Who are we?
Our website address is https://www.servicecompany.be.
Use of personal data collected
The purpose of this Privacy Policy is to inform you about how we use your personal data, for which we comply with the strict requirements of the Act of 8 December 1992 on the protection of privacy with regard to the processing of personal data, as amended by the Act of 11 December 1998, and with the requirements of the General Data Protection Regulation (GDPR).
Details of the data controller and data protection officer
The controller for the purposes of the GDPR, other data protection legislation in the EU Member States and other relevant data protection regulations is:
The Service Company SRL
Chaussée de Louvain 47,
1410 Waterloo, Belgium
The data protection officer can be contacted at the following address: arnaud@servicecompany.be
Purposes of processing and legal principles governing the processing of your personal data
We collect, process and use your personal data for the following purposes:
- Drawing up and executing contracts
- Distribution of newsletters and product reviews
- Marketing activities such as prize draws
- Customer service and support
- The provision of media services, e.g. for processing orders for the products and services we offer online.
Article 6, paragraph 1, letter a), of the GDPR serves as the legal basis for processing activities for which we obtain your authorisation/consent for a specific processing purpose.
Article 6(1)(b) of the GDPR states that personal data may be processed for the performance of a contract, e.g. when purchasing a product. The same applies to any processing activity that is necessary for the performance of pre-contractual activities, such as the processing of requests for information about products or services.
Article 6(1)(c) of the GDPR applies in cases where we are bound by a legal obligation that requires personal data to be processed, for example to comply with tax obligations.
Article 6(1)(d) of the GDPR states that personal data may be processed in order to protect your vital interests or those of another natural person.
Article 6(1)(f) of the RGPD applies to our legitimate interests, for example when using service providers to carry out orders (e.g. delivery services), when carrying out surveys and statistical analyses or when attempting to log in. Our interest lies in providing you with a user-friendly, attractive and secure website and in optimising it to meet our commercial interests while at the same time meeting your expectations.
Duration of storage and routine deletion of personal data
We will only process and store your personal data for as long as is necessary to fulfil the purpose for which we are required to do so by law or regulation. When the purpose ceases to apply or is fulfilled, your personal data will be deleted or restricted. Where data is restricted, it will be deleted as soon as the retention periods imposed by law, statute or contract no longer prevent its deletion, provided that there is no reason to assume that deletion would prejudice your legitimate interests, and provided that such deletion does not involve a disproportionate amount of effort due to the specific nature of the data storage.
Data collection and general information (log files)
Pursuant to Article 6, paragraph 1, letter f) of the RGPD, our website collects a series of general data and information on each access, which are temporarily stored in the log files of a server. A log file is created as part of the automatic connection made by the processing computer system. The following data may be collected:
- Website access (date, time and frequency)
-
- How you arrived on the website (landing page, hyperlink, etc.)
- Volume of data transmitted
- The browser and browser version you are using
- The operating system you are using
- The Internet service provider you use
- The IP address that your Internet service provider assigns to your computer when you connect to the Internet
The collection and storage of this data is necessary for the operation of the website in order to ensure the functionality of the website and to correctly deliver the content of our website. We also use the data to optimise our website and ensure the security of our IT systems. For this reason, data is stored for a maximum of seven days as a technical precaution.
We also use this data for marketing purposes, product advice, market research and structuring our services to meet demand by creating and analysing user profiles under pseudonyms, provided that you have not asserted your right to refuse or withdraw your authorisation/consent for the use of your data in this way (see notes on your right to object under "Your rights"). This includes the "Remember me" function, which you can also deactivate in your user account.
Cookies, web analysis services and social media
We use cookies, web analysis services and social media plugins on our website, for which there is a separate cookie policy.
Processing of personal data when establishing contact, registering and submitting guest orders
a) Establishing contact
When you contact us by telephone, e-mail or via the contact form, the information you provide will be recorded by us on the basis of Article 6(1)(a) of the RGPD in order to answer your questions. The contact will be logged in order to provide proof of contact, in accordance with legal requirements. Your consent will be obtained for data processing by completing the contact form and reference will be made to this Data Protection Policy. The data collected in this respect will be deleted by us at the end of the interview in question, and when the matter in question has been definitively settled.
b) Registration
On our website, we offer you the option of registering by providing personal data. This data is entered into a data registration form, sent to us and stored by us. Registration is carried out in order to fulfil a contract or to carry out pre-contractual activities, and is therefore based on Article 6, paragraph 1, letter b ), of the RGPD.
In order to conclude and execute contracts, we need contact details that depend on the specific case, such as name, delivery address, billing address, e-mail address and information about the payment method you have chosen. We also use your data to update our customer data, for which only relevant data is stored. To avoid typographical errors and to ensure that the products you order actually reach you, we check that your address is complete and correct when it is entered.
c) Guest orders
You have the option of submitting orders as a guest. If you choose this ordering method, you do not need to register before submitting your order. Please note that you will need to re-enter your details when placing any future orders.
