Privacy statement
1. Introduction
Thank you for your trust. We value privacy and consequently do our utmost to protect your personal data when you use our products and/or services. We treat your personal data as confidential information.
This privacy statement (the “Privacy Statement”) aims to inform you in detail about our use of your personal data. Please read this Privacy Statement to learn more about how we collect, use, store and share your personal data and your rights in connection with our use of your personal data.
2. Scope
This Privacy Statement applies to (i) All (current and former) customers, (ii) All prospects who express interest in our products and/or services, (iii) all visitors to our website (see section 14 of this Privacy Statement), (iv) persons employed in any business or organization with which we have or had a customer relationship and (vi) any other person who contacts us in any way.
3. Who are we?
Mindthebed.com is a website of Victory-S BV. A limited liability company under Belgian law with its registered office at 3900 Pelt, Snoepluststraat 3 (company number 0824.177.524, RPR Hasselt). Victory-S BV is the data controller of your personal data.
4. What information are you collecting about me?
We may process the following categories of personal data:
– Personal identifying information, such as name, first name, gender, etc., among others;
– identification data issued by the government, such as company numbers, among others.
– contact information, such as address, (mobile) phone number, email address, etc., among others;
– contract data, such as product/service, , customer history, etc., among others;
– billing information, such as billing address, VAT number, amount payable, outstanding amounts, etc., among others;
– Financial identification information, including your bank account number, etc;
– payment information, including payment preference, account number, direct debit information, payment history, etc;
– solvency data, such as, if you are a business customer, credit ratings, etc.;
– recovery data, such as payment delays, credit histories, data related to collection procedures, etc., among others;
– relations, such as including what your position is within your organization, etc.;
– electronic identification data, such as IP addresses (i.e. a number that can usually identify a specific computer or other network device on the Internet), user IDs, device IDs, location, etc., among others;
– usage data, including, among other things, information about your use of our website, our online services, or other online content from mindthebed.com, log files, browsing habits, etc.;
– professional activities, such as which NACE-digit code an enterprise belongs to;
– data related to complaints or incidents;
– national registration number, if you provide us with a copy of your identity card;
– camera footage, from surveillance cameras to our property(s).
We do not process sensitive personal data, except when you voluntarily submit sensitive personal data to us yourself. Sensitive personal data are personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, health data, data relating to a person’s sexual behavior or sexual orientation.
5. How do you obtain my personal data?
We only process personal data that we receive directly from you, for example through contact(s) with us, through use of our products and/or services or through use of our website.
6. Am I required to provide my personal data?
In principle, you are not obliged to share personal data with us. However, the provision of personal data is necessary if you wish to enter into a contract with us and subsequently for the performance of that contract.
7. For what purposes do you use my personal data?
We use your personal data for the purposes listed below. We have also indicated below the legal basis of each processing. We may provide additional information regarding processing purposes when collecting your personal data.
7.1. Management of the contractual relationship
We process your personal data to enter into a contract with you and then to perform that contract with us. This includes, but is not limited to, processing your order, making arrangements for delivery or placement, preparing and sending invoices, and reminders if necessary, and any communication regarding the contract. The legal ground for the aforementioned processing is the conclusion or performance of your contract with us, or our legitimate interest.
7.2. Handling of (customer) requests
When you make a request and share your contact information with us for this purpose, we use this information to respond to that request. This includes data collection through online contact, such as through the contact form or through Facebook. With regard to existing customers and pre-contractual measures taken at the request of potential customers, the legal ground for processing is the preparation or execution of your contract. For other questions from non-customers, we have a legitimate interest in providing you with answers.
7.3. Marketing communications regarding products/services (or products/services of affiliated companies
We use your personal data to send promotional and marketing communications. We may use your personal data for this purpose based on our legitimate interest. The commercial interest of Victory-S BV consists of offering and improving our products and services.
However, where your consent is required, we will not process your personal data for these purposes until you have given your consent. You may opt out of promotional and marketing communications at any time by contacting us using the contact information below.
7.4. Website: analysis/optimization/management
On our website, we use cookies and related technologies for functional, analytical and advertising purposes. More information about this can be found in section 15 of this Privacy Statement and in our cookie statement, at www.xxx/cookies.
