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Français 1. General data :
This privacy policy sets out the measures taken to protect your privacy. The protection of the privacy of our customers and visitors is very important to us and we are committed to it. Therefore, by means of this privacy policy, we want to inform you in the best possible way about what information is collected and/or stored when you visit our website, when you fill in the contact form and when you enter into an agreement, explain the reasons why we do this and what control options you have at your disposal.
SMOKERSHOP - ESQW SRL considers it important to explain the terms used by the legislator well and in understandable language, which is why various terms are extra explained in this privacy policy.
a. Processing manager
The data controller is the person who collects the personal data when visiting the website, when filling in a contact form on this website, when filling in the participation form and/or any personal data he/she becomes aware of as a result of the organization of specialized trade fairs. It is extremely important that we, as data controller, are always available for any questions or comments regarding this privacy policy, our data can be found here :
SMOKERSHOP - ESQW SRL
Rue de la Croix Rouge 1
7740 Pecq
KBO: 0827.695.456
TEL : +32 69 49 03 63
b. Person involved
The data subject is a living natural person who can be identified in a direct or indirect manner by means of personal data. These personal data are to be understood in a very broad way and include names, contact details, personal characteristics, ... but also contracts or other documents that allow an individual to be identified.
c. Applicable law
The processing of personal data within SMOKERSHOP - ESQW SRL is subject to the European Regulation 2016/679 of the European Parliament and of 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..
2. Collection of personal :
a. Definition of personal
The term personal data should be understood to mean all data or information relating to an identifiable person. Due to the broad wording, a great deal of data can be considered as personal data.
b. The use of our website and applications.
Through the use of our website, various personal data is collected in different ways:
- 1. The personal data that are processed by the use of our website (e.g. the contact form, subscribe to the newsletter, ...).
- 2. The personal data that are processed when using our webshop.
- 3. Automatic collection of personal data, simply by visiting our website.
The different ways of collecting personal data are of course subject to their own specific terms and conditions in the privacy legislation. That is why it is important that the differences between the methods of collection are interpreted.
1.Processing of your personal data through the use of the website.
Personal identification data such as name, address, email, telephone number are necessary for the use of our online services (the use of the contact form, registration for the newsletter, direct use of our email address, telephone contact, ...) and must be communicated to us by yourself. Depending on the service you wish to use, the following categories of data may be requested:
| Type of personal data | Description of personal data |
| Personal identification data : | Name, title, address (private, work), telephone number (private, work), e-mail, identification details assigned by the responsible party. |
The information provided by you is deemed to be correct and complete. In the event of incorrect data being provided, we reserve the right to deny you, as a user, access to our services.
2. Processing of your personal data through the use of the webshop.
When using our webshop, a contract is always concluded between the parties (purchase agreement) in which various data are requested and/or collected, this concerns the following personal data:
| Type of personal data | Description of personal data |
| Personal identification data : | Name, title, address (private, work), telephone number (private, work), e-mail, identification details assigned by the responsible party. |
| Identification data, other than the National Register number, issued by the government : | VAT number. |
| Personal details : | Age, gender, date of birth |
| Financial identification data : | Identification and bank account numbers, credit or debit card numbers. |
| Financial transactions : | Amounts to be paid and paid by the person included in the file, methods of payment, statement of payments. |
| Habits : | Tobacco consumption, alcohol consumption. |
| Social contacts : | 1. |
3. Automatic collection of personal data.
Cookies and tracking technologies are used to collect various personal and other data in an automated way, simply by visiting our website:
| Type of personal data | Description of personal data |
| Electronic identification data : | IP addresses, connection points, ... |
| Electronic localization data : | Approach to location, surroundings,... |
| Surfing behavior : | Which pages are viewed for how long a web page is viewed, clicks, hits, ... |
| Through which channel is our webs visited : | Search terms, through which web page our website is. |
| Which device is used : | PC, smartphone, tablet, ... |
| Which system software is used : | Windows, Android, Apple, ... |
| Which browser is used : | IE, Mozilla, Chrome,... |
These data are completely anonymous and can therefore not be linked to personal identification data, which makes it impossible for the controller to identify the data subject. Of course, if necessary, your explicit consent to the use of cookies and tracking technology will be requested on the basis of the Telecommunications Act. This is done by means of our cookie policy as shown on our website.
c. Classic contractual relationship.
