Protecting the security and the privacy of your personal data is important to BALTA. This Policy is intended to inform you about the personal data that BALTA collects via its websites, contact forms, order or sample request forms, at trade fairs or events, or via other communication means such as e-mail, telephone, fax and social media. This Policy explains what type of personal data is gathered, how the personal data is used, and with whom the personal data is shared.
This Policy applies to the processing of personal data that BALTA collects via its websites, via its contact forms, via its order or sample request forms, at trade fairs, or via your communication with us by e-mail, telephone, fax and social media.
2 WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
BALTA is responsible for the processing of your personal data. This means that BALTA determines for what purposes and with what means your personal data will be processed.
BALTA has set up a data protection point of contact to which any questions regarding the processing of your personal data can be sent. Its contact details can be found under article 13 of this Policy.
3 PERSONAL DATA BEING PROCESSED
We collect your personal data in three ways:
3.1 INFORMATION PROVIDED BY YOU
We receive your personal data directly from you if you share your personal data with us, by e.g. filling out our contact form, order form or sample request form, by giving us your contact details at trade fairs or events, or by contacting us (including via e-mail, telephone, fax or social media).
We may collect, store and use the following information:
basic identification information (such as your name, e-mail address, postal address, telephone number and other personal and/or contact details);
information regarding your profession (such as the company you work for, your function, etc.);
financial data (such as your credit/debit card information or other payment details) in case of orders;
information regarding your purchasing habits (e.g. the products you purchase);
the content of your communication to us;
the details of your communication to us (such as the date and time of the communication, etc.);
your preferences regarding communications as indicated by you;
information required to process your order (such as details relating to the order placement, etc.);
other personal data you choose to provide to us.
3.2 AUTOMATICALLY OBTAINED INFORMATION
In addition, we may collect, store and use other information received via a variety of technologies, as described below.
It may occur that we receive automatically obtained information about your preferences and surfing behavior on our websites. This information does not enable us to identify you directly. Therefore, we cannot know who you are merely based on the automatically obtained information. We can combine the automatically obtained information with the information provided by you.
3.3 INFORMATION OBTAINED FROM THIRD PARTIES
We may also receive your personal data from third parties (e.g. trade fair organisers). In this case, we usually receive personal data such as your name, e-mail address, address, gender, birth date and telephone number.
4 LEGAL BASIS FOR PROCESSING OF YOUR PERSONAL DATA
BALTA always relies on a legal basis for the processing of your personal data. As the case may be, we process your personal data relying on the following legal basis:
We process your personal data in order to perform a contract to which you are a party (e.g. fulfilling your order) or if the processing is necessary in order to comply with a legal obligation to which BALTA is subject;
We furthermore process your personal data based on your consent. In certain cases we will request your explicit consent. In other cases, your consent can be expressed e.g. by ticking a box to this effect during your navigation on our site, or via another positive action from which your consent is inferred, e.g. by choosing to contact us via a contact form or filling out a form at a trade fair. In this case, you have the right to withdraw your consent for the future at all times;
In some cases, the processing of your personal data may be based upon a legitimate interest of BALTA (e.g. continuous improvements to our websites in order to ensure you have the best experience possible, safeguarding our network, products and services from misuse, marketing of our products and services, etc.). In this case, we always take your fundamental rights and freedoms relating to the protection of personal data into account.
5 PURPOSE FOR PROCESSING
ITC processes and may disclose your data for the following purposes:
5.1 TO PROVIDE YOU WITH THE INFORMATION, PRODUCTS AND SERVICES YOU REQUEST FROM ITC
We process your personal data in order to answer your questions or requests. If you request an order or a sample, we will process your personal data in order to supply you with the products.
For this purpose, we can process personal data such as your basic identification information, your communication with us, financial data (e.g. your credit/debit card information or other payment details), details relating to your order placement, etc.
Depending on the individual case, these data are processed on the basis of your request to take steps prior to entering into a contract with us or on the basis of the performance of a contract to which you are a party.
5.2 FOR GENERAL ADMINISTRATION PURPOSES OF ITC
We process your personal data for general administration purposes, e.g. to draft invoices, to manage our customer data, to comply with our accounting obligations, etc.
For this purpose, we may process personal data such as your basic identification information (name, address, telephone number, e-mail address, etc.), information regarding your profession (the company you work for, your function, etc.), financial data (e.g. your credit/debit card information or other payment details), etc.
