Version 25/05/2018. Compliance with the “General Data Protection Regulation” (GDPR)
1. General Warning
1.1 1.1 Group « Choux de Bruxelles » composed of following companies: « Groupe Choux de Bruxelles SA », « A Propos Catering SPRL », « A Propos SA », « Fresh Belgium SA », « RGMP SPRL », « PBA-PSK Catering SPRL », « Good Robinson SA », « Ostend Sea Place SA », « Café Georgette SPRL », « L’Arche du Gourmet SPRL », « EP CONCEPT SPRL », « Gio’s Strada SPRL », « La Chaufferie SPRL » (hereafter named, « Choux de Bruxelles ») respects the privacy of its users (hereafter named, « user »).
1.2 « Choux de Bruxelles » processes the personal data transmitted to it in accordance with the legislation in force, and in particular the law of 8 December 1992 on the protection of privacy and its implementing decrees.
1.3 The access to the website www.chouxdebruxelles.be (hereafter named, « website ») implies the full and unreserved acceptance by the Internet user of this Privacy Charter (hereafter named, « policy »), as well as its General Terms and Conditions of Sale (hereafter named, « GTC »).
1.4 1.4 The User acknowledges having read the information below and authorizes “Choux de Bruxelles” to process, in accordance with what is specified below, the personal data that he communicates on the website as part of the service offered by « Choux de Bruxelles » (hereafter named, « Service »).
1.5 Whilst informing the User, “Choux de Bruxelles” may have to modify and adapt the policy, in particular in order to comply with any new legislation and/or applicable regulations (such as the adoption of the new European regulation on the processing of personal data – Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data – of 14 April 2016, and applicable from 25 May 2018), the recommendations of the Belgian Privacy Commission, the guidelines, recommendations and best practices of the European Data Protection Board and the relevant decisions of the courts and tribunals.
1.6 The policy is valid for all pages hosted on the website and for registrations of this website. It is not valid for pages hosted by third parties to which “Choux de Bruxelles” may refer and whose privacy policies may differ. “Choux de Bruxelles” can therefore not be held responsible for any data processed on these sites or by them.
1.7 The communication of personal data is sometimes necessary in order to access certain parts of the website (for example for a request via our online quote). Without communication by the User to “Choux de Bruxelles” of this data, access may be refused.
2. Data controller
2.1 Access to the website takes place in principle without having to provide any personal data, such as, in particular, surname, first name, postal address, e-mail address, etc.
2.2 However, as part of the Service, the User may be required to transmit certain personal data. In this case, the controller of this data is: « Groupe Choux de Bruxelles SA » – Boulevard Louis Schmidt 1 – 1040 Brussels – N° BCE : 840.411.958
2.3 We have appointed Dorian NEVE as Data Protection Officer (DPO); he guarantees compliance with privacy legislation and the confidential processing of personal data. Any questions or requests regarding the processing of this data can be addressed to him at the address email@example.com.
3. Collected information
3.1. 3.1. DATA TRANSMITTED TO CHOUX DE BRUXELLES BY THE ACTIVE INTERVENTION OF USERS
By browsing the website, by filling in the forms or newsletters on the website, through the social networks linked to “Choux de Bruxelles”, the User allows “Choux de Bruxelles” to record, store or use in its CRM software (Odoo) for the purposes mentioned in point 4, the following information:
- > identification data, such as first and last name, e-mail address, date of birth and physical contact information
- > banking information necessary for the Service, such as bank account numbers, IBAN and BIC/SWIFT
- > billing information
- > communications between Users and “Choux de Bruxelles”
- > the additional information requested by “Choux de Bruxelles” from the User in order to identify him or prevent him from violating any of the provisions of the policy
- > any other information voluntarily transmitted to “Choux de Bruxelles” by the User for a purpose determined in the policy, in the GTC, on the website or on any other communication medium used by “Choux de Bruxelles”
3.2. 3.2. DATA THAT ARE AUTOMATICALLY TRANSMITTED TO CHOUX DE BRUXELLES WHEN CONSULTING THE WEBSITE
3.2.1. 3.2.1. THE « COOKIES »
In order to facilitate navigation on the website as well as to optimize technical management, the website may use “cookies”.
