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Privacy Policy

1. What do we do with your personal data?

1.1. OCTOGOLD SA, a company with limited liability organised under Belgian law, with statutory seat located at 1170 Watermael Bosvoorde, Chaussee De La Hulpe 185 (Belgium) and registered with the Crossroads Bank for Enterprises under company number 0824.870.479 (“Octogony”, “we”, “our”, “us”) processes personal data related to its former and past customers or customers’ representatives, its prospects, its suppliers’ representatives, the visitors to its websites and other data subjects (the “data subject”, “you”, “your”)

1.2. This Privacy Policy (the “Policy”) applies to any processing by Octogony of your personal data.

2. Undertaking

2.1. We use our best efforts to bring our data processing activities into compliance with applicable data protection legislation, including Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”) and the Belgian Data Protection Act of 8 December 1992, each as applicable, and as amended, restated or replaced from time to time (the “Applicable Data Protection Law”).

3. Categories of personal data

3.1. We process the following categories of personal data, in particular for the purposes described hereafter:

  • Your personal identification data (surname, first name, title, birth date), email address, postal address, log-in details and password for processing your purchase orders, shipping our products to you and supporting our after sales efforts (including returns of purchased items). We will process your telephone number to confirm shipping details. If you order products in a B2B context, we will process your professional identification data (including VAT number) only for invoicing purposes;
  • Your professional identification data (job function, company address, etc.) for managing our suppliers’ relationships;
  • Data related to your professional life (work aptitudes, experience, information on your CV, etc.) for recruitment purposes;
  • Your bank account number, only processed when you pay through direct debit;
  • Your electronic identification data (IP address, dates and hour of access to the website, pages consulted, etc.), only processed, on an aggregated basis, for measuring our website audience and for generally improving your user experience on our website;
  • Your personal identification data and email address when you make a request for information through our website;
  • Video footage of you, only processed in the context of the surveillance of our premises through CCTV and only to the extent permitted by applicable law

3.2. We may also process the certain other categories of personal data where their processing is necessary for the establishment, exercise or defence of a legal claim.

3.3. We may also process your personal data:

  • To carry out corporate restructuring operations;
  • For the management of disputes with customers, suppliers and other data subjects.

3.4. The provision of your personal data may be necessary for:

  • The performance of a contract to which you are a party (e.g. the purchase contract between you and Octogony) or in order to take pre-contractual steps at your request (e.g. in the context of a request for information for the purchase of Octogony products);
  • Compliance with a legal obligation applicable to us (e.g. with regard to invoicing, surveillance of our premises, taxation, etc.);
  • The legitimate interests pursued by us (or by a data recipient) provided that these interests prevail over your fundamental rights and freedoms.

3.5. In some cases, we will ask for your free, prior and informed consent before processing some of your personal data (e.g. your email address for direct marketing purposes if you are not yet a customer, etc.).

3.6. We do not subject you to decisions based exclusively on automated processing that produce legal effects concerning you or affect you significantly.

3.7. The provision of some of your personal data (e.g. your name, address, email address, etc.) is a condition to the conclusion of the purchase contract for Octogony products.

3.8. The possible consequences of not providing your personal data could include our inability to meet our obligations under the purchase contract (e.g. the shipping of products) or a breach by us of one or more obligations under applicable laws (e.g. accounting or tax laws).

3.9. Please note that we may process personal data contained in the electronic communications you have with us or that you voluntarily provide in the context of a request for information.

4. Source of the data

We may collect your personal data as follows :

  • Directly from you, e.g. through the request for information process (online or in-store); or
  • From publicly accessible information (on the Internet).

5. Recipients of your personal data

5.1. We may disclose your personal data to the following recipients:

  • The customer support team;
  • The directors of and authorized personnel of Octogony for whom access to such personal data is necessary to perform their duties;
  • Octogony's individual departments and brands, as each department and brand is individually responsible for the proper functioning of Octogony;
  • Our legal counsels and/or lawyers in the context of corporate restructuring operations and litigation proceedings;
  • Third party service providers related to the operation and maintenance of the information systems processing your personal data (these providers only have access to the personal data necessary to carry out their missions);
  • Third party service providers for shipping our products to you, payment processing and marketing;
  • Government entities authorised to access and/or obtain your personal data in accordance with applicable law;
  • The courts and tribunals of the judicial order in the event of a dispute involving you;
  • Law enforcement authorities in the event of a finding or a suspicion of the occurrence of an offence involving you in accordance with or as required by applicable law.

