1. What is the scope of this Privacy Policy?
European Truck Trailer Parts BV, a company incorporated and existing under the laws of Belgium, having its registered office at Belgium, 8800 Roeselaere, Liebeekstraat 13, with company registration number 0472.930.329 (hereinafter “ETTP”) values the protection of privacy.
This Privacy Policy informs about ETTP’s Processing activities regarding Personal Data ETTP collects, about the rights of the data subjects and the measures taken by ETTP to protect privacy. In this Privacy Policy the terms “You” or “Yours” will be meant to designate such data subjects.
This policy covers the collection and Processing of Personal Data whenever You contact ETTP or are contacted by ETTP, among others though the Website or social media or in the process of ETTP’s business activities.
You are requested to read this Privacy Policy carefully, with the understanding that it may be amended from time to time, among others in light of feedback received by ETTP or changes in its operations and/or legal or regulatory provisions. In addition, when You visit the Social media pages, You should consult the privacy policies of the specific social media providers.
Whenever You provide Personal Data that relate to another individual than, please provide the concerned individual with (a copy of) this Privacy Policy before providing ETTP with the said data.
2. What do the terms used in this Privacy Policy mean?
Certain terms are capitalized in this Privacy Policy. They are defined below or elsewhere in this Privacy Policy for ease of understanding:
a) GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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).
b) Breach: a breach of security resulting in accidental or unlawful destruction, loss, alteration or unauthorized disclosure of or access to Processed Personal Data.
c) Personal Data: any information that allows You to be identified, within the meaning of the GDPR.
d) Processing: any operation or set of operations involving Personal Data or a set of Personal Data, whether or not carried out by automated means, such as collection, recording, organization, structuring, storage, updating, copying or altering, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, assembly or combination, restriction, erasure or destruction.
e) Website: website of ETTP (ettp.be).
f) Social media pages: the social media pages of ETTP, such as the pages on Facebook, LinkedIn and Twitter.
3. What Personal Data does ETTP collect and how does it collect it?
ETTP collects contact data (name, title, address (private, work), previous addresses, telephone number (private, work), email address, A, IP addresses.) about (i) persons ETTP engages with in the process of cooperation with third parties (such as data of third party personnel, appointees and other contacts) and (ii) potential customers, prospects and other contacts useful for ETTP business activities and its network. This data is collected through cooperations with third parties, the Website, Social media pages as well as through correspondence.
In addition, through the Website, ETTP collects cookies. Cookie collection and use are governed by ETTP Cookie Policy (https://www.ettp.be/en/cookie-statement).
ETTP does not Process sensitive data, nor Personal Data of minors. ETTP therefore urges You not to transmit such data to ETTP.
4. What is the purpose and legal basis for the Processing?
We Process Personal Data for entering into and performing agreements, customer and supplier management, accounting activities and marketing activities such as sending promotional or commercial information.
Depending on the nature of Processing, the grounds for Processing are the performance of the contract, the fulfilment of legal and regulatory obligations and/or ETTP’s legitimate interest.
All Personal Data shall be Processed only for the purpose for which it was collected and to the extent necessary to achieve that purpose. This limitation applies to the amount of Personal Data as well as to the scope of Processing, retention period and accessibility. As such, if You contact ETTP, ETTP will use Your Personal Data for the purpose of responding to Your questions or comments, if You register for an event, ETTP will use Your Personal Data to register You for the event and to keep You informed about any changes or updates regarding the event, if You contact ETTP in the course of business activities, ETTP will use Your Personal Data for such business activities etc.
If Personal Data needs to be Processed for a purpose other than the purpose for which they were initially collected, ETTP will ensure that the Processing does not take place in a way that is incompatible with the purpose for which Personal Data were provided. If the desired finality is incompatible with the original finality for which Personal Data have been provided, ETTP will seek Your consent for the Processing in light of this new purpose, provided the consent is freely given.
For marketing activities that are individualized (such as personalized emails, newsletters or invitations to events), You will be asked for Your consent, which You may withdraw at any time, and this by means of a simple request to ETTP as referred to in Article 9 of this Privacy Policy, or through the means provided in the communication in question.
5. How long does ETTP Process Personal Data?
ETTP Processes Personal Data only as long as necessary for the purposes of the Processing for which it was collected, according to the type of relationship ETTP has with You.
Personal Data that are not necessary for the execution of a contract, for the fulfilment of mandatory legal provisions resting on ETTP or for the defense of its legitimate interest, in particular the data for the purpose of marketing activities, will be deleted or anonymized within a period of 1 year after the end of the relationship in the framework of which they were collected. The Personal Data necessary for the performance of a contract will be Processed for the term of the contract and thereafter for the period necessary to exercise ETTP’s rights under the contract.
