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Vasco Group NV (Belgium) BE0428.107.718, Vasco BV (Belgium) BE0479.567.901 (hereinafter: "Vasco Group" or "We") process personal data in accordance with this privacy statement (hereinafter: "Privacy Statement"). Vasco Group attaches great value and importance to the privacy and secure processing of personal data of their (potential) customers, end customers, suppliers, prospects and business relations (hereinafter: "You" or "Your"). With this Privacy Statement, We inform You about how We handle Your personal data. This Privacy Statement contains, inter alia, information about the personal data that Vasco Group collects, as well as how Vasco Group uses and processes them.
The Privacy Statement applies inter alia to all (commercial) relations between Vasco Group and its (potential) clients, end-customers, prospects, suppliers and business relations, and the following websites: vasco.eu, shop.vasco.eu, superia.be (hereinafter: "the Website"). Vasco Group endeavours at all times to act in accordance with (i) EU Regulation 2016/679 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 and repealing Directive 95/46/EC (hereinafter: "AVG"), (ii) the Belgian law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data and, (iii) all other applicable (national) legislation relating to the processing of personal data (hereinafter: "Privacy Legislation"). When You provide personal data to Vasco Group, for example through Your visit to the Website, the use of Vasco Group's services, the purchase of our products, Your subscription to our newsletter, Your visit to a Vasco Group stand at a trade fair or Your participation in Vasco Group events, We process such data in accordance with this Privacy Statement. Please note that the provision of certain mandatory personal data is a necessary condition for providing our services/products. In the absence of the aforementioned personal data, our products/services cannot be offered or can only be offered inadequately. With regard to Your use of the Website, please read this Privacy Statement in conjunction with our cookie policy.
For the purposes of this Privacy Statement, Vasco Group is the controller ("controller") and alone or in cooperation with others determines the purposes and means of processing Your personal data. Vasco Group's contact details are included under the heading "Contact Vasco Group". Vasco Group may process Your personal data through the intervention of third-party service providers who receive clear instructions to this effect and who will only process Your personal data in accordance with Vasco Group's instructions and the Privacy Legislation. If You so request, the details of the third-party service providers can be disclosed at any time.
Vasco Group processes Your personal data in order to provide You with a safe, optimal and personalised user experience. Vasco Group processes personal data in compliance with the Privacy Legislation. Vasco Group will only process data that is strictly necessary for the purposes, as stipulated in the Privacy Statement or on the basis of a legal obligation.
Providing certain personal data is (sometimes) a condition for enjoying certain services and products (e.g. to subscribe to the newsletter, to receive certain goods and/or services by delivery). Hereby it is indicated which data are mandatory to fill in and which are optional.
In case Vasco Group's legitimate interest is the legal basis for processing as indicated in the tables below, Vasco Group will always:
Assess the necessity of the processing activity in relation to the purpose of the processing (proportionality test); and
assess whether You, the data subject, could reasonably expect the specific processing to take place, so that we can assess the possible impact of the processing activity on your fundamental rights and freedoms.
Vasco Group therefore always strives to minimise the impact on Your fundamental rights and freedoms. We can guarantee that Vasco Group will only process Your personal data on the basis of a legitimate interest when We are absolutely sure that a balance can be found between Your rights and freedoms and Our interests. If no balance can be guaranteed, Vasco Group will:
stop processing your personal data in that specific situation (for that specific purpose); or
invoke another legal basis for processing your personal data (e.g. consent).
MODE OF COLLECTION | PERSONAL | OBJECTIVES | LEGAL BASIS | STORAGE PERIOD |
Fill in contact form | Name, first name, telephone/gsm number, e-mail address, address, personal data provided by the data subject in the open fields of the contact forms, personal data included in the documents and images to be uploaded by the data subject.
| Answering questions on technical support, supporting with an administrative/logistical problem, requesting quotation and laying plan, handling complaints.
