2. In general
2.1 Your personal data are processed by Ideal Standard International NV, having its offices at 1930 Zaventem, Da Vincilaan 2, registered with the Crossroad Bank of Enterprises under the number 0891.422.179, and its affiliate companies of the Ideal Standard Group (hereinafter “we”, “us”, “our”, “Ideal Standard”). You can contact us via e-mail at email@example.com.
3. Types of personal data we process
3.1 Every time that you visit or use our Website, we collect:
• Technical information relating to the devices that you use, such as the IP-address, browser type, geographical location and operating system;
• Information that relates to your browser behaviour, such as how long you visit, which links you click on, which pages you visit or how many times you visit a certain page.
For contact form
3.2 When you fill out a contact form on our Website, or contact us via e-mail, telephone, fax or social media channels, we collect:
• The identity information you provide us with, such as your name, e-mail address, postal address, phone number and mobile telephone number;
• The content of your communication or enquiry and the technical details of the communication itself (such as with whom you correspond at our end, date and time, etc.);
• Your preferences with regard to the communication medium used;
• Publicly available information of your profile on social media channels;
• Any other personal data you choose to provide to us;
3.3 When you create a wishlist, we collect:
• The identity information you provide us with, such as your name and e-mail address;
• The products you place on your wishlist;
• The people you share your wishlist with.
For entering into agreement
3.4 When we enter into an agreement with you or for the performance of that agreement, we collect:
• Your VAT number;
• Your delivery and /or invoice address.
3.5 All of the personal data mentioned above, we receive directly from you. It is possible that we receive additional information about your preferences and surfing behaviour from partners such as Google. If you require more information about the personal data these parties process about you and make available to others, we refer you to their respective privacy policies.
4. Purposes for which we collect and use your personal data
Purposes for which we collect and use your personal data and the legal grounds on which these purposes are based
4.1 The purposes
We process your personal data to provide you specific information concerning our services and products that you request via the Website, by email, telephone, fax or social media channels
The legal grounds
In order to take steps prior to entering into a contract with us, we may base the processing of your personal data on the necessity for the performance of that contract, or in the process of entering into that contract.
4.2 The purposes
Except if you are an existing customer who has already purchased similar goods or services from us and who we wish to target with our own commercial messages, we will only send you communications, promotions, offerings, newsletters and other advertisements via email or other communication channels, if you explicitly consented to receiving such communications, promotions, offerings, newsletters and other advertisements.
The legal grounds
This processing activity is based on your consent.
4.3 The purposes
We 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.
Your personal data may be transferred upon our 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.
The legal grounds
This processing activity is necessary to comply with legal obligations imposed on us.
4.4 The purposes
We process your personal data to perform statistical analyses or in the context of surveys so that we may improve our Website, advertisements, products and services or to develop new products and services.
We process your personal data to conduct market research and business development.
We process your personal data for marketing purposes, such as to provide you with targeted communications, newsletters, promotions, offerings and commercial messages of Ideal Standard and selected partners.
We 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.
We may also process your personal data for the preservation of the legitimate interests of us, our partners or a third party if and when your registration with or use of the Services can be considered (a) a violation of the Terms or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Website, (c) a danger to the Website or any of our 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.
The legal grounds
For these purposes, the processing of your personal data is based on our legitimate interests, such as:
• Continuous improvements of our 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 and overall successful.
5. To whom we send your personal data
5.1 We rely on third party processors to provide you our Website and to process your personal data on our behalf. These third party processors are only allowed to process your personal on our behalf upon our explicit written instructions.
5.2 We warrant that all third party processors are selected with due care and are obliged to ensure the safety and integrity of your personal data.
5.4 We do not send your personal data in an identifiable manner to any other party than the ones mentioned in Articles 5.1 and 5.2 without your explicit permission to do so. However, we may send anonymised data to other organisations that may use those data for improving products and services as well as to tailor the marking, displaying and selling of those goods and services.
6. Location and transfer
6.1 We process your personal data within the European Economic Area (EEA). However, in order to process your personal data for the purposes outlined in Article 4 above, we may also transfer your personal data to other Ideal Standard entities or to third parties who process your personal data on our behalf outside the EEA. Each entity outside the EEA that processes your personal data will 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
• A contractual arrangement between us and that entity, such as an agreement based on the European Commission’s Standard Contractual Clauses.
6.2 We may transfer anonymized and/or aggregated data to organisations outside the EEA. Should such transfer take place, we will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data you might enjoy under applicable mandatory law.
7. Quality assurances
• an overriding interest of us, or any other third party, in keeping your personal data identifiable;
• A legal or regulatory obligation or a judicial or administrative order that prevents us from de-identifying them.
7.4 We will take the appropriate technical and organisational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access by our personnel 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 electronic communication channels, you can change your preferences for receiving such communications, promotions, offerings, newsletters and other advertisements by clicking on opt-out link provided in such communications.
8. Your rights
Right to access your data
8.1 You have the right to request access to your personal data processed by us pertaining to you. We reserve the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us. Each request must specify for which processing activity you wish to exercise your right to access and must specify to which data categories you wish to gain access to.
Right to correct your data
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.
Right to withdraw consent
8.3 You have the right to withdraw your earlier given consent for processing your personal data, in which case Article 7.2 will apply.
Right to erase your data
8.4 You have the right to request that personal data pertaining to you be erased if they are no longer required in light of the purposes outlined in Article 4 or if you withdraw your consent for processing them. However, you need to keep in mind that a request for erasure will be evaluated by us against:
• Overriding interests of us or any other third Party;
• Legal or regulatory obligations or administrative or judicial orders, which may contradict such deletion;
• For the establishment, exercise or defence of legal claims.
Instead of deletion you can also ask that we limit 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 4 but you need them to defend yourself in judicial proceedings.
Right to oppose the processing of your data
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.
Right to obtain a copy of your data
8.6 You have the right to receive from us in a structured, commonly used and machine-readable format the personal data you have provided to us.
Where to exercise your rights
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 firstname.lastname@example.org or if available, you could use the contact form provided in this Website. 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, we may ask you for your signed confirmation and proof of identity.
We will promptly inform you of having received this request. If the request proves valid, we shall honour it as soon as reasonably possible and at the latest thirty (30) days after having received the request.
Where to file complaints
8.8 If you have any complaint regarding the processing of your personal data by us, you may always contact us via email@example.com. If you remain unsatisfied with our response, you are free to file a complaint with the competent data protection authority.