Privacy statement

The private limited company “ETRAMO bvba”, established at 2110 WIJNEGEM, Vosveld 20, with company registration number 0417.212.044 (“we”/”us”) is responsible for the processing of your personal data as part of its activities.

The purpose of this privacy statement is to inform you of the personal data we process about you, the reasons for which we process and share this data, how long we store it and how you can exercise your rights.

Personal data that we collect and process

We collect and use your personal data to the extent necessary for our activities.

For this purpose, we process various categories of personal data, including:

identification data (e.g. name, IP address, contact details);
data regarding employment (e.g. job/position, name of the employer);
usernames, passwords and other login details (customer portal etramo.be);
financial data (e.g. bank account details, data that we receive from the credit insurer);
data regarding your agreements with us and your use of our products and services (e.g. order history, quotations, (non-)payments, complaints, etc.);
data relating to your interactions with us through our website, meetings/phone calls, e-mails, etc.
The personal data concerning you that we use are mostly data that you have provided to us directly, or data that we have obtained through one of the following sources:
- our business customers and service providers (e.g. credit insurer);
- publications/databases made available through official bodies (e.g. Belgian Official Gazette);
- websites/social media pages containing information that you personally have made public;
third parties (e.g. address traders).

Therefore, in some cases we also use information about you, while you actually do not have a direct relationship with us, for example if a customer (e.g. your employer), a service provider or a commercial partner provides us with information about you as (legal) representative, shareholder, employee, etc.

For what purpose and on what basis do we process your personal data

We process your personal data:

to enter into and execute agreements and by means of this, to provide you with information about our products and services, help you and answer your questions, evaluate whether we can offer you a product or service and under which conditions, and to supply products or services to you/our business customers of which you are, e.g. an employee;
based on our legitimate interestto be able to conduct our activities effectively and perfectly freely, to improve our products and services and to defend our rights, which includes proof of transactions, IT infrastructure management and security, conducting (e-mail) marketing campaigns for our products and services that you may be interested in.

Consequences of not providing personal data

We shall inform you in advance of cases where you are obliged to provide personal data that must then be processed on the basis of:

a legal or contractual obligation and/or;
because this is a necessary condition to be able to conclude an agreement.

In this case, you shall also be informed of the consequences arising from your possible refusal to provide this personal data. If you refuse to provide certain personal data, it is generally applicable that we can attach the consequences deemed advisable in relation to this.

How long we retain your personal data

We do not store your personal data any longer than is necessary to achieve the purposes for which your data was collected and to comply with applicable laws and regulations, or possibly longer if this is required in order to answer legal claims.

For example, most personal data is stored for the duration of the execution of the Agreement and for 10 years after the end of the contractual relationship.

Recipients of personal data

To fulfil the purposes defined above, we share your personal data with others.

This includes the following recipients:

transport companies;
banks;
(credit) insurers;
other commercial partners;
bookkeeper;
other service providers that we engage (e.g., suppliers of IT services, marketing agencies, online (e-mail) marketing platforms such as MailChimp, etc.);
financial and both judicial and public authorities, at their explicit request and to the extent permitted by law;
certain regulated professions such as lawyers and bailiffs.

Transfer of personal data outside the European Economic Area (“EEA”)

In certain circumstances – e.g. as part of the organisation and management of our (e-mail) marketing campaigns – we rely on companies established outside the EEA.

In case of international transfers to a country outside the EEA that the European Commission has recognised as a country with an appropriate level of data protection, your personal data will be transferred on this basis.

For transfers to countries outside the EEA that are not recognised by the European Commission as countries with an appropriate level of data protection, we will implement one of the following safeguards to ensure that your personal data is protected:

standard data protection provisions, as approved by the European Commission;
binding corporate rules.

To receive a copy of these safeguards or for more details about where you can find them, you can send a written request to us through the contact details mentioned in this Privacy Statement.

Your rights and how to exercise them

Based on the GDPR, you have the right to:

inspection allowing you to acquire information about the processing of your personal data and obtain a copy of such personal data;
rectification, when you think that your personal data is incorrect or incomplete, you can submit a request to correct and/or amend these personal data;
erasure, allowing you in a limited number of cases to request that we delete your personal data;
restriction of processing, allowing you to request that we temporarily stop processing your personal data;
objection, allowing you to object to the processing of your personal data for reasons related to your specific situation, while you have an absolute right to object to the processing of your personal data for direct marketing purposes;
transferability,entitling you, to the extent legally applicable, to obtain your personal data that you have provided to us or, to the extent technically possible, to have this data transferred to a third party.

In order to exercise the rights mentioned above, you must submit a request to us through;

a letter to ETRAMO bvba, Vosveld 20, 2110 WIJNEGEM, BELGIUM;
e-mail to privacy@etramo.com.

Questions or Complaints

If you have questions or observations, you can reach us through the contact details mentioned in this Privacy Statement.

It may occur, despite our careful approach, that you have a complaint about how we process your personal data and/or handle your rights. In this case, you can submit a complaint to the Data Protection Supervisor.

In Belgium, the Data Protection Authority is the supervisor for the processing of personal data. You can find the contact details of the Data Protection Authority on the website: www.gegevensbeschermingsautoriteit.be

Changes

This Privacy Statement was prepared on 15 April 2019.

We reserve the right to make changes to this Privacy Statement.

With this in mind, we request that you always consult the latest version of this Privacy Statement online. We shall keep you informed of important changes by means of e-mail or through our website.