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Privacy Policy

General

This privacy policy ("Privacy Policy") governs the processing of your personal data as part of your use of our Website (the "Website") and related services (collectively referred to as the "Services"). This processing is carried out by Jackie Treehorn BV as the data controller, with its registered office at Pyckestraat 48A, 2018 Antwerp ("we", "us"), registered with the KBO under number 0637.818.352, in accordance with applicable legislation on the protection of personal data.

By using our Website and/or our Services, you acknowledge that you have carefully read this Privacy Policy and that you agree to it without reservation. We reserve the right to modify the Privacy Policy from time to time in our sole discretion. Any such changes will be communicated through the Website.

By clicking on the checkbox stating: "I have read and understood the Privacy Policy in full and agree to it without reservation. I consent to the processing of my personal data as set out in this Privacy Policy", you declare that you have indeed read and consented to this Privacy Policy. You declare that you understand the purposes for which your personal data will be processed. You also agree that your continued use shall be construed as continued consent. You may withdraw your consent at any time by emailing support@rubey.be.

Please note that we may use so-called "cookies" or similar technology as part of the Website and/or the Services. Cookies are small text files placed on a device's hard disk, which contain certain information, sometimes including personal data. For more information regarding our use of cookies, please read our cookie policy.

This Privacy Policy was last updated on 25 April 2022.

What & why we process data

When you use the Website and/or Services, we process personal data relating to you. Such personal data include:

When? Filling in the contact form
Which?
Name, e-mail address, telephone number, company and message
Why (purpose)?
Processing the question
Duration:
/
Legal basis?
Permission

When? Register for the newsletter
Which?
E-mail address
Why (purpose)?
Sending out the newsletter
Duration:
five years
Legal basis?
Permission

In principle, we obtain the personal data mentioned above directly from you. However, if you choose to register through a social media account (e.g. Facebook or Google Plus), these data are collected through your social media profile. We encourage you to consult the privacy policy of your social media service provider to determine what data is processed by your social media service provider when you use the social media login feature. We do not forward any of the personal data you provide through the Website to social media providers unless you consent. In addition to the above purposes, we may also process your personal data:

1. To provide you with the information on products and services you request in a personalised and efficient manner, whether through the Website, email, telephone or social media channels.
2. To process your personal data so that we can provide the Services.
3. For direct marketing purposes, i.e. to provide you with targeted communications, promotions, offers and other advertisements from us or our selected partners. For this, we will ask your prior consent.
4. To perform statistical analysis to improve our Website and/or Services, or to develop new products or services.
5. To provide to a financial institution or payment service provider, to enable your financial institution and the payment service provider to fulfil their legal obligations.
6. To transfer to the police or judicial authorities as evidence of possible crimes or if there is reasonable suspicion of an unlawful act or crime committed by you through your registration with or use of the Website or the Services.
7. In the context of a possible merger with, acquisition of/by or demerger by a third party, even if that third party is located outside the EEA.

      If and when your registration on the Website or use of the Website or Services may be considered (a) a violation of the terms or conditions or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Services, (c) a threat to the Website or Services or our or our subcontractors' systems from viruses, Trojan horses, spyware, malware, or any other form of malicious code, or (d) in any way illegal or unlawful, discriminatory or offensive, we may process your data in the interests of ourselves, our partners or third parties.

      With whom we share data

      We will not transmit your personal data in an identifiable manner to third parties if this is not required to provide the Services, without your express consent.

      We may use third party processors to provide you with the Website and/or Services. We ensure that third party processors may only process your personal data on our behalf, and upon written instructions from us. We guarantee that all third party processors are selected with due care to ensure the security and integrity of your personal data.

      We may transfer anonymised and/or aggregated data to other organisations that can use this data to improve products and services and to organise the marketing, presentation and sale of products and services in a tailored way.


      Where we process data

      We and our third party processors will only process your identifiable personal data in the EEA.


