We understand that your trust in us is the most important capital of "Etramo NV" (hereinafter referred to as "Etramo", "we" or "us"). Your privacy is therefore essential to us.
The current privacy statement (hereafter referred to as "Privacy Statement") applies, inter alia, to (i) our website www.etramo.com our website www.etramo.com (hereinafter referred to as the "Website"), (ii) visits to the buildings and / or the establishment of Etramo and (iii) all (commercial) relationships between Etramo and its customers, prospects, business partners and those who have subscribed to its magazine.
This Privacy Statement contains, among other things, information about the personal data that Etramo collects, as well as information about how Etramo uses and processes this personal data.
Etramo wishes to emphasise that it always tries to act in accordance with the "Privacy Legislation", namely (i) the Belgian Privacy Protection Act of 8 December 1992 concerning the protection of privacy with regard to the processing of personal data, (ii) the EU Regulation 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 (General Data Protection Regulation) and (iii) the (future) Belgian legislation on the implementation of the aforementioned Regulation.
Visiting the Website, calling on the services of Etramo, buying products / goods from Etramo, subscribing to the newsletter, registering for a seminar or event of Etramo, taking a subscription to the magazine of Etramo as well as any and every form of communication with Etramo implies your explicit approval (by means of communication of your personal data or opt-in) of the Privacy Statement and thus of the way in which Etramo collects, uses and processes your personal data.
I. Types of personal data
Etramo can collect and process the following personal data:
- First Name
- E-mail address
- Telephone number (fixed and / or mobile)
- Home address
- Client number
- Camera footage
- Company Name
- Company Address
- Invoice address
- Social media data
- Communication preference
- IP address
- All personal data contained in the comments field of the contact form
- All other personal data transferred voluntarily to Etramo (for example during correspondence).
Etramo also automatically collects anonymous information regarding the use you make of the Website. For example, Etramo will automatically log which parts you visit from the Website, which web browser you use, which website you visited when you accessed the Website. We cannot identify you on the basis of this data, but it allows Etramo to compile statistics regarding the use of the Website.
II. Method of collection of personal data
This personal data is collected from or in the context of:
- A visit of the Website
- A collaboration with Etramo
- Correspondence with and originating from Etramo
- Visiting the buildings and / or the Etramo site
- Requesting a price quotation
- Registering for a seminar and / or event of Etramo
- The use you make of the services of Etramo
- Signing up for the Etramo newsletter (regardless of whether this is done through the website or physically)
- Subscribing to the Etramo magazine (regardless of whether this is done through the website or physically)
- The exchange of business cards
- The verification of your identity
The personal data collected by Etramo are thus expressly and voluntarily provided by you.
The provision of certain personal data is (sometimes) a condition to be able to enjoy certain services (e.g. access to certain parts of the Website, subscription to newsletters, participation in certain activities and events). This will always result in the indication which data are mandatory and which are optional.
III. Use of personal data
Etramo may use your personal data for the following purposes:
- The execution of an agreement with Etramo (including the follow-up of said agreement)
- Answering questions (whether or not asked through the contact form)
- Optimising the quality, management and content of the Website
- Sending newsletters
- Statistical purposes
- The preparation of a quotation
- Follow-up after a meeting
- Sending targeted marketing and advertising, updates and promotional offers based on your communication preferences and - if applicable - on the basis of your explicit approval
- Conducting surveys (e.g. customer satisfaction surveys) and other market studies
- Confirmation of registration for a seminar and / or event of Etramo
- Sending of invoices and the collection of payments
- Sending you our magazine
The processing takes place on the following legal grounds, as the case may be:
- You have given permission for the processing of your personal data for one or more specific purposes
- The processing is necessary for the execution of the agreement with Etramo or at your request before the conclusion of an agreement
- The processing is necessary to comply with a legal obligation that is imposed on Etramo
- The processing is necessary for the representation of the legitimate interests of Etramo or of a third party, except when your interests or fundamental rights and freedoms that protect your personal data, outweigh those interests (especially if you are a minor)
IV. Disclosure of personal data to third parties
Etramo will not disclose your personal details to third parties, unless it is necessary for the execution of the agreement and its optimisation (such as but not limited to processing of payments, sending of deliveries and for the delivery of services to Etramo). In this context, your personal data may possibly be made public to payment providers, software suppliers, cloud partners, transport partners, external IT consultants, financial institutions, insurance companies, government and other legal bodies as well as to external service providers.
