Privacy Policy

Intro

Version of 15/05/2023

This privacy policy applies to the processing of personal data by De Leiding BV (with registered office at Kerkstraat 108, 9050 Gentbrugge, Belgium, with company number 0694.734.685) (hereinafter “”De Leiding BV“) via our websites (hereinafter “”Sites“), mobile sites and applications, and other mobile interactive features (collectively, “”Apps').

“Robinetto” and “Robi” are registered brands of De Leiding BV.

1. Your privacy is important to us

You share personal information with us so that we can provide you with the best possible service. We think it's important that you also know why we ask for your personal information and what we do with it. Below you'll find more information about why we request information from you and how we obtain and use this information from you.

De Leiding BV cares for your privacy and strives to always act in accordance with the provisions of the applicable data protection regulations (the”Data Protection Legislation”), such as Regulation (EU) 2016/679 of the European Parliament and 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 (the so-called “GDPR” or “GDPR”) and the Belgian law of 31 July 2018, as well as any future changes and/or additions to those regulations.

The person responsible for processing your personal data is De Leiding BV.

Please read this privacy policy carefully, as it contains essential information about how your personal data is processed and which cookies are used. Where we refer to “personal data” in this privacy policy, we mean the information you provide to us about yourself, such as your name, address, email address and phone number, as well as products you have purchased or, for example, emails you have sent to us.

By providing your personal data, you consent to de Leiding BV to process this data and declare that you have taken note of this privacy policy and that you accept it integrally and unconditionally. If you have any questions after reading this, please let us know via our contact page.

2. How do we collect your data?

You share information with us in various ways. In doing so, we use information that we received directly from you via the Websites or Apps, as well as information collected by ourselves (e.g. information about your visit to our Websites or Apps).

You are not obliged to provide your personal data, but you understand and agree that the use of our Websites and Apps and the provision of certain services will become impossible if you refuse processing. You are solely responsible for the accuracy of the information you provide.

3. What information do we collect from you and what do we use that information for?

De Leiding BV processes the personal data listed below on the legal grounds set out below and only for the purposes set out below:

a. Usage and consumption data

On the one hand, this is information that you share with us when using our Websites and Apps without registering: IP address, surfing behavior, origin, search terms. We use this information to maintain and improve our Websites and Apps. This means that we include personal data in anonymous statistics, from which the identity of specific people or companies cannot be determined. The legal basis for this processing is De Leiding BV's legitimate interest in continuously improving its Websites, Apps and services.

On the other hand, we may collect data about the use and consumption of our products. We use this data to optimize our products and services and to possibly make recommendations about the use of our products. By purchasing and using our products, you agree that we may link this usage and usage data to your personal data such as your name, address, and telephone number and use it to provide you with recommendations on how to use our products.

b. Cookies

Our Websites and Apps also use cookies that ensure that the following personal data is collected:

We use the following types of cookies:

  • Strictly necessary cookies: These cookies are essential to enable you to navigate the website and use its features. Without these cookies, services you request, such as remembering your login details, cannot be provided.
  • Performance cookies: These cookies collect information about how you use our website, for example which pages you visit most often. This data can help us optimize our website and simplify navigation.
  • Functionality cookies: These cookies allow our website to remember choices you make (such as your username, language, or region where you are) and provide enhanced, more personal features.
  • Targeting or advertising cookies: These cookies are used to display ads that are more relevant to you and your interests.

The legal basis for this processing is your explicit prior consent. We use this information to maintain and improve our Websites and Apps. For further provisions regarding the use of cookies, see below.

c. Request or order information online

For your information request or order, we need your name, email address, address and any VAT number and phone number.
We use this information to provide you with the requested information, to deliver and invoice the products ordered and to keep you informed about your order or to contact you with questions or comments about your order.
The legal basis for processing this data is to provide a service that was requested by you and/or performance of an agreement concluded between us.

d. Subscribe to the newsletters

You can sign up for our newsletters. When you register, we ask for your name and email address. This way, you can stay up to date with promotions, promotions and the latest projects, and we can invite you to events.
The legal basis for processing this data is to provide a service that was requested by you and/or performance of an agreement concluded between us.

If you no longer want to receive newsletters from us, you can always unsubscribe by following the link at the bottom of the email you receive. You can also mail to hello@robiwater.be.

e. Your opinion

To keep improving our services, we would love to hear your opinion. That is why we can contact you for an assessment or an informal customer or market research.
The legal basis for this processing is De Leiding BV's legitimate interest in continuously improving its Websites, Apps and services.
We keep track of the details of the review, as well as who writes which review. If you do not want to participate in reviews or want reviews removed at a later time, you can always indicate this by using the link at the bottom of the email, or by contacting us at our contact page.

f. E-mail correspondence and phone calls

All e-mail communications with De Leiding BV are stored, as well as chat conversations and data about any telephone conversation with you. If a phone call is recorded, we will inform you in advance. This information is only used to answer your question as well and quickly as possible and to improve our services. The legal basis for this processing is the provision of a service that was requested by you and/or performance of an agreement concluded between us.

g. Marketing

Your personal data (name, address and e-mail) can also be used for direct marketing, in particular for sending advertisements and other marketing material related to Robinetto, Robi and De Leiding BV, its products and/or services.
The legal basis for this processing is De Leiding BV's legitimate interest in continuously improving and promoting its Websites, Apps and services and/or your consent to use your data for direct marketing purposes.
At any time, you can indicate that you no longer wish to receive direct marketing and/or withdraw your previously granted consent, without justification and free of charge, for example, by clicking on the unsubscribe link provided for this purpose, at the bottom of each promotional e-mail message or by contacting us at our contact page whether hello@robiwater.be.

