PRIVACY POLICY

CURAFYT BV ("we", "our", "we" or "CURAFYT") commits to protect the privacy of all users of our website, curafyt.com (hereinafter the "Website"). Please read the privacy policy below that explains how we use and protect your information. We will be the "Data controller" of the data we receive from you.

1. CONTACT DETAILS

If you have any questions or requests regarding this privacy policy or questions about how we process your data more generally, please contact us via the following e-mail address: info@curafyt.com.

2. HOW WE COLLECT YOUR DATA

We collect your personal information when you communicate with us or our services, such as when you use our Website to place an order. We also record how visitors use our Website, so that we can improve our services and optimise our customers' experience.

We collect data:

when you create an account with us or change your account settings;
when you place an order with us and also during the order procedure (including for payment and delivery of the order);
when you contact us directly via email, phone, post, message or via our chat function; and
when you surf on our Website (before and after you create an account with us).

3. INFORMATION WE COLLECT ABOUT YOU

When you visit our Website or place an order through the Website, you will be asked to provide information about yourself such as your name, contact details, delivery address, VAT number (for B2B clients only), delivery details and payment information such as a debit or credit card.

We also collect information about your use of the Website and information from any messages you post on the Website or when you contact us or provide us with feedback, including by email, letter, telephone or chat.

We collect technical information from your mobile device or computer, such as the operational system, the type of device and connection type and the IP address at which you access our Website.

4. USE OF YOUR DATA

We will have a legal basis for processing your data if:

we have to process your data for the execution of a contract with you, or at your request before entering into a contract;
we have your consent;
we have a valid reason for processing your data; or
we are legally obliged to do so.

If we need to process your data for the purpose of fulfilling a contract with you, or at your request before entering into a contract, we will use your data to:

allow us to give you access to the relevant parts of the Website;
provide the services requested by you;
enable us to receive payments from you; and
if necessary, to contact you regarding our services, such as any problems you may have with your order.

We also process your data when we have a valid reason for doing so - for example, the personalisation of our service, including the processing of data to make it easier and quicker for you to place orders. These reasons are listed below:

to improve the efficiency and quality of services that our customers can expect from us in the future;
to tailor the content for you, such as to ensure that you see the advertisements that are most relevant to you, based on the properties determined by us;
to enable our customer service department to help you in the most efficient way with your questions or complaints;
to contact you in order to receive your opinion and feedback about our services and to inform you if there are any significant changes or developments to the Website or to our services, including informing you that our services are provided in a new area where you have asked us to provide them;
to analyse your activities on the Website so that we can manage, support, improve and develop our business and for statistical and analytical purposes as well as to help us prevent fraud;
to enforce our contractual provisions with you and any other agreement;
if you submit comments and feedback about the Website and other services, we may use such comments and feedback on the Website and in any other marketing or advertising materials. For this purpose, we will only identify you by your first name and the city you live in;
we will also analyse data about your use of our services on the basis of your location data, in order to develop profiles for you and which relate to you. This means that we may make certain assumptions about what you may be interested in and use them, for example, to send you more customised marketing messages, or to inform you about special offers or products which we think may be of interest to you. This activity is called profiling. You have certain rights regarding this type of processing. Please see the 'Your rights' section below for more information;

If required by law, we will use your information to:

create an overview of your order(s); and
comply with any legal obligation or regulatory requirement to which we are subject too.

5. COOKIES

You can set your browser to refuse all or some cookies, or to notify you when websites use or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or may not function properly. For more information about our cookies, please consult our Cookie Policy.

6. DIRECT MARKETING

If you have given your consent or if we have a valid reason to do so (and this is permitted by law), we will use your details to inform you of other products and services that may be of interest to you and we may contact you by e-mail or telephone. You can manage your e-mail marketing preferences by: visiting our website at www.curafyt.com and clicking on "Account" which is indicated as a "human" icon in the top right-hand corner.

7. CONSERVATION OF YOUR DATA

We will not retain your information longer than we deem necessary.

The data we collect will be retained for as long as necessary to fulfil the purposes set out in the "Use of your data" section above or for a period specifically imposed by applicable laws or regulations, such as the retention of data for legal reporting purposes.

