Privacy policy
Last updated: 13.10.2023
CONTENT
A. General
Who are we?
How do we protect your personal data?
Are we sharing or selling your personal data?
Are your personal data transferred outside of the EEA?
How long are your personal data kept?
How can you exercise your privacy rights?
B. Specific
Website visitors
Subscribers to direct marketing or press releases
Consumers (B2C)
Customers (B2B)
Prospect customers (B2B)
Employees, self-employed representatives, contractors and freelancers
Applicants
Shareholders and directors
Whistleblowers
Suppliers
C. In conclusion
How do you stay informed of changes to this Policy?
Contact information
How do you report a breach of this Policy?
A. General
Van de Velde cares about your privacy!
That is why we want to provide you with information about what happens to your personal data. Within this Privacy Policy (“Policy”) you will find what personal data we collect, why we collect it, how long we store it, what your rights are and how you can exercise them.
1. Who are we?
Van de Velde NV is a company incorporated under Belgian law with registered office at Lageweg 4, 9260 Schellebelle, Belgium and with company registration number 0448.746.744 ("Van de Velde" or "we" or “us”). Any reference in this Policy to Van de Velde also includes the European subsidiaries of Van de Velde NV, a list of which can be consulted here.
Van de Velde is the controller of your personal data. This means that Van de Velde determines the purpose and means for the processing of your personal data.
Your personal data are a.o. collected in our stores, on our websites, at our events, while applying for a job or starting as an employee, when created as a supplier or B2B customer or when filing an application to sell our brands.
When referring to “our websites”, the following websites are included (“Website”), unless expressly waived in this Policy:
By providing us with your personal data, you are deemed to have read, accepted and be bound by this Policy, the relevant Terms and Conditions and the Cookie Policy (jointly called the ‘Terms’). The Terms are always available for consultation on the relevant Website, in-store or during the event.
2. How do we protect your personal data?
2.1 Legal compliance
We act in accordance with the provisions of the Belgian Data Protection Act (‘Acts of 30 July 2018 on the protection of physical persons with regard to the processing of personal data’) and the European General Data Protection Regulation 2016/679 (“GDPR”).
2.2 Technical, physical and organizational measures
We work hard to protect your privacy and personal data. Van de Velde uses a combination of technical and organizational measures to keep your data safe.
Our employees are trained to correctly handle your personal data. Furthermore in the framework of every project that is aiming to process personal data, an assessment is performed with regard to security and the protection of this data, all while keeping into account your interests. Also our internal information Security Policy, security requirements and management standards are followed up for compliance by our employees.
We may also employ specialized profiles who are responsible for the security of our network, our infrastructure and our information systems. In addition, we use all sorts of technical measures to protect your personal data against unauthorized access, unauthorized use and loss or theft of our data, such as: password protection, firewalls, antivirus and access controls for our employees. No method of transmitting or storing of data is completely secure however, so should a data breach occur with adverse consequences for you, then you will be personally informed in the circumstances provided by the law. If you have a security-related concern, please contact us at privacy@vandevelde.eu.
Furthermore, you acknowledge and accept that third parties may access information transmitted over a public network and that Van de Velde is in no way responsible or liable in the event of such unauthorized use.
3. Are we sharing or selling your personal data?
We do not sell your personal data.
We do not share your personal data to any third parties without your prior consent, unless:
to companies associated by law with Van de Velde, established in the European Economic Area or the United States of America. Your personal data is shared with these companies for the same purposes as those stated within this Policy. These companies qualify as joint controllers in this context. You may request a list of these companies by sending an email to privacyvandevelde.eu. This list is also available at the corporate website of Van de Velde, under ‘Investor relations, Group structure’;
to a legal successor acquiring part or the whole of Van de Velde;
when we are required to do so by law or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the Website or the rights, property or personal safety of any person. Examples are:
Third-party recipients regarding employees and freelancers:
Social inspection and Social security services
Commercial register(s)
Third-party recipients regarding all categories of subjects:
Government institutions (including tax authorities) and agencies
Law enforcement authorities
Parties to legal proceedings in which Van de Velde is involved (including our legal or other advisors
to franchisees of Van de Velde;
to independent retail partners of Van de Velde if you access a Website via a link from the retail partner in question and make a purchase;
when it is necessary to provide you with our services. Some of our databases are made accessible or transferred to third parties who work in our assignment and who assist us in delivering our products and services. The transfer of your data only takes place for the purposes as mentioned within this Policy and is limited to the data that they need for the performance of our assignment. We ensure that they, just like us, manage your data safely, respectfully and with due care and we provide adequate contractual guarantees. Examples are:
Third-party recipients regarding consumers:
Commercial employees
Independent retailers
Service providers for web hosting, cloud services or maintenance services.
