Privacy Policy

General

This Privacy Policy governs the processing of your personal data by Pollet Pool Group NV, with registered office at 8680 Koekelare, Brouwerijstraat 14, and registered in the Crossroads Bank for Enterprises under number 0419.321.102 (hereinafter collectively referred to as: “Pollet“, “We“, “Us“, “Our“) when you:

Please read this Privacy Policy carefully. It contains essential information on how your personal data is processed and which cookies are used. By sharing your personal data on our Website www.polletpoolgroup.eu, by contacting us by email/phone or by submitting a question/complaint, you declare that you are aware of this Privacy Policy.

Below you can find an overview of answers to the most important questions about the processing of your personal data by Pollet.

1. Who is responsible for processing?

Pollet Pool Group NV, with registered office at 8680 Koekelare, Brouwerijstraat 14, Crossroads Bank for Enterprises no. 0419.321.102, processes your Personal Data in the context of its activities.

Pollet acts as controller within the meaning of privacy legislation, and in this capacity, we want to inform you about the processing of personal data.

This Privacy Policy therefore only applies to personal data that Pollet processes as controller. You can address your questions regarding the processing of your personal data to our Privacy Manager via privacy@boekan.be.

2. What personal data does Pollet process?

Pollet processes personal data that are relevant or necessary for the purposes for which they are processed.

Personal data is all data that identifies you or makes you identifiable as a natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to the personal data processed.

Pollet processes different categories of data depending on the purpose of the processing:

Category 1, based on cookies: your IP address and details about your visit on our Website;
Category 2, when registering or via one of the input forms on our Website: your surname and first name, possibly the name of your company and VAT number, address details, your email and any other data you submit to us in the free input field;
Category 3, if you call or email us: your email address and/or telephone number, as well as the data you disclose yourself;
Category 4, when subscribing to our newsletter: your email address;
Category 5, when placing an order: your surname and first name, possibly the name of your company and VAT number, address and billing details and your email.

Specifically and depending on the marketing tools, cookies and similar techniques used by us on our Website, the following personal data and may be processed:

Tool / Service	Type of personal data
Enhanced Conversions	Names, email addresses, phone numbers, addresses, customer identifiers, online identifiers, internet protocol addresses
Google Ads Customer Match	Names, email addresses, phone numbers, addresses, customer identifiers
Google Analytics	Online identifiers such as cookie identifiers, internet protocol addresses and device identifiers; customer identifiers
Google Data Studio	Data related to individuals to create reports, charts and diagrams
Google Optimize	Online identifiers such as cookie identifiers and internet protocol addresses
Google Tag Manager	Online identifiers such as cookie identifiers and internet protocol addresses
Facebook Ads Custom Audiences	Email addresses, phone numbers, addresses
HotJar	Online identifiers such as cookie identifiers and internet protocol addresses
CRM	Names, email addresses, phone numbers, addresses, customer identifiers, online identifiers, internet protocol addresses

Prominent Disclosure

The PPG Belgium App on our PPG Belgium Webshop may lead you to a form (e.g. Request Pool Cover), to provide us with information on the pool/accessory you need, e.g. a cover (size, shape, …) and we also request you to provide us with some pictures/drawings on the pool at hand. With the information on the pool specifications together with the pictures/drawings of it, we will be able to provide you with a correct answer to your request.

Besides the fact that most of the information on the pool we request you to fill in is non-personal information, we wish to inform you that, depending on whether you activated or not the GPS functionality on the device (classic camera, other (smart) device) you take your pictures with, the pictures you send us may contain information on your location.

We collect and store these pictures until the warranty period we need to respect on our deliveries has expired.

We take various technical and organisational measures to protect the personal data we process against unauthorized access or modification, against disclosure and destruction as well as against loss and theft, such as: password protection, data encryption, firewalls, antivirus, logging and monitoring of keep our systems, access management, ICT software up to date, where required and possible we will anonymize the personal data, etc..

If we consider it useful to obtain information from a supplier/manufacturer regarding your request, we will transfer the pictures to them. We only work together with suppliers/manufacturers who apply the same safety standards on data storage as ourselves. We will not transfer your pictures to other third parties than the ones mentioned hereabove without asking for your prior consent.

Of course, you have always the possibility to request us to return the pictures/drawings you have provided to us at any moment as well as their removal from our IT systems.

3. For what purposes does Pollet process your personal data, and on what legal grounds?

We process your personal data exclusively for the following purposes:

Category 1: Providing and improving our Website and including Personal Data in anonymous statistics, with as legal basis your explicit, prior consent upon your first visit to our Website as well as, subject to prior consent, to be able to target your marketing more effectively
Categories 2 and 3: Answering questions and requests for information, with the legal basis of performing a service or selling a product you have requested;

Categories 2, 3 and 4: Direct marketing, newsletters, actions and promotions by Pollet itself, with as legal basis our legitimate interest with regard to existing customers or your explicit, prior consent if you are not yet a Pollet customer. You can indicate at any time that you no longer wish to receive our newsletters via the opt-out option in our newsletters or by contacting us directly by email or phone;

Category 5: The delivery and invoicing of products or services ordered by you, with as legal basis the performance of a contract requested by you and for which the processing of your Personal Data is necessary or because it is required by law or because Pollet has a legitimate interest to do so.

