Privacy Policy Your privacy is of essential importance for Vasco Group. This privacy statement is designed to inform you about how we, the undersigned, the various legal entities that are part of Vasco Group, deal with your personal data. This privacy statement contains information about the personal data that is collected by Vasco Group, as well as the way in which Vasco Group uses and processes this personal data. This privacy statement (referred to hereinafter as the “Privacy Statement”) applies to all (commercial) relations between Vasco Group and its customers, end-customers, prospects and business partners (including use of our website https://www.vasco-group.eu (referred to hereinafter as the “Website”)). Vasco Group makes every effort at all times to act in accordance with the “Privacy Legislation”, i.e. EU Directive 2016/679 dated 27th April 2016 relative to the protection of natural persons in relation to the processing of personal data and regarding the free circulation of that data, and to the withdrawal of Directive 95/46/EC, as well as current and future national legislation regarding the implementation of the aforementioned Directive. When you provide Vasco Group with personal data, for example as the result of visiting the Website, using the services of Vasco Group, purchasing our products, subscribing to one of our newsletters, visiting a Vasco Group stand at an exhibition or taking part in events run by Vasco Group, we process this data in compliance with this Privacy Statement. In terms of your use of the Website, please read this Privacy Statement in conjunction with our cookie policy. Cookie Policy Types of personal data Vasco Group collects and processes the following types of personal data: Surname First name E-mail address Address (delivery address/billing address) Telephone number (landline and/or mobile) Fax number Job title Gender Customer number Account name (if you use our price quote tool or Climate Control App) Other business card details Date of birth (exceptional) Other personal details that are necessary to deal with specific matters (such as photos, floor plans, visit reports, etc.) All other personal data provided voluntarily to Vasco Group, such as information about how spare time is spent, civil status, etc. Vasco Group also gathers anonymous data automatically about your use of our Website. For example, Vasco Group will automatically log which parts of the Website you visit, which web browser you are using and the website via which you accessed the Website. We cannot identify you based on this data, but can use it to produce statistics about use of the Website. II. Method of collecting personal data This personal data is collected at the time of or in the context of: A visit to the Website Requests for price quotes Collaboration or (in)direct contractual relations with Vasco Group Correspondence with Vasco Group (e.g. via the contact form on our Website) Creating an account (e.g. for our price quote tool or Climate Control App) Subscribing to (one of) our newsletters Registering for or taking part in an event or exhibition Registering for or taking part in a technical training or other course Exchanging business cards Registering at the main building Dealing with a complaint relating to a product Our historical databases may also contain personal data that we have obtained in the past from third parties. We do our utmost to avoid processing this data and we take measures to limit any such processing to a minimum. Providing certain items of personal data is (sometimes) a condition for receiving certain services (such as gaining access to certain parts of the Website, to subscribe to newsletters, to take part in certain activities and events). If this is the case, we always state which items of data are mandatory and which are optional. III. Use of personal data Vasco Group may use your personal data for the following purposes: To fulfil an agreement with Vasco Group To produce and follow up on price quotes To answer questions (whether or not asked via the contact form) To deal with complaints To protect (visitors to) Vasco Group To improve the quality, management and content of the Website Registrations for events To enrol for technical training or other courses To send out newsletters To send out targeted marketing and promotional offers, provided you have given your explicit consent to do so Statistical purposes To maintain relations with customers and prospects Product development Security and the prevention of theft Processing will only take place, depending on the case, if: - the processing is necessary, for example: to fulfil the agreement with Vasco Group or in order to take measures at your request prior to the conclusion of an agreement, to comply with a legal obligation incumbent on Vasco Group, to protect your vital interests or those of another natural person, or to promote the justified interests of Vasco Group or a third party. Exactly what interests these may be will differ according to the processing. For more information you can always contact privacy@vasco.eu Naturally we always take account of your interests, fundamental rights and freedoms and will not process your personal data to promote our own justified interests or those of a third party if your interests outweigh them (for example if you are under-age). you have given your permission for your personal data to be processed for one or more specific purposes. IV. Transferring personal data to third parties Vasco Group will not transfer (sell or rent) your personal data to third parties, except where you have expressly agreed for us to do so. In the context of the processing types stated above, Vasco Group may possibly pass on your personal data to its suppliers (e.g. mailing service providers, payment providers, software providers, IT partners, transport partners, subcontractors, lawyers, external accountants, insurers, etc.) and to entities that are part of Vasco Group. If Vasco Group shares