Various postal services for the delivery of your parcels ordered from us (e.g. UPS, DHL, De Post, Post NL).
Social media channels to the extent that you contact us via social media. Social media channels have their own privacy and cookie policies, so the personal data you provide them will be covered by those policies and not ours.
Third-party recipients regarding subscribers to our newsletter: Social media channels to inform you of relevant information, updates and marketing content (such as advertising based on look-a-like profiles). Social media channels have their own privacy and cookie policies, so any personal information you provide to them will be subject to those policies and not to ours.
when we have or the third party has a legitimate interest for transfer. We will only transfer your personal data based on an assessment of your rights and freedoms and you will always be transparently informed about them (except in case of legal exceptions). Examples are:
Third-party recipients regarding employees:
Providers of payroll and employee benefits;
Insurance companies;
Providers of HR tools.
Third-party recipients regarding applicants:
Third parties who provide services for authenticating applicants and verifying the information submitted (such as competent authorities responsible for maintaining educational, electoral or, where applicable, criminal records);
Synergie Belgium NV to handle the application process for certain open positions;
Hudson Belgium NV to conduct screening tests of applicants.
to recognized financial or bank institutions. Examples are:
Regarding consumers: Authorized financial or banking institutions, when intervention is required for the smooth running of the payment process;
In addition, we reserve the right to request information about you from other third parties such as credit reporting agencies. We will add that information to the information about you that we have already processed. This allows us to: (1) offer your goods or services; (2) enhance and facilitate your purchasing experience; and (3) help prevent money laundering and fraud. If we make such a request, we will inform you first and let you know whether the request will be stored in a credit file.
Regarding employees, self-employed representatives, contractors and freelancers:
Bank
Credit card company
when you provide your consent. In any other case where we would be transferring your data to third parties, we will provide you with a transparent notice through which you are informed of the third party, the purpose of the transfer and their processing. Where it is required by law, we will obtain your explicit consent to do so. An example regarding consumers is:
If you have a point of sale explicitly identified as your preferred point of sale. Van de Velde determines that, after the transfer, this preferred point of sale will be responsible for processing your personal data in accordance with its own privacy policy, which cannot be verified by Van de Velde. Please contact the point of sale in question with any questions you may have.
When we transfer your personal data to our trusted partners, we do so only for the purposes stated in this policy and we ensure that all transfers of personal data comply with the applicable legislation.
We may also disclose anonymous, aggregated statistics for commercial and internal/external reporting. For example: about visitors to our Website in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes. These statistics will not include information through which you may be identified.
If you have any queries about the processing of your data by such third parties, please contact the third party in question. To the extent that this processing goes beyond the scope of purposes determined by Van de Velde, the third party is fully responsible for such processing, and Van de Velde can in no way be responsible or liable for such processing.
4. Are your personal data transferred outside of the EEA?
Van de Velde transfers personal data to countries outside the European Economic Area (“EEA”). In these cases, Van de Velde has taken appropriate protective measures to ensure that the personal data is protected in accordance with applicable privacy laws.
Currently, personal data may be transferred to the following countries outside the European Economic Area:
United Kingdom: the Adequacy Decision forms the legal basis for the transfer
United States: the standard data protection provisions adopted by the European Commission forms the legal basis for the transfer
5. How long are your personal data kept?
By law, we are not allowed to store personal data for longer than is necessary to achieve the purpose for which we collected it. The retention period can therefore be different according to the processing activity. In part B ‘Specific’ below, you can consult the applicable retention period(s) for each category of data subject.
In addition, we may need to keep your data for a certain period of time in order to comply with a variety of local laws in view of our accounting and tax obligations.
After the applicable storage period(s) have expired, personal data will be deleted or anonymized.
