Last updated: 12/01/2023
WHO ARE WE?
Your personal data collected in stores, at Van de Velde events and on the Van de Velde websites ("Website") is administered by Van de Velde NV, a company incorporated under Belgian law with registered office at Lageweg 4, 9260 Schellebelle, Belgium and with company registration number 0448.746.744 ("Van de Velde" or "we" or “__us__”). Any reference in this Policy to Van de Velde also includes the European subsidiaries of Van de Velde NV, a list of which can be consulted here.
Van de Velde is the controller of your personal data. This means that Van de Velde determines the purpose and means for the processing of your personal data.
WHEN IS THIS POLICY APPLICABLE?
All personal data Van de Velde collects during your visit to the Van de Velde stores, a Van de Velde event, or a Website will be handled in accordance with this Policy.
Van de Velde protects your privacy and acts in accordance with the provisions of the Belgian Data Protection Act (the ‘Act of 30 July 2018 on the protection of physical persons with regard to the processing of personal data'), the UK Data Protection Act 2018 and the European General Data Protection Regulation 2016/679 (“__GDPR__”). Please read this Policy to learn more about how personal data are collected and processed by us through the Website, at events and in stores.
WHO IS PROTECTED BY THIS POLICY?
This Policy only applies to the personal data that Van de Velde processes as controller (see chapter: “*Who are we?*”). This Policy applies to the processing of personal data of our consumers (private) and customers (business) in relation to our products and services. This Policy also applies when you visit our offices or our stores, websites, use our apps, participate in market research, surveys, contests, actions or events, or otherwise use our products and services. The personal data of former consumers and customers will also be treated and secured as carefully as possible, in accordance with this Policy.
What personal data are we processing?
Data you provide to us at our stores and events: In the Van de Velde stores and at Van de Velde events, the following personal data may be collected. When filling in a 'keep me posted card', you are free to submit the following information: name, address, e-mail, date of birth, favourite store, telephone and shape ID. When creating a Shape ID, you submit the following additional information: size, date of birth, and shape ID. For attendance at one of our events, you submit the following information; name, address, e-mail, date of birth, favourite store, telephone.
Data you provide to us through the use of our services: You may also provide personal data through the use of our services. Personal data can be collected such as name, address, sex, age, civil status, email address, financial characteristics, place of residence, landline and mobile phone number, size, breast volume and circumference and purchase history. This is for example the case when you place an order on the website, register as a customer, subscribe to one of the following services: electronic newsletter, MMS marketing (by mobile phone) or press information, when you call our Customer Services or when you send us a letter, text message, chat or an e-mail.
WHAT DO WE USE YOUR PERSONAL DATA FOR?
Van de Velde processes your personal data for various purposes, whereby we only process the data that are necessary to achieve the intended purpose.
We use personal data when it is necessary for: i. processing an order; ii. providing goods, services and/or information requested by you; iii. providing you with the information, goods and services offered through our Website for billing and order fulfilment; iv. verifying and carrying out financial transactions in relation to payments you make online; v. administering your account with us; vi. auditing the download of data from our Website; vii. measuring and monitoring the use and improving the quality and content of this Website; viii. customizing the content and layout of this Website; ix. improving Van de Velde’s products and services; x. organising and inviting you to our events; xi. profiling (in order to provide you with personalized commercial information); xii. targeting on online platforms; xiii. organising contests; xiv. sending personalized commercial information through Whatsapp; xv. complying with the legal or regulatory provisions to which we are subject; xvi. providing general or direct marketing towards you; xvii. maintaining your shape in order to assist you better with your next purchase. xviii. processing a dropshipment order or a ‘Reserve & Fit’ reservation with an independent retailer of Van de Velde
The processing of the personal data of categories (i) to (v) is necessary for the performance of the contract you have with Van de Velde.
Categories (vi) to (xiv) are processed within the framework of the legitimate interests Van de Velde holds to process these personal data, including prevention of fraud or misuse of services, marketing research, website improvement purposes, organisation of events and contests, and profiling. In these cases Van de Velde will always aim for a balance between our legitimate interest and your privacy. The processing within the framework of categories (xvi) and (xvii) only takes place in case you have provided your consent there to. The processing within the framework of category (xviii) is necessary for the performance of the contract you have with an independant retailer of Van de Velde.