We collect, process and use the data provided by you for orders as a guest for the purposes of fulfilling the contract in accordance with Article 6(1)(b) of the GDPR. We store the information you provide for the duration of the processing and fulfilment of your order. Your data is then deleted unless you decide to activate your customer account within 14 days of placing your order. Data that must be stored in accordance with legal obligations, statutes or contractual retention requirements will be restricted rather than deleted to prevent its use for other purposes.
d) Miscellaneous clauses
On the basis of Article 6(1)(c) and (f) of the GDPR, we use and store your personal data and technical information where necessary to prevent or investigate misuse or other unlawful behaviour on our website, e.g. to maintain data security in the event of attacks on our computer systems. This may also be done on the basis of orders issued by public authorities or judicial bodies, insofar as we are required to do so by law, as well as to safeguard our rights and interests and to enable us to defend ourselves in court.
Transmission of personal data to third parties
When transmitting your personal data, we ensure that the level of security is always as high as possible, which is why your data is only transmitted to carefully selected service providers and partner companies who are bound by contractual obligations. We also pass on your data to organisations that are located in the European Economic Area and are therefore subject to the EU's strict data protection legislation or are bound by a corresponding security standard. The transfer of data to third countries is not currently carried out or planned.
a) Transfer to affiliated companies of the Group in accordance with Article 6, paragraph 1, letter b), of the RGPD
We transfer your personal data to affiliated companies of the Group for the purpose of concluding and executing contracts relating to the performance of deliveries and services on our website, for storage in central databases and for the Group's internal invoicing and accounting purposes. In particular, this is necessary so that you can use all our services. If you wish to collect your order from the point of sale, the latter will be informed of your order and will process it. If you contact a point of sale or our customer hotline with questions, complaints or returns, they will also have access to your order data so that they can answer your questions.
b) Transmission to product partners in accordance with Article 6(1)(b) of the RGPD
As part of the services and products we offer on our website, we work with various partner companies for certain product groups. If you order products from these partners, we will pass on the personal data you provide during registration and, if further purchases are made, your additional personal data specified under "My account" for the conclusion and performance of contracts (in particular your e-mail address, delivery address and billing address). Your contractual partner will be specified on the relevant product pages, in the General Terms and Conditions of Sale and in the Legal Notice. Please note that your contractual partner is itself responsible for its own data security precautions and that additional or different Privacy Policies may apply to those Product Pages.
c) Transmission to service partners in accordance with Article 6(1)(b) and (f) of the RGPD
For the operation and optimisation of our website and for the performance of contracts, we commission various service companies to act on our behalf, e.g. to provide centralised IT services, host our website, process payments and ship products, install equipment or distribute newsletters. We pass on the information required for the respective purposes to these service partners (e.g. name, address).
Some of these companies (bpost SA under public law) act on our behalf with regard to the processing and execution of orders and are therefore only authorised to use the data provided in accordance with our instructions. In this case, we are legally obliged to ensure that the companies we use take adequate data security precautions. We therefore agree specific data security measures with these companies and monitor these measures on a regular basis.
Where the products to be shipped are large and heavy, your order will be shipped via a service provider such as DHL Global Forwarding, UPS or DPD Belgium. These service providers will receive information from us, such as the email address provided by you with your order, to enable them to arrange a specific delivery time with you.
Contrary to the requirements for external processing, we pass on data to third parties in the following cases for the purpose of fulfilling the contract, in which case these parties are themselves responsible for the use of the data:
- In the case of product shipment, data is transmitted to logistics companies or to the postal service provider specified in the order.
- As regards payment for the products ordered, the data is transmitted to the payment organisation or a financing bank indicated in the order. When a credit card is used as a method of payment, a security check based on the transaction will be carried out with the help of payment organisations such as Atos Worldline, Ingenico, Verifone, Bancontact, Master Card, PayPal and VISA in order to prevent any credit card fraud.
For payment purposes, we do not collect or store payment information such as credit card numbers or account details. This information is solely and directly transmitted to the payment organisation in question. When a credit card is used as a payment method, one exception is the "pseudo card number". In order to avoid you having to re-enter your credit card details each time you make a payment, a pseudo card number is saved on your customer account. This pseudo card number is only used to pay for products and services on our website, ordered under your customer account, and is not identical to your credit card number.
d) Transmission to other third parties in accordance with Article 6, paragraph 1, letters c) and f), of the RGPD
Finally, we may transmit your data to third parties or government bodies in accordance with current data protection legislation if we are legally obliged to do so (e.g. on the basis of an order from a public authority or judicial body) or if we are entitled to do so (e.g. because it is necessary for the investigation of criminal activities or to assert and enforce our rights). Finally, we may pass on your data to third parties or government bodies in accordance with current data protection legislation if we are legally obliged to do so (e.g. on the basis of an order from a public authority or a court) or if we are entitled to do so (e.g. because it is necessary for the investigation of criminal activities or to assert and enforce our rights and interests).
