Privacy statement

1. Who we are

The website https://smart-drop.be/ (hereinafter referred to as the "Website") is provided by:

Comeos (hereinafter referred to as "Comeos", "We" and "Us")

Address
Avenue Edmond Van Nieuwenhuyse 8
1160 Brussels
Belgium

VAT number
BE 0407.150.471

Do not hesitate to contact us with any privacy-related questions.

2. Why this privacy statement?

Each person who visits or uses our Website (hereinafter referred to as the "User") provides certain personal data. This happens when you submit a contact form, request further information and so on.

This personal data is information that allows us to identify you as a natural person, which we may or may not actually do. You become identifiable the moment it is possible to establish a direct or indirect link between one or more pieces of personal data and you as a natural person. Comeos takes the security of the personal data you submit via our Website very seriously. We describe how we handle your personal data below.

We use and process your personal data in accordance with the GDPR and other relevant legal provisions. Any reference in this Privacy Statement to the GDPR is a reference to the Regulation of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (General Data Protection Regulation). This Privacy Statement informs each User of how Comeos may process their personal data.

Comeos reserves the right to amend this Privacy Statement at any time. The User shall be notified of any substantial changes. We advise the User to consult this document regularly.

3. Links to other websites

The content of our Website may contain links, hyperlinks or framed links to third-party websites or other forms of electronic portals. A link does not automatically imply that there is a connection between us and the third-party websites or that we (implicitly) agree with the content of these websites.

We have no control over these third-party websites and are not responsible for the safe and correct operation of the link and its final destination. As soon as the User clicks on the link, they leave our Website and can no longer hold us liable for any damage.

Third-party websites may not offer the same guarantees as we do. If you follow a link on this Website that leads to a third-party website and you submit your personal data to such a website, the processing of the personal data is not subject to this Privacy Statement, but to any privacy policy of the third-party website's operator. We therefore recommend that you carefully read the General Terms and Conditions and the Privacy Statement of these third-party websites.

4. Who processes the personal data?

4.1. Data controller

Comeos is the data controller and it decides alone or in cooperation with others which personal data is collected and for what purpose and with what resources this personal data is processed.

Comeos has taken the necessary technical and organisational measures to effectively protect its Users' personal data against unauthorised access and use.

4.2. Data processor(s)

Comeos is free to use data processors. A data processor is a natural person or legal entity that processes personal data at the data controller's request of or on its behalf.

The data processor is legally obliged to ensure the security and confidentiality of the personal data.

The data processor shall always act according to the data controller's instructions. Comeos relies on the following categories of data processors:

  • Companies we have engaged for hosting purposes
  • Companies we have engaged for administrative purposes

In order to optimally protect the Users' personal data, Comeos has made the necessary contractual arrangements with the aforementioned data processors to ensure they apply the same standards as Comeos.

5. On what legal basis is your personal data processed?

In accordance with the GDPR, we process personal data on the following legal grounds to provide information to the User:

  • Based on our legitimate interest in sending information and newsletters to our customers
  • Based on the explicit consent to send information and newsletters to prospects and other interested parties
  • Based on the explicit consent to send promotional offers (direct marketing)

6. Which personal data is processed?

Comeos undertakes to collect and process only the personal data that is relevant and necessary for the purposes they are being processed for. The following categories of personal data are processed:

  • Personal identification data (surname, first name, address, login details)
  • Contact details (phone number and email address)
  • Electronic identification data (IP address, cookies, click behaviour)
  • Communication content (emails, forms, etc.)

This personal data may be collected when you are using our services or our Website (such as when filling out a contact form). The amount of personal data collected depends on your use of the Website and the Website's functionalities.

7. We also use cookies!

In addition, we use cookies to recognise Users and offer a personalised user experience, remember Users' technical choices (such as their language), monitor and analyse the Website's use and detect and correct any errors on the Website. You can refuse those cookies. If you do this, the website or parts of it may no longer function properly. Please refer to our Cookie Policy for more information on our use of cookies.

8. For which purposes are your personal data used?

Comeos collects your personal data to provide a secure, optimal and personal user experience to every User of our Website. The collection of personal data is expanded further as the User uses our Website more intensively. Comeos reserves the right to suspend or cancel certain operations if personal data is missing, incorrect or incomplete.

