PRIVACY POLICY SPUNTINI NV

 Latest version: May 2023

We understand that your trust in us is the most important asset of SPUNTINI NV (with registered office at 8540 Deerlijk, Nijverheidslaan 70, VAT BE-0431.898.834, RPR Ghent, Kortrijk division, hereinafter "SPUNTINI", "we" or "us"). Your privacy is therefore essential to us.
This Privacy Policy applies inter alia to (i) our "Website" (i.e. https://www.spuntini.be), (ii) our Webshop as available through the Website and (iii) all (commercial) relationships between SPUNTINI and our customers, prospects and business partners.
This Privacy Policy describes (i) how we collect, process and store your personal data; (ii) the rights you can exercise with respect to your personal data; and (iii) the measures we take to protect it and secure your personal data.
SPUNTINI respects your privacy and we always endeavour to act in accordance with applicable privacy legislation, such as (non-exhaustively): (i) the General Data Protection Regulation 2016/679 of 27 April 2016 ("AVG"); (ii) the Data Protection Act 2018 of the United Kingdom (UK) ("UK AVG"); (iii) the Belgian Privacy Act of 30 July 2018; (iv) the ePrivacy Directive 2002/58/EC of 12 July 2002, including future amendments and revisions thereto; and/or (v) (future) national legislation relating to the implementation of the AVG (together: "Privacy Legislation").
Please read this Privacy Policy in conjunction with our legal disclaimer and cookie policy.

SPUNTINI as data controller

Legal entity	SPUNTINI NV (“SPUNTINI”)
Adress	Nijverheidslaan 70, 8540 Deerlijk (Belgium)
VAT number:	BE-0431.898.834

SPUNTINI is the provider and owner of the Website and Webshop. In light of the Privacy Legislation, SPUNTINI will act as the PROCESSOR of your personal data for the purposes described in this Privacy Policy. This means that we are in control of (and therefore responsible for) your personal data.

Method of collecting personal data

What personal data we collect, store and otherwise process and the purpose for which we process it may differ depending on your relationship with SPUNTINI. In particular, we distinguish five different scenarios:

• You are browsing our Website;
• Your company is an active customer of SPUNTINI and/or you are an authorised user of the Webshop;
• You (wish to) receive updates and newsletters related to SPUNTINI products;
• You are a prospect and/or seeking a commercial relationship with SPUNTINI;
• You are | your company is a partner or a supplier of SPUNTINI.

Processing activities SPUNTINI

• You are browsing our Website

   

Contact SPUNTINI via the contact form on the Website
Objective:	To answer any questions and/or strike up a conversation
Personal data:	❑ First name		❑  E-mail
	❑ Surname		❑  Address
	❑ Company name		❑ Phone number
	❑ Nature of request/voluntary information provided
Legal basis:	Permission
Retention period:	Up to one (1) year after your contact with SPUNTINI
Cookies
When you browse our Website, we may also collect your personal data via cookies stored on your device(s) to optimise the functioning of the Website. Please refer to our Cookie Policy for more information. Your company is an active SPUNTINI customer and/or your company is an authorised user of the webshop     General communication support Objective: Enabling communication with and support for customers Personal data: ❑ First name ❑ E-mail address ❑ Surname ❑ Preferred language ❑ Function ❑ Voluntary information provided ❑ Phone number ❑ Company ❑ Company number ❑ Seller ❑  Address ❑ VAT number ❑ Business relationship Legal basis: Necessary for the performance of the agreement Retention period: Until one (1) year after the termination of the commercial relationship between your company and SPUNTINI Tenders | proposals Objective: Preparation of (additional) offers | proposals Personal data: ❑ First name ❑ Company ❑ Surname ❑ E-mail address ❑  Address ❑ Function ❑ Company number ❑ Business relationship ❑ VAT number ❑ Phone number ❑ Preferred language Legal basis: Legitimate interest Retention period: Until one (1) year after the termination of the commercial relationship between your company and SPUNTINI Setting up your SPUNTINI account in the Webshop Objective: Setting up your account for the SPUNTINI Webshop Personal data: ❑ First name ❑  E-mail adres ❑ Surname ❑ Phone number ❑ Name of company ❑  Login Legal basis: Necessary for the performance of the agreement Retention period: Until one (1) year after the termination of the commercial relationship between your company and SPUNTINI Delivery of products Objective: Enabling the delivery by SPUNTINI of the ordered products Personal data: ❑ First name ❑ Company ❑ Surname ❑ E-mail address ❑  Address ❑ VAT number ❑  Function ❑ Company number ❑ Business relationship ❑ Phone number ❑ Preferred language ❑ Seller Legal basis: Necessary for the performance of the agreement Retention period: Up to one (1) year after delivery of the products Billing Objective: Billing Personal data: ❑ First name ❑ Company ❑ Surname ❑ E-mail address ❑  Address ❑ VAT number ❑  Function ❑ Company number ❑ Business relationship ❑ Phone number ❑ Preferred language ❑ Seller Legal basis: Necessary for the performance of the agreement Retention period: Until seven (7) years after the end of the fiscal year in which the invoice was issued You (wish) (to receive) updates and newsletters relating to services and products of SPUNTINI
The SPUNTINI newsletter | update
Objective:	Providing more information on the products sold by SPUNTINI
Personal data:	❑ E-mail address
Legal basis:	Consent or, if you are a customer or partner of SPUNTINI, legitimate interest
Retention period:	Until you have objected to the processing of your personal data for this purpose (cfr. Section 8 - "Right to object")