| Explicit consent | End of processing support request + 1 year for administrative purposes + automatic archiving of emails after 6 months
|
Cookies on the Website (*) | IP address, surfing behaviour, search behaviour, search terms, through which website You accessed the Website, which web browser You use. | Optimise and personalise browsing experience. | Explicit consent (consent can be withdrawn at any time for non-essential cookies) | Depends on type of cookie. Session cookies are deleted immediately after the browser session, other cookies are always set for a specific, proportional period.
|
Newsletter | Authority: private or professional, e-mail address | Providing information on (new) products and/or services of Vasco Group. | Legitimate interest for active customers Explicit consent for non-customers
| As long as the customer/recipient has not unsubscribed from the newsletter |
Product configurator | Country, nearest city, specifications of the property (e.g. ventilation, insulation, heating control, description of rooms), the product Vasco Group installed at the client's premises, name, first name, e-mail address.
| Perform heat calculation and provide product configuration report. | Explicit consent | Immediately after receiving the product configuration report |
Webshop | Name, first name, address, e-mail address, phone/gsm number, address, tracking number, date and time of collection, collection location, payment details. | Handling and delivery of Your order. Responding to complaints regarding Your order. | Implementation of agreement | End of the ordering process (extending the retention period until the end of the complaints procedure if the customer complains about the order received) + 1 year for administrative purposes.
|
Fill in application form | Name, first name, e-mail address, address, phone number, CV, other personal data provided voluntarily. | Selection and recruitment of potential new employees | Explicit consent
| Digital: maximum 1 month and maximum 6 months for long-term procedures.
|
(*) For more information on the use of cookies, please refer to the cookie policy available on the Website.
MODE OF COLLECTION | PERSONAL | OBJECTIVES | LEGAL BASIS | STORAGE PERIOD |
Communication with (future) business partners | Name, first name, e-mail address, phone/gsm number, company, job title, LinkedIn profile. | Correspondence by phone or e-mail whether or not to answer questions. | Performance of the agreement with Vasco Group or to answer a question/request prior to the conclusion of an agreement
|
|
Communication with (future) customers | Name, first name, e-mail address, phone/gsm number, job title. | Correspondence by phone or e-mail whether or not to answer questions. | Performance of the contract with Vasco Group or to answer a question/request prior to the conclusion of a contract (consent) |
Future clients: 1 year, unless it becomes a client of Vasco Group.
|
Communication with (future) suppliers | Name, first name, e-mail address, phone/gsm number, job title. | Correspondence by phone or e-mail whether or not to answer questions. | Performance of the contract with Vasco Group or to answer a question/request prior to the conclusion of a contract. (consent) | Suppliers: as long as Vasco Group and the supplier have a business relationship + automatic archiving of emails after 6 months + 1 year for administrative purposes.
Future suppliers: 1 year, unless the future supplier becomes a supplier of Vasco Group.
|
Invoicing / accounting | Name, first name, e-mail address, phone/gsm number, bank account number, company.
| Invoicing / accounting | Implementation of agreement | 10 years (= the statutory minimum retention period) |
Visitors | Name, first name, company, date, arrival time and departure time. | Safety and security reasons (e.g. when evacuating due to fire, it is necessary to know who is on the premises) and for insurance purposes.
| Legitimate interest | 1 year after date of visit by visitor to Vasco Group's buildings/sites |
Applications (other than via the Website) | Insofar as the selection office transmits these personal data and insofar as they are mentioned on the CV and cover letter: name, first name, gender, address, marital status, family status, e-mail address, education/diploma, photo, hobbies, telephone/GSM number, languages, references previous employer/work experience, skills, nationality, date of birth.
| Selection and recruitment of potential new employees | Explicit consent | Digital: maximum 1 month and maximum 6 months for long-term procedures.
|
Climate Control App (**) | Name, first name, address, e-mail address, telephone/GSM number, preferred language, preferred settings of the device linked to the Climate Control Application, characteristics of the device on which the Climate Control Application is installed (e.g. type of operating system ...), IP address, measurement data: the functionalities of the relevant device (e.g. room temperature, holiday mode of the device ...)
| Account creation, optimising the Climate Control App, providing customer service, troubleshooting, more energy-efficient equipment settings, statistical purposes. | Implementation of agreement Explicit consent | Until deletion of the account by the user. Measurement data are kept for 3 years after their collection. |
Social media, events and trade fairs | Name, first name, e-mail address, photos, videos; Linkedin profile | Marketing purposes | Explicit consent | Until the data subject has withdrawn consent. |
(**) For more information regarding Vasco Group's use of Your personal data in the context of the Climate Control App, please refer to the Privacy Statement Vasco Climate Control available in the Climate Control App.
