We understand that your trust in us, is SHUTTR's most important asset (SHUTTR is commercially operating under the brand “Voncleef” and is hereinafter referred to as "SHUTTR", "we" or "us"). As such, your privacy is essential for us.
This privacy statement (hereinafter referred to as "Privacy Statement") is applicable, inter alia, to (i) our website https://voncleef.com/ (hereinafter referred to as the "Website") and (ii) all (commercial) relations between SHUTTR and its customers, prospects and business partners.
This Privacy Statement includes information about the personal data collected by SHUTTR, as well as the manner in which SHUTTR uses and processes this personal data.
SHUTTR wishes to emphasize that it always attempts to act in accordance with (i) the Belgian Privacy Law of 30 July 2018 regarding the protection of natural persons in relation to the processing of personal data and/or (ii) the EU Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC.
Visiting the Website, creating an account, subscribing to the newsletter and/or the purchase of products of SHUTTR implies your explicit approval (through disclosure of your personal information or opt-in) of the Privacy Statement and consequently how we collect, use and process your personal data.
- Types of personal data
SHUTTR can collect and process the following personal data:
- E-mail address
- Telephone number (landline and/or mobile phone)
- Account name
- All personal data provided in the field ‘Special instructions for seller’ when completing a purchase and/or provided via the chat box
- Methods of personal data collection:
These personal data are collected in the context of:
- Visiting the Website
- Creating an account
- Subscription to the newsletter
- Incoming and outgoing correspondence with SHUTTR, including use of the chat box
- Online purchase of goods
All personal data, collected by SHUTTR, are thus expressly and voluntarily provided by you.
Providing certain personal data is (sometimes) a requirement to be able to enjoy certain services (e.g. to gain access to certain parts of the Website, to subscribe to newsletters, to participate in certain activities and events, delivery of your online order). In this respect, it shall be indicated which data must be provided mandatory and which data is optional.
- Use of personal data
SHUTTR can use your personal data for the following purposes:
- Performance of the agreement with SHUTTR (incl. delivery of your online order and follow-up thereof)
- Providing support/assistance (e.g. in case of problems)
- Issuing invoices and the collection thereof
- Responding to questions (whether or not received through the chat box)
- Creation of an account and the confirmation thereof
- Optimising the quality, management and content of the Website
- Sending newsletters
- Creating statistics
Processing takes place on the following legal grounds, as the case may be:
- You have given consent to the processing of your personal data for one or more specific purposes
- Processing is necessary for the performance of the agreement with SHUTTR or in order to take steps at your request prior to entering into an agreement
- Processing is necessary for compliance with a legal obligation to which SHUTTR is subject
- Processing is necessary in order to protect your vital interests or those of another natural person
- Processing is necessary for the performance of a task carried out in the public interest
- Processing is necessary for the purposes of the legitimate interests pursued by SHUTTR or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data (in particular when you are a child).
- Disclosure of personal data to third parties
SHUTTR shall not disclose your personal data to third parties, unless it is necessary in the context of performing the agreement and optimisation thereof (including but not limited to payment processing, transport of deliveries and database management). In this respect, your personal data may be disclosed to payment providers, software providers, cloud partners, transport partners.
If it is necessary that SHUTTR discloses your personal data to third parties, the third party concerned is required to use your personal data in accordance with the provisions of this Privacy Statement.
Notwithstanding the foregoing, it is however possible that SHUTTR discloses your personal data:
- To the competent authorities (i) if SHUTTR is obliged to do so under the law or under legal or future legal proceedings and (ii) to safeguard and defend our rights
- If SHUTTR, or the majority of its assets, are taken over by a third party, in which case your personal data – which SHUTTR has collected – shall be one of the transferred assets.
In all other cases, SHUTTR will not sell, hire out or pass on your personal data to third parties, except when it (i) has obtained your permission to this end and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your personal data.
- Cross-border processing of personal data
Any transfer of personal data outside the European Economic Area (EEA) to a recipient whose domicile or registered office is in a country which does not fall under the adequacy decision enacted by the European Commission, shall be governed by the provisions of a data transfer agreement, which shall contain (i) the standard contractual clauses, as referred to in the 'European Commission decision of 5 February 2010 (Decision 2010/87/EC)', or (ii) any other mechanism pursuant to privacy legislation, or any other regulations pertaining to the processing of personal data.
- Storage of personal data
Unless a longer storage period is required or justified (i) by law or (ii) through compliance with another legal obligation, SHUTTR shall only store your personal data for the period necessary to achieve and fulfil the purpose in question, as specified in the Privacy Statement under 'Use of personal data'.
- Your privacy rights
In light of the processing of your personal data, you enjoy the following privacy rights:
- Right of access to your personal data
- Right to rectification, completion or update of your personal data
- Right to delete your personal data ('right to be forgotten'). (SHUTTR wishes to point out that in this context certain services will no longer be accessible and/or can no longer be provided if you delete resp. request deletion of certain required personal data)
- Right to limit the processing of your personal data
- Right to transferability of your personal data
- Right to object to/oppose the processing of your personal data
If you wish to invoke your privacy rights please contact legal[at]voncleef.com or complete the form for exercising your privacy rights and deliver it to SHUTTR by email or post.
In principle, you can exercise these rights free of charge via the above-mentioned form. In addition, you can always, via your personal account, update, modify and/or verify your personal data, which you were required to submit when creating your account.
If you no longer wish to receive newsletters or information about the products of SHUTTR, you can unsubscribe at any time by clicking the "unsubscribe" button underneath each of SHUTTR’s emails.
- Security of personal data
SHUTTR undertakes to take reasonable, physical, technological and organisational precautions in order to avoid (i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data.
SHUTTR shall store all personal data, which it has collected in […].
Notwithstanding SHUTTR’s security policy, the checks it carries out and the actions it proposes in this context, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the internet, or any method of electronic storage is 100% secure, SHUTTR is, in this context, not in a position to guarantee absolute security.
Finally, the security of your account will also partly depend on the confidentiality and complexity of your password. SHUTTR will never ask for your password, meaning that you will never be required to communicate it personally. If you have nonetheless communicated your password to a third party – for example because this third party has indicated that it wishes to offer additional services - this third party shall have access to your account and your personal data via your password. In such cases, you are liable for the transactions which occur as a result of the use made of your account. SHUTTR therefore strongly advises you, if you observe that someone has accessed your account, to immediately change your password and contact us.
- Update Privacy Statement
SHUTTR is entitled to update this Privacy Statement by posting a new version on the Website. As such, it is strongly recommended to regularly consult the Website and the page displaying the Privacy Statement, to make sure that you are aware of any changes.
- Other websites
The Website may potentially contain hyperlinks to other websites. When you click on one of these links, you may be redirected to another website or internet source that could collect information about you through cookies or other technologies. SHUTTR does not bear any responsibility, liability or control authority over these other websites or internet resources, nor about their collection, use and disclosure of your personal data. You must check the privacy statements of these other websites and internet sources in order to be able to judge whether they act in accordance with the Privacy Legislation.
- Contact SHUTTR
If you have questions and/or remarks about this Privacy Statement or the manner in which SHUTTR collects, uses and/or processes your personal data, please contact us:
- Via e-mail: legal[at]voncleef.com
- Via post: SHUTTR, for the attention of Mike Van Cleven, Prins Albertlaan 39C, 9100 Sint-Niklaas (Belgium)
In case you are not satisfied with the way SHUTTR handled your questions and/or remarks or have any complaints about the way SHUTTR collects, uses and and/or processes your personal data, note that you have the right to lodge a complaint with the Data Protection Authority.