A “cookie” is a small file containing information saved by a website on the User’s computer or smartphone. This “cookie” can be retrieved during a subsequent visit to the same smartphone or website. The “cookie” cannot be read by a website other than the one that created it. The website uses “cookies” for the purpose of proper administration of the website, in particular to save the User’s browsing preferences, or to obtain information relating to the pages consulted and the dates and times of consultation.
Most “cookies” only work for the duration of a session or visit. It is also possible for the User to configure his browser to be informed during each creation of “cookie” or to prevent their registration, individually or not. Disabling cookies may, however, prevent access to certain parts of the website or make it more difficult to access them.
Disabling cookies may, however, prevent access to certain parts of the website or make it more difficult to access them.
“Choux de Bruxelles” uses on its website the social plug-ins of the social network providers Facebook, Instagram and Google+. These social plug-ins establish a direct connection to the social network’s server via the User’s browser. The provider of the social network on which the User has clicked receives the information that the User has visited the website. If the User is registered and identified on the social network concerned, the provider may make a correlation between the User’s profile and the website visited. The network provider can then establish future interactions. If the User is not registered with the social network, the provider may store the User’s IP address. In order to avoid the transfer of this data to the social network provider, the User must not click on the button corresponding to the social network.
Google analytics. The website also uses Google Analytics. This service, offered by Google, analyzes the activity of the website. For these purposes, Google collects information related to web traffic and the number of visitors. This tool allows “Choux de Bruxelles” to measure the site’s performance in terms of navigation and to group activity reports and other services.
3.2.2. 3.2.2. INFORMATION STORED ON CONSULTED SERVERS
When the User accesses the website, the consulted servers automatically record certain data, such as the type of domain with which the User connects to the Internet, the IP address assigned to the User (when connecting), the date and time of access to the website and other traffic data, location data or other data relating to communication, the consulted pages, the type of browser used, the platform and/or operating system used, the search engine and the keywords used to find the website…
However, no personal data identifying the User is collected through these recordings. This information is kept only for statistical purposes and to improve the website.
4. Purposes of the processing
4.1. 4.1. GENERAL PURPOSES
Without prejudice to what has been specified in point 3.2 concerning the data transmitted automatically, the website collects, stores and processes the personal data of its Users in particular for the following purposes :
- > to establish, carry out and conduct the contractual relationship with the User
- > for the User to participate in games/contests/quizzes and, in general, to provide the Service
- > to incorporate Users’ personal data into one or more automated files
- > to analyze, adapt and improve the content of the website
- > to carry out internal statistical surveys and market research and deploy various statistical systems and studies
- > to allow the User to receive messages and manage his account from different devices (computer, tablet, smartphone …)
- > to detect and/or prevent fraud or similar activities of an illegal nature
- > to facilitate the provision and use of the website and improve the Services offered by “Choux de Bruxelles” as well as the Users’ experience
- > to respond to requests for information
- > for any marketing actions and promotions offered by “Choux de Bruxelles” to Users who have subscribed to the Newsletter
- > to inform them about the evolution of the website and its functionalities
- > for any other purpose for which the User has given his express consent
4.2. 4.2. COMMUNICATION TO THIRD PARTIES
« Choux de Bruxelles » considers personal data as confidential information. They will not communicate them to third parties under conditions other than those specified by the policy or under the conditions under which the law requires it to do so, in particular the competent authorities that so request.
Are considered as partners of « Groupe Choux de Bruxelles SA », « A Propos Catering SPRL », « A Propos SA », « Fresh Belgium SA », « RGMP SPRL », « PBA-PSK Catering SPRL », « Good Robinson SA », « Ostend Sea Place SA », « Café Georgette SPRL », « L’Arche du Gourmet SPRL », « EP CONCEPT SPRL », « Gio’s Strada SPRL » in the exercise of their missions (hereafter named, « Partners »). In this context, “Choux de Bruxelles” may communicate to its Partners, the personal information of its Users, for the purposes of fulfilling the purposes developed in paragraph 4.1.