Depending on the individual case, these data are processed on the basis of the performance of a contract to which you are a party, on the basis of compliance with a legal obligation to which BALTA is subject or on the basis of BALTA’s legitimate interest to manage its customer data.
5.3 FOR DIRECT MARKETING PURPOSES
We process your personal data in order to send you communications, promotions, offerings, newsletters and other advertisements via e-mail, mail, telephone or other person-to-person electronic communication channels. These data are processed based on your explicit consent or upon BALTA’s legitimate interest.
In case of consent, we may develop a profile based upon your purchase behavior. In this profile, we take your preferences and interests into account, e.g. with respect to the products you have purchased and other products which might interest you. Based upon the information collected in the profile, we can send you general information and advertisements or information and advertisements concerning products that fit your profile or that might interest you.
For this purpose, we can process personal data such as your basic identification information, your purchase behavior, the products you are interested in, etc.
You prefer not to receive such information any longer? You can unsubscribe from our marketing materials at any time. Furthermore, you are able to contact us regarding this topic at any given moment (see article 10 of this Policy regarding your right to object and article 13 of this Policy with our contact details).
5.4 TO COMPLY WITH LEGAL OBLIGATIONS OR REASONABLE REQUESTS
BALTA processes your personal data to comply with legal obligations to which BALTA is subject or to comply with reasonable requests from official authorities, agencies or representatives, as well as legal obligations from financial institutions (such as anti-money laundering, fraud prevention and counter-terrorism legislation).
For this purpose, we can process personal data such as your basic identification information, financial data (e.g. your credit/debit card information or other payment details), the company you work for, your function etc.
5.5 TO IMPROVE OUR WEBSITES, PRODUCTS AND SERVICES
If you use our websites, have purchased our products, requested a sample or contacted us with a question or complaint, we process your personal data in order to improve our websites, products and services. Furthermore, we process your personal data in order to analyze the functioning of our websites and the quality of our products and services.
For this purpose, we can process personal data such as your basic identification information, your purchasing habits, the content of your communication with us, electronic identification data, etc.
Depending on the individual case, these personal data are processed based on your explicit consent or the legitimate interest of BALTA of improving our websites, products and services.
5.6 FOR SECURITY REASONS
BALTA may process your personal data for the preservation of the legitimate interests of BALTA, its partners or a third party if and when your registration with or use of the communication channels can be considered as or in order to prevent:
b) a threat to the security or integrity of the communication channels;
c) a danger to the communication channels or any of BALTA’s or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code; or
d) any hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal communication.
For this purpose, we can process personal data such as your communication with us, your basic identification information, etc.
6 WHO HAS ACCESS TO YOUR PERSONAL DATA?
BALTA shares your personal information within its organization, e.g. with our employees or affiliated companies. Furthermore, BALTA shares your personal data with third parties insofar as reasonably necessary for the purposes set out in this Policy.
We rely on third-party service providers to perform a variety of business operations on our behalf (for example to fulfill your product and service requests, to answer your questions, to host our websites, to deliver our e-mails or other communications, to deliver our products or product samples, to manage payments or to take other actions on our behalf). In so doing, we may need to share your personal information with the following third parties:
Certain processors who act on our behalf, such as e.g. marketing and communication companies;
Service providers who provide us with a variety of services, including but not limited to payment service providers, transport service providers, IT service providers, HR service providers, insurance service providers;
Affiliated companies, including our affiliated companies in the US and in Turkey
Attorneys and external advisors if this is necessary to give us advice or to defend our rights;
Supervisory authorities: in certain cases, BALTA may transfer your personal data to police, judicial or other authorities if we believe that we are required to do so based upon the applicable legislation or regulation or based upon another lawful request or order;
Possible acquirers of ITC in the event that (a part of) our activities would be taken over by a third party and other third parties when necessary for M&A purposes;
Vendors, distributors, subcontractors, suppliers or agents of BALTA.
The aforementioned third parties only receive the personal information they need to perform the services we request. In all cases, we require that sufficient safeguards for the protection and confidentiality of your personal data are in place.
7 DOES ITC PROCESS YOUR PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (“EEA”)?
ITC processes your personal data first and foremost within the EEA. Your personal data however may be transferred to, stored and processed in a country outside the EEA, including but not limited to the United States or Turkey (e.g. because we share certain systems with other affiliated companies of BALTA or because we use a foreign processor).
