General

This Privacy Policy governs the processing of your personal data by any entity of the Pollet Group as listed in Annex 1 (hereafter collectively referred to as: “Pollet”, “We”, “Us”, “Our”) when you:

• Visit or use one of our websites (hereafter referred to collectively as “Websites”) and/or provide personal data in doing so (for example by filling in the contact form, sending an email, making contact by telephone, etc.);
• In any way use our products or services;
• Wish to communicate with us by email, telephone, fax and social media;
• Wish to communicate with us at trade fairs and events;
• Explicitly accept this Privacy Policy.

Below you can find an overview of answers to the most important questions about the processing of your personal data by Pollet.

The identity of the controller and who is protected by the Privacy Policy

In Annex 1 you will find the registered offices and company numbers of Pollet to which this Privacy Policy applies.

Pollet acts as controller within the meaning of the data protection legislation and, in this capacity, we wish to inform you about the processing of personal data.

This Privacy Policy is therefore only valid for the personal data that Pollet processes in its capacity as controller. You can address any questions concerning the processing of your personal data to our privacy officer at privacy@boekan.be.

Which personal data does Pollet process?

Pollet processes personal data that are relevant to or necessary for the purposes for which they are processed.

Personal data are all data that identify you as a natural person or make you identifiable. A natural person who can be identified directly or indirectly on the basis of the personal data processed is considered identifiable.

Pollet processes different categories of data depending on the purpose of the processing:

• Identification or contact details such as your first name and surname, address, telephone number, email address, electronic identification data such as your public IP address, cookies;
• Details of the assignments, orders or specific interests you have;
• Company and/or invoicing details.

Specifically, and depending on the marketing tools we use, the following personal data are processed:

Tool / Service	Type of personal data
Enhanced Conversions	Names, email addresses, telephone numbers, addresses, customer identifiers, online identifiers, Internet Protocol addresses
Google Ads Customer Match	Names, email addresses, telephone numbers, addresses, customer identifiers
Google Analytics	Online identifiers such as cookie identifiers, Internet Protocol addresses and device identifiers; customer identifiers
Google Data Studio	Data relating to individuals to create reports, graphs and charts
Google Optimize	Online identifiers such as cookie identifiers and Internet Protocol addresses
Google Tag Manager	Online identifiers such as cookie identifiers and Internet Protocol addresses
Facebook Ads Custom Audiences	Email addresses, telephone numbers, addresses
HotJar	Online identifiers such as cookie identifiers and Internet Protocol addresses
CRM	Names, email addresses, telephone numbers, addresses, customer identifiers, online identifiers, Internet Protocol addresses

For what purposes does Pollet process your personal data?

We process your personal data for the purposes set out below:

• To contact you if you wish to purchase goods or services from us, or to respond to your general questions via the various ways in which you can contact us (shop visit, event, trade fair, email, social media, etc.);
• To ensure that orders and deliveries go smoothly when you purchase a product or use a service;
• In the context of our day-to-day business operations relating to our legal obligations: for managing our accounts, customer management, management of disputes, supplier management, public relations, management of insurance policies, etc.;
• In the context of our recruitment policy. If you submit your application for a vacancy at Pollet, we will process your data at your request for the possible conclusion of an employment contract;
• To carry out statistical analyses in order to improve our Websites, products and services or to develop new products and services;
• To share personal data about you on our Websites or social media;
• For marketing purposes, i.e. to provide you with targeted communications, promotions, offers and other advertising from Pollet and selected partners.

Unless you are an existing customer who has already bought similar goods or services from us and whom we wish to target with our own marketing material, Pollet will send you communications, promotions, offers, newsletters and other advertising via email or other person-to-person electronic communication channels only if you have expressly consented to receiving such communications, offers, newsletters and other advertising.

Legal basis for processing your personal data

We process your personal data on the basis of the following legal grounds:

• Because of the legal obligations that rest on us;
• Because of the performance of the contract you enter into with us or the pre-contractual steps you take during your application;
• Because of the legitimate interest that we can invoke in order to assist you with our products and services;
• Because of the explicit consent you have given for this.

Do we share your personal data with third parties?

Your personal data are processed mainly for internal use.

Pollet will never sell your personal data or make them available to third parties for commercial purposes.

We will always ask for your prior consent before transferring data to third parties, except for transfers that are necessary for complying with legal obligations, where you already have information about the transfer, or where the personal data must remain confidential in the context of professional secrecy.

Although processors are not regarded as third parties, we would like to inform you that Pollet uses processors with whom we exchange personal data, such as contractors, ICT service providers, communications agencies, etc. Through processor agreements we ensure that the processors who process your personal data on our behalf always do so in compliance with the data protection legislation and only for the purposes explained above. Pollet will check that the processors process the personal data in a secure, fair, lawful and proportionate manner.

If the processors used by Pollet process personal data outside the European Economic Area (EEA), Pollet will, in accordance with the data protection legislation, ensure by contractual or other measures that these data enjoy an appropriate level of protection there comparable with the protection they would receive in the EEA.

Where necessary for its day-to-day business operations, and always in compliance with the data protection legislation, Pollet will also share personal data with parties such as law firms and debt collection agencies, banks and insurance companies.

Which techniques do we use to protect the privacy of your personal data?

Pollet takes the necessary technical and organisational measures to protect your privacy.

We take various technical measures to protect the personal data we process against unauthorised access or alteration, against disclosure and destruction, as well as against loss and theft, such as: password protection, encryption of data, firewalls, antivirus software, logging and monitoring of our systems, access management, keeping ICT software up to date and, where required and possible, anonymising the personal data, etc.

