SOWL S.A., with its head office at Chaussée d’Ixelles 12, 1050 Brussels, Belgium, company number BE 0888.719.344, acting as data controller, processes and uses personal data relating to its customers (hereinafter referred to as the “Customers”) in accordance with the applicable data protection regulations, in particular European Regulation 2016/679 of 27 April 2016 referred to as the General Data Protection Regulation (hereinafter referred to as the “GDPR”).
The purpose of this privacy notice is to explain why and how SOWL collects personal data about its Customers (hereinafter referred to as “Customer Data”), how it protects them and how long it retains them. This notice does not affect specific provisions that may be included in other documents.
- Why does SOWL process Customer Data?
SOWL stores and processes Customer Data, in electronic or non-electronic form, for administrative, marketing and customer management purposes, particularly in view of the following non-exhaustive activities: processing and responding to any communications, demands or requests that Customers submit to SOWL (including via the website) or following a first contact from SOWL, processing information relating to actual or potential online sale of products and/or services of SOWL and sending statements and invoices to Customers, providing Customers with newsletters and other marketing communications, conducting surveys and market research, improving SOWL products and/or services and resolving disputes.
- What are the legal bases of Customer Data processing?
Customer Data are processed lawfully, fairly and transparently. They are processed on the basis of one or more of the following legal grounds:
• with a view to concluding and managing the performance of a sales contract or other contract with a Customer, including the billing procedure;
• in order to comply with legal requirements applicable to SOWL (e.g., regarding tax matters etc.);
• in the context of the legitimate interests of SOWL and/or a third party that, in the opinion of SOWL, also benefit Customers, such as, but not limited to, direct marketing and data analysis;
• the consent of the Customer concerned (e.g., in order to respond to a customer satisfaction survey). The Customer concerned may withdraw his consent at any time, on the understanding that such withdrawal will not affect the lawfulness of the processing carried out prior to such withdrawal on the basis of this consent.
- What categories of Customer Data are processed?
Customer Data are all kinds of personal information concerning an identified or identifiable natural person.
To the above-mentioned ends, personal data processing may include the following categories:
• personal identification data, such as name and address;
• electronic identification data, such as e-mail address and telephone number;
• personal details, such as date of birth, language, nationality and gender;
• consumer habits (volume of purchases, sales history etc.);
• participation in events (including family members, if applicable);
• data derived from surveys.
- Where do Customer Data come from?
When a Customer contacts SOWL, the initial data usually come from the Customer himself or indirectly through his visit to our website (e.g., cookies). SOWL may also contact a Customer for prospecting purposes when the original data have not been obtained from him but from others who have submitted these data to SOWL. As part of his relationship with SOWL, the Customer in question will provide SOWL with additional information (e.g., the details required for the purchase order). If the Customer does not provide SOWL with the information required by law or the contract, SOWL may decide not to consider requests or orders placed by such Customers. Also, if the Customer does not provide other information, he may not receive the benefits associated with it. For example, if a Customer does not wish to share his e-mail address with SOWL, he or she will not receive any of SOWL's electronic newsletters.
SOWL may also receive data relating to a Customer from other customers, suppliers or, more generally, other persons with whom the Customer may exchange such data as part of his relationship with SOWL.
- Who has access to Customer Data?
For the purposes listed above, personal data may be divulged and even possible processed by:
• Customers themselves;
• SOWL staff who need to know the personal information involved;
• individuals and legal entities that have direct contacts with SOWL, such as its branch companies or franchisees;
• public authorities pursuant to applicable regulations, such as the tax administration;
• service providers (for example, for maintenance of the website, for assistance during promotional campaigns etc.) and other professional counsellors of SOWL who need to know this information.
- Are Customer Data transferred outside their country of residence?
In general, these data are kept in Belgium but we may transfer certain information concerning Customers abroad, but always in connection with the management of our activities. If this is a transfer of data outside the European Union, SOWL will have put in place appropriate guarantees in accordance with the GDPR.
- How long are Customer Data stored?
Customer Data are stored no longer than is necessary for the purposes listed above.
As concerns data transmitted as part of observations or requests, the transmitted data are stored for 1 month after we have replied.
As concerns data transmitted indirectly by our system, the data are stored for only 1 month after a visit to our website.
Your data transmitted during an online order on our website are stored for 12 months.
Otherwise, Customer Data are stored for as long as SOWL may have a legal responsibility for which the use of Customer Data may be relevant, taking into account applicable statutes of limitations and legal storage obligations.
- How are Customer Data protected?
SOWL makes every effort to store and protect Customer Data against loss, disclosure or unauthorised access.
- What are individuals’ rights and whom can they contact?
Individuals whose personal information is collected and processed as Customer Data have, at any time and on condition they provide sufficient identity proof, the right to contact SOWL, if they wish:
• to access, rectify or delete their personal data;
• to restrict or oppose processing of their personal data (for example, for the purposes of direct marketing);
• to receive the data they have provided, in a structured format that is currently in use and can be read by a machine and to transmit them to another data processing officer if they wish to do so, when they have been processed following their consent and/or the performance of the contract;
• to receive additional information on guarantees in case of international data transfers;
• to file a complaint with the Belgian Data Protection Authority or another EU supervisory authority if they believe that SOWL has not acted in accordance with applicable data protection regulations.
For any further information about these rights, you can contact SOWL:
• by e-mail (firstname.lastname@example.org), or
• by letter (SOWL s.a., chaussée d’Ixelles 12, 1050 Brussels, Belgium)
SOWL may modify this privacy notice at any time when necessary, especially in order to comply with changes in the regulations or the demands introduced by data protection authorities.
Latest update: 6/12/2018