- The controller of the processing
- Purposes and legal basis for the processing of personal data
- The personal data processed and the case being, the necessity of the provision thereof
- Duration of the processing and retention of data
- Categories of recipients and transfer of personal data
- Your rights in relation to the processing of your personal data
- Technical and organizational measures
- Contact Pozyx in relation to data processing
I. The controller of the processing
1.1 The legal entity controlling the processing of your personal data is Pozyx NV, a Belgian company with limited liability whose registered offices are located at Vrijdagmarkt 10 box 201, 9000 Ghent, Belgium. Pozyx is registered with the Register for Legal Entities in Belgium under number 0634.767.208.
Pozyx NV is the controller of the processing of your personal data because it has determined the purposes and means of the processing, and this although this processing may be performed for the benefit of Pozyx NV [or any of the following affiliated companies: [complete if applicable]].
1.2 Pozyx NV and the affiliated companies are hereafter referred to as “Pozyx”, “us” or “we”.
II. Purposes and legal basis for the processing of personal data
2.1 Pozyx processes personal data of its customers and suppliers, as well as of contact persons of its customers and suppliers for the following purposes:
- The purpose of executing contractual relationships (including in the context of e-commerce) as well as legally required purposes that are linked to that purpose;
- the purpose of providing support or other services;
- for direct marketing;
Pozyx processes personal data of visitors of its websites for the following purposes:
- responding to the visitor’s request sent to us via the contact page.
- evaluating and responding to the visitor’s job application and for the management of our human resources database.
2.2 The legal basis for these processing operations is respectively:
1) the purpose of executing contracts and services
2) the purpose of direct marketing
- the necessity for the performance of our contract with you.
the legitimate interests pursued by Pozyx and its contract party to organize, and interact in relation to, the conclusion or performance of a contract.
In our view, given the limited use made of your contact details, such interests are not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please revert to title VI below on Your legal rights in relation to privacy.
- legal reasons (such as after sales warranty), compliance or tax and accounting reasons. The legal basis of our processing is then to be found in European or national law.
3) the purpose of responding to the visitor’s request on our websites
the legitimate interests pursued by Pozyx to promote sales, reinforce the relationship with the customers, enhance customer loyalty, etc.
For processing activities which are in general considered little intrusive (e.g. promotion sent by regular mail), such interests are in our view not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please revert to title VI below on Your legal rights in relation to privacy.
We may also invoke the same legal basis of our legitimate interest, for newsletters sent by e-mail to our own customers if your e-mail contact details were received directly from you in the context of a sale, and are only used for the promotion of Pozyx’s own similar products. Every newsletter however carries a link allowing you to unsubscribe from the newsletter.
For marketing initiatives such as calling you or sending you text messages, we will always first ask your consent. The same is true for e-mail newsletters that do not comply with the aforementioned conditions.
Your consent will be asked at the moment that we receive your personal data (e.g. on the website or if you visit a shop). You may revoke your consent at any moment in accordance with title VI below.
- the legitimate interests pursued by Pozyx to treat and give follow up to your request.
the legitimate interests pursued by Pozyx to treat and give follow up to your job application and manage a useful and pertinent human resources database.
Given your initiative to send your request via the contact page (which we assume you want us to reply to) and the limited use made by us of your contact details to reply, such interests are in our view, not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please revert to title VI below on Your legal rights in relation to privacy.
III. The personal data processed and the case being, the necessity of the provision thereof
1) The personal data you submit to Pozyx (when placing an order, closing a contract, filing a request on the contact page of our website, visiting our offices or any other form of contact [verder aanvullen indien nodig] with Pozyx, are:
And the case being:
- Contract related information
- Information about the company you are representing
- E-mail address
- Telephone and/or mobile number
- Identification number
- Location data
- account number
- Kind of contactperson (professional customer, retail customer, student, direct sales customer) and justification thereof (e.g. VAT number, declaration of employer, diploma or certificate, student card)*
- For direct customers: closing days* and times visited
- Ticket information linked to customer account number
- Customer wishes in relation to direct marketing
- Analysis data based on purchases
- Date of birth (
- Customer participation to trainings , services or promotions
- Recordings of telephone calls to customer services
The aforementioned personal data indicated with a * have to be provided, if the customer wants to benefit from the status of a professional customer, student or direct sales customer or wants to obtain a loyalty card or purchase online. For (other) retail customers that purchase in a store, the provision of personal data is entirely on a voluntary basis.
Pozyx may reserve specific promotions to segmented customers, e.g. based on history of purchases, kind of customer, date of birth or customer wishes.
