Policy on the personal data of customers / prospects

1. Preamble
BRUNEAU attaches great importance to the protection and confidentiality of your personal data and ensures daily compliance with the currently applicable regulations and, in particular, with the General Data Protection Regulation ("GDPR").

We therefore invite you to consult this information policy, which aims to present you with the way in which we process your data in order to offer and implement our services, as well as the way in which you can exercise your rights regarding the use of your data.

2. Who are we?
JM Bruneau BELGIUM - VAT BE 0465 015 822 - Limited company with registered office at 1 Esplanade Oscar Van De Voorde 9000 GENT is responsible for processing your personal data.

3. Whose data do we process?
We process the data of our customers and prospects.

Our customers are all natural or legal persons who have purchased products or services from JM Bruneau Belgium and/or opened an account on the website www.jm-bruneau.be.

This also applies to all our prospects, to whom JM Bruneau Belgium might address commercial offers.

4. Why and on what grounds do we process your data?
The data we process are mainly collected directly from you via the forms and questionnaires available on our website and catalogues or when you create a customer account.

We may also collect information about you indirectly from time to time through our partners.

Your data are collected and processed solely for the purpose of carrying out the following processing operations, which are necessary for the provision of our services:

- Customer relationship management (CRM);
- Prospect relationship management (PRM);
- Order and delivery management;
- Management of the administrative follow-up of the customer account;
- Management of unsubscription and opt-out requests;
- Data retention in relation to legal security and tax obligations;
- Service improvement and satisfaction survey;
- Behaviour analysis and targeting;
- Management of promotional offers;
- Research in marketing and statistics;
- Newsletter management;
- Management of fraud prevention;

This list is intended to be as exhaustive as possible; any new use, modification or deletion of an existing processing operation will be brought to your attention by an amendment to this policy.

We may also send you promotional offers or news about us based on our legitimate interest.

5. What categories of data do we process?
In order to provide you with all the services offered by BRUNEAU, we inevitably need to collect and process some of your personal data, including:

Please note that we respect the principle of data minimisation which consists of collecting only the data strictly necessary for the processing implemented by BRUNEAU in order to offer you its services.

6. For whom are your data intended?
We ensure that your data are only accessible to internal or external recipients authorised for this purpose, which are:

- internally, BRUNEAU's authorised departments (e.g. sales department, accounting department);
- externally, our authorised subcontractors selected for this purpose and, where applicable, our partners.

Third parties authorised to receive data must necessarily comply with the requirements of the GDPR and may be penalised in the event of improper use of your data.

The data can be communicated to authorities that are legally authorised to take cognisance of them, such as judicial and administrative authorities and the police in case of legal claims.

7. How long do we keep your data?
Our policy on the conversation of your data is determined in the light of the legal and contractual constraints incumbent on us and, failing that, according to our needs, as described below:

After the set deadlines, the data are either deleted or kept after they have been anonymised, for instance for statistical reasons. They may be retained in the event of a (prior) dispute.

The deletion or anonymisation of data is irreversible and cannot be undone later by BRUNAU.

8. Your rights
The collection of your personal data does not mean that you are dispossessed of them. As a user of BRUNEAU or as a prospect whose data are processed, you can claim the following rights:

- Access and copy rights: you have the right to obtain BRUNAU's confirmation as to whether or not your personal data are being processed and, if they are, to have access to them. You can thus obtain from BRUNAU information on the purpose of the processing, the categories of data concerned and the recipients or categories of recipients.

You also have the right to obtain a copy of the personal data being processed. For any excessive request for such copies, BRUNEAU may require payment of the costs that such a new request would involve. If the request is made electronically, the information will be given in a commonly used electronic form, unless otherwise requested.

- Right of rectification and right to erasure: you may obtain from BRUNEAU, as soon as possible, the rectification of your inaccurate or incomplete data. You also have the right to obtain the erasing of your data as soon as possible, in particular when such data are no longer necessary with regard to the purposes for which they were collected or processed.

- Right to restriction of processing: you have the right to restriction of processing which applies in particular when you dispute the accuracy or lawfulness of the use of your personal data. The processing restriction continues as long as BRUNEAU verifies the veracity of such a request or during the discussions with a supervisory authority. You may also request BRUNEAU to restrict processing if we no longer need the data for processing purposes.

- Right to data portability: you may only claim the right to data portability if three cumulative conditions are met. These three cumulative conditions are conditions necessary for the application of your right and, in particular, when your data is based on consent by automated means, which is not the case with the services provided by BRUNEAU.

- Right to object: you may object, for reasons relating to your particular situation, to the processing of your personal data where this is based on the legitimate interests of BRUNEAU. You may also object to the processing carried out for prospecting purposes.

- Right to determine the destination of personal data upon your decease: you can determine guidelines regarding the retention, erasure and communication of your personal data after your decease.

- Right to lodge a complaint with a supervisory authority: you may lodge a complaint with the Data Protection Authority if you consider that the processing of your personal data constitutes a breach of the regulations applicable to personal data. Please contact:

Data Protection Authority
Drukpersstraat, 35
1000 Brussels
Tel: +32 (0)2 274 48 00

9. Exercising your rights
If you wish to exercise any of your rights personally, please contact us at the following address:

personaldata@jm-bruneau.be

To ensure that your request is handled efficiently and quickly, please do not forget to indicate the right(s) you wish to exercise. Please note that if we have any doubts about your identity, we may ask you to provide us with a document proving your identity.


10. Subcontracting
Please note that we may engage any subcontractor of our choice to process your personal data in order to provide our services to you (e.g. data hosting, marketing).
In this case, we will of course ensure that our subcontractors comply with their obligations under the GDPR. In particular, we undertake to conclude with all our subcontractors a written agreement governing our relations and our obligations with them.


11. Transfer of data outside the European Union
In general, your data cannot be transferred to and processed in a country outside the European Union and will always be stored within the European Union.

Where appropriate, we take great care to comply with the requirements of the applicable data protection regulations in order to ensure the confidentiality and compliance of your personal data.

12. Security
BRUNEAU formulates and implements security measures to prevent the unauthorised destruction, loss, alteration or dissemination of your data. The computer systems and paper documents used are managed and protected in such a way as to guarantee the security and confidentiality of your data.

13. Policy updates
We reserve the right to change the presentation and content of this policy. Any new version of the policy on our website will replace the previous one.

14. For more information
For more information on the protection of personal data, please contact our data protection officer at dpo@jm-bruneau.be.


For more general information, please visit the website of the Data Protection Authority at www.dataprotectionauthority.be.