If it is necessary for Etramo within this framework to disclose your personal data to third parties, the third party in question is obliged to use your personal data in accordance with the provisions of this Privacy Statement.
Without prejudice to the foregoing, it is possible that Etramo may disclose your personal information:
- To the competent authorities (i) if Etramo is obliged to do so by law or in the context of judicial or future court proceedings and (ii) to indemnify and defend the rights of Etramo.
- When Etramo or almost all of its assets are taken over by a third party, in which case your personal data (that Etramo has in its possession) will be one of the transferred assets.
In all other cases Etramo will not sell, rent or pass on your personal data to third parties unless they have (i) obtained your consent and (ii) a data processing agreement was reached with the third party concerned, which contains the necessary guarantees regarding confidentiality and privacy in accordance with the treatment of your personal data.
V. Cross-border processing of personal data
As a rule, we do not transfer your data to recipients who have their domicile or seat outside the European Economic Area. Nevertheless, should this be necessary, any transfer of personal data outside the European Economic Area (EEA) to a recipient residing or having its registered office in a country not covered by an adequacy decision issued by the European Commission will be governed by provisions of a data transfer agreement, which will either contain (i) the standard contractual clauses as defined in the 'Decision of the European Commission of 5 February 2010 (Decision 2010/87 / EC)' or (ii) provide appropriate safeguards by any other mechanism on the basis of the Privacy Protection Act or any other regulation concerning the processing of personal data.
VI. Storage of personal data
Unless a longer retention period is required or justified (i) by law or (ii) by compliance with another legal obligation, Etramo will only keep your personal data for the period necessary for the achievement and fulfilment of the purposes, such as described in this Privacy Statement under 'III. Use of personal data '.
VII. Your privacy rights
In the context of the processing of your personal data, you have the following privacy rights:
- Right to inspect your personal data
- Right to rectification, completion or update of your personal data
- Right to the deletion of your personal data ('right to be forgotten ') (Etramo would like to point out in this regard that certain services will no longer be accessible or can no longer be provided if you delete or have certain necessary personal data deleted)
- Right to a limitation of the processing of your personal data
- Right of transferability of your personal data
- Right of objection / opposition to the processing of your personal data.
When you wish to exercise your privacy rights, please contact email@example.com.
As a principle you can apply these rights free of charge via the e-mail address mentioned above.
If you do not wish to receive newsletters or information about the services, products and / or goods from Etramo, then you can simply unsubscribe at any time by clicking the "unsubscribe" button, as provided for at the bottom of each e-mail from Etramo.
VIII. Security of personal data
Etramo commits to taking appropriate and reasonable physical, technological and organisational security measures in the interests of preventing (i) unauthorized or unlawful access to your personal data, as well as (ii) loss, misuse or alteration of your personal data.
Etramo will store all personal data it has collected on the server on its site, potentially with a back-up in the cloud at data centres in the EU.
Notwithstanding (i) the security policy of Etramo, (ii) the check-ups it carries out and (iii) the actions it takes in this context, an infallible level of safety can never be guaranteed. No method of transfer or transmission via the internet nor any method of electronic storage is 100% secure, so that Etramo cannot guarantee absolute security in this context.
IX. Update Privacy Statement
Etramo is entitled to update this Privacy Statement by placing a new version on the Website. In this regard it is strongly advised to regularly consult the Websites and the relevant page on which the Privacy Statement is displayed to ensure that you are fully aware of any changes.
X. References to other websites
XI. Contact Etramo
If you have questions about the Privacy Statement or about the way in which Etramo collects, uses or processes your personal data, please contact us:
- Via e-mail: firstname.lastname@example.org or
- By mail: Etramo NV, Vosveld 20, B-2110 Wijnegem, Belgium
If you are dissatisfied with the way in which Etramo handled these questions or comments or if you have any complaints about the way in which Etramo collects, uses or processes your data, you can submit a complaint to the Privacy Commission.
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Data processing agreement
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Server log files
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