2) The visitors of our websites additionally submit the following personal data
- Data filled out on the contact page
- Response to request
- Curriculum Vitae and cover letters (job applicants)
other information that you provide to us
- your IP address
- your browser type
- your mobile network provider
the following information:
- the producer
- the model
- the platform
- OS versione
- OS language
- OS users language
- application ID’s
- cookie information
- information about your use of the website, including the pages you visited;
IV. Duration of the processing and retention of data
1) For contract parties
We process your personal data as long as necessary in the context of the contracts entered into with you. After termination of our active collaboration with you, your personal data are retained for as long as necessary for legal, compliance or tax and accounting reasons.
We process your personal data for direct marketing purposes until you oppose or withdraw your consent to the processing of your personal data for that purpose.
2) For visitors to the website that fill in the contact page:
Personal data that was provided by job applicants will be kept in the human resources database for a period of six months as of the date of collection. If we were to decide to keep your personal data for a longer period, we will contact you to obtain your consent.
V. Categories of recipients and transfer of personal data
5.1 Personal data retained by Pozyx may be shared within affiliated companies for the purposes of Pozyx set out under title II:
- As indicated under title I, if Pozyx NV is the controller of the processing of personal data for itself and a number of affiliated companies. To the extent that these affiliated companies participate in some of the processing operations, they do so under Pozyx NV’s control (unless the affiliates qualify as joint controllers for legally required processings).
- Pozyx may communicate some personal data to affiliated companies as the affiliated companies collaborate closely on a management level. This communication is limited to what is necessary for the purposes.
5.2 To the extent that this communication of personal data would entail a transfer outside of the European Union to a country where there is no adequate level of data protection, Pozyx will make sure that there are adequate contractual safeguards in place to protect your privacy.
5.3 Apart from the communication of personal data with affiliated companies, Pozyx may work with the following categories of third party processors: suppliers of IT and hosting services, consultants and providers of direct marketing services. Pozyx will make sure that all its processors have entered into appropriate processor contracts.
VI. Your rights in relation to the processing of your personal data
6.1 In relation to the personal data that are processed by Pozyx, you have a number of legal rights:
- You have a right to get access to your personal data and to have these data corrected.
- You may ask Pozyx to erase your personal data, or to restrict the processing thereof.
- To the extent that the processing is based on the legal basis of a legitimate interest or the processing is done for direct marketing purposes, you have the right to oppose to that processing.
- To the extent that the processing is based on your consent, you have the right to revoke your consent at any time.
- You may ask to receive the personal data which you have provided to us, in a structured, commonly used and machine-readable format and transmit these to another controller.
6.2 Within a duration of maximum 1 month after receipt of your request, we will act upon your request and reply. If for some reason we cannot accommodate your request, we will inform you of the reasons thereof. If we are not in a position to identify you properly, we may ask you to provide a proof of your identity as a prerequisite to accommodating your request.
VII. Technical and organizational measures
7.1 Pozyx will take all technical and organizational measures needed to ensure the safety and confidentiality of your personal data against unwanted, unlawful and unauthorized (i) destruction, modification, adaptation or loss of personal data and/or (ii) communication of or access to personal data and/or (iii) means of processing.
These measures will be in accordance with the applicable law and the risks related to the processing and the kind of personal data being processed, taking into account the state of the art and the costs they involve.
7.2. Pozyx will implement all measures needed to conform its collaborators and personnel to its obligations concerning your personal data and shall submit a written confidentiality obligation to these collaborators who need to access the personal data.
8.1 Pozyx shall inform you in case of an infringement on your personal data that causes a high risk for your rights, unless a legal prohibition would apply. More specifically Pozyx will inform you about (i) the kind of infringement, (ii) the facts that were communicated to the competent authority and (iii) the measures taken.
IX. Contact Pozyx in relation to data processing
9.1 In order to invoke your rights under title VI, please contact us at our dedicated privacy e-mail address: privacy@Pozyx.com, or send us a letter at Pozyx NV, Privacy, Vrijdagmarkt 10 box 201, 9000 Ghent, Belgium.
Alternatively, If your sole aim is to give or revoke your consent in relation to direct marketing or modify your direct marketing preferences, you can turn to your usual shop and ask the shop manager to adjust your privacy settings.
Alternatively, if your sole aim is to unsubscribe from a newsletter, text messages or live calls, you can also click the unsubscribe link in the newsletter, reply with “stop” on a text message or ask the live caller not to call you again.
9.3 If you have any complaints in relation to how Pozyx processes your personal data, you may file a complaint with the Supervisory Authority: www.gegevensbeschermingsautoriteit.be