Pollet also takes organisational measures to protect your personal data, such as appointing a privacy officer; employing staff who ensure the security of our network, our infrastructure and information systems; measures to manage physical access to our offices; our staff have access only to those personal data that are necessary for the performance of their duties and are trained to carry out their tasks with respect for your privacy at all times; we implement the data protection legislation in our business processes, procedures and work instructions.

These measures are regularly evaluated and refined by subjecting them to internal and external audits.

Despite these security measures, it may still occur that third parties succeed in circumventing them and unlawfully obtaining and/or using your personal data. We cannot be held liable in any way for this and are therefore in no way liable for any unlawful use of your personal data by third parties.

How long do we keep your personal data?

Pollet retains your personal data:

• for as long as necessary or relevant to achieve the above-mentioned processing purposes;
• for the period for which we are legally obliged to do so (e.g. in the context of warranty, accounting or employment law obligations);
• for as long as a contractual relationship is in place;
• for as long as a legal dispute or investigations may arise in relation to the services or products we have supplied.

We handle your personal data in accordance with this Privacy Policy for as long as we retain them.

What rights do you have in relation to the processing of your personal data?

In accordance with the data protection legislation, you have certain rights regarding the processing of your personal data. Below you can already find an overview of these rights.

Right to information and access

You have the right to be informed whether Pollet processes your personal data and, where this is the case, to obtain access to those personal data and to the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients (in particular recipients in third countries);
• where possible, the retention period or, if that is not possible, the criteria used to determine that period;
• the right to lodge a complaint with the supervisory authority;
• information about the source of the data if we obtain personal data via a third party; and
• the existence of automated decision-making, including profiling.

You have the right to request a free copy of your personal data in a commonly used format. If you request additional copies, Pollet may charge a reasonable fee to cover the administrative costs.

Right to rectification

You have the right to ask Pollet to complete or correct any incomplete or inaccurate personal data that Pollet processes.

Right to erasure (“right to be forgotten”)

You have the right, in the following cases and without undue delay, to have your personal data erased by Pollet:

• your personal data are no longer necessary for the purposes for which they were collected or otherwise processed by Pollet;
• you withdraw your earlier consent to the processing and there is no other legal basis on which Pollet can rely for the (further) processing;
• you object to the processing of your personal data and there are no other grounds for (further) processing by Pollet;
• your personal data are being processed unlawfully;
• your personal data must be erased in order to comply with a legal obligation;
• your personal data were collected when you were still a minor.

In some cases, we will not be able to grant your request for erasure of data, for example where the processing is necessary for the establishment, exercise or defence of legal claims or because the processing of these personal data is necessary for compliance with legal obligations. We will inform you further about this in our response to your request for erasure.

Right to restriction of processing

You have the right to request restriction of the processing of your personal data if one of the following circumstances applies:

• you dispute the accuracy of those personal data: their use will be restricted for a period during which Pollet will verify the accuracy of the data;
• the processing of your personal data is unlawful: instead of erasing your data, you request restriction of their use;
• Pollet no longer needs your data for the original processing purposes, but you need them for the establishment, exercise or defence of legal claims: instead of erasing your data, their use will be restricted for the establishment, exercise or defence of the legal claims;
• for as long as no decision has yet been taken on the exercise of your right to object to the processing, you request restriction of the use of your personal data.

Right to data portability

You have the right to ask Pollet to obtain your personal data in a structured, commonly used and machine-readable format and to have the right to transfer those data to another controller. You may ask us to transfer the data directly to the other controller, unless this is technically not possible.

This right only applies to personal data that you have provided to Pollet on the basis of your consent or for the performance of a contract, and where the processing is carried out by automated means.

Right to object and automated individual decision-making

You have the right to object to the processing of your personal data if you are in a particular and specific situation that justifies such objection.

Pollet will cease processing your personal data unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or where the processing of your personal data is related to the establishment, exercise or defence of legal claims.

You have the right not to be subjected to a decision based solely on automated processing, including profiling. This right does not apply in the following cases: where profiling or automated individual decision-making is permitted by a legal provision which also provides for appropriate measures to safeguard your rights and freedoms; where it is necessary for the conclusion or performance of a contract; where it is based on your explicit consent.

How can you exercise your rights?

You can contact us for more information about the Privacy Policy or about exercising your rights using the following details:

• By letter addressed to BOEKAN NV, for the attention of the privacy officer, Brouwerijstraat 14, 8680 Koekelare;
• By email to: privacy@boekan.be.

If you wish to exercise any of the above rights, you must provide us with proof of identity (such as a copy of your identity card) or of a power of attorney obtained.

As soon as we receive a complaint via one of the channels mentioned above, you will receive an acknowledgement of receipt. Your request will then be dealt with within a reasonable period.

Right to lodge a complaint with a supervisory authority

If you have any complaints about the processing of your personal data, we would kindly ask you to contact us directly first via one of the contact channels mentioned above so that we can resolve the matter for you.

You also always have the right to lodge a complaint with the competent supervisory authority.

You can find the contact details of the relevant supervisory authorities in Annex 2.

Which cookies do we use?

When you visit our Websites, certain cookies may be placed on your device while you use the Websites. You can find more information about this in our Cookie Policy.

How are changes made to the current Privacy Policy?

Pollet’s Privacy Policy is amended from time to time, for example due to adjustments to our products/services that affect the processing of personal data.

We will publish all changes to this Privacy Policy and the most recent version on our Websites.

Annex 1:

Pollet Group (Pollet) consists of, and this Privacy Statement therefore applies to, the following entities: