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Privacy policy

Vasco Group NV (Belgium) BE0428.107.718, Vasco BV (Belgium) BE0479.567.901, Vasco Group GmbH (Germany) DE124395941, Vasco Group Sp. z.o.o. (Poland) PL6912359171, Brugman Fabryka Grzejników Sp. z.o.o. (Poland) PL6912121564, Vasco Group Srl (Italy) IT03603120266 and Vasco Group Sarl FR24337626352 (hereinafter "Vasco Group" or "We") process personal data in accordance with this Privacy Statement. Vasco Group attaches great value and importance to the privacy and secure processing of personal data of their (potential) clients, end customers, prospects and business partners (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 it (hereinafter, "Privacy Statement").

GENERAL INFORMATION 

1.1. The importance of this Privacy Statement 

The present privacy statement applies to all (commercial) relations between Vasco Group and its (potential) clients, end-clients, prospects and business partners (including as regards the use of the website vasco.eu, brugman.eu, superia.be Vasco Group endeavours at all times to act in accordance with the Privacy Legislation, including the 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"), as well as current and future national legislation regarding the implementation of the aforementioned Regulation. When you provide personal data to Vasco Group, for example through your visit to the Website, the use of Vasco Group services, the purchase of our products, your subscription to one of our newsletters, your visit to a Vasco Group stand at a trade fair or your participation in Vasco Group events, we process these data in accordance with this Privacy Statement. Please note that the provision of certain mandatory personal data is a prerequisite for providing our services/products. In the absence of the aforementioned personal data, it will not be possible to offer our products/services or they will be inadequate. Please read this Privacy Statement in relation to Your use of the Website in conjunction with our cookie policy.

1.2. Who processes the personal data? 

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. You can always contact us by using the contact details in article 10 of this Privacy Statement. Data protection office details are as follows: Hans Steenbreker (Hans.steenbreker@vasco.eu) Vasco Group may process 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 AVG. If You so request, the data of the processors can be communicated at any time. 

PERSONAL DATA 

2.1. What personal data are processed? 

Vasco Group collects and processes the following types of personal data: 

  • Electronic identification data including Your IP address, surfing behaviour, search behaviour, search terms, via which website You accessed the Website, which web browser You use; see also further our cookie policy;
  • Personal identification data including name, first name, e-mail address, address (delivery address/billing address), telephone number (landline and/or mobile), fax number, job title, gender, date of birth (exceptional);
  • Financial identification data including payment details; 
  • When concluding an order/agreement: identification data including name, address, company details, e-mail address, telephone number as well as billing and payment details; 
  • After registering on the Website: customer number, account name, login details (if you use our quotation tool or Climate Control App); 
  • If you subscribe to the newsletter: Your e-mail address as well as Your address;  
  • Identification data obtained through social media including usernames, profile pictures, comments, likes, shares and other interactions; 
  • Any other personal data voluntarily communicated to Vasco Group such as data on leisure activities, marital status, images etc. 

2.2. For what purposes are Your personal data processed? 

Vasco Group may use your personal data for the following purposes:

  • To allow You to contact Vasco Group whether or not through the contact form and for answering questions, handling complaints, etc., the legal basis is the performance of the contract; 
  • To allow You to register for events and technical training and courses, the legal basis is the performance of the agreement; 
  • The conclusion and execution of an agreement; the preparation and follow-up of quotations, as well as in order to implement a correct customer management policy, as well as managing Your account (e.g. for our quotation tool or Climate Control App); the legal basis is the execution of the agreement; 
  • To provide, manage and optimise as well as secure the Website; the legal basis is Vasco Group's legitimate interest to continuously improve its Website and services;  
  • To analyse trends and interactions on our social media pages, the legal basis is Vasco Group's legitimate interest to improve our services and communications; 
  • Sending targeted marketing and promotional offers based on supplied information and data as well as sending newsletters, the legal basis is Your explicit consent; 
  • The purposes for the use of cookies as set out in our Cookie Statement, with the legal basis being Your express consent; 
  • Security and theft prevention; the detection of and protection against fraud, error and/or criminal behaviour, the legal basis is to protect the vital interests of You or other natural persons; 
  • Promoting the legitimate interests of Vasco Group or of a third party. Exactly which interests this concerns varies depending on the processing. For more information, You can always contact privacy@vasco.eu. Naturally, We always take Your interests, fundamental rights and freedoms into account and We will not process Your personal data in order to serve Our legitimate interests or those of a third party, if Your interests would outweigh these (e.g. when You are a minor). 

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 general legal principles. Vasco Group will only process data that is strictly necessary for the purposes, as stipulated in this Privacy Statement or on the basis of a legal obligation. Our historical databases may contain personal data, which We have obtained from third parties in the past. We make every effort to avoid processing such data and take measures to minimise such processing. The provision of certain personal data is (sometimes) a condition for certain services (e.g. to access certain parts of the Website, to subscribe to newsletters, to participate in certain activities and events). If this is the case, We always indicate which data are mandatory and which are optional.

TRANSFER OF PERSONAL DATA TO THIRD PARTIES 

3.1. General

Your personal data may be transferred to affiliated entities (of the Vasco Group) or to another partner of Vasco including suppliers (e.g. mailing service providers, payment 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. 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. 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 business. 

3.2. Reorganisation or transfer of business 

In the event of a full or partial reorganisation or transfer of Vasco Group's business, whereby it reorganises, transfers, ceases operations, or in the event of Vasco Group's bankruptcy, this may involve the transfer of Your data to new entities or third parties through which all or part of Vasco Group's business activities are conducted. Vasco Group will make every reasonable effort to notify You in advance before Vasco Group discloses Your data to such third parties, but You acknowledge that this may not be technically or commercially feasible in all circumstances. Vasco Group will not sell, rent, distribute or otherwise commercially provide Your personal information to third parties, except as described above or with Your prior consent. 

3.3. Legal obligation 

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 to notify You in advance, except where required by law. 

CROSS-BORDER PROCESSING OF PERSONAL DATA 

If We were to transfer Your personal data to parties outside the European Economic Area (EEA) who are domiciled or headquartered 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 the "European Commission Decision of 5 February 2010 (Decision 2010/87/EC)" or (ii) provides appropriate safeguards through any other mechanism under the Privacy Act or any other regulation governing the processing of personal data. 

RETENTION PERIOD 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 this Privacy Statement.

YOUR PRIVACY RIGHTS 

If You wish to exercise one or more of the rights below, please contact privacy@vasco.eu. In principle, You can 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, and only if the aforementioned right is granted to You. The request will be made in accordance with Article 11 of this Privacy Notice. 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 grant 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 therefore no longer have the relevant personal data, there is the possibility that certain services/products will no longer be accessible. 

6.1. Guarantee of compliance with principles Vasco Group processes Your data only: 

  • In accordance with the purposes set out herein or in a manner not incompatible with this original purpose; 
  • In a proper, lawful and transparent manner where the processing, as the case may be, is based on the following bases: consent, legitimate interest, performance of agreement or a legal obligation; 
  • In a manner proportionate to the stated objective; 
  • In a proper way; 
  • During the duration necessary for the purpose in question, which will be explained to You upon request; 
  • In a manner that includes adequate safeguards against unauthorised access, unlawful processing and/or accidental loss or damage. 

6.2. Right to access your personal data 

You have the right, provided You adequately prove Your identity, to obtain from Vasco Group a determination as to whether or not Your personal data have been processed and, if so, to obtain access to the personal data.

In doing so, You can obtain information on the categories of personal data, the processing purposes, the recipients of personal data, the (criteria to determine the) time period (to be) during which Your personal data will be stored and the rights that You can exercise pursuant to the AVG.

6.3. Right to rectification or deletion of Your personal data 

Personal data that is incomplete or inaccurate can always be corrected or deleted. You can exercise Your right to rectification by providing a statement to Vasco Group in accordance with Article 11 of this Privacy Statement. Furthermore, You have the right to have Your personal data erased 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 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 does point out to You that certain services/products will no longer be accessible or can no longer be provided, if You delete or have certain personal data deleted. 