When we do so, we transfer the information in compliance with the applicable data protection laws. In this respect, BALTA is committed to always ensuring an adequate and sufficient level of protection through procedures and controls. In particular, BALTA makes sure that we can rely on an adequacy decision under article 45 of the General Data Protection Regulation (“GDPR”), that we conclude standard contractual clauses under article 46.2 GDPR or that we can rely on any other appropriate safeguard (e.g. complying with the Privacy Shield framework).
If you have any questions or would like more information about the transfer of your personal data outside the EEA, you can contact us via the contact details provided in article 13 of this Policy.
8 HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will retain your personal data for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. We may retain documentation containing personal data if we believe that such data may be relevant to any ongoing or prospective legal proceedings.
9 HOW ARE YOUR PERSONAL DATA PROTECTED?
We strive to protect the quality and integrity of your personal data as well as possible. To this end, we will take the appropriate technical and organizational measures to help us keep your information secure, accurate, current and complete and to help us protect your personal data against accidental loss, destruction or damage.
10 WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?
Under the GDPR, you have a number of rights with regard to your personal data. Some of these rights have a very specific scope or are subject to special conditions or exceptions.
Right of access: This means e.g. that you can ask us whether or not we process your personal data and for what purposes we do this. For more information, please consult article 15 GDPR.
Right of rectification: You also have a right to obtain the rectification of inaccurate personal data. For more information, please consult article 16 GDPR.
Right to erasure (‘right to be forgotten’): In some cases, you can request us to erase your personal data e.g. when personal data is no longer required for the purposes for which we have collected it, when the personal data is processed based upon your consent and you withdraw your consent, etc. In some exceptional cases, BALTA is not obliged to grant your request to erase your personal data. For more information, please consult article 17 GDPR.
Right to restriction of processing: You may request a restriction of your personal data e.g. if you dispute the accuracy of your personal data, if the processing activity is unlawful, etc. A restriction of the processing means that we may only store your data temporarily, except in case you nevertheless consent to the processing of your data, in the context of legal proceedings or in the public interest. A restriction can be terminated afterwards. For more information, please consult article 18 GDPR.
Right to data portability: If we process your personal data based upon your consent or based upon the performance of a contract, you can ask us to transfer your data to yourself or to another controller (if this is technically possible). In exceptional cases, BALTA is not obliged to follow up on your request. For more information, please consult article 20 GDPR.
Right to object: You can inform us of the particular reasons why you wish to object to the particular processing activity based upon BALTA’s legitimate interest. If these particular reasons outweigh our legitimate interests, we will terminate the processing activity. BALTA cannot follow up on your request when we process your personal data for the purposes of a legal claim. If we process your personal data for direct marketing purposes, you can always request us to stop processing your personal data without you having to provide a special reason. For more information, please consult article 21 GDPR.
Right not to be subject to automated individual decision-making: BALTA will not process your personal data for profiling purposes unless you have given us your explicit consent (see articles 4 and 5 of this Policy). For this reason, you have the liberty to choose whether or not you wish to receive personalized information and advertisements. In these cases, BALTA will ensure that you have the right to obtain human intervention or to express your point of view. For more information, please consult article 22 GDPR.
Right to withdraw earlier given consent: If the processing of your data is based on your consent, you also have the right to withdraw your consent at any time, without this affecting the legitimacy of the processing done prior to the withdrawal of your consent.
Right to lodge a complaint: In accordance with article 77 GDPR, you have the right to lodge a complaint with the supervisory authority of your habitual residence, your place of work or the place of an alleged infringement of the GDPR. The Belgian Data Protection Authority is the supervisory authority for Belgium and can be contacted at email@example.com.
Do not hesitate to contact us if you want to exercise one of these rights or if you have any questions or complaints in this regard. When doing so, understand that BALTA may ask you for your proof of identity.
11 WHAT ABOUT LINKS TO OTHER WEBSITES?
The BALTA websites can contain links or references to other websites or social media, which are offered by other companies. BALTA is not responsible for the processing of your personal data via these websites or social media, nor does this Policy apply to these websites or social media. BALTA advises you to check the privacy policies of these websites or social media.
12 HOW ARE YOU INFORMED OF CHANGES TO THIS POLICY?
This Policy was last modified on the date indicated above.
We strive to provide you with the best service. Therefore, BALTA reserves the right to modify, change or amend this Policy at its own discretion and from time to time. Such modification, change or amendment shall be communicated via our websites.
13 QUESTIONS REGARDING THIS POLICY
Questions or complaints regarding this Policy, our websites and/or the other processing of your personal data, can be directed to us:
By e-mail at firstname.lastname@example.org
By mail to:
ITC Group NV