Privacy Policy
1. Introduction
This privacy policy aims to inform you about how Made collects and processes personal data via its website www.made.be (the “Website").
You are typically a visitor of the Website.
Made respects your privacy and is committed to protecting your personal data in accordance with the applicable Belgian and European data protection legislation (including the General Data Protection Regulation (“GDPR”)).
Please read this privacy policy carefully. It describes not only your rights, but also the way in which you can exercise them. By using our Website, disclosing your personal data, or accepting this privacy policy, you acknowledge the manner in which Made collects and processes your personal data as described in this privacy policy.
2. Who we are and how to contact us?
“Made” refers to Made By Rombit BV, having its registered office at Meir 30, 2000 Antwerp, Belgium and with company number 0507.837.956.
This privacy policy only describes our data processing activities as controller. Under the GDPR, controllers are the main decision-makers: they exercise overall control over the purposes and means of the processing of personal data.
Made has appointed a data protection officer, whom you can contact for questions about this privacy policy, your privacy and the processing of your personal data by sending an email to dpo@rombit.be.
3. What personal data do we process?
Made processes different types of personal data; this depends on the functionalities you use on our Website and on the personal data you share with us.
If Made processes your personal data, it may process the data listed below:
Identification and contact details
Data that allows us to identify and contact you, such as:
name and first name;
email address;
phone number;
company name;
job title and function.
Technical information
Data required to use our Website, for the proper functioning of our Website and for analytical purposes:
technical information about your computer, mobile and other devices used to visit our Website (such as, your IP- address, unique device identifiers, operating system, browser type);
information regarding your usage of our Website (such as, history, logs, date, time, location, frequency, duration of the pages you have viewed, consent preferences);
information regarding consent(s) given by you (such as, the date and time of your consent, IP-address or unique device identifiers).
We use cookies and similar technologies to collect this technical information. For more information, we refer to our cookie policy.
4. For which purposes do we process your personal data, on which legal basis and for how long?
General
Made processes personal data for the purposes specified in this section 4 (if and to the extent applicable to your situation). This list may evolve and will be updated as necessary.
For certain processing purposes, Made requires your consent. The consent you give is always free and you have the right to withdraw it at any time. You can withdraw your consent by sending an email to: dpo@rombit.be. Your withdrawal of consent does not affect the processing of personal data prior to such withdrawal or our processing activities which are based on any other legal basis.
4.1. Management and booking of appointments and introductory sessions and (in general) responding to your requests (after you have filled out a contact form)
Purpose
To contact you to arrange and manage appointments or introductory sessions;
To send any related (background) information to our appointment and/or introductory session (such as commercial offers, additional information about services performed and/or to be performed);
To respond to any other of your inquiries and requests, as may be specified in a contact form, including providing answers or additional information.
Type of personal data
Identification and contact details;
Technical information;
Any accompanying message and/or information you share with us via the relevant contact form on our Website.
Legal basis
Performance of a contract.
Retention term
As long as necessary to contact you as part of the performance of the contract (including as long as necessary to answer your request or to manage any appointments).
For more details about the retention period, you can always send an email to: dpo@rombit.be.
4.2. Operation of our Website
Purpose
To use our Website;
To ensure the proper functioning of our Website;
To allow us to recognize the visitor that is using our Website;
To remember your preferences (such as consent preferences) so that we can automatically read and respect your preferences on all subsequent and future visitor sessions;
To allow us to keep evidence of particular consents you have provided to us.
Type of personal data
Technical information.
We use cookies and similar technologies to collect this technical information. For more information, we refer to our cookie policy.
Legal basis
Performance of a contract;
Legitimate interest.
Retention term
The retention period varies from as long as the duration of a session/Website visit, to as long as necessary for Made's legitimate interest or the performance of the agreement concluded between you and Made (as applicable).
Technical information will in any event be deleted or pseudonymized 12 months after the collection of the data.
For more details about the retention period, you can always send an email to: dpo@rombit.be.
For information on the retention period of personal data processed through cookies, we refer to our cookie policy.
4.3. Analytical purposes
Purpose
To improve our Website;
To tailor our Website to your use;
To monitor effectiveness and accessibility of our Website;
For other technical, statistical and diagnostical purposes.
Personal data collected from you for these purposes will only be used by us (to the greatest reasonable extent possible) in an aggregated and de-identified format.
Type of personal data
Technical information.
We use cookies and similar technologies to collect this technical information. For more information, we refer to our cookie policy.
Legal basis
Consent.
Retention term
The retention period varies from as long as the duration of a Website visit, to as long as your consent is not withdrawn (as applicable).
Technical information, will in any event be deleted or pseudonymized (i) upon your withdrawal of consent; and (ii) 12 months after the collection of the data.