    5.2. Subject to your approval and selection, your data will be shared with the following categories of companies:

    • Social Media sites;
    • Product fitters;
    • Retailers where you have placed an order;
    • Affiliated brands with which Octogony establishes a partnership;

    If you want more information about the third party with whom we share your personal data, you can contact our services on the details below. (art. 12)

    5.3. In the event of corporate restructuring operations (e.g. mergers or acquisitions), we may transfer your personal data to a third party involved in the transaction (for example, a buyer) in accordance with Applicable Data Protection Law.

    6. Third-parties

    6.1. We take appropriate measures to ensure that our third-party vendors process your personal data in accordance with Applicable Data Protection Law.

    6.2. We also ensure that our processors undertake to, among other things, process your personal data only on our instructions, not hire subprocessors without our consent, take appropriate technical and organisational measures to ensure an adequate level of security of your personal data, ensure that persons authorised to access your personal data are subject to obligations of confidentiality, return and/or destroy your personal data at the end of their services, comply with audits and assist us in following up on your requests regarding the exercise of your data protection rights.

    7. Transfers outside of the European Economic Area

    7.1. We transfer your personal data to countries located outside of the European Economic Area (“EEA”), such as the United States.

    7.2. In case your personal data is transferred to countries located outside of the EEA, we will ensure that appropriate safeguards are taken, such as :

    • The country to which the personal data are transferred has benefited from an adequacy decision by the European Commission under Article 45 of the GDPR; or
    • Standard data protection contractual clauses as approved by the European Commission pursuant to Article 47 of the GDPR have been established; or
    • In case of a transfer of personal data to the United States, the transfer complies with the conditions imposed by the EU-US Privacy Shield under Article 45 of the GDPR.

    7.3. For further information about transfers of personal data outside of the EEA, please consult the following link: https://edps.europa.eu/data-protection/data-protection/reference-library/international-transfers_en.

    7.4. If you would like to obtain more information about the appropriate safeguards taken by Octogony for the transfer of personal data outside of the EEA, please contact our Data Protection Correspondent by email at privacy@octogony.com.

    8. Retention

    8.1. We ensure that your personal data are kept for no longer than is necessary for the purposes for which they are processed.

    8.2. We use the following criteria to determine the retention periods of personal data according to the context and purposes of each processing operation:

    • The date of your last purchase of Octogony products;
    • The date of your last visit on the website of Octogony
    • The sensitivity of personal data;
    • Security reasons (for example, the security of our premises or of our information systems);
    • Any current or potential dispute involving you (for example, a litigation involving the warranty of a Octogony product);
    • Any legal or regulatory obligation to retain or delete personal data (for example, a retention obligation imposed by accounting or tax laws).

    9. Your rights

    9.1. Subject to Applicable Data Protection Law, you have the rights to access, rectify and erase your personal data, the rights to object to or limit the processing of your personal data, the right to data portability and the right to withdraw consent.

    Right

    What does it mean ?

    The right to be informed

     

    You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Policy.

    The right of access 

    You have the right to obtain access to your personal data.

    This is so you are aware and can check that we are using your personal data in accordance with Applicable Data Protection Law.

    The right to rectification 

    You are entitled to have your personal data rectified if they are inaccurate or incomplete. 

    The right to erasure (the “right to be forgotten”)

    You have the right to have your personal data erased. However, the right to erasure (or the “right to be forgotten”) is not absolute and is subject to special conditions. We may retain your personal data to the extent permitted by applicable law, and in particular when their processing remains necessary to comply with a legal obligation to which Octogony is subject or for the establishment, exercise or defence of a legal claim. 

    The right to restrict processing

    You have rights to restrict further use of your personal data (e.g. when Octogony does not need your personal data anymore but your personal data are still necessary for the establishment, exercise or defence of a legal claim).

    The right to data portability

    You have the right, under certain circumstances, to receive the personal data concerning you and that you have provided to Octogony in a structured and commonly used machine-readable format and to transmit them to another data controller.

    The right to object to processing

    You have the right to object to certain types of processing (e.g. when the processing is based on the legitimate interests of Octogony and, taking into account your particular situation, your interests or fundamental rights and freedoms prevail).

    The right to withdraw consent

    If you have given your consent to the processing by Octogony of your personal data, you have the right to withdraw your consent at any time. 

    Please forward any request regarding your rights as data subject to our Data Protection Correspondent by email at privacy@octogony.com. We will try to comply with your request as soon as reasonably practicable and always under the timeframes set forth by Applicable Data Protection Law. Please note that we may need to retain certain of your personal data for certain purposes as required or authorised by law. Please also note that, if we have doubts about your identity, we may require you to provide us a proof of your identity to prevent unauthorised access to your personal data.

    10. Right to object to marketing

    10.1. If you are a customer, we process your email address for direct marketing purposes.

    10.2. You have the right to object at any time to the processing of your personal data for direct marketing purposes by unsubscribing from our mailing list or by sending an email to our Data Protection Correspondent at privacy@octogony.com.