6. How can you exercise your privacy rights?
An overview of your rights:
You have the right to access, rectify or erase personal data. Furthermore, you are entitled to object to the use of your personal data for direct marketing purposes. You also have the right to ask for the provision of a copy of all your personal data which are processed by us, where technically feasible. You also have the right to exercise your right to data portability.
This also applies to the consumers of a B2B customer whose personal data we process.
Practicalities:
How to exercise your rights? To exercise your rights, or if you require further information regarding your rights, simply email privacy@vandevelde.eu. In order to exercise your right of access and to prevent any unauthorized disclosure of your personal data, we must verify your identity. In case of doubt or ambiguity, we will first ask you for additional information (for example a copy of your identity card).
Will you have to pay? You can exercise your privacy rights free of charge, unless your request is manifestly unfounded or excessive, in particular because of repetitive nature. In such a case we have – in accordance with the General Data Protection Regulation – the right and the choice to charge you a reasonable fee (taking into account the administrative costs to provide the requested information or communication) or to refuse to comply with your request.
How will you receive an answer? If you submit your request electronically, the requested information will be provided to you electronically if possible, unless you request otherwise. In any case, we will provide you with a concise, transparent, understandable and easily accessible answer.
When will you receive an answer? We will respond to your request as soon as possible, and in any case within one month of receipt of your request. Depending on the complexity of the request and the number of requests, this period could be extended for an additional two months if required. If this would be the case, we will notify you within one month of receipt of the request.
B. Specific
This policy applies only to the personal data we process as data controllers (see above: “Who are we?”). This includes the personal data of our:
website visitors (see §1 below);
subscribers to direct marketing (see §2 below);
consumers (B2C) in connection with our products and services (see §3 below);
customers (B2B) and their consumers (B2C) in relation to our products and services (see §4 below);
prospect customers (B2B) in connection with our products and services (see §5 below);
employees, independent agents, freelancers and contractors (see §6 below);
applicants (see §7 below);
shareholders and directors (see §8 below);
whistleblowers (see §9 below);
suppliers (see §10 below).
All personal data we collect as described below will be processed in accordance with this Policy. We process your personal data for various purposes, processing only the data necessary for the intended purpose.
Your personal data will not be used for commercial purposes without your consent.
1. Website visitors
Our web server, as part of its normal functions, collects the following information from everyone who visits the Website: IP address, internet service provider, the software, the type and language of your browser, the search engine and keywords you used to find the Website, the date and time you visited the Website, the pages on the Website you visited, the pages of other websites from which you clicked through to the Website. This information is collected with cookies. More information about cookies can be found in our Cookie Policy on the relevant Website.
2. Subscribers to direct marketing or press releases
2.1 When do you provide us with personal data as a subscriber to direct marketing?
When you subscribe to direct marketing (via electronic newsletter, SMS, Whatsapp or by mail) or press releases, you can provide us with personal data.
For electronic newsletters and press releases, your e-mail address is a required field.
For direct marketing by mail, your first name, last name and address are mandatory fields.
For direct marketing via SMS or Whatsapp, your cell phone number is a required field.
2.2 For what purposes do we process your personal data?
We use your personal data when necessary to provide general or direct marketing to you. We will provide you with (personalized) communications only when you have consented to us processing your personal data for direct marketing.
We may contact you (1) in writing, at your home address; (2) by calling you or texting you on the telephone number(s) you have provided; or (3) by e-mail or fax, with information regarding events, promotions, actions, products, services and/or contests. If you prefer not to receive any marketing communication from us, or if you prefer for you personal data not to be processed for direct marketing, you can opt out at any time by sending an email to privacy@vandevelde.eu.
If you subscribe to our newsletter, we may tailor our communications and online advertising based on the information you provide us. In this context, social media allows us to inform you of relevant information, updates and marketing content (such as advertising based on look-a-like profiles.) In addition, social media allows us to function as customer service (for example, if you use social media to contact us). We remind you that social media channels have their own privacy and cookie policies, so the personal data you provide them will be subject to those policies and not ours.
2.3 How long do we keep your personal data?
For the marketing purposes for which you have given your consent, your contact details will be kept by us as long as you do not withdraw this consent.
3. Consumers (B2C)
3.1 When do you provide us with personal data as a consumer?
When you as a consumer use one of our websites, create a profile in a store, or contact our customer service department, you may provide us with personal information.