Data processing is essential for the operation of our Website and the associated services.

Data is processed exclusively for the following specific purposes:

  • Follow-up of requests for information
  • Customer management: customer administration, support, complaint monitoring and newsletter distribution
  • Dispute resolution
  • Protection against fraud and violations
  • Personalised marketing and advertising if you have expressly consented to this. In that case, you are free to withdraw your consent at any time
  • When you visit the Website, some personal data is also collected for statistical purposes. Comeos uses Google Analytics and Hotjar data to track and analyse internet traffic and the User's browsing behaviour. The results of these analyses allow us to optimise the use of our Website. When you visit the Website, you consent to the collection of this data for statistical purposes as described above

Users always provide the personal data to Comeos themselves and can therefore exercise a certain level of control. If certain personal data is incomplete or appear to be incorrect, Comeos reserves the right to postpone certain expected operations temporarily or permanently.

9. Who receives your personal data?

Your personal data is only processed for Comeos' internal use. Your personal data shall not be sold, transferred or communicated to any third parties unless you have given us express consent to do so in advance.

10. How long do we keep your personal data?

Your personal data shall be stored for as long as necessary to pursue the purposes set out in Article 5. It shall be deleted from the database when it is no longer necessary to pursue these purposes or when the User has validly exercised their right to have their personal data erased.

11. What are your rights?

11.1. Guaranteed lawful and secure processing of personal data

Your personal data shall always be processed for legitimate purposes as set out in Article 5.
It shall be collected and processed in an appropriate, relevant and proportionate manner and shall not be stored for longer than necessary to achieve the intended purposes.

11.2. Right of access

If you can prove your identity, you are entitled to access information about the processing of your personal data. This means you have the right to access the purposes of the data processing, the categories of personal data, the categories of recipients to whom the personal data is sent, the criteria that determine the data retention period and the rights that you can exercise with regard to your personal data.

11.3. Right to rectification of personal data

Inaccurate or incomplete information can be corrected. It is primarily the User's responsibility to make the necessary adjustments to their "User Profile". You can also contact us with a change request.

11.4. Right to erasure of your personal data

You also have the right to request the erasure of your personal data in the following cases:

  • Your personal data is no longer needed for the intended purpose
  • You withdraw your consent to the processing of your personal data and there is no other legal basis for processing your personal data
  • You have legitimately objected to the processing of your personal data
  • Your personal data is being processed unlawfully
  • Your personal data must be deleted based on a legal obligation

The erasure of personal data is mainly related to visibility; the erased personal data may continue to be stored temporarily.

11.5. Right to restrict processing

In some cases, you have the right to request that the processing of your personal data is restricted. This particularly applies to any disputes regarding the accuracy of your personal data, to cases in which the personal data is required in the context of legal proceedings and to periods in which Comeos needs to establish that you can validly exercise your right to erasure.

11.6. Right to object

You always have the right to object to the processing of your personal data for direct marketing purposes, profiling purposes or purposes arising from the data controller's legitimate interests. Comeos shall stop processing your personal data, unless Comeos can demonstrate compelling legal reasons for processing your personal data that take precedence over your right to object.

11.7. Right to data portability

You have the right to obtain the personal data provided to Comeos in a structured, commonly used and machine-readable format (such as in an Excel file). In addition, you are entitled to transfer said personal data to another data controller, unless this is technically impossible.

11.8. Right to withdraw consent

You have the right to withdraw your consent at any time (if you have given it for direct marketing purposes, for example).

12. How can you exercise your rights?

To exercise your rights, send a written request and proof of identity by registered letter to:

Comeos
Avenue Edmond Van Nieuwenhuyse 8
1160 Brussels
Belgium

Or by email to info@comeos.be.

We shall respond as soon as possible within one (1) month of receiving your request.

13. Possibility to lodge a complaint

If you do not agree to Comeos' processing of your personal data, you have the right to lodge a complaint with the Data Protection Authority (DPA):

Rue de la Presse/Drukpersstraat 35, 1000 Brussels
Tel. +32 (0)2 274 48 00
Fax +32 (0)2 274 48 35
Email: contact@apd-gba.be

This is without prejudice to any remedy before a civil court. If you were to suffer any damages as a result of the processing of your personal data, you can file a claim for compensation.