• You are a prospect and/or seeking a commercial relationship with SPUNTINI

General communication with SPUNTINI & prospecting by SPUNTINI
Objective:	Conduct quality interviews (via email, phone or business social media channels) in which SPUNTINI provides more information about its products
Personal data:	❑ First name	❑  E-mail adres
	❑ Surname	❑ Phone number
	❑ Name of company	❑ Country
	❑ Industry/sector type	❑ Preferred language
	❑ Social media / business channel	❑ Voluntary information provided
Legal basis:	Legitimate interest
Retention period:	Until you have requested to no longer be contacted by SPUNTINI or until one (1) year after your last contact with SPUNTINI, whichever comes first ( + six-month monitoring period)

   

Register for | participating in a SPUNTINI (network) event
Objective:	Getting an overview of event participants, as well as follow-up communication after the event.
Personal data:	❑ First name	❑  E-mail adres
	❑ Surname	❑ Name of company
Legal basis:	Permission
Retention period:	Until you have requested to no longer be contacted by SPUNTINI or until one (1) year after your last contact with SPUNTINI, whichever comes first ( + six-month monitoring period)

• You are | your company is a partner or supplier of SPUNTINI

General communication and delivery of services
Objective:	Communicating as part of our commercial relationship
Personal data:	❑ First name	❑ E-mail address
	❑ Surname	❑ Phone number
	❑ Company	❑ Preferred language
	❑ Function	❑ Voluntary information provided
Legal basis:	Necessary for the performance of the agreement
Retention period:	For the duration of your commercial relationship with SPUNTINI and in any case in accordance with any agreements concluded with SPUNTINI
Billing
Objective:	To pay your invoices for services rendered (including related communications)
Personal data:	❑ First name	❑ Company
	❑ Surname	❑ E-mail address
	❑  Address	❑ VAT number
	❑ Function
Legal basis:	Necessary for the performance of the agreement
Retention period:	For the duration of your commercial relationship with SPUNTINI and in any case in accordance with any (processing) agreements concluded with SPUNTINI

Legal basis

More information on the applicable basis for each of the listed processing activities can be found in Section 3 above.
In case the legal basis for processing is a legitimate interest, SPUNTINI will always (i) assess whether it is proportionate to the purpose for which your personal data was collected and used; and, (ii) take into account your reasonable expectations and ensure a balance with your fundamental rights and freedoms. If we cannot ensure this, we will stop storing | using your personal data or we will establish a new legal basis.

Retention periods

More information on the applicable retention periods for each of the listed processing activities can be found in Section 3 above.
Unless where a longer retention period is required or justified by (i) law or (ii) by compliance with other regulations, SPUNTINI will only retain your personal data for the period necessary to achieve and fulfil the purposes described above under Section 3.

Disclosure of personal data to third parties

Affiliated companies SPUNTINI

SPUNTINI may disclose your personal data to its affiliates in the context of support or support services.

Other third parties

SPUNTINI will not provide your personal data to other third parties, unless this is necessary to fulfil the purposes described in this Privacy Policy. In this context, (some of) your personal data may be provided to:

Payment providers (e.g. to process payment or detect/prevent money laundering or fraud);

Software and cloud providers (to facilitate hosting of (the data in) the Webshop);

Freelancers or other service providers (e.g. to help develop the Website and/or Webshop).