Some additional information on our direct marketing activities (xv.): Van de Velde will provide you with (personalized) communications only when you have consented to us processing your personal data for direct marketing. We may contact you (1) in writing, at your home address; (2) by calling you or texting you on the telephone number(s) you have provided; or (3) by e-mail or fax, with information regarding events, promotions, actions, products, services and/or contests. If you prefer not to receive any marketing communication from us, or if you prefer for your personal data not to be processed for direct marketing, you can opt out at any time by sending an email to email@example.com.
HOW DO WE PROTECT YOUR PERSONAL DATA?
We work hard to protect your privacy and personal data at our offices, in our stores and on our Website. Van de Velde uses a combination of technical and organisational measures to keep your data safe.
Our employees are trained to correctly handle your personal data. Furthermore in the framework of every project that is aiming to process personal data, an assessment is performed with regard to security and the protection of this data, all while keeping into account your interests. Also our internal information Security Policy, security requirements and management standards are followed up for compliance by our employees.
We also employ specialized profiles who are responsible for the security of our network, our infrastructure and our information systems. In addition, we use all sorts of technical measures to protect your personal data against unauthorized access, unauthorized use and loss or theft of our data, such as: password protection, firewalls, antivirus and access controls for our employees. No method of transmitting or storing of data is completely secure however, so should a data breach occur with adverse consequences for you, then you will be personally informed in the circumstances provided by the law. If you have a security-related concern, please contact us at firstname.lastname@example.org.
ARE WE SHARING OR SELLING YOUR PERSONAL DATA?
We do not sell nor share your personal data to any third parties without your prior consent, unless:
to companies associated by law with Van de Velde, established in the European Economic Area or the United States of America. Your personal data is shared with these companies for the same purposes as those stated within this Policy. These companies qualify as joint controllers in this context. You may request a list of these companies by sending an email to email@example.com. This list is also available at the corporate website of Van de Velde, under 'Investor relations, Group structure' (www.vandevelde.eu/en/group-structure); — To an independent retail partner if you access the Website through a link of the concerned independent retail partner and make a purchase;
to a legal successor acquiring part or the whole of Van de Velde;
to recognized financial or bank institutions whose intervention is necessary for the smooth course of the payment procedure;
to credit reference agents. We reserve the right to request information about you from other third parties such as credit reference agencies. We will add this information to the information we have previously processed about you so as to enable us to: (1) provide goods or services to you; (2) improve and enhance your buying experience; and (3) contribute to money laundering and fraud prevention. Where we make such a request we will first inform you of this intention and of whether any record of the search will be recorded on a credit file;
when we are required to do so by law or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the Website or the rights, property or personal safety of any person. (We refer to chapter “What do we use your data for”);
when it is necessary to provide you with our services. A) Some of our databases are made accessible or transferred to third parties who work in our assignment and who assist us in delivering our products and services. Consider for example our commercial agents, the independent retailers and our service providers of web hosting, cloud services or maintenance services. Furthermore, several postal services are assisting us to provide you with the packages you order from us (e.g. UPS, DHL, De Post, Post NL etc.). The transfer of your data only takes place for the purposes as mentioned within this Policy and is limited to the data that they need for the performance of our assignment. We ensure that they, just like us, manage your data safely, respectfully and with due care and we provide adequate contractual guarantees. B) If you subscribe to our newsletter, we might tailor our communications and online advertising based on the information you provide to us. Social media enable us in this context to provide you with relevant information, updates and marketing content (such as advertisements based on look-a-like profiles). Furthermore social media enable us to function as customer service (for instance when you use social media to contact us). Please be aware that social media channels have their own privacy and cookie policies in place, so the personal information you give them will be subject to their rules and not ours.
when we have or the third party has a legitimate interest for transfer. We will only transfer your personal data based on an assessment of your rights and freedoms and you will always be transparently informed about them (except in case of legal exceptions).
when you provide your consent. In any other case where we would be transferring your data to third parties, we will provide you with a transparent notice through which you are informed of the third party, the purpose of the transfer and their processing. Where it is required by law, we will obtain your explicit consent to do so.