When creating a profile, your first name, last name, e-mail address and password are required fields. Optionally, date of birth, phone number and consent for direct marketing can be entered. Your size and purchase history can be saved in the profile.
When placing an order, your first name, last name, street and house number, postal code and city are mandatory fields. Optionally, a phone number can be entered.
When completing the fit quiz, you can enter your e-mail address to receive the results of the fit quiz.
When you contact our customer service (by phone, letter or e-mail), personal data can be provided.
When referring to “our websites”, the following websites are included (hereinafter: “Website”),
In addition, you may also provide us with personal data when you attend an event, visit our offices, use our apps, participate in market research, surveys, contests, promotions or otherwise use our products and services.
3.2 For what purposes do we process your personal data?
We use personal data when it is necessary for:
processing an order;
providing goods, services and/or information requested by you;
providing you with the information, goods and services offered through our Website for billing and order fulfillment;
verifying and carrying out financial transactions in relation to payments you make online;
administering your account with us;
auditing the download of data from our Website;
measuring and monitoring the use and improving the quality and content of our Website;
customizing the content and layout of our Website;
improving Van de Velde’s products and services;
organizing and inviting you to our events;
profiling (in order to provide you with personalized commercial information);
organizing contests;
complying with the legal or regulatory provisions to which we are subject;
maintaining your shape in order to assist you better with your next purchase;
processing a dropshipment order or a ‘Reserve&Fit’ reservation you placed with an independent Van de Velde retailer
The processing of the personal data of categories (1) to (5) is necessary for the performance of the contract you have with Van de Velde.
Categories (6) to (12) are processed within the framework of the legitimate interests Van de Velde holds to process these personal data: prevention of fraud or misuse of services, marketing research, website improvement purposes, organization of events and contests, and profiling. In these cases Van de Velde will always aim for a balance between our legitimate interest and your privacy.
The processing within the framework of category (14) only takes place in case you have provided your consent thereto.
The processing within the framework of category (15) is necessary for the performance of the contract you have with an independent retailer of Van de Velde.
3.3 How long are we keeping your personal data?
The retention period varies depending on the processing, for example:
Generally, we will store your personal data for five years after your most recent login to or transaction with us.
If you make a purchase on a Website as a ‘guest’, we will store your personal data for two years after the transaction, in the context of returns within the legal warranty period.
Personal data collected for contests will only be kept for one year after the contest is closed.
4. Customers (B2B)
4.1 When do you provide us with personal data as a B2B customer?
When you create a profile as a B2B customer on www.vandeveldeservice.com (hereinafter: ‘Website’), first name, last name, e-mail address and preferred language are mandatory fields. When you contact our customer service (by telephone, letter or e-mail), you may also voluntarily provide us with other personal data, including address, gender, place of residence, fixed telephone number and mobile telephone number.
Finally, within the scope of dropshipment, you may also provide us with personal data of your consumers, such as their delivery address, name and phone number.
4.2 For what purposes do we process your personal data?
processing an order;
providing goods, services and/or information requested by you;
providing you with the information, goods and services offered through our Website for billing and order fulfillment;
verifying and carrying out financial transactions in relation to payments you make online;
administering your account with us;
auditing the download of data from our Website;
measuring and monitoring the use and improving the quality and content of our Website;
customizing the content and layout of our Website;
improving Van de Velde’s products and services;
complying with the legal or regulatory provisions to which we are subject;
The processing of the personal data of categories (1) to (5) is necessary for the performance of the contract you have with us.
Categories (6) to (9) are processed within the framework of the legitimate interests we hold to process these personal data: prevention of fraud or misuse of services, marketing research, website improvement purposes, organization or events and contests, and profiling. In these cases we will always aim for a balance between our legitimate interest and your privacy.
4.3 How long are we keeping your personal data?
Generally, we will store your personal data for 5 years after your most recent order with Van de Velde. However, the retention period may vary depending on the processing. With regard to dropshipment, for example, we will store the personal data of your consumers for one year after delivery.
5. Prospect customers (B2B)
When you apply to become a retail partner through www.vandeveldeservice.com or www.vandevelde.eu (hereinafter: ‘Website’), first name, last name, e-mail address, phone number, city and country are mandatory fields. Your personal data will be processed for the purpose of processing your application. Personal data you hereby provide will be kept for five years.
