Remove Insul nv Privacy policy (version 08/04/2024)

Who are we?

We are Remove Insul NV, located at Klein Frankrijkstraat 36/0003 in 9600 Ronse and registered in the Crossroads Bank for Enterprises under number BE 0453.507.860 (hereinafter "Remove Insul").

In the context of our activities, personal data are collected, stored, transmitted or otherwise processed by us. Based on the applicable privacy legislation, we qualify as a "data controller" in relation to the personal data we process.

What is the importance of this Privacy Policy?

We attach great importance to your right to privacy and always seek to protect your personal data in accordance with applicable data protection legislation, and more specifically the European General Data Protection Regulation (GDPR). In this Privacy Policy, we explain how we collect your personal data, how and for what purposes we will process this data, and to whom your personal data may be disclosed. Furthermore, this Privacy Policy also contains important information about your rights regarding the processing of your personal data. We therefore recommend that you read this policy carefully.

From time to time it may be necessary to amend this Privacy Policy. In that case, we will always send you by e-mail, a copy of the new version. The most recent version of this Privacy Policy is also always available on our website.

Please note: If you share your personal data with us, we expect you to have read this Privacy Policy carefully first.

Note: This does not mean that we require your 'consent' to process your personal data. We do not process your personal data on the basis of your consent unless specifically indicated (e.g. for sending our (electronic) newsletter).

From whom do we collect personal data?

In the course of our activities (as described above), we may collect personal data from our customers, from visitors to our website, from persons who fill in a contact form on our website, from persons who have subscribed to our (electronic) newsletter and from persons who otherwise (e.g. by their name and contact details being passed on to us as employees or appointees of our customers, suppliers or commercial partners) come into contact with us.

How do we collect personal data about you?

We may collect information about you in a number of ways:

• directly from you when you provide your personal data to us as part of our commercial activities;
• directly from you when you visit our website, when you fill in a contact form on our website and/or when you subscribe to our electronic newsletter;
• through your employer with whom we have a contract or partnership (e.g. when you act as a contact for our customers, suppliers or commercial partners); and
• through third parties and official sources

What personal data do we collect?

We may collect the following data from you :

• Personal identification data: name, address, phone number, mobile phone number, email address;
• Electronic identification data: IP addresses, information collected via cookies.

Whenever certain information is mandatory to fill in, and other information only optional, this will be clearly indicated for you.

What do we use this data for?

We use this data for the following purposes :

• for our customer management;
• for managing our website;
• to provide you with information you have requested, e.g. if you have asked a question via the contact form on our website;
• for marketing purposes, both for our (paper) mailings and for our (electronic) newsletter (if you have subscribed to it).
  For your full information, you can find below the legal grounds relevant to these processing operations:

• we base the processing of your personal data for our customer management or to provide our customers with certain information on the necessity for the performance of the contract;
• in all other cases, we base the processing of your personal data for the management of our website or to provide you with certain information (e.g. after making contact via our website or when sending paper mailings) on the necessity for the protection of our legitimate commercial interests as a company (in particular the interest to be able to establish contacts with prospects and potential customers),
• The processing of your personal data for electronic direct marketing purposes (sending our (electronic) newsletter) is based on your opt-in consent. Only if you have unambiguously indicated that you would like to receive our (electronic) newsletter (you are completely free to do so), will we register you for this purpose.

With whom do we share your personal data?

• With our service providers ('processors'):
• As part of our activities as listed above, we sometimes share your personal data with third parties, in particular service providers (e.g. IT/cloud service providers or PR/marketing service providers who organise mailing campaigns for us) who act as 'processors' for us.
• With our commercial partners:
• We may also share your personal data with our commercial partners (so that they can contact you).
• With your employer and your relations in the context of your professional activities.
• Within our group of companies.
• We may also share your personal data within Altrad Group companies for commercial purposes.
• With public authorities:
• Furthermore, we may also share your data with public authorities, police forces or the courts if there is a legal obligation to do so.
  We always ensure that appropriate protective measures are taken when we transfer your personal data to third parties. For example, we will conclude a processor agreement where necessary, which sets out restrictions on the use of your personal data and obligations regarding the security of your personal data. Your personal data and your profile will not be loaned or sold to third parties for marketing purposes without your prior explicit consent. Your personal data will not be transferred to countries outside the European Economic Area (EEA).