7.5. Legal or regulatory obligations
In certain cases, we are required to process your personal data based on an obligation under laws or regulations, including reporting obligations, accounting, dealing with official complaints and cooperating with competent government authorities, regulators, tax authorities, judicial authorities and the police.
7.6. Indemnification of rights and third parties
Victory-S BV has a legitimate interest to process personal data in order to protect the rights, property and safety of itself, its customers or third parties (including prevention, detection, investigation of fraud or potential crime, security of buildings and facilities, management of disputes, litigation or legal proceedings (to the extent not already contained in customer management necessary for the performance of the agreement or a legal obligation)).
7.7. Support services
Exceptionally, personal data are processed for information technology and support services. We process this personal data to ensure (information) security and the proper functioning of our organization. This is based on our legitimate interest to do so.
7.8. Donations and public relations
Victory-S BV processes the personal data of data subjects for its administration of donations and of relevant industry contacts, for public relations purposes. This is based on legal obligations in connection with payments and on our legitimate interest in creating goodwill.
7.9. Prospecting potential trading partners
We process personal data in the context of prospecting for potential business partners. This is based on Victory-S BV’s legitimate interest in doing business.
8. Will you share my personal data with third parties?
We will keep your personal data within our company unless transfer is required or permitted as described in this section 8. Your personal data may be shared with (i) affiliated companies, (ii) third parties providing services to us (e.g., subcontractors, as well as IT providers), (iii) competent government authorities, (iv) professional counselors, (v) a credit rating agency, (vi) another customer (e.g., as a reference) and (vii) in the context of a possible merger or acquisition of Victory-S BV.
We assign certain services to carefully selected vendors. We provide personal data to suppliers only as necessary for the provision of services. We may disclose your personal information to third parties who provide services to us such as billing services, mail delivery, sales services, address services, customer services, accounting and payment services, call center services, printing services, market research firms, marketing and media companies, gift shops, IT service providers, consulting firms, bailiffs, lawyers and commercial partners. Under certain circumstances, we are required to share your data based on a valid request from authorized government authorities (e.g., tax authorities, judicial authorities, police, data protection authority), based on a legal or regulatory obligation or with professional counsel (e.g., a trustee or lawyer). Only if you are a business can the time period within which you pay be passed on to a credit rating agency (e.g. Graydon). Finally, it could ever happen that Victory-S BV or one of its parent companies, in the context of a merger, acquisition or other business transaction, discloses restricted personal information to a potential buyer, seller or their advisors.
9. Will my personal data be transferred outside the EEA?
Certain suppliers may be located outside the European Economic Area (EEA). We have implemented a comprehensive data protection policy and we will only share your personal data with suppliers outside the EEA if they have signed a (processor) agreement and can guarantee adequate protection of personal data under an adequacy decision of the European Commission (e.g. EU/US Privacy Shield Framework), or under appropriate safeguards (e.g. EU Standard Contractual Clauses they have entered into with us).
10. How long will you keep my personal data?
Personal data is not kept longer than required by law or than necessary for the purposes for which it was processed. Consequently, the retention period depends on legislation and the purposes of the processing. We keep your data in accordance with the retention periods specified by law. In principle, we keep most customer data (contract, billing, payments …) for ten (10) years, as this is the maximum period during which a legal action could be brought. If no specific retention period is required by law, we determine the period based on the purpose of the processing in light of statutes of limitation or generally accepted retention periods in light of custom or regulatory guidelines.
11. Is my personal data secure?
We have focused on implementing good IT applications designed to protect your privacy and personal data. We use generally accepted technical and organizational security measures and have security policies that adequately protect personal data in our systems. The systems are appropriately protected against unauthorized access, unauthorized use or disclosure, unauthorized modification and unwarranted destruction or accidental loss. Our employees and partners who have access to your personal data are bound by strict confidentiality.
12. Can I modify or withdraw my consent?
When we offer certain products or services, we need your consent in certain cases. If you are no longer interested in these products or services, you can modify or withdraw your consent at any time. Previous actions that happened during the consent period do remain lawful.
