1. Data Controller and Data Protection Officer

1.1.

In this Privacy Policy, Delka (hereinafter referred to as "Delka" or "we") explains how it processes your personal data as the data controller. This Privacy Policy applies to the processing of personal data relating to customers, prospective customers (prospects), and natural persons who enter into a contractual relationship with Delka in any other capacity as purchasers or suppliers.

Delka has an establishment and may be contacted by email at the address specified in section 7.4.

1.2.

Any information relating to an identified or identifiable natural person constitutes personal data. This includes information that can reasonably be linked to an individual.

1.3.

The Data Protection Officer may be contacted by email at:

info@themis-security.be

2. Personal Data We Process

2.1.

Delka may collect your personal data in various ways. We process the personal data you provide when you conclude a contract with us, but also when you participate in an activity, use our services, provide us directly or indirectly with personal information, or allow us to record information about your interests, behaviour and preferences (cookies).

Information You Provide to Us

2.2.

If you submit a request to Delka, for example via the website, we require the following personal information:

a) Name, address and postal code;

b) Email address and other contact details;

c) Any additional information relevant to your request, such as your business activity, your email address or any other supplementary information.

2.3.

If you conclude a contract with Delka, depending on the type of contract, product or service, we require the following personal information:

a) Name, address and postal code;

b) Contact details (telephone number and email address);

c) Financial information (bank account details).

This personal data must be provided directly to Delka or to its partners. If you do not provide the mandatory information (which varies depending on the type of contract), we may be unable to provide the requested service or conclude the contract.

Information About Your Use of Our Services and/or Products

2.5.

If you use the services offered by Delka or enter into a contract with us, we process personal data such as:

a) Information relating to your device, for example a MAC address, IP address or another identifying number;

b) Your communication preferences and settings;

c) Information that we associate with specific profiles we create based on your consumer behaviour (for example, how often you visit our website, make a purchase or request a service);

d) Browsing behaviour, determined on the basis of our own observations or through cookies (see also Article 6 of this Privacy Policy);

e) Customer satisfaction survey results;

f) Information relating to your use of the services we provide.

3. Legal Bases and Legitimate Interests

We process personal data on the basis of the following legal grounds:

a) Consent;

b) Performance of a contract concluded with you or implementation of pre-contractual measures;

c) Compliance with a legal obligation;

d) Performance of a task carried out in the public interest;

e) Legitimate interests pursued by Delka or by a third party.

We process personal data on the basis of legitimate interests when we use your information to provide services and content, related products and services, communicate with you, and carry out advertising or marketing activities relating to products or services that you have previously purchased.

Our legitimate interests include, for example:

4. Purposes for Which We Process Personal Data

4.1.

Delka processes personal data for the following purposes:

a) Maintaining customer relationships (including maintaining a direct relationship between Delka, members of the authorised distribution network, service partners and related financial service providers), including for the performance of a contract and the pursuit of legitimate interests.

b) Processing and administering orders (including invoicing) in order to respond to your request and/or prepare or perform a contract.

c) Providing customer service, fulfilling warranty obligations and the obligations of service partners, handling complaints and requests, responding to your enquiries and performing contracts, or for legitimate interests.

d) Proactively contacting customers in the event of defects or malfunctions of equipment or to schedule service appointments, for the performance of a contract or for legitimate interests.

e) Carrying out or coordinating product recall actions where necessary, on the basis of legitimate interests or legal obligations.

f) Conducting market research to improve our operations, brands, services and products, and to identify customer needs and expectations, on the basis of legitimate interests.

g) Complying with legal obligations, resolving disputes and enforcing our rights.

h) Improving data quality through address and postal code verification, on the basis of our legitimate interests.

i) Linking and analysing cookies from our websites with customer data already known to us. We do this to tailor the content of our communications as closely as possible to your personal preferences, in pursuit of our legitimate interests.

5. Third Parties Involved in the Processing

5.1.

In certain cases, Delka shares personal data with third parties acting as independent data controllers. Below we explain when this occurs and why.