For more details about the retention period, you can always send an email to: dpo@rombit.be.
For information on the retention period of personal data processed through cookies, we refer to our cookie policy.
4.4. Business administration
Purpose
To manage our client relations;
To execute our business administration;
To manage potential complaints about our products and/or services.
Type of personal data
Identification and contact details;
Any additional information you share with us in relation to any complaint.
Legal basis
Legitimate interest.
Retention term
Up to ten (10) years after the expiry or termination of our client relationship; or
As long as necessary for Made legitimate interest(s).
For more details about the retention period, you can always send an email to: dpo@rombit.be.
4.5. Adherence to our legal obligations
Purpose
To comply with our legal obligations;
To cooperate with any ongoing judicial investigation, court order or lawsuit;
To protect our and/or the rights of third parties;
To respond to requests from data subjects.
Type of personal data
Identification and contact details;
Any accompanying message and/or information you share with us related to a data subject request and/or judicial investigation or lawsuit;
Other types of personal data, depending on the legal obligation concerned.
Legal basis
Legal obligation.
Retention term
Up to ten (10) years after the expiry or termination of our client relationship; or
As long as required by law.
For more details about the retention period, you can always send an email to: dpo@rombit.be.
4.6. Direct marketing
Purpose
To send you promotional e-mails and newsletters about our products and services, including about new features, functionalities, special offers and other information which we think might interest them.
Type of personal data
Identification and contact details;
Technical information.
Legal basis
Consent.
You shall have the right at any time to object to the processing of your personal data for direct marketing purposes, including profiling, to the extent that it is related to such direct marketing, free of charge, by sending an e-mail to: dpo@rombit.be.
We use cookies and similar technologies to collect this technical information. For more information, we refer to our cookie policy.
Retention term
The retention period varies from as long as the duration of a Website visit, to as long as your consent is not withdrawn (as applicable).
Personal data obtained for direct marketing purposes will in any event be deleted as soon as you withdraw your consent.
For more details about the retention period, you can always send an email to: dpo@rombit.be.
For information on the retention period of personal data processed through cookies, we refer to our cookie policy.
5. Personal data of third parties
If you disclose any personal data of third parties to us, you guarantee that you have informed those third parties and you have received all necessary consents to communicate the third parties’ personal data to Made.
6. Cookies
Our Website uses cookies and similar technologies. For more information, we refer to our cookie policy.
7. Disclosures of Personal Data
Made may share your personal data, as required for the purposes set forth in section 4, with:
third party service providers (such as IT service providers, security providers, or hosting providers);
professional advisers (such as lawyers or auditors); and
third parties to whom we intend or choose to sell, transfer or merge (parts of) our shares, business or assets.
Upon request, Made shall, as soon as possible after the request, inform you of the third parties with whom your personal data have been shared by providing you a more detailed list.
In addition, we may disclose your personal data if this is required by law, or if we determine in good faith that such disclosure is required in order to comply with any pending judicial inquiry, judicial order or litigation and/or to safeguard our rights.
Processors and sub-processors of Made always act under the responsibility of Made. If Made engages processors or sub-processors, this will always be done in accordance with a data processing agreement that meets the requirements of the GDPR. We require all our processors or sub-processors to take appropriate technical and organizational (including security) measures to protect your personal data in line with our policies. We do not allow our processors or sub-processors to use your personal data for their own purposes. In the event we disclose your personal data as described above, we will implement appropriate safeguards to ensure the integrity and confidentiality of your personal data.
Your personal data will only be viewed and made available to processors, sub-processors, employees and other third parties on a “need-to-know” basis, limited to the extent necessary to perform their services.
8. International transfers
In principle, Made does not transfer your personal data to third countries located outside the European Economic Area ("EEA") unless you are located outside the EEA and are visiting our Website from outside the EEA. It is possible that Made -through its (sub-)processors- does transfer your personal data to countries outside the EEA. In this event, Made will only transfer your personal data outside the EEA in accordance with the applicable data protection legislation and subject to appropriate safeguards.
Please contact us if you want further information on the specific mechanism(s) used by us when transferring personal data out of the EEA.
9. Data security
Made is committed to trying to make sure that your personal data is secure and makes all reasonable and appropriate efforts to protect the confidentiality of your personal data. We have implemented appropriate technical and organizational measures, safeguards and assurances to process your personal data in accordance with the GDPR, in particular to protect your personal data against loss, misuse, or unauthorized alteration or destruction.
Made maintains a team of technicians, automated systems, and advanced technologies, following the industry best practices and makes all necessary efforts to protect the confidentiality of your personal data.
Please contact us if you would like more information on the specific measures taken.
Despite the above measures taken by us, you should be aware that there are always risks associated with sending personal data over the internet. The security and protection of your personal data can never be fully guaranteed, nor can we guarantee that unauthorized third parties will never be able to defeat those measures or use your personal data for improper purposes.