When entering into an agreement between the parties, various data may be requested and/or collected, this concerns the following personal data:
| Type of personal data | Description of personal data |
| Personal identification data : | Name, title, address (private, work), telephone number (private, work), e-mail, identification details assigned by the responsible party. |
| Financial identification data : | Identification and bank account numbers |
| Identification data, other than the National Register number, issued by the government : | VAT number |
| Personal details : | Age, gender, date of birth |
| Financial identification data : | Identification and bank account numbers, credit or debit card numbers. |
Without this information there is no possibility of concluding any agreement, therefore information provided by you must be correct and complete. In the event of incorrect information, we reserve the right to withdraw from the contract and already reserve the right to claim damages.
e. No processing of sensitive personal data
As required by law, we do not process sensitive data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual preferences, health or trade union membership.
3. Purposes of processing
a. Definition
The processing of personal data collected by us means any processing relating to the collection, recording, organisation, storage, updating, modification, retrieval, consultation, use, distribution, making available, bringing together, combining, archiving, deleting and destruction.
b. Purposes of using our website
The processing of personal data as described in points II.b.1 and 3 of this policy is necessary to achieve our legitimate purposes :
| Processing | Description | Legal basis |
| Commercial : | We can contact you to gauge your satisfaction, any comments, sharing on facebook, .... | Justifiable interest |
| Direct Marketing : | As a customer, you will be kept informed about our projects, actions and promotions by means of a newsletter. You can unsubscribe at any time. /td> | Justifiable interest |
Purposes of processing in a contractual relationship
The processing of personal data as described in points II.b.2 and II.c of this policy is necessary for the execution of the agreement.
| Processing | Description | Legal basis |
| Customer management : | The management of the given orders, the payment of the suppliers. The prospection of potential suppliers and their evaluation. | Necessary for the performance of the contract. |
| Supplier management : | The management of the given orders, the payment of the suppliers. The prospection of potential suppliers and their evaluation. | Necessary for the performance of the contract. |
The processing of personal data as described in point II.b.2 and II.c of this policy also takes place on the basis of our legal obligation as imposed by the law of 24 January 1977 on the protection of the health of consumers with regard to food and other products.
| Processing | Description | Legal basis |
| Customer management : | Keeping the accounts | Legal obligation |
| Supplier management : | Keeping the accounts | Legal obligation |
| Age control : | Age verification | Legal obligation |
The processing of personal data as described in points II.b.2 and II.c of this policy is also based on our legitimate interests. This processing enables us to develop new products, to provide a commercial follow-up as an additional service, to inform you about our new projects, to evaluate our marketing actions and, if necessary, to innovate.
| Processing | Description | Legal basis |
| Commercial monitoring | After a purchase we can contact you to gauge your satisfaction, any comments, share on facebook, ... | Justifiable interest |
| Direct Marketing : | As a customer, you will be kept informed about our projects, actions and promotions by means of a newsletter. You can unsubscribe at any time. | Justifiable interest |
| Customer management : | Customer administration, order management, allocation of loyalty points and deliveries. Personalized marketing and advertising. | Justifiable interest |
1. Quality and balance of interests
As data controller, we ensure the quality and legality of the personal data we collect and process. We hereby take all necessary measures to delete or correct data that is inaccurate or incomplete. When collecting and processing the available personal data, we reserve the right to collect and process only those data that are useful for achieving our processing purposes. We do not collect or process excessive data or data that may "ever" be applicable.
4. Data retention period
The personal data is stored for the full duration necessary for the realization of our processing purposes. A longer retention or further processing than necessary to achieve the purposes is not done:
- 1. In view of the legal retention periods, the data useful for the performance of the contract will be kept for a period of 10 years after termination of the aforementioned contract.
- 2. The personal data used for the commercial follow-up are kept for a period of 10 years in order to be removed or at least made anonymous afterwards, which makes it impossible to identify the users.
- 3. If the person concerned unsubscribes from direct marketing, the personal data will be removed or made anonymous unless this is further necessary for the execution of the assignment.