    11. Security

    11.1. We implement adequate technical and organisational measures to ensure a level of security of your personal data that is appropriate to the risks.

    11.2. We take appropriate measures to ensure that we report security incidents leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.

    12. Questions and complaints

    12.1. If you have any questions or complaints about the way we process your personal data, please send them to our Data Protection Correspondent by email at privacy@octogony.com or by post at OCTOGOLD SA, 1170 Watermael Bosvoorde, Chaussee De La Hulpe 185, Belgium.

    12.2. You have the right to lodge a complaint at the competent supervisory authority. The competent supervisory authority for Belgium can be contacted at:
    Data Protection Authority
    35 Rue de la Presse / Drukpersstraat, 1000 Brussels
    +32 (0)2 274 48 00
    contact(at)apd-gba.be

    13. Payment services

    13.1. The payment services integrated into our website are provided by PayPal (www.paypal.com) and Stripe (www.stripe.com)

    13.2. PayPal processes among others your credit card information. The processing of those personal data is governed by the Privacy Policy of PayPal available here: www.paypal.com/be/webapps/mpp/ua/privacy-full?locale.x=en_BE

    13.3. Stripe processes among others your credit card information. The processing of those personal data is governed by the Privacy Policy of Stripe available here: https://stripe.com/be/privacy

    13.4. We invite you to read the Privacy Policy of PayPal and the Privacy Policy of Stripe to understand how they process your personal data.

    14. COOKIES

    14.1. www.cliogoldbrenner.com makes use of cookies. A cookie is a file that is sent with pages of this website and/or flash applications and stored by your browser on the hard drive of your device. The information stored therein can be sent back to our servers on your next visit.

    The use of cookies is necessary for the functioning of our website. But cookies that you do not immediately see the effect of are also very important. Thanks to the anonymous input of visitors, we can improve our website and make it more user-friendly.

    14.2.    Consent for the use of cookies

    The use of certain cookies requires your consent. We do this through our cookie banner when you visit our website.

    14.3.    The types of cookies used and their purposes

    www.octogony.com uses the following types of cookies:

    Functional cookies: these allow the website to function better and are more user-friendly for the visitor. For example, we store your login details, wishlist and shopping basket.

    Analytical cookies: every time you visit a website a cookie is generated. These cookies remember whether you have visited the website before. A cookie is only created on the first visit. On subsequent visits, existing cookies are used. This cookie is used only for statistical purposes. Thus, the following data are collected:

    • Which pages you have viewed
    • How long you stayed on a certain page
    • Which page you left the site at

    Social media related cookies: these register which articles and pages you share via their social media sharing buttons, such as Facebook and LinkedIn. They can also contain tracking cookies that follow your web browsing behavior.

    14.5. You can at all times easily block and delete cookies yourself via your internet browser. You can also set your internet browser in such a way that you receive a message when a cookie is placed. You can also indicate that certain cookies should not be placed. For this option, see the help function of your browser. Deleting cookies in your browser can have consequences for the use of www.octogony.com

    If you do not want cookies, we cannot guarantee that our website will function properly. It may be that some functions of the site are lost or even that you can no longer visit the website at all. In addition, refusing cookies does not mean that you will no longer see any advertisements. The ads will simply no longer be in line with your interests and may therefore be repeated more often.

    How you can adjust your settings differs per browser. Consult the help function of your browser if necessary.

    14.6. The texts of our website can be adjusted at any time as a result of ongoing developments. This also applies to our cookie statement. Therefore, please read this statement regularly to keep abreast of the latest developments.

    It is also possible that through our websites, cookies are placed by others, of which we ourselves are not always aware. Do you encounter unforeseen cookies on our website that you cannot find in our overview? Please let us know via privacy@octogony.be. You can also contact the third party directly and ask them what cookies they place, the reason for that, the life span of the cookies and how they have guaranteed your privacy.

    15. Miscellaneous

    15.1. We reserve the right to modify this Policy at any time, so please review it frequently. We will inform you of changes we make to this Policy so that you are at any time aware of the way we process your personal data.

    15.2. We use cookies on our website www.cliogoldbrenner.com. For more information about how we use cookies, please read our Cookie Policy.

    15.3. In the event of a conflict or inconsistency between a provision of this Policy and a provision of another policy or another document of Clio Goldbrenner relating to the processing of personal data, the provision of this Policy shall prevail.

    15.4. This Policy is governed by Belgian law and any litigation arising out of, or in connection with, the formation, execution, interpretation and termination of this Policy will be submitted to the courts of Brussels.

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