your personal data with third parties in this context, the third party in question is still obliged to use your personal data in accordance with the provisions of this Privacy Statement. However, notwithstanding the above, it is possible that Vasco Group may disclose your personal data: To competent authorities (i) in cases where Vasco Group is obliged to do so by law or in the context of (future) (legal) proceedings, and (ii) to safeguard and defend the interests of Vasco Group. When Vasco Group or virtually all of its assets are being acquired by a third party, in which case the personal data that Vasco Group has collected forms part of the assets being transferred V. Processing personal data across borders If we were to pass on your personal data to parties outside the European Economic Area (EEA) that have their place of residence or registered office in a country regarding which no adequacy decision is issued by the European Commission, we will ensure that your personal data is protected by way of an agreement that either (i) contains the standard contractual clauses stated in the ‘Decision of the European Commission dated 5th February 2010 (Decision 2010/87/EC)’, or (ii) offers sufficient guarantees through any other mechanism under the Privacy Legislation or any other regulations governing the processing of personal data. VI. Storing personal data Except in cases where longer-term storage is required or justified (i) by law, or (ii) by compliance with some other legal obligation, Vasco Group will only keep your personal data for the period required to achieve or fulfil the purposes stated in this Privacy Statement under ‘III. Use of personal data’. VII. Your privacy rights In the context of processing your personal data, you as the data subject have the following rights: The right of access to your personal data; The right to rectification regarding, and right to supplement or update your personal data; The right to erasure regarding your personal data (‘right to be forgotten’) (however in this context Vasco Group would point out that certain services will no longer be accessible or can no longer be provided if you delete or have deleted certain items of personal data); The right to restriction of the processing of your personal data; The right to portability of your personal data; The right to object to the processing of your personal data. If you wish to exercise one or more of these rights, you may contact privacy@vasco.eu. In principle you may exercise these rights at no cost to yourself. For the sake of good order, we emphasise that these rights are not absolute rights and that Vasco Group may possibly not be able to fulfil your wishes due to specific well-founded reasons. If you do not wish to receive our newsletters or information about Vasco Group products, you can unsubscribe from them at any time by clicking on the “unsubscribe” button, as provided in every marketing e-mail sent out by Vasco Group. VIII. Securing personal data Vasco Group undertakes to take all appropriate and reasonable physical, technological and organisational security measures for the purpose of preventing unauthorised or unlawful access to your personal data, or the loss, misuse or alteration of your personal data. In principle, Vasco Group will store (or have stored) all personal data that it has collected on servers located within the EU. Notwithstanding the security policy of Vasco Group, the checks that we carry out and the actions that we take in this context, an infallible level of security can never be guaranteed. IX. Updates to the Privacy Statement Vasco Group may update this Privacy Statement by publishing a new version of it on the Website. We will always notify you of this by publishing a clear message to this effect on our homepage. X. Redirections to other websites The Website may contain hyperlinks to other websites. When you click on one of these links, you may be redirected to another website or Internet source that intentionally gathers information about you via cookies or other technologies. Vasco Group has no responsibility, liability or powers of control over these other websites or Internet sources, nor over the way they collect, use and disseminate your personal data. You must yourself review the privacy policy of these other websites and Internet sources so that you can assess whether they operate in accordance with the Privacy Legislation. XI. Contacting Vasco Group If you have any questions about this Privacy Statement or about the way in which Vasco Group collects, uses or processes your personal data, you can contact us: By e-mail: privacy@vasco.eu or By post: Vasco Group, Kruishoefstraat 50, 3650 Dilsen, Belgium If you are not satisfied with the way in which Vasco Group deals with your questions or comments, or if you have any complaints about the way in which Vasco Group collects, uses or processes your personal data, you can lodge a complaint with the Data Protection Authority. This Privacy Statement was signed on 25/05/2018 by the following entities of Vasco Group: Vasco Group NV, 3650 Dilsen-Stokkem (Belgium), Kruishoefstraat 50, VAT number BE 0428.107.718, Vasco BVBA, 3650 Dilsen-Stokkem (Belgium), Kruishoefstraat 50, VAT number BE 0479.567.901, Superia Radiatoren BVBA, 8210 Zedelgem (Belgium), Remi Claeysstraat 66, VAT number BE 0430.122.051. VASCO GROUP GMBH, Flugplatz 21,44319 Dortmund (Germany), VAT number DE124395941. Brugman Fabryka Grzejników Sp. z.o.o., Ul. Jaworzyńska 295, 59-220 Legnica (Poland), VAT number PL6912121564. Vasco Group Sp. z.o.o., Ul. Jaworzyńska 295, 59-220 Legnica (Poland), VAT number PL6912359171. Vasco Group Srl, Via Murialdo 15, 31046 Oderzo (TV, Italie), VAT number IT03603120266. Brugman Radiatorenfabriek BV, 7651 AM Tubbergen (Netherlands ), Boskampstraat 26, VAT number NL810253392B01. Vasco Group Sarl, Bâtiment l’Amiral, 1/5 Rue Jean Monnet, 94130 Nogent-sur-Marne (France), VAT number FR24337626352. 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