4. Who has access to your data?

In order to process your personal data, we provide access to your personal data to our employees. However, within De Leiding BV, the data is only accessible to responsible persons who need to have access to it in function of their tasks. We guarantee the confidentiality of your information by imposing contractual obligations on these employees and requiring them to comply with this privacy policy as well.

5. Transfer to third parties

We use external processors to help us with certain services. These services may include delivery services, credit/debit card processing, marketing activities and providing customer service. This includes, among other things, that we temporarily transfer personal data to third parties for certain tasks or investigations because they need it to provide their services to De Leiding BV and ultimately to you. We always contract this with these processors and limit the data we share with third parties only to the information that the processor needs to provide its services. For example, this processor will never be allowed to use your data on its own initiative and your data must be deleted as soon as that processor has completed the assignment.

Specifically, we work with the following external suppliers for data processing and use:

  • Campaign Monitor Pty Ltd., for email newsletters
  • Zestia LTD, Capsule CRM, for monitoring sales and customer relationships
  • Rentman B.V., for planning projects and installations and making quotes and invoices
  • Exact Holding B.V., for keeping our accounts
  • Lyanthe B.V., for processing incoming and outgoing invoices
  • Formagrid Inc., to organize the ROBI installation service
  • Shopify, for our webshop
  • Jaimy NV, for planning the ROBI installation service
  • Sufio inc., for preparing and sending outgoing invoices

For marketing purposes, we use Google and Facebook cookies (see further under “Cookies”).

De Leiding BV also uses Google Analytics to analyze the use of the Websites and Apps and the effectiveness of AdWords ads on Google search result pages. The information thus obtained, including the address of your computer (IP address), is transferred to and stored by Google on servers in the United States. Read it Google privacy policy for more information. Google uses this information to record how our Websites and Apps are used, to provide us with reports about the Websites and Apps, and to provide its advertisers with information about the effectiveness of their campaigns. Google may share this information with third parties if Google is required to do so by law, or insofar as these third parties process the information on Google's behalf. De Leiding BV has no influence on this. De Leiding BV has not granted Google permission to use Analytics information obtained from it for other Google services, but has agreed to the Google Analytics Terms of Service. By using our Websites and Apps and/or using our products, you consent to the processing described above.

We can also share your information in the event that our organization or part of it is sold and the buyer needs your information to continue providing services to you.

De Leiding BV will not sell, rent, distribute or otherwise make commercially available your personal data to third parties, except as described above or with your prior consent.

6. Duration of processing

The personal data is stored and processed by us for a period that is necessary, depending on the purposes of the processing and depending on the contractual relationship between you and De Leiding BV.

7. Your rights

a. Right of access

You have the right to know at any time whether or not De Leiding BV processes your personal data. If De Leiding BV processes this data, you have the right to view this data and receive additional information about:

  • the processing purposes;
  • the categories of personal data concerned;
  • the recipients or categories of recipients (in particular recipients in third countries);
  • if possible, the retention period or, if that is not possible, the criteria for determining this period,
  • the existence of your privacy rights;
  • the right to file a complaint with the supervisory authority;
  • the information that De Leiding BV has about the source of the data if De Leiding BV would have obtained the data from a third party;
  • the existence of automated decision making.

You also have the right to receive a free copy of the processed data, in an understandable form. De Leiding BV can charge a reasonable fee to cover its administrative costs for any additional copy you request.

b. Right to correct personal data

You have the right to have incomplete, incorrect, inappropriate or outdated personal data corrected or deleted without delay.
To keep your details up to date, De Leiding BV requests you to notify us of any change, such as a transfer or change of email address.

c. Right to erase data (“right to be forgotten”)

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

  • your personal data is no longer necessary for the purposes for which it was collected or otherwise processed by De Leiding BV;
  • you withdraw your previous consent to the processing and there is no other legal basis that De Leiding BV can rely on for (further) processing;
  • you object to the processing of your personal data and there are no overriding legitimate grounds for (further) processing by De Leiding BV;
  • your personal data is being processed unlawfully;
  • your personal data must be deleted to comply with a legal obligation;
  • whether your personal data was collected when you were still a minor;

It must be taken into account that De Leiding BV cannot always delete all requested personal data, for example when De Leiding BV is legally obliged to keep this information (e.g. billing information) or when its processing is necessary for the establishment, exercise or defense of legal claims. De Leiding BV will provide you with further information about this in the response to your request.