For all data transfers outside of the European Economic Area, we ensure through the appropriate safeguards embedded in the contract or other measures that your data receives an adequate level of protection comparable to the protection it would have within the EU in accordance with the European regulations.
We may also disclose anonymous, aggregated statistics for commercial and internal/external reporting. For example: about visitors to our Website in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes. These statistics will not include information through which you may be identified.
If you have any queries about the processing of your data by such third parties, please contact the third party in question. To the extent that this processing goes beyond the scope of purposes determined by Van de Velde, the third party is fully responsible for such processing, and Van de Velde can in no way be responsible or liable for such processing.
WHAT ARE YOUR PRIVACY-RIGHTS AND HOW CAN YOU EXERCISE THEM?
An overview of your rights: You are entitled to review and to request the rectification or erasure (“right to be forgotten”) of your personal data. Furthermore, you are entitled to object to the use of your personal data for direct marketing purposes. You also have the right to ask for the provision of a copy of all your personal data which are processed by us, where technically feasible. You also have the right to exercise your right to data portability.
Practicalities: How to exercise your rights? To exercise these rights, or if you require further information regarding your rights, simply email firstname.lastname@example.org. In order to exercise your right of access and to prevent any unauthorized disclosure of your personal data, we must verify your identity. In case of doubt or ambiguity, we will first ask you for additional information (for example a copy of your identity card).
Will you have to pay? You can exercise your privacy rights free of charge, unless your request is manifestly unfounded or excessive, in particular because of repetitive nature. In such a case we have – in accordance with the General Data Protection Regulation – the right and the choice to charge you a reasonable fee (taking into account the administrative costs to provide the requested information or communication) or to refuse to comply with your request.
How will you receive an answer? If you submit your request electronically, the requested information will be provided to you electronically if possible, unless you request otherwise. In any case, we will provide you with a concise, transparent, understandable and easily accessible answer.
When will you receive an answer? We will respond to your request as soon as possible, and in any case within one month of receipt of your request. Depending on the complexity of the request and the number of requests, this period could be extended for an additional two months if required. If this would be the case, we will notify you within one month of receipt of the request.
Finally, you have the right to lodge a complaint with your local data protection authority or with the Belgian Data Protection Authority (our lead supervisory authority) regarding the processing of your personal data by Van de Velde. The Belgian Data Protection Authority can be reached at:
Drukpersstraat 35, 1000 Brussel. +32 (0)2 274 48 00 / email@example.com / www.dataprotectionauthority.be
HOW LONG ARE WE KEEPING YOUR PERSONAL DATA?
By law, we are not allowed to store personal data for longer than is necessary to achieve the purpose for which we collected it. The retention period can therefore be different according to the processing activity. Some examples: Generally, we will be storing your personal data for a period of 5 years after your most recent login or transaction with Van de Velde. Personal data that has been collected for contests will only be kept for 1 year after the contest has been closed. For marketing purposes for which you have provided us with consent, your contact information will be kept by us for as long as you don’t withdraw your consent. Finally, in order to meet our accounting and tax obligations, we are subject to a variety of local laws to keep your data for a certain period of time.
After the applicable storage period(s) have expired, your personal data will be deleted or anonymized.
How can you stay informed of adjustments to this Policy? Van de Velde reserves the right to change, adapt, supplement or remove this Policy wholly or partly at any time as it sees fit. This can happen for example in the light of market evolutions or new processing activities we employ. Therefore you are invited to check this Policy regularly for changes. By using a Website after any such change has been made to this Policy, you are deemed to have accepted this change, regardless of whether you have read this Policy.
If you do not accept this Policy, please leave the Website through which you are consulting this Policy immediately. You will not be allowed to create a profile or receive direct marketing if you do not accept this Policy.
HOW CAN YOU GET INTO CONTACT WITH US?
If you have questions, suggestions, or concerns about this Policy, or about our use of your information, please contact us at firstname.lastname@example.org.
You may also contact us at: Van de Velde NV Lageweg 4 9260 Schellebelle Belgium Company registration number: 0448.746.744