Naturally, we have ensured that the necessary contracts or similar legally binding acts are in place to ensure that these third parties treat your personal data in accordance with Privacy Law (e.g. Article 28 AVG).
In addition, we may transfer your personal data:

to competent authorities: for example, because (i) we are required to disclose your personal data by law or in the context of (future) legal proceedings, or (ii) this is necessary to protect our rights; or

in the context of mergers and acquisitions: that is, if SPUNTINI or most of its assets, is acquired by a third party, in which case your personal data - which SPUNTINI has collected - may be one of the transferred assets.

Cross-border processing of personal data

In the event that any of the aforementioned third parties or other recipients are located in a country outside the European Economic Area, SPUNTINI will ensure that one or more of the listed EU-approved safeguards are in place:

• European Commission adequacy decision;

• Data transfer agreement (cf. the model contractual clauses set out in European Commission Implementing Decision (EU) 2021/914 of 4 June 2021, including implementation of a transfer impact assessment);

• Binding corporate rules;

• or,certification mechanisms.

Your privacy rights

The Privacy Law gives you certain rights over your personal data in relation to SPUNTINI. You can exercise these rights by contacting us, as indicated in Section 12, and by using the Data subject rights form (see at the end of this Section 8).

Access:	you can ask for confirmation whether or not personal data relating to you are being processed. If so, you may ask us to provide you with a copy of your personal data. We may charge you a small fee for this service;
Rectification:	you can ask us to correct or complete information that you believe is incorrect or incomplete;
Delete:	you may ask us, under certain conditions, to delete your personal data. Please note that in this context, certain services will no longer be accessible and/or can no longer be provided.
Objection:	you can object to the processing of your personal data by us under certain conditions.
Limitation of processing:	you can ask us to restrict the processing of your personal data, unless we have legitimate interests in processing your personal data that outweigh your interests.
Data portability:     Filing complaint:	you can ask us to transfer your personal data to another organisation under certain conditions, or directly to you in a commonly used structured format that can be read by an automatic device. You can file a complaint with the competent supervisory authority.

Updates | Newsletters. You can always change your communication preferences in the SPUNTINI Communication Preferences Centre (you will find a unique link in the footer of each SPUNTINI communication). If you no longer wish to receive any of our SPUNTINI communications, you may object to these direct marketing communications by (i) using the Data subject rights form (as indicated above); or (ii) indicating "Yes, I object" in our Communication Preferences Centre (as indicated above). Upon receipt of your objection, we will stop processing your personal data for SPUNTINI communications. This will be done free of charge.
You can download the "Data Subject Rights Form" here.

Security

SPUNTINI undertakes to take reasonable, physical, technological and organisational precautions to prevent (i) unauthorised access to your personal data, and (ii) the loss, misuse or alteration of your personal data.
Notwithstanding the controls implemented by SPUNTINI and the actions it proposes in this context, an infallible level of security cannot be guaranteed. As no method of transmission or dispatch over the Internet, nor any method of electronic storage is 100% secure, we are unable to guarantee absolute security.
Finally, the security of your account will also partly depend on the confidentiality and complexity of your password. SPUNTINI will never ask you for your password, which means that you will never have to disclose it personally. SPUNTINI therefore strongly recommends that, if you find that someone has gained access to your account, you immediately change your password and contact us.

Update

We have the right to update this Privacy Policy by posting a new version on the Websites, whereby we will indicate the revision date at the top of this Privacy Policy. As such, it is strongly recommended that you regularly check the Website(s) and the Privacy Policy pages to ensure that you are aware of any changes.

Complaints?

Are you unhappy with the way we collect, store or otherwise handle or secure your personal data? We are sorry to hear that and we are willing to take all measures to remedy this situation. Please contact us as indicated above.
You also have the right to lodge a complaint with the competent supervisory authority (i.e. the Belgian Data Protection Authority or the data protection authority of (i) your place of residence or (ii) your place of work) if you believe that the processing of your personal data is in breach of Privacy Law. You can send an e-mail to the Belgian Data Protection Authority at contact@apd-gba.be or any other e-mail address provided by the Belgian Data Protection Authority (https://www.dataprotectionauthority.be/citizen/actions/contact).

Contact

If you require any further information or wish to comment, please contact SPUNTINI at:

• Via email: info@spuntini.be