ALTERNATIV WORKSPACE SOLUTIONS SA/NV
1. Who are we?
We offer products and services for everything relating to the furnishing and renovation of offices. Companies can purchase Our products and services at Our establishments, via email or via the webshop. Employees of Our corporate customers can also purchase products via email or via the webshop.
- GDPR or General Data Protection Regulation: Regulation (EU) no. 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, and repealing Directive 95/46/EC.
- DPL or Data Protection Law: Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of Personal Data.
- Personal Data: any information relating to an identified or identifiable natural person.
- Data Controller: the person who, alone or together with others, determines the purpose of and means for Processing Personal Data.
- Processing: an operation or set of operations performed upon Personal Data or a set of Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of data.
3. From whom do we collect Personal Data?
We collect Personal Data from You as an employee, self-employed person or consumer, depending on whether You place an order with Us on behalf of Your employer, as a self-employed person or as a consumer, or if Your company designates You as a contact person.
We also collect Personal Data from You as a visitor to Our website and Our webshop. On the website and webshop You can only register if You are 16 years or older.
4. How do We collect Personal Data?
We collect your Personal Data when You contact us regarding Our products and services, when You place an order at one of our establishments, by email or via the webshop, when You use Our website or webshop or the social media platforms on which We operate, or when You subscribe to Our newsletters.
5. What Personal Data do We process?
The Personal Data We process are: surname, first name, title, address, professional and private email address, the company You work for or represent, IP address and information about web pages You visit (e.g., which web pages, when and how long you visited – see section XIII below concerning cookies), Your phone number (including mobile phone number), information about payments for Our products and services, information about job applications, data surrounding arguments and disputes, and any other Personal Data You may voluntarily provide to us when We communicate with You.
6. For what purpose and on what legal basis do We use Your Personal Data?
We process Your Personal Data for the purpose of entering into and performing the contract with You, including:
- Answering Your questions regarding our products and services
- Handling and processing Your requests for quotations and orders (drawing up a quotation, confirming and executing an order, changing or refusing an order, etc.)
- Drawing up invoices, monitoring payments and other accounting activities
- Delivery and any installation of the ordered products
- Providing technical support
- Providing after-sales services
- Handling the consumer’s right of withdrawal in distance selling
- Executing (contractual and statutory) warranties and indemnities
- Handling possible complaints
When You as an employee, self-employed person or representative of a company, contact us or visit Our website and webshop, or when Your company provides us with Your contact details, We will process Your Personal Data on the basis of the legitimate interest of A.W.S. to provide information about products and services, for the purpose of entering into agreements and for the efficient execution of those agreements with Your company.
We may also use Your Personal Data:
- To provide You with good access to the user profile on the webshop and to improve the use of the website and the webshop. This is based on Our justified interest to offer You a better experience when using Our website and webshop.
- To combat fraud and infringements, and to manage disagreements and litigation on the basis of Our legitimate interest in detecting and curbing fraud and infringements, such as inadmissible or unlawful statements, in order to secure Our IT systems, and to conduct litigation.
- To reply to an application with a view to the conclusion of a possible employment contract or other cooperation agreement.
- For direct marketing purposes within what is specified later in this policy regarding direct marketing.
- For possible analyses in the context of business restructurings or takeovers, based on Our legitimate interest and that of the parties involved in those transactions to bring those transactions to a successful conclusion.
- To comply with any legal obligations to which We may be subject.
7. Who has access to Your Data?
All Our employees have an obligation of confidentiality and may only process Personal Data to the extent necessary for their duties. In addition, the following persons have access to Your Personal Data:
- Service providers
We work closely with third party service providers, such as IT service providers who build and maintain the website and webshop, transporters, print services, etc., so that We can offer You various high-quality and reliable products and services designed to meet Your needs. These service providers may gain access to Your Personal Data to the extent necessary to assist us in carrying out the aforementioned services. These service providers may also be agents or associated companies.
- Business support services
We are also obliged to use various business support services, such as accountants and auditors, to whom We may pass on Your Personal Data if necessary.
We may also disclose Your Personal Data to third parties who assist us in the context of any disputes and litigation, such as the liability insurer or attorneys and bailiffs in the context of legal proceedings (e.g., liability disputes or unpaid invoices), or to protect Our property, safety, people and other rights and interests.
We may also disclose Your Personal Data to third parties in the context of any business acquisition or restructuring, such as prospective purchasers of shares or companies with which We may merge or which may acquire our business or an area of activity or set of assets.
Apart from in these cases, Your Personal Data will not be disclosed to third parties. If We do wish to disclose Your Personal Data to a third party, We will inform You or, if necessary, obtain Your consent. However, We may process anonymous or aggregated data and communicate it to third parties. Finally, We may also pass on Your Personal Data to authorities or judicial bodies if We are legally obligated to do so.
If third parties process Your Personal Data on Our behalf, We will make the necessary contractual arrangements to ensure that they only process Your Personal Data in accordance with A.W.S. instructions and in accordance with the GDPR and the DPL, including the implementation of adequate security measures.
8. Direct Marketing
Your Personal Data may be used by us to send You information about offers that may be of interest to You. This information may be sent to You by email. In cases where this is necessary, We will of course first obtain Your consent.
To the extent that We process Personal Data in accordance with Your free consent, You have the right to withdraw Your consent at any time.
9. How long will Your Personal Data be kept?
We will keep Your Personal Data only for as long as necessary for the relevant purposes, or for as long as contractually defined. We regularly review Our retention periods for Personal Data.
Where we are required by law to keep certain types of Personal Data for specified legal periods (e.g., accounting information), We will comply with those periods.
