Confidentiality charter

1. RESPONSIBLE FOR PROCESSING AND DATA PROTECTION DELEGATE

1.1. In this privacy statement, ETECH  below:”ETECH sprl”or “us” explains how it manages your personal data as a “processing manager.” This privacy statement applies to the processing of the personal data of customers,  potential customers (prospects) and individuals who contract with  ETECH  in any other way as a buyer or supplier. ETECH has a settlement unit in Belgium and can be contacted at the coordinates mentioned in point 7.4

1.2. All information about an identified or identifiable individual is personal data. This is information that can reasonably be linked to an individual.

2. THE PERSONAL DATA WE TREAT AS A PROCESSING MANAGER

2.1. ETECH  can collect your personal data in a number of ways. We process the personal data you share with us when you participate in an action or use our services and you communicate data to us directly or indirectly or allow us to record data about your interests, behavior and preferences (cookies).

Information you provide us

2.2. If you apply to ETECH, for example via the website, we need the following personal information :

a) Name, address, zip code ;
b) Email address and other contact information ;
c) Possibly other information that is relevant to your request, such as: your activity or other complementary options.

2.3. If you are contracting with ETECH, we need the following personal information, depending on the type of contract, product or service:

a) Name, address, zip code ;
b) Contact data (phone number and email address) ;
c) Business number ;
d) financial data (bank account)

This personal data must be communicated directly to us. If you do not provide us with the “mandatory” information (which differs depending on the type of contract), we may not be able to provide you with the requested service and conclude the contract.

Information about your use of our services and/or products

2.4. If you use the services offered by ETECH or enter into a contract with us, we treat data such as :

a) data about your machine, such as a MAC address, IP address or other number;
b) your communication preferences and settings;
c) the data we link to certain profiles we draw from you based on your consumer behavior (for example: the frequency with which you visit our site, make a purchase or request a service);
d) navigational behavior, determined on the basis of our own observations or cookies (see also Article 6 of this privacy statement) ;
e) the results of customer satisfaction surveys ;
f) your use of the services we offer.

3. LEGITIMATE FOUNDATIONS AND INTERESTS

We process personal data based on the following legal basics :

a) Consent
b) Executing a contract with you or pre-contracting measures
c) Legal obligation
d) Executing a public interest mission
e) Legitimate interest of ETECH or a third party

We treat personal data for a legitimate interest when we use your data to provide related content and content, products and services, to communicate with you, and for advertising or marketing purposes related to products or services you have purchased in the past. Our legitimate interests include, for example: marketing and advertising related to products or services you have purchased in the past, communication, IT management and security, research and analysis of our own products or services, business management,legal affairs, internal management and sharing with our affiliates.

4. THE PURPOSES FOR WHICH WE DEAL WITH PERSONAL DATA

4.1. ETECH processes personal data for the following purposes (goals, objectives):

a) maintain customer relationships (including maintaining a direct relationship between ETECH, licensed network members, service partners and related financial service providers, including contract execution and the pursuit of legitimate interests) ;
b) process and administer orders (including billing) to meet your request and/or prepare or execute a contract ;
c) provide customer service, meet warranty obligations and those of approved network members or service partners, process complaints and requests, respond torequests and execute contrats, or for legitimate interests ;
d) proactively contact customers in the event ofhardwaredefects or malfunctions or to schedule service appointments, execute a contract or for legitimate interests ;
e) carry out or coordinate any recall actions, due to legitimate interests or legal obligations ;
f) conduct market research to improve our operations, brands, services and products, and identify customers’ wishes, due to legitimate interests ;
g) sending informational and commercial messages via e-mail, mail or other communication channels. For direct marketing, you always have the option to opt out by opposing the treatment, or by withdrawing your consent if you have given it ;
h) advertising and marketing, including targeted ads (“interest-based ads,” such as via Facebook and Google) to connect devices and analyze the impact of advertising and marketing activities because of our legitimate interests ;
i) comply with legal obligations, settle disputes and enforce our rights ;
j) improve the quality of data through the address and control of the postcode, due to our legitimate interests ;
k) link and analyze the cookies on our websites with the customer data we know. We do this to tailor the content of our communication as much as possible to your personal preferences, for the pursuit of our legitimate interests.