6. Employees, self-employed representatives, contractors and freelancers
6.1 When do you provide us with personal data as an employee, self-employed representative, contractor or freelancer?
We collect and process your personal data at the time of your start-up or during your working period. Van de Velde may have received certain of your personal data from other sources than you directly, such as recruitment agencies or head-hunters.
This may include the following categories of personal data:
Current or previous employees of Van de Velde:
Personal identifying data (e.g. first name, last name, home address, private email address...)
General identifying data (e.g. license plate, national register number, ID card number…)
Identifying data issued by the authorities (e.g. social security number, Dimona employment number…)
Financial identifying data (e.g. bank account number…)
Personal characteristics (e.g. gender, date of birth, place of birth, nationality, language…)
Household composition (e.g. date of marriage/cohabitation, hospitalisation of a partner and/or children…)
Training and education (e.g. academic curriculum)
Current employment (e.g. job title and description, length of employment contract, joint industrial committee…)
Previous employment (e.g. information about previous employment, being employer, period and title and description…)
Remuneration (e.g. salary, bonus, benefits…)
Data on mobile phone use (e.g. current operator and registration type, portable mobile phone number...)
Data relating to physical health (e.g. medical certificate)
Self-employed representatives of Van de Velde
Personal identifying data (e.g. first name, last name, address, email address, phone number...)
Identifying data issued by the authorities (e.g. identifying number of the commercial register..)
Financial identifying data (e.g. bank account number)
Remuneration (e.g. commission amounts)
Current employment (e.g. title and description of the representation assignment, length, notice period...)
Contractor or freelancer active with Van de Velde
Personal identifying data (e.g. first name, last name…)
Remuneration (e.g. trate for services provided, rate for travel costs…)
Current employment (e.g. commissioning party, job title and description, length of working relationship…)
6.2 What if you refuse to share your personal data with us?
Your refusal to share any of the aforementioned personal data with Van de Velde may:
render difficult the performance of the contract of employment (employees) or the working relationship;
Render impossible the performance of the contract of employment (employees) or working relationship, concerning certain personal data such as name, address and date of birth.
6.3 For what purposes do we process your personal data?
management and administration of employees (a)(b)
payroll services and management of other employee benefits (a)(b)
preventive periodic medical exam of workers (a)(b)
insurance (accident at work insurance, hospitalisation insurance, pension savings group insurance, long-term incapacity for work group insurance) (a)(b)
resumption of work after long period of incapacity for work (a)(b)
planning, organizing, sharing and monitoring tasks and positions (a)(c)
checking the work-related activity at the workplace by camera, clocking-in system or other computer system (a)(c)
registration as director of a subsidiary of Van de Velde in a (foreign) commercial register (a)(c)
sharing of personal data with bank for direct debit from Van de Velde’s bank account (a)(c)
implementing or applying laws and regulations (b)
outplacement (b)
application for thematic leave and time credit (b)
safety operations (= safeguarding persons and/or goods) (b)(c)
financial and management reporting (b)(c)
communication with employees (c)
(a) The processing of personal data in categories (1) to (9) is necessary for the performance of the contract you enter into with us.
(b) The processing of personal data of category (1) to (5), and category (10) to (14) is necessary for the fulfilment of a legal obligation.
(c) The personal data of category (6) to (9), and category (13) to (15) are processed within the framework of our legitimate interests: the performance of ordinary business activities such as informing about, evaluating and improving the operation of (the persons working for) Van de Velde and protecting Van de Velde’s property and interests against damage.
The processing of personal data is based on one of the purposes mentioned above (depending on the specific category and purpose of the processing). Not all legal bases apply at the same time.
6.4 How long are personal data kept?
Typically, we will store your personal data for five years from the termination of the (employment) agreement. However, retention periods pay vary depending on the processing. For example, pension plans are kept for 10 years from the day the last benefit is due under the plan, and individual pension slips for five years from the day the payment was made for the person concerned.
7. Applicants
7.1 When do you provide us with personal data as an applicant?
When you submit your application via www.workingatvandevelde.eu, www.workingatrigbyandpeller.com or www.werkenbijlincherie.nl (hereinafter: ‘Website’), first name, last name, e-mail address, gender, address, mobile number, CV and language are mandatory fields. Optionally, you can enter your date of birth and phone number.