6.4. Right to restrict/object to the processing of your personal data; 

As a User, You have the right to obtain a restriction of processing by Vasco if any of the following applies: 

  • You dispute the accuracy of the personal data; 
  • Vasco Group's processing appears to be unlawful and You do not wish to erase the personal data; 
  • Vasco Group no longer needs Your personal data for the purposes of processing, but You still need them for the establishment, exercise or substantiation of a legal claim;  
  • Vasco Group must assess the presence of the grounds for erasure of the personal data during this period. Furthermore, You have the right to object to the processing of Your personal data at any time due to reasons related to Your specific situation. Vasco will hereafter cease processing Your personal data, unless Vasco Group can invoke compelling legitimate grounds for processing Your personal data that outweigh Your right to object. In addition, You have the right not to be subjected to a decision based solely on automated processing where it has legal effects or such decision may significantly affect You. Finally, You have the right to object to the processing of personal data for direct marketing at any time. 

6.5. Right to data portability 

You have the right to obtain the personal data provided to Vasco Group in a structured, common and machine-readable form if the processing is done on the basis of Your consent. In addition, You have the right to transfer these personal data to another controller where the processing of Your personal data rests solely on Your consent. 

6.6. Right to withdraw Your consent 

You always have the right to withdraw Your consent. The withdrawal of consent does not affect the lawfulness of processing based on the consent before its withdrawal. 

6.7. Right to oblivion 

Whenever You have rightly requested rectification, erasure or further limited processing of data, the controller will notify each recipient of these personal data, unless this proves impossible or would involve an unreasonable effort. You may also receive information about these recipients at any time.

PERSONAL DATA SECURITY

Vasco Group undertakes to take appropriate and reasonable physical, technological and organisational security measures in order to prevent unauthorised or unlawful access to Your personal data, or loss, misuse or alteration of Your personal data. Vasco Group will in principle keep all personal data it has collected on servers within the EU. Notwithstanding Vasco Group's security policies, the controls We implement and the actions We take in this context, a foolproof level of security can never be guaranteed. You must comply with security rules at all times, including preventing unauthorised access to Your login and code. You are solely responsible for the use of Your computer, Your IP address and Your identification data, as well as for their confidentiality. 

UPDATE PRIVACY STATEMENT 

It is possible that our Privacy Statement may be amended and modified in the future. This will be clarified in our Privacy Statement. It is up to You to consult this document regularly. Any substantial change will always be clearly communicated through a notification on our home page. 

LINKS TO OTHER WEBSITES

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.

CONTACT VASCO GROUP 

If You have any questions about this Privacy Statement or about how Vasco Group collects, uses or processes Your personal data, please contact us: 

  • Vasco Group NV 
  • Kruishoefstraat 50 
  • 3650 Dilsen-Stokkem 
  • Belgium 
  • 0428.107.718 
  • 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 lodge a complaint with the Data Protection Authority.

ENTITIES OF VASCO GROUP 

This Privacy Statement applies to the following entities of Vasco Group:

  • Vasco Group NV 

    3650 Dilsen-Stokkem (België) 

    Kruishoefstraat 50 

    BTW nummer BE 0428.107.718 

     

  • Vasco BV 

    3650 Dilsen-Stokkem (België) 

    Kruishoefstraat 50

    BTW nummer BE 0479.567.901 

     

  • Vasco Group GmbH 

    Ruhrallee 55 

    44319 Dortmund (Germany) 

    BTW nummer DE124395941 

     

  • Vasco Group Sp. z.o.o. 

    Ul. Jaworzyńska 295 

    59-220 Legnica (Poland) 

    BTW nummer PL6912359171 

     

  • Brugman Fabryka Grzejników Sp. z.o.o. 

    Ul. Jaworzyńska 295 

    59-220 Legnica (Poland) 

    BTW nummer PL6912121564 

     

  • Vasco Group Sarl 

    Bâtiment l’Amiral 

    1/5 Rue Jean Monnet, 94130 Nogent-sur-Marne (France)

    BTW nummer FR24337626352

     

  • Vasco Group BV

    Boskampstraat 26 

    7651 AM Tubbergen (The Netherlands) 

    BTW nummer NL801865633B0TVA FR24337626352.

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