In determining the relevant retention period, we will consider the following factors

our contractual obligations and rights in relation to the information concerned;
legal obligation(s) under applicable law to retain data for a certain period of time;
limitation periods in accordance with applicable law(s);
our legitimate interests for which we have carried out consideration tests (see section above entitled "Use of your information");
litigation or potential litigation; and
guidelines issued by the relevant data protection authorities

In addition, we will delete all your data if it is not (or no longer) necessary to keep this data for the intended purposes.

8. FRUITING OF YOUR DATA

The information we collect about you will be transferred to and stored on our servers located within Canada and the United States (through Shopify).

Share your information with third parties. We will share your information with third party service providers. The types of third party service providers to whom we may share your information include:

payment service providers (including online payment service providers and fraud detection service providers): for the purpose of providing our services, for example, when they process data such as credit card payments for us, provide support services for you or perform fraud checks for us;
IT service providers (including cloud service providers): for data storage and analysis;
delivery partners: so that they can deliver your order;
marketing and advertising partners: so that they can ensure that you see the advertisements that are most relevant to you and that they can send you marketing emails on our behalf.

Curafyt will take all necessary steps to make sure that your data will be treated in a safe way and in accordance with this privacy policy, when they are transferred to third parties.

If our company enters into a partnership or is bought/sold or merged with another business entity, your data may be disclosed or transferred to the target company, our new business partners, new owners or their advisors.

We may also share your data:

if we are required to disclose or share your information in order to comply (and/or if we believe we are required to comply) with legal or regulatory requirements. This includes exchanging data with other companies or other organisations for the purposes of fraud protection and prevention;
to enforce our contractual provisions with you and any other agreement;
to protect the rights of Curafyt, deliverers, or others, including to prevent fraud; and
with third parties when we deem it reasonably necessary to prevent crimes, for example with the police.

9. SAFETY

We use powerful technologies and procedures to ensure that the personal information we hold about you is appropriately protected.

We take the necessary measures to protect your data against unauthorised access and against unlawful processing, accidental loss, destruction and damage.

Once you have chosen a password that allows you to access certain parts of the Website, you are responsible for keeping this password confidential. We advise you not to share this password with anyone.

Unfortunately, sending information via the Internet is not completely safe. Although we will take measures to protect your information, we cannot guarantee the security of any data you transmit to the Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security measures to try to prevent unauthorised access.

10. YOUR RIGHTS

In accordance with data protection legislation, you have a number of rights in relation to the data we collect about you. If you wish to exercise any of these rights, please contact us using the contact details above.

The right to be informed. You have the right to obtain clear, transparent and easily understandable information about our use of your data and your rights. This is why we provide you with the information in this policy.
The right of access. You have the right to access your data (if we process them). This enables you to check, for example, whether we use your data in accordance with data protection legislation. If you wish to access your data, please contact us (see contact details).
The right of rectification. You have the right to correct your data if it is incorrect or incomplete. You can request us to correct errors in the data processed by us by contacting us (see contact details).
The right of erasure. This is also known as 'the right to be forgotten' and it allows you, in simple terms, to request that the data collected by us be deleted or deleted by contacting us (see contact details).
The right to limit the processing. You have the right to 'block' or 'limit' the further use of your data. If the processing is limited, we may save your data, but not use it further.
The right to transfer data. You have the right to obtain your personal data in an accessible and transferable format, so that you can reuse it for your own purposes at different service providers. However, this is not a general right, there are exceptions. To find out more about this, please contact us (see contact details).
The right to file a complaint. You have the right to complain about our way of processing your personal data to the national data protection authority.
The right to withdraw your consent. If you have given your consent to something we do with your data (i.e. we are subject to your consent to process your information on a legal basis), you have the right to withdraw your consent at any time. You can do this by contacting us (see contact details). However, the withdrawal of your consent does not render our use of your data unlawful at the time of your consent.
The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing and profiling. You can object by changing your marketing preferences or making the cookies unusable as set out in sections 5 and 6 above.

11. CHANGES TO YOUR PRIVACY POLICY

Any change in our privacy policy will be published on the Website and, where necessary, we will notify you of the changes, for example by e-mail or push notification. This privacy policy was last updated on: 17/04/2020.

12. COMPLAINTS

If you are not satisfied with our response to a complaint or believe that our processing of your information does not comply with data protection legislation, you can submit a complaint to the Belgian Data Protection Authority using the following contact details:

Address: Belgian Data Protection Authority, rue de la Press, 35, 1000 Brussels (Belgium)

Telephone number: +32 (0) 2 274 48 00

Website: https://www.privacycommission.be