7.2 What do we use your personal data for?
Your personal data will be used to identify you and assess your suitability for the vacancy you have applied for at Van de Velde. This processing is done (i) to manage the staff of Van de Velde (including applicants); (ii) to manage the (pre-)contractual relationship; (iii) to prevent irregularities; and (iv) to create statistics and tests. Van de Velde only requests information reasonably necessary for the identification and evaluation of potential candidates for open vacancies.
If your application is successful, some of the personal data collected as part of this recruitment process will be transferred to your employee file. Full details regarding what personal data Van de Velde will hold about you as an employee can be viewed in §6 above.
7.3 How long do we keep your personal data?
Van de Velde keeps personal data of unsuccessful candidates for a period of maximum 6 months after they are rejected. Unsuccessful candidates may be considered by Van de Velde for future positions, if you consent. If so, your personal data will be kept by Van de Velde for one year so that you can be contacted with regard to other vacancies than the one you have applied for.
Your personal data will be retained by Hudson for one year starting from the creation on the testplatform and then automatically anonymized.
8. Shareholders and directors
As a shareholder, you can provide us with personal data for participation in a general meeting (in person or by proxy). Surname, first name and address are mandatory fields. We will retain your personal data for 10 years after this general meeting.
As a registered shareholder, you must provide us with personal data for registration in the shareholder’s register and payment in dividends. This includes: last name, first name, address, number of shares and account number. We will keep your personal data as long as you are registered in the registered shareholders register.
As a director, your personal data are collected to fulfil the necessary legal formalities (publication Belgian Official Gazette, PDMR list FSMA, anti-money laundering legislation…). We will retain your personal data for as long as you remain a director.
9. Whistleblowers
As a whistleblower, you can provide us with personal data when making a whistleblower report via the provided platform at www.vandevelde.eu, via the whistleblowing@vandevelde.eu mailbox, by phone or in person. The whistleblower can make this report anonymously. Your personal data will only be processed to provide you with feedback on the report.
Van de Velde will keep e-mails in the whistleblowing@vandevelde.eu mailbox and personal details in the report register as long as the report has not been finally rejected. Van de Velde will retain other information, except personal data, in the notification register for 5 years from the initial report.
10. Suppliers
As a supplier, you may provide us with personal data when you register as a supplier and throughout your relationship with Van de Velde. These personal data are processed for contact and invoicing purposes. Van de Velde will retain all supplier details for 5 years after payment of the last invoice issued to us.
C. In conclusion
1. How do you stay informed of changes to this Policy?
Van de Velde reserves the right to amend, modify, supplement or delete all or part of this Policy at any time and at its sole discretion. This may be necessary in view of market developments or new processing activities that we carry out. Therefore, we ask you to check regularly to see if this Policy has changed. If you use a Website after a change has been made to this Policy, you will be deemed to accept that change regardless of whether you have read this Policy.
If you do not accept this Policy, you must immediately leave the Website on which you are viewing this Policy.
You may not create a profile or receive direct marketing if you do not accept this Policy.
2. Contact information
If you have a question or comment about the processing of your personal data, please contact privacy@vandevelde.eu or Van de Velde N.V. (0448.746.744), Lageweg 4, 9260 Schellebelle, Belgium.
3. How do you report a breach of this policy?
If you suspect a (future) breach of your privacy, we ask you to report it. You can do so in accordance with the procedure set out in the “Internal reporting” scheme in Van de Velde’s Whistleblower policy. The Whistleblower policy can be consulted via this link. Under the Whistleblower policy, the report is treated confidentially and the person making the report is protected against possible reprisals. In addition, you can make an anonymous report via this link. For questions, please contact whistleblowing@vandevelde.eu.
You also have the right to file a complaint with a local supervisory authority or with the Belgian Data Protection Authority (our lead supervisory authority) with respect to Van de Velde’s processing of your personal data. Below are the contact details of the Belgian Data Protection Authority: Drukpersstraat 35, 1000 Brussel. +32 (0)2 274 48 00 / contact@apd-gba.be / www.gegevensbeschermingsautoriteit.be