13. What rights do I have?
According to the Data Protection Law, you have, always under the legally defined conditions:
– right of inspection: for example, you have the right to know whether and if so what personal data we process about you and the right to a free copy of that personal data;
– right to rectification: at your request, we will correct personal data that is incomplete or inaccurate;
– right to data erasure: if you wish, we will erase your personal data, if there is no legal obligation to keep them and Victory-S BV does not have a compelling interest in keeping them either (e.g. to defend our rights);
– right to restriction of processing: you have the right to ask us to retain only certain personal data;
– right to portability: for example, you have the right to ask Victory-S BV for a copy of the personal data you have provided to us and to receive them or have them transmitted to a third party in a structured, accessible and IT-wise readable format;
– The right not to be subject to a decision based solely on automated decision-making that legally affects you or otherwise significantly affects you. In the latter case, you have the right to human intervention by Victory-S BV, the right to express your point of view and the right to challenge the decision;
– The right to withdraw your consent at any time;
– The right to file a complaint with Victory-S BV;
– the right to contact the Data Protection Authority (Press Street 35, 1000 Brussels, T. +32 (0)2 274 48 00, F. +32 (0)2 274 48 35, contact@apd-gba.be) in case of complaints regarding the processing of your personal data. However, we encourage you to seek resolution directly with us first.
– You have the right to object: You always have the right to ask to stop processing of your personal data that is done on the basis of a legitimate interest of Victory-S BV or a third party, including profiling to that end, for reasons related to your specific situation. If you object, your personal data will no longer be processed for that purpose unless Victory-S BV invokes overriding legitimate interests or the processing is related to the establishment, exercise or substantiation of a legal claim. Victory-S BV also processes your data for direct marketing purposes. If you no longer wish to receive any or certain direct marketing, you may opt out at any time, including profiling for direct marketing purposes. Victory-S BV will then respect your wishes for future direct marketing campaigns.
If you wish to exercise your rights under the Data Protection Law, contact us at info@mindthebed.com or by mail to Snoepluststraat 3, B-3900 Pelt. Thank you to please date your request, sign it and include at least the phone number and email address by which you are known to Victory-S BV. Victory-S BV may request additional proof of your identity, such as in the form of a copy of the front of your identity card. Your request will be handled in accordance with Data Protection Laws.
14. To which websites does this Privacy Statement apply?
This Privacy Statement applies to the www.mindthebed.be website. Our website may contain hyperlinks to websites operated by third parties. Mindthebed also has a company page on several social networking sites (including Facebook). These pages are used primarily for the purpose of more active communication and information about our products and services. We may also use these pages to invite you to contests in which you can participate with a view to winning a prize. Victory-S BV has no control, nor access to the personal data collected by the various social networking sites. For more information regarding the processing of your personal data by the various social networking sites, thank to read the privacy statements of these networks, or contact them directly:
Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland (https://www.facebook.com/about/privacy).
Third-party websites each have their own privacy statements. We request that you review these privacy statements, as we have no responsibility or liability for the privacy policies of third-party websites and use of such websites is at your own responsibility.
15. Do you use cookies and related technologies?
When you use our website, receive emails from us, or use any of our services, Victory-S BV places cookies or employs similar technologies such as pixels. Victory-S BV also uses cookie-related technologies. Cookies are (temporary) text files which ensure that you do not have to enter the same information every time you return to the website. They also help us understand how you use our website or emails and how we can improve them. More information about cookies and related technologies can be found in our cookie statement at www.xxx./cookies.
16. Can this Privacy Statement be changed?
This Privacy Statement may be amended from time to time. Before sharing personal data with us, it is recommended that you read the most recent version of this Privacy Statement. The date of the most recent update is indicated on the first page. If significant changes are made to this Privacy Statement, we will provide more prominent notification (e.g., email).
17. How do I contact you regarding this Privacy Statement?
For questions or comments regarding this Privacy Statement, you may always contact the governing body of Victory-S BV. This can be done by mail Snoepluststraat 3, B-3900 Pelt, by telephone (+32) 469 226 221 or by e-mail info@mindthebed.com, always mentioning ‘Data Protection’.