10. Data retention
Made will only retain your personal data for as long as reasonably necessary to fulfil the purposes determined in section 4 of this privacy policy, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Made may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or the organization you work for. Afterwards it is still possible that they can be found in our back-ups or archives, but they will no longer be actively processed in a file.
The applicable retention periods are set out in the table above under section 4.
11. Your legal rights
If and in as far as provided for in the applicable data protection legislation, you have the right:
to receive confirmation as to whether we process your personal data and, where this is the case, to access such personal data,
to have any inaccurate or incomplete personal data corrected without undue delay,
to have your personal data deleted by us under certain circumstances, namely when one of the following applies:
if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
if you withdraw your consent on which the processing is based, and where there is no other legal ground for the processing;
if you object to the processing in case the processing is for direct marketing purposes;
if the personal data have been unlawfully processed; or
if the personal data have to be erased for compliance with a legal obligation in EU or national law;
to obtain your personal data and to transfer them to another controller or processor,
to obtain a limitation of the processing of your personal data, to the extent possible and subject to the applicable data protection legislation, at any time, when one of the following applies:
if you contest the accuracy of the personal data, for a period enabling Made to verify the accuracy of the personal data;
if the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; or
if Made no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;
to receive your personal data in a structured, common and machine-readable format,
to prevent the processing of your personal data and the use of your personal data for direct marketing purposes; and
where the processing of your personal data is based on points (e) and (f) of article 6(1) of the GPDPR, to object to the processing of personal data.
You can exercise these rights by sending an e-mail to: dpo@rombit.be.
In the event you request a copy of your personal data being processed by Made, your data will be delivered as soon as reasonably possible. Made may either (i) charge a reasonable fee, taking into account the administrative costs of providing such a copy, or (ii) refuse to act on such a request, when the request for a copy is manifestly unfounded or excessive. Made will inform you of the applicable fee before charging it.
Made reserves the right to request a copy of the front side of your identity card if Made is unable to identify you or if Made has reason to doubt your identity. You may, however, blackline any information which is not necessary for identification or verification purposes.
If and to the extent provided for in the applicable data protection legislation, you have the right to file a complaint with the competent supervisory authority should the processing of your personal data violate the applicable regulations. In Belgium the competent authority is the Data Protection Authority (“Gegevensbeschermingsautoriteit”):
www.gegevensbeschermingsautoriteit.be
Drukpersstraat 35, 1000 Brussels, Belgium
+32 (0)2 274 48 00
We would, however, appreciate the chance to deal with your concerns before you approach the authority, so please contact us in first instance
12. Third party links
Our Website may contain links to third party websites and/or applications. Made is not responsible for the content of these websites and applications and is not responsible for the privacy standards and practices of such third parties. We recommend you to read the relevant privacy policies of these third parties and their websites before you accept their cookies and visit their website to ensure yourself that your personal data is sufficiently protected. Nonetheless, we seek to protect the integrity of our Website and welcome any feedback about these websites and/or applications.
13. Liability
If Made has legitimately transmitted your personal data to a third party (not being its (sub-)processor), Made shall not be liable for any unlawful processing or unlawful use by that third party.
Under no circumstances does Made accept responsibility for any direct or indirect damages resulting from faulty or unlawful use of the personal data by a third party (not being its (sub-)processor).
Additionally, Made is not liable if third parties unlawfully process or use your personal data and Made has implemented appropriate technical and organizational measures to prevent such unlawful processing or use.
Made is in any case only liable for the damage caused by the processing of personal data if it did not comply with its specific obligations under the GDPR. Made shall in no event be liable for any special, incidental, indirect or consequential losses or damages.
The foregoing exclusions and limitations shall only apply to the maximum extent permitted by applicable law.
14. Changes to this privacy policy
Made may amend this privacy policy at all times. Any changes we may make to our privacy policy will be indicated on the Website and when proportionate and in line with the significance of the changes, may be notified to you by e-mail or advised to you on your next Website visit. The date of the most recent version is shown in the top right-hand corner of the privacy policy. Please review Made privacy policy periodically to stay informed of changes that may affect you.
Amended versions of this privacy policy take effect ten (10) days after their publication on the Website and/or other form of announcement and, if necessary, will always be submitted for approval, unless such modifications are necessary to comply with a legal requirement. In the latter case, such changes will take effect immediately.
15. Applicable law and competence
This privacy policy shall be governed, interpreted, and implemented in accordance with Belgian laws.
The Antwerp courts (department Antwerp) are exclusively competent to decide on any dispute that may arise from the interpretation or implementation of this privacy policy, without prejudice to the consumer’s right to present a dispute before a competent court on the basis of a mandatory statutory provision.