“Choux de Bruxelles” may transmit to third parties the personal information of its Users to the extent that this information is necessary for the performance of a contract with its Users (for example, a restaurant so that it can record a reservation made through the website or an event room so that it can organize its service). In this case, these third parties will not communicate this information to other third parties, except in one of the following two situations:
- > the communication by such third parties of such information to their suppliers or subcontractors to the extent necessary for the performance of the contract, and
- > when these third parties are obliged by the regulations in force to communicate certain information or documents to the competent authorities in the fight against money laundering, as well as in general to any competent public authority
The communication of this information to the aforementioned persons must, in all circumstances, be limited to what is strictly necessary or required by the applicable regulations.
In order to introduce new products to its Users who may be of interest to them, “Choux de Bruxelles” may also communicate the personal information of its Users to third-party companies, provided that the Users have explicitly consented to this.
4.3. 4.3. DIRECT MARKETING
Personal data will not be used for direct marketing purposes for products or services other than those to which the User has already subscribed. The User retains the right to object at any time, upon request and free of charge, to such use. To do this, the User simply unsubscribes using the corresponding link in each newsletter, or communicates his unambiguous request to the address firstname.lastname@example.org. The User will be responsible, in any case, for the veracity of the data provided and undertakes to inform CHOUX DE BRUXELLES of any modification of these data. Choux de Bruxelles reserves the right to use this data to communicate information relating to the services issued and distributed as part of the company’s legitimate interest in promoting these services to its customers.
5.1 5.1 “Choux de Bruxelles” has taken adequate measures to ensure that the servers hosting the processed personal data prevent, as far as possible: unauthorized processing, access or modification of such data; improper use or disclosure of such data; and the unlawful destruction or accidental loss of such data.
5.2 In this regard, employees of “Choux de Bruxelles” who have access to this data are subject to a strict obligation of confidentiality. However, “Choux de Bruxelles” can in no way be held responsible in the event of misuse of this data by a third party despite the security measures adopted.
5.3 Users undertake not to commit acts that could be contrary to this policy, the GTC or, in general, the law. Offences against the confidentiality, integrity and availability of computer systems and data stored, processed or transmitted by such systems, or attempting to commit any of these offences, shall be punishable by imprisonment from three months to five years and a fine of twenty-six euros to two hundred thousand euros or one of these penalties only.
6. Data shelf life
“Choux de Bruxelles” will normally keep the personal data of its Users for as long as necessary to achieve the purposes pursued (see point 4). “Choux de Bruxelles” may also continue to hold personal data concerning the unsubscribed User, including any correspondence or request for assistance addressed to “Choux de Bruxelles”, in order to be able to respond to any questions or complaints addressed to him, and in order to comply with all applicable laws (including in tax matters), in particular the retention of information relating to payments made.
7. Rights of the data subject
7.1 7.1 The User may at any time request access, rectification or, where applicable, deletion of his personal data, with the exception of those of which “Choux de Bruxelles” would have a legal obligation to store, by sending a written request, accompanied by a copy of his identity card or passport to the controller at the following postal address: “Choux de Bruxelles”, Legal Department, Boulevard Louis Schmidt 1, 1040 Brussels; or to the email address email@example.com.
7.2 “Choux de Bruxelles” will then take the necessary steps to satisfy this request as soon as possible.
8. Note concerning minors
Persons under the age of 18 and persons who do not have full legal capacity are not allowed to communicate their personal data to “Choux de Bruxelles”.
9. Applicable law and competent jurisdiction
9.1 The policy is subject to Belgian law, to the fullest extent permitted by the applicable rules of private international law.
9.2 In the event of a dispute relating to the validity, application, interpretation or execution of the policy, the courts of the judicial district of Brussels (Belgium) shall have exclusive jurisdiction, to the fullest extent permitted by the applicable rules of private international law.
9.3 9.3 Before taking any steps aimed at the judicial resolution of a dispute, the Customer undertakes to try to resolve it amicably by contacting “Choux de Bruxelles” directly, if necessary through mediation, before resorting to arbitration, litigation, or any other method of dispute resolution.