10. Your rights
In conformity with the GDPR, You as a data subject may exercise various rights concerning Your Personal Data which is processed by Us. This is explained in more detail below.
What rights do you have?
- Right to access and a copy
Access – You always have the right to free access to Your Personal Data which We process, unless such access is excluded by law.
You also have the right to receive certain information about this Processing. More specifically, You are entitled to information about the following:
- whether or not the Personal Data is being processed;
- the Personal Data itself;
- the purposes of the Processing of the Personal Data;
- the categories of Personal Data and their retention period;
- the categories of recipients to whom this Personal Data is provided;
- the rights relating to this Personal Data;
- the source of this Personal Data, if it was not sourced from you;
- the existence of automated decision-making based on this Personal Data, as well as the underlying logic and consequences of that decision-making.
Copy – Furthermore, You are entitled to receive a copy of Your Personal Data, free of charge, to the extent that You are permitted to consult it in accordance with the GDPR. If You require several copies of the same information, A.W.S. reserves the right to charge a fee for administrative costs.
- Right to rectification
In addition, You have the right to demand that all incorrect or incomplete processed Personal Data be corrected or completed free of charge. If We determine that the Personal Data is indeed incorrect or incomplete, it will be corrected or completed.
You may also request that Personal Data is temporarily not processed further (except in certain cases provided for by law) until the accuracy or completeness of the Personal Data has been verified and any inaccuracy or incompleteness has been corrected (except in certain cases provided for by law). See the section on “right to restriction of Processing” below.
- Right to data portability
You also have the right, within certain limits determined by the GDPR, to ask Us to transfer a copy of Your Personal Data in a machine-readable format (e.g., XML) to You and/or directly to another institution or person of Your choice. However, this right only applies to Personal Data that You have provided to Us yourself.
- Right to withdraw consent
If You have given us Your consent for a particular Processing of Your Personal Data, You have the right to withdraw Your consent at any time. We will then no longer process the Personal Data. However, this does not affect the lawfulness of the Processing prior to the withdrawal of Your consent.
- Right to object to the Processing
When We process Your Personal Data based on Our legitimate interest, You may in certain cases object to such Processing.
However, if the Processing does not involve a form of direct marketing, We may still proceed with the Processing of Your Personal Data if this is necessary for compelling legitimate grounds. Pending an assessment of these grounds, You may request that We temporarily cease Processing the Personal Data in question (except in certain cases provided for by law). See the section on “right to restriction of Processing” below.
- Right of erasure
If You believe that Your Personal Data should no longer be processed (e.g., because this data is no longer necessary or is being processed unlawfully), You can request erasure of Your Personal Data from Our files.
Instead of erasure, you may also request that your Personal Data remain stored but not be processed further (except in certain cases provided for by law). See the section on “right to restriction of Processing ” below.
However, as the Data Controller, We are not obliged to remove Personal Data if it may or must still be lawfully processed in accordance with the GDPR.
- Right to restriction of Processing
In some cases, however, the right to restriction of Processing does not apply and We may still process your Personal Data. These cases are as follows:
- if You yourself have given Your specific consent for a certain Processing;
- if A.W.S. itself needs the Personal Data in the context of a legal action;
- if the Personal Data must be processed to protect the rights of another natural or legal person; or
- for important reasons of public interest.
How to contact Us for this?
- Exercising your rights
Contact point – To exercise Your rights, You can contact us at the address mentioned in this policy.
Verification – If Your request is unclear or if there is any doubt as to the identity of the person trying to exercise the rights on Your behalf, We may request the necessary additional information. If the applicant refuses to provide the necessary information, We may refuse the request.
Handling period – After submitting Your request, You will receive a confirmation of receipt and We will let You know as soon as possible, and at the latest within one month, what action will be taken in response to the request. In case of complex or frequent requests, this period may be extended to three months after the submission of the request. If so, We will inform You of this.
Free of charge – This request procedure is in principle completely free of charge. However, if Your request is manifestly unfounded or if You make excessive use of Your rights, in particular by repeatedly making similar requests, We have the right to refuse these requests or to charge a reasonable fee for the administrative costs.
- Questions or complaints
Questions – For all questions about the Processing of Personal Data by A.W.S. You can contact us by email (firstname.lastname@example.org) or by letter (ALTERNATIV WORKSPACE SOLUTIONS SA/NV, Zomerstraat 15, 1050 Elsene (Brussels), Belgium).
11. Security measures to prevent loss, misuse or alteration of Your Personal Data
We use security measures to protect Your Personal Data against unauthorized access and against unlawful Processing, accidental loss, destruction and corruption.
However, information transmitted via the internet will never be 100% secure. As a result, We cannot guarantee the security of the information You transmit to us.
Once We have received the information, We do Our utmost to ensure the security of Our systems.
Where We have provided You with an access code or password (or where You have chosen one) so that You may visit certain parts of Our website, You are responsible for keeping this password confidential. We request that you not share Your password with anyone.
12. The use of “Cookies”
Our website and webshop use technology to track Your browsing on the site (cookies).
13. Links to other websites
14. Transfer of Your data to outside the EU
The Personal Data that You provide us is exclusively processed within the European Union. If a Processing of Your Personal Data would be done in countries outside the European Union (“EU”), We will take the necessary steps to ensure that such processing is done in accordance with the GDPR, such as by using standard contractual clauses allowing a transfer of Personal Data to third countries.
If you use Our services while you are outside the EU, Your Personal Data may be transferred outside the EU so that We can continue to provide You with these services.
15. Questions or comments?