1. INTRODUCTION

SRL ORÉ, whose registered office is located at Avenue Victor Jacobs 8-10, 1040 Etterbeek, Belgium, registered with the Crossroads Bank for Enterprises under number 1002.260.715, as data controller, attaches great importance to the protection and respect of your privacy.

The purpose of this privacy policy is to explain how SRL ORÉ

- collects, uses and stores personal data;

- transfers or discloses such data;

- undertakes to respect your data protection rights;

“Personal data” means any personal data concerning you, i.e. any information that allows you to be identified directly or indirectly as a natural person.

“Data processing” means any operation or set of operations which is performed on your personal data. The concept of processing covers, among other things, all aspects related to the collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by dissemination or otherwise making available, alignment or combination, as well as archiving, erasure or destruction of such personal data.

In no case does this declaration modify the contractual conditions that may exist between you and SRL ORÉ, which remain unchanged.

SRL ORÉ processes your data in complete transparency and in compliance with all applicable laws concerning data protection and privacy, including the “GDPR” (Regulation 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data).

2. PERSONAL DATA COLLECTED

SRL ORÉ may collect your personal data when you visit our website or our social networks during your browsing or when you purchase our products, use our services, participate in a survey or competition or when you contact us.

The categories of information we may collect are as follows:

● identification data: first and last name, gender, date of birth, number and information contained on your identity card and/or passport, bank details and possibly company number;

● contact details: personal address, email address, telephone numbers;

● electronic identification data and other information we collect through automated means when you use our Online Services (website, social media or applications). We collect data through automated means through your browser or device, through the use of cookies and other technologies for tracking visitors to the Website (including audience analysis), including your IP address, MAC address, your browsing habits, the Products and Services you like and the contents of your abandoned shopping cart. Please see our Cookie Policy (hyperlink) for additional information

● data linked to your account : to create your account you must provide information such as names, gender, date of birth, we also keep all other relevant information linked to your purchases (date and amount of your purchases, products purchased, etc.);

● any other information you have provided to us;

Personal information relating to your physical and mental health, suspected offences, or convictions for criminal offences is considered "sensitive" personal data under applicable data protection laws. We will only process this data if you have given your explicit consent, or if necessary, or if you have deliberately made this data public.

In order to verify and/or complete our databases, information may be collected directly from you or, in particular, from the following sources:

- publications made accessible by official authorities;

- databases made public by third parties;

- from third parties such as other agencies, our clients and our suppliers;

- websites, social networks containing information that you have made public

Data is also collected through the deposit of cookies and tracers on the user's terminal ( Cookie Policy ) (hyperlink)

3. FOR WHAT PURPOSES IS YOUR PERSONAL DATA USED AND WHY

We use your personal data:

To perform our obligations to you: We use this data to enter into and perform our contracts, including: providing you with the products, services and information you have requested, including managing and processing your requests, queries or complaints; to enable you to purchase our products; to participate in our competitions or campaigns targeting potential customers, to respond to your request for customer service offers, to answer your queries, to provide you with essential information regarding our products and services that you have requested; for billing; etc.

For legitimate interests

Your data is also processed to promote our products and services, to communicate with you, by email, post, social media or otherwise for direct marketing or other commercial purposes, for satisfaction surveys and to help us improve your and our experience, for customer and after-sales services.

We may also use your data to provide updates about changes to SRL ORÉ's policies, terms and conditions and any other matters we may need to communicate to you, to analyze your online interactions (collected using cookies), for the purpose of improving commercial proposals, for and during the resolution of all disputes, claims or investigations in relation to the use of the Site, for the establishment of statistical and commercial analyses, etc.

To comply with our legal obligations

The personal data we collect may be used in the context of compliance with a legal obligation to which we are subject, in particular control bodies, tax authorities or investigative bodies.

Only persons aged 16 or over may give their own consent. For persons under 16, parental or legal guardian consent is required.

You can withdraw your consent at any time.

4. SOCIAL NETWORKS

When you are active on the various social media platforms (Instagram, Pinterest, Tik Tok, etc.), you must make choices about how you share Personal Data on your respective profile(s) on these social media.

SRL ORÉ is subject to the privacy policies of these social media platforms. You should therefore read the applicable privacy statements and terms of use of your Personal Data on these social media platforms.

Indeed, depending on the choices you have made in your settings on these different social media platforms, certain Personal Data may be shared with SRL ORÉ.

5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We cannot retain your personal data beyond the time necessary for the processing for which it was collected. Specifically, we distinguish between a retention period and an archiving period.

§ The retention period is the maximum period for which your data will be used for a specific processing operation. When it expires (either the purpose pursued has been fulfilled or has disappeared, or your right to object has been exercised), your data is deleted from our database.

§ The archiving period meets our legal obligations (for example, to meet our accounting and tax obligations, we are required to keep your billing data for a maximum of 7 years) or the legal necessity to keep your data beyond the retention period for evidentiary purposes.

As soon as we no longer need your personal data, we will securely delete or destroy it. We also consider any options for reducing the useful life of your personal data and anonymizing your personal data so that it can no longer be associated with or identified by you, in which case we may use this information without further formality.

6. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

In order to achieve the aforementioned purposes, we may share your personal data with third parties.

For certain services, we use specialized partners who act as subcontractors. They must then follow our instructions and comply with our Privacy Policy.

We may make your personal data accessible to our clients, our legal advisors, external third-party service providers, such as IT systems, support, social media, hosting service providers and any suppliers who assist us in carrying out our activities.

7. TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (“EEA”)

In most cases, your personal data is processed within the European Union. In the case of international transfers from the EEA to a third country for which the European Commission has issued an adequacy decision recognizing that country as having a level of protection for personal data equivalent to that provided by EEA legislation, your personal data will be transferred on that basis.

For transfers to countries for which the European Commission has not issued an adequacy decision, we rely on an exemption applicable to the situation and/or we require our partners to treat your information securely and in compliance with European data protection laws.

8. HOW DO WE PROTECT YOUR PERSONAL DATA?

SRL ORÉ takes all necessary technical and organizational measures to protect your personal data against loss, misuse, disclosure, unauthorized access or alteration of said data.

SRL ORÉ is committed to limiting access to personal data to situations where such access is essential. The number of our company's employees who have access to your personal information is limited and carefully selected. These employees have access to your personal information only as long as they need this information to properly perform their duties. These employees have been trained and informed of their data protection obligations.

Furthermore, we apply various technical measures to protect your data, including, among others, password protection, hard drive encryption software, firewalls, antivirus software, intrusion and anomaly detection, and access controls for our employees. In the event of a data leak with negative consequences for your personal data, you, as a customer, will be personally notified under the circumstances provided for by law.

In addition, these security measures are regularly reviewed and adapted to ensure an adequate level of protection.

9. LINK TO SOCIAL NETWORKS

Our website contains links to social media sites that we use (Facebook, LinkedIn, Twitter). If you follow a link to any of these social media sites, please note that these sites have their own privacy policies and that we are not responsible for these policies. We encourage you to read the terms of these policies before sending any personal data to these websites.

10. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

Right to information

You have the right to obtain clear, transparent, understandable and easily accessible information about how we use your personal data and your rights.

Right of access

You have the right to access the personal data we hold about you and obtain a copy of the personal information we hold about you in order to check that we are lawfully processing that data.

We may require payment of a reasonable fee, which takes into account the administrative costs incurred in providing the information. Requests that are manifestly unfounded, excessive or repeated may not receive a response.

Right of rectification

You have the right to require that your personal data be rectified if it is inaccurate or out of date and/or completed if it is incomplete.

Right to erasure (or “right to be forgotten”)

In certain cases, you have the right to obtain the erasure or deletion of your personal data. This is not an absolute right, as we may be required to retain your personal data for legal or legitimate reasons.

Right to restriction of processing

You have the right to request that we restrict the processing of your personal data. This right applies in specific circumstances, namely:

§ when you contest the accuracy of the personal data we process about you. In this case, our processing of your personal data will be restricted for the duration of the verification of the accuracy of the data;

§ when you object to our processing of your personal data for the purposes of our legitimate interests. You can request that the data be restricted while we verify our grounds for processing your personal data;

§ when your data has been unlawfully processed by us, but you prefer that we limit their processing rather than erase them;

§ when we no longer need to process your personal data but they are still necessary for the establishment, exercise or defense of legal claims;

Right to object

You may object to the processing of your data for reasons related to your personal situation. SRL ORÉ will cease processing your personal data unless it can demonstrate that there are compelling legitimate grounds for the processing that override your right to object. You have the absolute right to object to the processing of your personal data for direct marketing purposes.

Right to data portability

You have the right to request the transfer of your data to you or to another controller in an electronic and structured format where technically feasible. This right only applies to data you have provided, where the processing is based on your consent or a contract, and is carried out using automated processes.

Right to withdraw your consent

If you have given your consent to the processing of your personal data, you can withdraw it at any time.

How to exercise your rights?

To exercise your rights, you must send us a written request and proof of identity, by mail to La SRL ORÉ, whose registered office is located at Avenue Victor Jacobs 8-10, 1040 Etterbeek, Belgium, registered with the Crossroads Bank for Enterprises under number 1002.260.715, or by email to contact@adorecosmetics.be We will respond as soon as possible, and at the latest 1 month after receipt of the request (subject to any extensions granted to us by law).

 11. Changes to our Privacy Policy

In a world of constant technological evolution, this Privacy Policy may be subject to change. We encourage you to review the latest version of this document on our website and we will notify you of any substantial changes via our website or other usual communication channels.

12. Questions and Complaints

If you have any questions regarding the use of your personal data as set out in this Privacy Policy, you can contact us by mail addressed to SRL ORÉ, whose registered office is located at Avenue Victor Jacobs 8-10, 1040 Etterbeek, Belgium, or by email at contact@adorecosmetics.be If you are not satisfied with the processing of your personal data by SRL ORÉ, you have the possibility to lodge a complaint with the Data Protection Authority (https://www.privacycommission.be/).

Last updated: March 2024