5. Transfer of personal data
SMOKERSHOP - LAGAZETTE BVBA may pass on your personal data to others. A distinction must be made here between processors and third parties (not processors) :
- 1. Passing on your personal data to processors.
The transmission is necessary for the realization of our purposes such as the execution of the agreement and the commercial follow-up (marketing). For this purpose, we work together with third parties or subcontractors such as IT service providers, mailing software, external employees, ...
- 2. Passing on your personal data to third parties in accordance with a legal obligation.
There is a legal obligation to pass on your data or at the request of judicial authorities or police forces.
6. Rights of the person concerned
a. Right to information
According to the legal provisions, SMOKERSHOP - ESQW SRL as data controller must clearly inform you about the collection and processing of personal data. This privacy policy is therefore a personal notice.
b. Right of access
As data controller, you have the right to obtain information from us about whether or not your personal data will be processed. If your personal data have been processed, you can view your data in our files with additional information about the processing purposes, the categories of personal data, possible recipients of your personal data, the retention period, complaints procedure, ... You can also request a copy of your personal data, without associated administrative costs. Please note that if you request several copies, SMOKERSHOP - ESQW SRL will charge a reasonable fee for this. The procedure for exercising this right can be found under point g.
e. Right to improvement
As a data subject, you have the right to correct any incomplete or incorrect personal data relating to yourself. The term "improvement" should be understood to mean that you can have incorrect data corrected or even deleted free of charge. The correctness and quality of your personal data is of great importance for the achievement of our purposes. The procedure for exercising this right can be found under point g.
d. Right of opposition
You have a double right of opposition. The legal provisions provide for a general right of objection and a right to object to direct marketing.
- General right to object
As a user/involved party, you therefore have a general right to object. You may object to the processing of your personal data if the data are incomplete or irrelevant according to the purposes of processing or if the data whose registration, communication or storage are prohibited or if the data have been stored for longer than the indicated duration. If your personal data are processed lawfully, you can, in accordance with the legal provisions of the privacy legislation, object to this processing for serious and justified reasons relating to your particular situation. You may object to the processing of your personal data if the data are incomplete or irrelevant according to the purposes of the processing or if the data whose registration, communication or storage are prohibited or if the data have been kept for a longer period than the indicated duration . However, you will need to show serious and justified reasons to prevent further processing.
- Right to object to direct marketing
You can oppose the processing of your personal data for direct marketing purposes free of charge and without any justification. You can consult the procedure for exercising this right of opposition under point g. If your personal data are processed lawfully, you can, in accordance with the legal provisions of the privacy legislation, object to this processing for serious and justified reasons relating to your particular situation.
e. Right to be forgotten
You can delete your personal data in your own name without unreasonable delay.
This is on condition that :
- The personal data are no longer needed for the purposes for which they were collected or processed;
- You revoke the given consent for specific purposes;
- The personal data has been unlawfully processed;
- Personal data must be deleted in order to comply with a legal obligation;
Those which are paid for by electronic means.
The procedure for exercising this right can be found under point g.
f. Right to obtain personal data
On request, you have the right to request SMOKERSHOP - ESQW SRL / data controller to retrieve your personal data that SMOKERSHOP - ESQW SRL possesses in a structured, common and machine-readable form. This can be requested for personal use as well as to pass it on to another data controller than SMOKERSHOP - ESQW SRL. If it is technically possible for us, you can also request the electronic transmission of your personal data to another company. The procedure for exercising this right can be consulted under point g.
g. Procedure for exercising rights
If you wish to exercise the aforementioned rights, you must send the request, whether or not justified, together with proof of identity, in particular a copy of the front of your identity card, by post or by e-mail to: SMOKERSHOP - ESQW SRL
Rue de la Croix Rouge 1
7740 Pecq
KBO: 0827.695.456
Mail: please use our contact form.
h. Declaration and competent body in case of infringements
If you believe that the above rights are not respected by us and wish to lodge a complaint, you can contact the Data Protection Authority:
Data Protection Authority
Drukpersstraat 35, 1000 Brussels
Tel:+32 (0)2 274 48 00
Fax :+32 (0)2 274 4835
contact@apd-gba.be