Conversion tracking with Facebook's visitor action pixel
We use the 'visitor action pixel' from Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, United States ("Facebook") to measure the effectiveness of online marketing measures. This tool enables us to track the actions of users after they have viewed and/or clicked on a Facebook ad and then placed an order. This enables us to record the effectiveness of Facebook ads for statistical and market research purposes. The data collected remains anonymous, which means that we can neither see the personal data of individual users nor associate it with other information about a user.
However, this data is stored and processed by Facebook. Facebook is able to link the behaviour of users who have clicked on an advertisement in the Facebook member zone and have been redirected to our websites. By using cookies, i.e. text files stored on your computer, Facebook is able to recognise the user in the Facebook member area and use the data for its own advertising purposes, e.g. targeted advertising, in accordance with Facebook's Data Use Policy. This only applies to users who have a Facebook account and are logged into the Facebook membership area. Users who are not Facebook members are not affected by this data processing.
Your rights
Of course, you have rights with regard to the collection of your data and we are pleased to inform you of these here. If you wish to exercise any of the following rights free of charge, simply send us a message. You can use the following contact details, without incurring any costs other than those applied by your communications provider to transmit the message:
- By email : arnaud@servicecompany.be
- By post: The Service Company, Chaussée de Louvain 47, 1410 Waterloo, Belgium
For your own security, we reserve the right to obtain other information necessary to confirm your identity when responding to an existing request. If identification is not possible, we also reserve the right to refuse to respond to your request.
a) Right to information
You have the right to ask us for information about the personal data stored about you.
b) Right of rectification
You have the right to request that the personal data stored about you be rectified and/or completed immediately.
c) Right to restrict processing
You have the right to request that the processing of your personal data be restricted if you dispute the accuracy of the data stored about you, if the processing is unlawful and if we no longer need the data, but you do not wish the data to be deleted and you are making this request in order to assert, exercise or defend legal claims, or if you have communicated your objection to their processing.
d) Right to erasure
You have the right to request the erasure of your personal data stored by us, unless the retention of the data is necessary for freedom of expression, freedom of information, to comply with a legal obligation, for reasons of public interest, to assert or defend against legal claims or to exercise legal rights.
e) Right to information
If you have exercised your right to rectification, erasure or restriction of processing, we will inform all recipients of your personal data of how the data has been rectified, erased or is now subject to restrictions on processing, unless it is impossible to do so or would involve a disproportionate effort.
f) Right to data portability
You have the right to have a copy of the data you have provided to us sent to you or to a third party in a structured, standardised and machine-readable format. If you request that the data be sent directly to another controller, this will only be done if it is technically feasible.
g) Right to object
If your personal data is processed on the basis of legitimate interests in accordance with Article 6(1)(f) of the GDPR, you have the right to object to the processing at any time in accordance with Article 21 of the GDPR.
h) Right to withdraw consent/authorisation
You have the right to withdraw your authorisation/consent for the collection of data at any time, with future effect. Data collected prior to the withdrawal taking legal effect will not be affected. We hope you understand that processing your withdrawal may take some time for technical reasons and that you may continue to receive messages during this time.
i) Right to submit a complaint to a regulatory authority
If the processing of your personal data violates data protection legislation, or if your data protection rights have been violated in any other way, you may submit a complaint to the regulatory authority.
The easiest and most convenient way to exercise your rights of rectification and deletion is to log in to your customer account and directly edit or delete the data stored there. Please note that once your data has been deleted, you will no longer have access to the services of our product partners via our website. This may also include re-download services. Therefore, please back up your data before exercising your right to deletion. Data that must be stored in accordance with legal obligations, statutes or contractual retention requirements will be restricted rather than erased to prevent its use for other purposes.
You have the right to lodge a complaint about the use of your personal data with the DPO of TSC (The Service Company SRL).
You can also lodge a complaint with the DPA (Data Protection Authority):
Rue de la Presse 35, 1000 Brussels
contact@apd-gba.be
Data protection in relation to application documents and procedures
We collect and process applicants' personal data for the purposes of carrying out application procedures. A Privacy Policy is in place for this purpose.
Links to the websites of other companies
Our website contains links to the websites of other companies. We are not responsible for the data security precautions taken by other websites accessible via these links. Please check the privacy policies of these external websites.
Changes to the privacy protection policy
In order to ensure that our privacy policy complies with legal requirements at all times, we reserve the right to make changes at any time. This also applies where the Privacy Policy needs to be amended to incorporate new or revised products or services.
Version: January 2021, Version 1.0