Your personal data may be transferred to affiliated entities (of the Vasco Group) or to another partner of Vasco Group including suppliers (e.g. mailing service providers, payment service providers, software suppliers, IT partners, transportation partners, subcontractors, lawyers, external accountants, insurers, etc.) if this is necessary to achieve the stated purposes. This transfer of data will always be limited to companies within the European Economic Area (hereinafter: EEA). If Vasco Group shares Your personal data with third parties in this context, the third party in question is always obliged to use Your personal data in accordance with the provisions of this Privacy Statement and the data processing or transfer agreement concluded with this third party, if applicable. Without prejudice to the above, Vasco Group may disclose Your personal data in the event We are obliged to do so or in the event of reorganisation or transfer of Our activities.
In the event of full or partial reorganisation, transfer of its business or in the event of Vasco Group's bankruptcy, Your personal data may be transferred to new entities or third parties through which all or part of Vasco Group's business activities will be conducted. Vasco Group will use reasonable efforts (without undertaking to do so) to give You prior notice if Vasco Group discloses Your personal data to such third parties. Vasco Group will not sell, rent, transfer or otherwise commercially provide Your personal data to third parties, except when Vasco Group has (i) obtained Your prior consent and (ii) entered into a data processing or transfer agreement with the relevant third party, which contains the necessary guarantees regarding confidentiality and privacy-compliant treatment of Your personal data.
In exceptional cases, Vasco Group may be required to disclose Your personal data pursuant to a court order or to comply with other mandatory laws or regulations or to safeguard its rights. Vasco Group will make reasonable efforts (without undertaking to do so) to notify You in advance.
If We would transfer Your personal data to parties outside the EEA who are resident or domiciled in a country not covered by an adequacy decision issued by the European Commission, We will ensure that Your personal data is protected by means of an agreement that either (i) contains the standard contractual clauses set out in European Commission Implementing Decision 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council, or (ii) provides appropriate safeguards through any other mechanism under the Privacy Legislation or any other regulation governing the processing of personal data.
Unless where a longer retention period is required or justified (i) by law or (ii) by compliance with another legal obligation, Vasco Group will retain Your Personal Data only for the period necessary to achieve and fulfil the purposes described in the tables in this Privacy Statement under the heading "Personal Data".
If You wish to exercise one or more of the rights below, You may contact privacy@vasco.eu or deliver Your request by post (see contact details Vasco Group under heading "Contact Vasco Group"). In principle, You may exercise these rights free of charge. If You wish to exercise any of Your rights, We will respond within one (1) month of receiving the request. We may ask You to identify Yourself at any time when You exercise Your rights. For the record, We stress that these rights are not absolute rights and that Vasco Group may not be able to fulfil Your request due to specific legitimate reasons including but not limited to legal obligations and legitimate interests of Vasco Group or of a third party. If you were to exercise (one of) Your rights and Vasco Group would thereby no longer have the relevant personal data at its disposal, it is possible that certain services/products will no longer be accessible.
You have the right to obtain confirmation from Vasco Group as to whether or not Your personal data will be processed and, if so, to obtain access to the personal data. You may thereby obtain information about the categories of personal data, the processing purposes, the recipients of Your personal data, the (criteria to determine the) period during which Your personal data will be stored and the rights You may exercise in accordance with the Privacy Legislation.
You have the right to have incomplete, incorrect or outdated personal data, corrected or erased.