4. Do we share your personal data with third parties?

Your personal data are mainly processed for internal use.

Pollet will never sell your personal data or make it available to third parties for commercial purposes.

We will always ask your prior consent to transfer data to third parties with the exception of the transfers necessary for the execution of legal obligations if you already have information related to the transfer or if the personal data must remain confidential in the context of a professional secret.

Although processors are not eligible as third parties, we would like to inform you that Pollet relies on processors with which we exchange personal data, such as contractors, ICT service providers, communication agencies, etc. For this purpose, we ensure by means of processor agreements that the processors who process your personal data on our behalf always do so in compliance with the privacy legislation and only for the purposes explained above. Pollet will verify that the processors will process the personal data in a safe, fair, lawful and proportionate manner.

In the event that the processors called upon by Pollet process personal data outside the European Economic Area (EEA), Pollet will ensure, in accordance with privacy legislation, through contractual or other measures, that these data enjoy an adequate level of protection there comparable to the protection they would enjoy in the EEA.

If necessary for its day-to-day business and always in compliance with privacy legislation, Pollet will also share personal data with parties such as lawyers and collection agencies, banks and insurance companies.

5. How do we protect your personal data?

Pollet takes the necessary technical and organizational measures to protect your privacy.

We take various technical measures to protect the personal data we process against unauthorized access or modification, disclosure and destruction, as well as loss and theft, such as: password protection, data encryption, firewalls, antivirus, logging and monitoring of our systems, access control, keeping ICT software up to date, where required and possible we will anonymise the personal data, etc.

Pollet takes organisational measures to protect your personal data, such as designating a responsible Privacy Manager; employing employees who ensure the security of our network, infrastructure and information systems; measures to manage physical access to our offices; our employees only have access to those personal data that are necessary for the performance of their tasks and are trained to perform their tasks with respect for your privacy at all times; we implement the privacy legislation in our business processes, procedures and work instructions.

These measures are regularly reviewed and updated by subjecting them to internal and external audits.

Despite the application of these security measures, it is still possible that third parties could circumvent these measures and obtain and/or use your personal data unlawfully. We cannot be held liable for this in any way and are therefore in no way liable for any unlawful use of your personal data that is made by third parties.

6. How long do we store your personal data?

Pollet keeps your personal data as long as this is necessary depending on the purposes of each processing:

For 36 months to contact you if you wish to purchase goods or services from us or to answer your general questions through various ways in which you can contact us (store visit, event, fair, mail, social media, etc.); If we see no more action on your customer profile for 36 months, we will delete your customer profile;
for marketing purposes and for newsletters, as long as you do not revoke explicit consent;
for the duration for which we are legally obliged to do so (e.g. in the context of warranty, accounting or labour law obligations);
Invoicing and accounting data must be kept for at least 10 years from the calendar year following the last invoice date for legal reasons.
while a contractual relationship is ongoing, including but not limited to the time required for orders and deliveries to run smoothly when purchasing a product or taking a service;
as long as there may be a legal dispute or investigations regarding the services or products provided by us.

We will handle your personal data in accordance with this Privacy Policy as long as we retain it.

7. What rights do you have regarding the processing of your personal data?

In accordance with privacy legislation, you have certain rights with regard to the processing of your personal data. Below you can find an overview of these rights.

Right to information and inspection

You have the right to be informed whether Pollet processes your personal data and, when this is the case, to obtain access to that personal data and to the following information:

the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients (in particular, recipients in third countries);
where possible, the retention period or, if this is not possible, the criteria for determining that period;
the right to lodge a complaint with the supervisory authority;
information about the source of the data if we obtain personal data through a third party; and
the existence of automated decision-making, including profiling.

You have the right to request a free copy of your personal data in a common form. If you request additional copies, Pollet may charge a reasonable fee to cover the administrative costs.

Right to rectification

You have the right to ask Pollet to complete or correct incomplete or inaccurate personal data processed by Pollet.

Right to erasure (“right to be forgotten”)

You have the right to have your personal data deleted by Pollet in the following cases, and without unreasonable delay:

your personal data are no longer necessary for the purposes for which they were collected or otherwise processed by Pollet;
you withdraw your previous consent for the processing and there is no other legal basis on which Pollet can rely for (further) processing;
you object to the processing of your personal data and there are no other grounds for (further) processing by Pollet;
your personal data are processed unlawfully;
your personal data must be erased in order to comply with a legal obligation;
your personal data were collected when you were a minor.