      We may transfer your anonymised and/or aggregated data to organisations outside the EEA. If such a transfer occurs, we will ensure that appropriate safeguards are in place to guarantee the security and integrity of your personal data, and that all rights in relation to personal data that you may enjoy under applicable mandatory law are guaranteed.

      If a transfer of your personal data and/or anonymised and/or aggregated data takes place, the following legal protection mechanism will be implemented:


      What service? Country outside the EEA Legal transmission mechanism
      Mailchimp Verenigde Staten Model clausules

      How we process data

      We will use our best efforts to process only those personal data that are necessary to achieve the purposes set out in this Privacy Policy. We will process your personal data in a lawful, fair and transparent manner. We will do our utmost to keep the personal data accurate and up to date.

      Your personal data will only be processed as long as necessary to fulfil the purposes set out in this Privacy Policy or until you withdraw your consent to its processing. Please note that withdrawal of consent may imply that you are no longer able to use all or part of the Website and/or Services. If you have registered with our Website, we will delete your personal data when you remove your profile, unless a legal or regulatory obligation or a court or administrative order would prevent us from doing so.

      We will take appropriate technical and organisational measures to keep your personal data secure against unauthorised access or theft and against accidental loss, manipulation or destruction. Access by our staff or staff of our external processors is only possible on a need-to-know basis and is subject to strict confidentiality obligations. You understand, however, that the care for safety and security are only best efforts obligations that can never be guaranteed.

      Your rights

      You have the right to request access to all personal data that we process about you.

      You have the right to request that any personal data about you that is incorrect or inaccurate be corrected free of charge. If you have registered on our Website, you can correct much of this data yourself through your profile. If such a request is made, you must also include with it evidence that the personal data for which correction is requested is incorrect.

      You have the right to withdraw your previously given consent to the processing of your personal data. You can withdraw your consent at any time by sending an e-mail to support@rubey.be.

      You have the right to request that personal data relating to you be deleted if it is no longer necessary in view of the purposes set out in this Privacy Policy or if you withdraw your consent to its processing. However, you should note that a deletion request will be assessed by us in the light of legal or regulatory obligations or administrative or judicial orders which may prevent us from deleting the personal data in question.

      Instead of deletion, you may also request that we restrict the processing of your personal data if (a) you dispute the accuracy of that data, (b) the processing is unlawful or (c) the data is no longer necessary for the stated purposes, but you need it to defend yourself in legal proceedings.

      You have the right to oppose the processing of personal data if you can demonstrate that there are serious and legitimate reasons relating to special circumstances that justify such an opposition. However, if the intended processing is classified as direct marketing, you have the right to object to such processing free of charge and without justification.

      If your personal data is processed on the basis of consent or on the basis of a contract and the processing is carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and, if technically possible, you have the right to transfer this data directly to another service provider. The technical feasibility of this is exclusively assessed by us.

      If you wish to make a request to exercise one or more of the above-mentioned rights, please send an e-mail to support@rubey.be. This request must clearly state which right you wish to exercise and why. It must also be dated and signed, and be accompanied by a digitally scanned copy of your valid identity card proving your identity. We will immediately inform you of the receipt of such a request. If the request proves to be well-founded, we will comply with it as soon as reasonably possible and no later than thirty (30) days after receipt of the request.

      If, in exercising your rights or processing your access requests, we find that they are manifestly made with the intention of causing inconvenience or damage to us, we reserve the right not to process them. If you contact us to exercise your rights, we will respond within one month. Exceptionally, this may take longer, but in that case we will inform you within one month as to why this will take longer. Whether or not you can exercise your rights depends on the processing and the legal basis for processing.

      If you have a complaint about the processing of your personal data by us, you can always contact us at the e-mail address support@rubey.be. If you are still dissatisfied with our response, you are free to lodge a complaint with the competent data protection authority. For more information, please visit https://www.dataprotectionauth...