6. To whom does ETTP transfer Personal Data?
ETTP may transfer the Personal Data to its staff members and affiliated companies, as well as to other persons, such as suppliers and cooperating partners, who will Process such data on behalf of ETTP. This transfer will only occur as far as these persons provide sufficient guarantees regarding appropriate technical and organizational measures so that the Processing meets the requirements of the GDPR and the protection of Your rights or as far as the transfer is necessary within the applicable legal or regulatory framework, taking into account the purposes of the Processing. Please note that ETTP may be obliged to transfer Personal Data to governmental authorities.
To the extent required by the GDPR, ETTP will enter into an agreement with the (sub)Processors in which the purpose of the Processing is defined and the Processor commits, among other things, to respect the confidentiality of the Personal Data, to limit the Processing to what is in accordance with the instructions of ETTP or to what is permitted by law and to cooperate in the exercise of the rights granted to You by the GDPR.
We will transfer Personal Data outside the European Economic Area or EEA only to countries that comply with the GDPR and where the means of transfer ensure adequate protection of Your Personal Data.
7. What technical and organizational measures does ETTP take?
To ensure that Personal Data receives an adequate level of protection, ETTP established appropriate internal procedures and entered into agreements with third parties. ETTP takes the necessary technical and organizational measures to Process Your Personal Data according to an adequate security level and to protect it against destruction, loss, falsification, modification, unauthorized access or notification by mistake to third parties, as well as any other unauthorized Processing. The specific measures taken by ETTP in this regard are described in the information security policy.
In the event of a Breach and violation of the availability, integrity or confidentiality of Personal Data, ETTP will notify the Breach to the competent data protection authority within 72 hours of becoming aware of it, unless the Breach is unlikely to pose any risk to Your rights and freedoms. ETTP will notify the Personal Data Breach to You if it is likely that the Breach poses any risk to Your rights and freedoms.
8. How does ETTP record Processing Activities?
To the extent required by law, ETTP keeps a register of the Processing activities carried out by it or under its responsibility, containing the information required by the GDPR, such as the name and contact details of the Data Protection Officer, the Processing purposes, the description of the categories of data subjects, of Personal Data and of recipients, the retention period, etc.
9. What are Your rights as a data subject?
In connection with Your Personal Data, You have the following rights as guaranteed by the GDPR.
- Right of inspection: You have the right to be informed acquaint Yourself, free of charge, with the Personal Data ETTP Processes and to be notified of the purposes for which ETTP Processes it.
- Right of correction: You have the right to obtain the correction of Personal Data, as well as to complete incomplete Personal Data.
- Right to erasure or restriction of the Personal Data: You have the right to request ETTP to erase the Personal Data or restrict its Processing as stipulated by the GDPR, except when ETTP may refuse to do so for the fulfilment of a legal obligation, the performance of the contract or ETTP’s legitimate interest, as regards the Personal Data collected for these purposes.
- Right to data portability: You have the right to obtain the Personal Data You have provided to ETTP in a structured, common and machine-readable form or to have it transferred to another controller.
- Right to object: You have the right to object to the Processing of Your Personal Data for serious and legitimate motives, except where ETTP may refuse to do so for the performance of a legal obligation, the performance of the contract or ETTP’s legitimate interest, as regards the Personal Data collected for these purposes.
- Right to withdraw consent: if the Processing of Personal Data is based on Your prior consent, You have the right to withdraw this consent.
To exercise the aforementioned rights, please contact ETTP by email at the following e-mail address jv@ettp.be. ETTP reserves the right to contact You and request additional information in order to verify Your identity. You will receive confirmation of Your request within thirty (30) days free of charge, it being understood that this period can be extended by an additional thirty (30) days, provided that the request in question is complex.
We make every effort to handle Your Personal Data in a careful and lawful manner in accordance with applicable regulations. If, nevertheless, You consider that Your rights would have been violated and ETTP does not deal with Your concerns in an appropriate manner, You are free to lodge a complaint with: Data Protection Authority, Drukpersstraat 35, 1000 Brussels (Tel. 02 274 48 00 - Fax. 02 274 48 35 - E-mail: contact@apd-gba.be)
10. Which law applies and which court has jurisdiction?
This Privacy Policy shall be governed by and construed in accordance with Belgian law. All disputes relating to this Privacy Policy, including its interpretation, shall fall under the exclusive jurisdiction of the courts of the district of Brussels, without prejudice to mandatory legal provisions to the contrary. Before taking any legal action, You agree to take all measures to settle the dispute amicably.