d. Right to restrict processing

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

  • you dispute the accuracy of the personal data: its use is restricted for a period that allows De Leiding BV to verify the accuracy of the data;
  • the processing of your personal data is unlawful: instead of deleting your data, you request the restriction of its use;
  • De Leiding BV no longer needs your data for the original processing purposes, but needs it for the establishment, exercise or defense of legal claims: instead of deleting your data, its use is restricted for the establishment, exercise or defense of legal claims;
  • as long as no decision has been made about the exercise of your right to object to processing, request that the use of your data be restricted.

e. Right to portability of personal data (“data portability”)

You have the right to request the transfer of your personal data (“recovery”), for example to make it easier to change service providers. This is only possible for the personal data that you have provided to De Leiding BV yourself, based on consent or after agreement. In all other cases, you cannot invoke this right (for example, when the processing of your data is based on a legal obligation).
There are two aspects to this right:

  • you can request De Leiding BV to receive the personal data concerned back in a structured, common and machine-readable form;
  • and you can request De Leiding BV to transfer the personal data concerned directly to another controller. In this case, you are responsible for the accuracy and security of the (email) address that you provide for the transfer. De Leiding BV can refuse this right if the transfer is not technically possible.

f. Right to object to the processing of your personal data

You have the right to object to the processing of your personal data on the grounds of your special situation if the processing is in the legitimate interest of De Leiding BV or in the context of the public interest. De Leiding BV will stop processing your personal data unless De Leiding BV can demonstrate compelling and legitimate grounds for processing that outweigh yours or if the processing of the personal data is related to the establishment, exercise or defence of legal claims (e.g. filing a request with the court).

g. Right to withdraw consent

Insofar as the processing of the personal data is based on consent, you have the right to withdraw your consent at any time.

h. Right to file a complaint

You have the right to file a complaint with the Data Protection Authority. You can reach them at the following address:
Data Protection Authority
Drukpersstraat 35
1000 Brussels

For more information, De Leiding BV refers to the website of the Data Protection Authority: www.dataprotectionauthority.be.

8. Exercising your rights

a. Request

You can exercise the above rights by sending a request (i) via our contact page; or (ii) via hello@robiwater.be; or (iii) at the following address: De Leiding BV, Kerkstraat 108, 9050 Gentbrugge, Belgium.

To exercise your rights and to prevent any unauthorized disclosure of your personal data, De Leiding BV must verify your identity. In case of doubt or uncertainty, De Leiding BV will first ask you for additional information (preferably a copy of the front of your identity card).

b. Costs

You can exercise your privacy rights free of charge, unless your request is manifestly unfounded or excessive, in particular because of its repetitive nature. In this case, De Leiding BV - in accordance with privacy legislation - has the right and the choice to (i) charge a reasonable fee (taking into account the administrative costs of providing the requested information or communication and the costs associated with taking the requested measures), or (ii) refuse to comply with your request.

c. Format

When you submit your request electronically, the information will be provided electronically, if possible, unless you request otherwise. In any case, De Leiding BV provides you with a concise, transparent, understandable and easily accessible answer.

d. Response

De Leiding BV will respond to your request as soon as possible, and in any case within one month of receiving your request. Depending on the complexity of the requests and the number of requests, that period may be extended by two months. In the event of an extension of that period, De Leiding BV will inform you here one month after receipt of the request.

e. No response to the request

If De Leiding BV does not comply with your request, De Leiding BV will always inform you in its response about the possibility to file a complaint with a supervisory authority and to file an appeal with the court.

9. Your data is safe and confidential with De Leiding BV

We have developed technical and organizational security measures to prevent the destruction, loss, falsification, alteration, unauthorized access or accidental notification to third parties of personal data collected as well as any other unauthorized processing of this data. Under no circumstances can De Leiding BV be held liable for any direct or indirect damage resulting from incorrect or unlawful use of the personal data by a third party. You must comply with the safety regulations at all times, including any unauthorized access to your computer and smartphone. You are therefore solely responsible for the use that is made of the website of your computer, IP address and your identification data, as well as for its confidentiality.

10. Cookie Policy

Our Websites and Apps use cookies and similar technologies to distinguish your user preferences from those of other users of our Sites and Apps. This helps us provide you with a better user experience when you use our Websites and Apps and also allows us to optimize our Websites and Apps. Specifically, we use the following cookies:

Strictly necessary cookies

Performance cookies

Functionality cookies

Unclassified cookies

  • Keeping track of language preference
  • Google Analytics: We use Google Analytics cookies to collect information about your visit to our Websites and Apps. For more information about how these cookies work, you can view Google's cookie and privacy statement. More info can be found here: https://policies.google.com/technologies/partner-sites.
  • Facebook pixel: Our Websites and Apps use Facebook cookies to improve your user experience, enable social media sharing, and improve the effectiveness of our campaigns. So we may, to a limited extent, offer you relevant advertisements based on your interest on our Websites and Apps. More information about Facebook's cookie policy can be found here: https://www.facebook.com/policies/cookies

11. Changes to this Privacy Policy

We reserve the right to make changes to this privacy policy. It is recommended that you review this privacy policy regularly so that you are aware of these changes.

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