveries, invoicing, checking creditworthiness, support and complaint monitoring.
- Personalized marketing and advertising. In that case, the Customer is always entitled to unsubscribe.
The Data Subject’s personal data may also be used for the following purposes:
- Dispute management.
- Protection against fraud and criminal offences.
We also use cookies in order to recognise the (IP address of) Visitors and to offer them a personalised user experience, to remember technical choices, and to detect and correct any errors which might be present on the Website. For more information concerning the use of cookies, we kindly refer you to our Cookie Policy.
Under no circumstances do we collect sensitive personal data, such as data about your race, political opinions, health, religious and other beliefs, sexual orientation or the like.
The Customer provides the personal data to Wolfers himself and therefore retains a certain degree of control. Wolfers reserves the right to suspend or cancel certain operations if the required personal data is missing, incorrect or incomplete.
7. Who receives your personal data?
Your personal data will only be processed for internal use within Wolfers. Your personal data will not be sold, passed on or communicated to third parties, unless you have given us your explicit consent beforehand, or if the transmission is necessary for the execution of the agreement or is legally required.
8. How long do we store your personal data?
Your personal data is stored as long as necessary to achieve the purposes pursued. Your personal data will be erased from our database as soon as it is no longer necessary for the purposes pursued or if you validly exercise your right to erasure.
9. What are your rights?
- Guarantee of a legitimate and secure process of your personal data
Your personal data is solely processed for the legitimate purposes explained in point 6. Your personal is collected and processed in an appropriate, relevant and non-excessive manner, and is not kept longer than necessary to achieve the intended purposes.
- Right to access
If you can prove your identity, you have the right to obtain information about the processing of your personal data. Thus, you have the right to know the purposes of the processing, the categories of personal data concerned, the categories of recipients to whom the personal data is transmitted, the criteria used to determine the data retention period, and the rights that you can exercise on your personal data.
- Right to rectification of your personal data
Inaccurate or incomplete personal data may be corrected.
- Right to erasure (or “right to be forgotten”)
You also have the right to obtain the erasure of your personal data under the following assumptions:
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- Your personal data is no longer necessary for the intended purposes;
- You withdraw your consent to the processing and there is no other legal ground for processing;
- You have validly exercised your right of opposition;
- Your personal data has been illegally processed;
- Your personal data must be deleted to comply with a legal obligation.
- Right to limitation of processing
In certain cases, you have the right to request the limitation of the processing of your personal data, especially in case of dispute as to the accuracy of the data, if the personal data is necessary in the context of legal proceedings or the time required to Wolfers to verify that you can validly exercise your right to erasure.
- Right to object
You have the right to object at any time to the processing of your personal data for direct marketing purposes. Wolfers will stop processing your personal data unless it can demonstrate that there are compelling legitimate reasons for the processing which prevail over your right to object.
- Right to data portability
You have the right to obtain any personal data which you have provided us in a structured, commonly used and machine readable format. At your request, this data may be transferred to another provider unless it is technically impossible.
- Right to withdraw your consent
You may withdraw your consent to the processing of your personal data at any time, for example for direct marketing purposes.
- How to exercise your rights?
If you wish to exercise your rights, you must send a written request and proof of identity by registered mail to Wolfers, Boulevard de Waterloo 1- 1000 Brussels (Belgium) or by email to info@wolfers.be. We will respond as soon as possible, and no later than one (1) month after receipt of the request.
- Possibility to lodge a complaint
If you have any comments or complaints about the way in which we handle your personal data, we ask you to report them to us first. In this way, we can reach an amicable solution by mutual agreement.
If, after this notification, you are still not satisfied with the processing of your personal data by Wolfers, you have the right to lodge a complaint with the competent Data Protection Authority (for Belgium: https://www.dataprotectionauthority.be/).
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