Furthermore, You have the right to have Your personal data deleted by Vasco Group without unreasonable delay. You can only invoke this right in the following cases, which Vasco Group will assess:
When Your personal data are no longer necessary for the purposes for which they were collected or processed;
When You withdraw Your consent and no other legal basis exists for the processing;
Where objection is made to the processing of the personal data and no overriding compelling legitimate grounds for the processing exist;
Where personal data have been unlawfully processed;
When Your data must be deleted in accordance with a legal obligation.
In this context, Vasco Group draws Your attention to the fact that certain services/products will no longer be accessible or can no longer be provided if You delete or have deleted certain necessary personal data.
You have the right to restriction of data processing by Vasco Group if any of the following applies:
You dispute the accuracy of the personal data;
Vasco Group's processing of Your personal data is unlawful and You do not wish to erase the personal data;
Vasco Group no longer needs Your personal data for processing purposes, but You still need them for the establishment, exercise or substantiation of a legal claim;
You have objected to processing, pending the answer to whether the objection is valid.
In the following cases, You have the right to obtain the personal data provided to Vasco Group in a structured, common and machine-readable form, so that You can store it for personal (re)use, or forward this personal data directly to another data controller. You can exercise this right if
Vasco Group processes your personal data on the basis of your consent; or
Vasco Group processes your personal data in connection with the performance of an agreement.
You have at all times the right to object to the processing of Your personal data for reasons relating to Your specific situation. Vasco Group will hereafter immediately cease processing Your personal data, unless Vasco Group can invoke compelling legitimate grounds for processing Your personal data which outweigh the interests, rights and freedoms of the individual or which are related to the establishment, exercise or substantiation of a legal claim. In addition, You have the right not to be subjected to a decision based solely on automated processing where it produces legal effects or where such decision is likely to significantly affect You. Finally, You have the right to object to the processing of personal data for direct marketing at any time.
Vasco Group undertakes to take appropriate and reasonable physical, technological and organisational security measures in order to prevent (i) unauthorised or unlawful access to Your personal data, as well as (ii) loss, misuse or alteration of Your personal data.
Vasco Group will in principle store all personal data collected on servers within the EEA. Notwithstanding Vasco Group's security policies, the controls We implement and the actions We take in this regard, an infallible level of security can never be guaranteed.
You must comply with security rules at all times, including preventing unauthorised access to Your login details. You are solely responsible for the use of Your computer, Your IP address and Your identification data, as well as for their confidentiality.
Vasco Group is entitled to update this Privacy Statement by posting a new version on the Website. It is up to You to consult this Privacy Statement regularly. Any substantial change will always be clearly communicated through a notification on our home page, and will be mentioned in the version history of this Privacy Statement.
The Website may contain hyperlinks to other websites. When You click on one of these links, You may be directed to another website or Internet resource that knowingly, through cookies or other technologies, collects information about You. Vasco Group bears no responsibility, liability or control over these other websites or Internet resources, nor their privacy policies or the uses/services of that website. You should check the privacy policies of these other websites and Internet resources yourself so that You can judge whether they act in accordance with the Privacy Legislation.
If You have any questions about this Privacy Statement or about how Vasco Group collects, uses or processes Your personal data, please contact us:
By post: Vasco Group NV, Kruishoefstraat 50, 3650 Dilsen-Stokkem, Belgium
or
Via email: privacy@vasco.eu
If You are dissatisfied with the way Vasco Group has handled these questions or comments or if You have any complaints about the way Vasco Group collects, uses or processes Your data, You may file a complaint with the competent supervisory authority. This may be the supervisory authority of (i) Your usual place of residence, (ii) Your place of work or (iii) the location of the alleged breach of the Privacy Legislation.
Contact details of the Belgian Data Protection Authority:
Data protection authority
Rue du Printing Press 35, 1000 Brussels, Belgium
Tel: +32 (0)2/274 48 00
Email: contact@apd-gba.be
This Privacy Statement applies to the following entities of Vasco Group:
Vasco Group NV
3650 Dilsen-Stokkem (Belgium)
Kruishoefstraat 50
VAT number BE 0428.107.718
Vasco BV
3650 Dilsen-Stokkem (Belgium)
Kruishoefstraat 50
VAT number BE 0479.567.901
Current version - October 2024: full update of privacy policy