In some cases, we will not be able to comply with your request for data erasure, for example when the processing is necessary for the establishment, exercise or defence of legal claims or because the processing of these personal data is necessary for compliance with legal obligations. We will inform you about this in our response to your request for data deletion.

Right to restrict processing

You have the right to request the restriction of the processing of your personal data if one of the following circumstances applies:

you dispute the accuracy of these personal data: their use is limited for a period during which Pollet will verify the accuracy of the data;
the processing of your personal data is unlawful: instead of erasing your data, you request to limit their use;
Pollet no longer needs your data for the original processing purposes, but you need them for the establishment, exercise or substantiation of a legal claim: instead of erasing your data, their use is restricted for the establishment, exercise or substantiation of the legal claim;
as long as no decision has been taken on the exercise of your right to object to the processing, you request to restrict the use of your personal data.

Right to transferability of personal data

You have the right to ask Pollet to obtain your personal data in a structured, commonly used and machine-readable form and the right to transfer that data to another controller. You can ask us to transfer the data directly to the other controller unless this is technically not possible.

This right is only valid for the personal data that you have provided to Pollet on the basis of your consent or for the execution of an agreement and where the processing is carried out via automated processes.

Right of objection and automated individual decision-making

You have the right to object to the processing of your personal data if you are in a special and specific situation that justifies such objection.

Pollet will cease processing your personal data unless it can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms or the processing of your personal data is related to the establishment, exercise or defence of legal claims.

You have the right not to be subjected to a decision based on processing that was exclusively automated, including profiling. This right does not apply to the following cases: when profiling or automated individual decision-making is permitted by a legal provision that also provides for appropriate measures to protect your rights and freedoms; when this is necessary for the conclusion or execution of an agreement, when this is based on your express consent.

8. How can you exercise your rights?

You can contact us for more information about the Privacy Policy or in connection with the exercise of your rights via the following details:

By a letter addressed to BOEKAN NV, to the attention of the Privacy Manager, Brouwerijstraat 14, 8680 Koekelare;
Via email to: privacy@boekan.be.

As soon as we receive a complaint via the above channels, you will receive a confirmation of receipt. Your request will then be processed within a reasonable period.

Finally, you have the right to file a complaint with the Belgian Data Protection Authority if it appears that we have not taken appropriate action on a request based on one of the above rights within 30 days:

GBA/APD

Drukpersstraat 35

1000 Brussels

Tel: +32 (0)2 274 48 00

contact@apd-gba.be

If necessary, you can also go to the civil court to claim damages.

9. Which cookies do we use?

When you visit our websites, it is possible that certain cookies are placed on your device during the use of the websites. This helps to provide you with a better user experience when visiting our Website and allows us to optimise it.

Without your prior consent, we only set the purely functional cookies necessary for our Website to work correctly. For all other cookies, we ask your permission first.

A cookie is a small text file containing data that a website (when a user visits it) wants to store on your device in order to remember information about you, such as your language preference or login information. These cookies are set by us and are called “internal cookies”. In addition, we use “external cookies”, namely cookies from a different domain from where you are located. We use cookies and other tracking technologies for the following purposes:

Strictly necessary cookies

These cookies are necessary for our Website to work and therefore cannot be disabled. You can set your browser to block or alert you to these cookies, but some parts of our Website will then not work.

Performance or analytical cookies

These cookies allow us to count visitors and their origins so that we can analyse and improve the performance of our Website. They help us understand which pages are the most and least popular and how visitors move throughout the site. All information collected by these cookies is aggregated and therefore anonymous. If you do not allow these cookies, we will not know who visited which pages of our Website when. As a result, we cannot optimise our website and offerings to the benefit of our customers.

Functional cookies

These cookies ensure that additional features and personal settings on our website, such as language choices or video images, work. They can be set by us or by external technology partners. If you do not allow these cookies, some parts of our website may not work correctly.

Marketing cookies

These cookies may be set by us or by third-party partners and advertisers on our Website.
These cookies make it possible to compile a profile of your interests and show you relevant ads on other websites. If you do not allow these cookies, you will see fewer ads targeted at you.

The exact cookies on our website will be listed in our cookie banner and accompanying policy.

Do you notice other cookies being set via our Website? That, of course, is not the intention. So let us know soon so we can make the necessary adjustments.

We give you as much information as possible about cookies placed by third parties, but sometimes we do not have that information. If you still want to know more, then you can refer to the privacy statements of these parties on their respective websites. Please note that we do not exercise any influence on the content of those statements, nor on the content of these third parties’ cookies.

On your first visit to our Website, you will be asked to accept our cookies. You can manage your choices at any time afterwards.

More information on cookies can also be found at: http://www.allaboutcookies.org/.

More information on online behavioural advertising and online privacy can be found here: http://www.youronlinechoices.eu/.