How long do we keep your personal data?

Your personal data will not be stored for longer than necessary for the purposes for which they were collected and processed (as described above). Afterwards, they may still be found in our backups or archives, but they will no longer be actively processed on file.

More specifically, the following retention periods apply:

• Customer data retention period: All data framed in the contractual relationship with customers or suppliers will be kept for 10 years after the end of the contractual relationship. This period corresponds to the limitation period for contractual claims;
• Direct marketing retention period: data will be used until:
• The data subject unsubscribes,
• ALTRAD SERVICES Benelux is notified that the e-mail address is no longer in use,
• ALTRAD SERVICES Benelux decides to stop sending mailings.

Only if we are required to do so by law, or if it is necessary to defend our interests in court (e.g. in the event of a dispute), will we retain your personal data for a longer period.

How do we protect your personal data?

We take the necessary administrative, technical and organisational measures to ensure a level of security appropriate to the specific risks we have identified. We thus protect your personal data as best we can against destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed. Furthermore, we always try to ensure that we keep your personal data accurate and up-to-date. We therefore kindly request that you inform us of any changes to your personal data (such as a change in your contact details). More information on our security measures is available upon request.

What are your rights and how can you exercise them?

You have the right (under certain conditions):

• to information and inspection of your data;
• to rectification of personal data;
• to deletion of your personal data ('right to be forgotten');
• To restrict processing;
• to object to the processing of your personal data;
• to obtain your personal data in a structured, common, and machine-readable form, and to transfer (or have transferred) that personal data to another controller.

For more information on these rights, and the circumstances under which you can exercise them, in particular your right to object (this is your 'opt-out' right for our electronic newsletter), see the Annex to this policy. In principle, you can exercise these rights free of charge. Only in the event of unreasonable or repeated requests may we charge a reasonable administrative fee for this. We always try to respond to your requests or questions as quickly as possible. It is also possible that we may first ask you for proof of identity to verify your request.

Finally, you also have the right to lodge a complaint with the Dutch and Belgian Data Protection Authority in connection with the processing of your personal data.

Contact

If you would have any questions, comments or complaints regarding this Privacy Policy or the processing of your personal data, please contact us via the contact form on our website.

Annex - Further explanation of your legal rights

Right to information and right to access your data

You can ask us for more information regarding our processing activities and the data we hold about you.

Right to correct incorrect or incomplete data

You may request us to correct or complete inaccurate or incomplete personal data.

Right to have your personal data deleted ('right to be forgotten')

Upon written request, we will delete your personal data:

- if they are no longer necessary for the purposes for which they were collected or processed; or

- if the processing was based solely on your consent, which you now withdraw; or

- if you have reasonable grounds to object to the processing of your personal data; or

- if the personal data have been processed unlawfully; or

- if the personal data must be deleted to comply with a legal obligation.

Exceptionally, we may refuse to delete your data (i) in order to exercise the right to freedom of expression and information; (ii) to comply with a legal obligation; or (iii) for the establishment, exercise or defence of legal claims.

Right to restriction of processing

You have the right to obtain the restriction of processing if one of the following situations applies:

- for a period enabling us to verify the accuracy of the personal data, if it is disputed; or

- if you request us to do so, in lieu of deletion of the data; or

- if we no longer need the personal data, but you need it for the establishment, exercise or defence of legal claims; or

- if you have objected to processing based on our legitimate interests.

Right to object to the processing of your personal data

You have the right at any time, because of your specific situation, to object to the processing of your personal data based on our "legitimate interest consideration". In such a case, we will no longer process these data unless there are compelling legitimate grounds for the processing which outweigh, or which are related to the establishment, exercise or substantiation of a legal claim.

Where personal data are processed for direct marketing purposes (in particular for sending our electronic newsletter or personalised advertising by ordinary mail), you have the right to object at any time or withdraw your consent. You also have the right not to be subjected to profiling for marketing purposes.

Right to data portability

In some cases, you have the right to obtain your personal data in a structured, common and machine-readable form, and the right to transfer that data to another controller. This right applies:

- if the processing is based on the legal ground of consent or necessity for the performance of a contract; and

- if the processing is carried out by automated methods.