5. THIRD PARTIES INVOLVED IN TREATMENT

 5.1. In some cases, ETECH  shares personal data with third parties, who are independent “processing managers.” Below, we explain when this is the case and why.  ETECH can share data with :

a) the service partners of ETECH ‘s distribution network, for the performance of a contract or for the pursuit of legitimate interests ;
b) third parties to whom we are legally obligated or authorized to provide data ;
c) third parties, if we suspect a violation of the rights of third parties, criminal offences or abuses, if they have a legitimate interest in them or if they are public authorities. They may also include authorities such as the police, the public prosecutor’s office ;
d) parties who assist ETECH in its services and are not subcontractors of personal data for the pursuit of its legitimate interests ;
e) parties assisting ETECH in the development of (direct) marketing activities in the pursuit of its legitimate interests.

5.2. Disclosure of personal data to the above-affected third parties will only take place if authorized on the basis of applicable laws and regulations.

5.3. ETECH  also uses third-party services that act as “contractors” (e.g., hosting service providers, certain software providers, mobility service providers, or parties that organize or execute actions or investigations for  ETECH). With these providers, TECHNOCHIM is obliged to enter into a subcontract which stipulates that they only process personal data in accordance with the instructions and under the control of ETECH.

5.4. Currently, we do not store personal data outside the European Union. If personal data were to be deliberately communicated outside the European Union, we will take additional guarantees such as, for example, the conclusion of a standard Eu-European Union contract.

5.5. Our websites may contain references and/or hyperlinks to one or more third-party websites. ETECH  is not responsible for how these third parties handle personal data. We recommend that you read the privacy statement of these websites to find out and control how they process your personal data.

5.6. As part of our activities (hosting, back up, website), we process the personal data you provide to us as a subcontractor under Article 8 of the RGPD regulations. This treatment is governed by our “RGPD agreement” transmitted when our contracts are signed.

6. MARKETING, PROFILING AND COOKIES

6.1. In addition, we and third parties automatically collect certain information about your activity history on our intrnet site andon third-party applications using automated means, such as cookies, in accordance with the preferences you have provided. Through some cookies and similar technologies, unique cookie IDs or other identifiers are assigned or collected.  This way, data can be collected while you’re using the website or apps or when it’s working in the background on your machine. We can combine them with other information about you or your machine, such as an IP address. If we need permission for this, we will ask you for it before proceeding with this treatment.

6.2. We invite you to read our cookie statement for more information on cookies and similar technologies used and how to set up your preferences.

7. YOUR RIGHTS, INCLUDING YOUR RIGHT TO OBJECT

7.1. You have the right to know what personal data we have stored about you and to whom we have disclosed your personal data.

7.2. In addition, you have the right to ask us, in accordance with applicable legislation, to correct, update, delete your personal data, limit the processing of your personal data or hand over your personal data in a structured, commonly used and machine-readable format to pass it on to another company.

7.3. We are required to draw your attention to your absolute right to oppose direct marketing and your rights to object to any treatment, including profiling, for the pursuit of the legitimate interests of ETECH or a third party and to make a claim to a data protection authority. In Belgium, this is the Privacy Commission designated as the Data Protection Authority (https://wwwautoriteprotectiondonnees.be).). In France, it is the National Commission for Information Technology and Freedom(https://www.cnil.fr/))

7.4. The rights to access, rectify, limit processing, erasure, or portability of your data, as well as a withdrawal of agreement, may be exercised free of charge by email, form, phone or mail to the following addresses or numbers ;

E-mail : info@etech-sprl.com

Courrier
ETECH sprl
Zoning Nivelles Sud – Chemin de la Vieille Cour 63
1402 Nivelles (Thines)
Belgique

8. SECURITY

8.1. We have taken appropriate technical and organizational steps to protect your personal data from unauthorized or illegal treatment.

8.2. If you feel that your data is not properly secured or if you have evidence of improper or improper use of your personal data, please contact our customer service at the address mentioned in point 7.4 above.

 9. SHELF LIFE

We retain personal data only for the time necessary for the purposes for which it was obtained, unless we are legally required to retain personal data for longer periods of time or if it appears necessary for the management of a potential dispute.

10. MODIFICATION

10.1. We reserve the right to unilaterally amend or complete this statement of confidentiality. We will inform you as much as possible of any changes. We advise you to check our privacy statement periodically.

10.2. This privacy statement was last updated on November 9, 2020.

11. CONTACT/QUESTIONS

11.1. For questions or comments regarding this privacy statement and/or the handling of personal data, please contact us at the addresses or numbers mentioned in point 7.4 above.