Delka may share personal data with:

a) Service partners within Delka's distribution network, for the performance of a contract or in pursuit of legitimate interests.

b) Third parties to whom we are legally required or authorised to disclose personal data.

c) Third parties where we suspect an infringement of third-party rights, criminal offences or abuse, provided that they have a legitimate interest or are public authorities. This may include authorities such as the police or the public prosecutor's office.

d) Parties assisting Delka in the provision of its services who are not personal data processors (such as accountants and legal advisers), in pursuit of Delka's legitimate interests.

e) Potential buyers or investors, for legitimate commercial and business purposes (such as the sale of business activities or shares, or corporate restructuring).

f) Parties assisting Delka in the development of (direct) marketing activities, in pursuit of its legitimate interests.

5.2.

Personal data will only be disclosed to the above-mentioned third parties where such disclosure is permitted under applicable laws and regulations.

5.3.

Delka also uses third-party service providers acting as data processors (for example hosting providers, certain software providers, mobility service providers, or parties organising or carrying out campaigns or surveys on behalf of Delka).

Delka enters into a data processing agreement with these service providers requiring them to process personal data only in accordance with Delka's instructions and under Delka's supervision.

5.4.

At present, we do not store personal data outside the European Union.

Should personal data intentionally be transferred outside the European Union, we will implement appropriate safeguards, such as entering into the European Commission's Standard Contractual Clauses.

5.5.

Our websites may contain references and/or hyperlinks to one or more third-party websites.

Delka is not responsible for the manner in which these third parties process personal data. We recommend that you read the privacy policy of those websites to understand how they process your personal data.

6. Marketing, Profiling and Cookies

6.1.

Delka may also share your email address and telephone number with Facebook so that Facebook can determine whether you have a Facebook account and, through the Facebook Custom Audience service, display personalised advertisements to you when you visit Facebook.

We also use Google services to display personalised advertisements based on the information you have provided on the website or to the application operator (for example when creating an account), your activities on that website or application (such as pages visited, searches performed or advertisements clicked), as well as demographic information and information about your interests and household.

We do this in pursuit of our legitimate interests.

You may object to this processing at any time, as described in Article 7 below.

6.2.

In addition, we and third parties automatically collect certain information relating to the history of your activities on our website and on third-party applications through automated means such as cookies, in accordance with the preferences you have provided.

Through certain cookies and similar technologies, unique cookie IDs or other identifiers are assigned or collected.

In this way, data may be collected while you use the website or applications, or while they operate in the background on your device.

We may combine this information with other information relating to you or your device, such as your IP address.

Where your consent is required for such processing, we will request it before carrying out the processing.

6.3.

We invite you to read our Cookie Policy for further information about the cookies and similar technologies we use and how you can configure your preferences.

7. Your Rights, Including Your Right to Object

7.1.

You have the right to know which personal data we hold about you and to whom we have disclosed your personal data.

7.2.

Furthermore, subject to applicable legislation, you have the right to request that we:

7.3.

We are required to inform you of your absolute right to object to direct marketing.

You also have the right to object to any processing, including profiling, carried out on the basis of the legitimate interests pursued by Delka or by a third party.

In addition, you have the right to lodge a complaint with a supervisory data protection authority.

In Belgium, this authority is the Data Protection Authority (Autorité de protection des données / Gegevensbeschermingsautoriteit).

7.4.

Your rights of access, rectification, restriction of processing, erasure, data portability and withdrawal of consent may be exercised free of charge by email, website form, telephone or post using the following contact details:

Email administration@delka.be
Website form  http://www.delka.be
Phone +32 87 76 63 38
Address Delka Rue de Battice 22 B4800 petit-rechain

8. Security

8.1.

We have implemented appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing.

8.2.

If you believe that your personal data is not adequately protected or if you have evidence of improper or unlawful use of your personal data, please contact our Customer Service Department using the email address provided in section 7.4 above.

9. Data Retention Period

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, unless we are legally required to retain such personal data for a longer period or where longer retention is necessary for the establishment, exercise or defence of legal claims.

10. Amendments

10.1.

We reserve the right to amend or supplement this Privacy Policy at any time.

Where reasonably possible, we will inform you of any significant changes. We recommend that you review this Privacy Policy periodically to remain informed of any updates.

10.2.

This Privacy Policy was last updated on 23 September 2019.

11. Contact / Questions

11.1.

If you have any questions or comments regarding this Privacy Policy and/or the processing of your personal data, you may contact us using the addresses or contact details provided in section 7.4 above.