STARWATCH (hereafter “STW”) is committed to respecting your privacy. STW has created this confidentiality policy (“Confidentiality Policy”) to lay down the terms governing the collection, the use and the communication of personal data (specifically any information that allows you to be identified, such as first name, family name, sex, mother tongue, date of birth, postal address (for delivery and billing), telephone number, e-mail address, bank card information, order/purchase history, repair history, IP addresses, preferences) on its site www.starwatch.watch , its mobile application and its social networks (Instagram, Facebook and Twitter). STW takes all reasonable measures to protect your information from misuse and to keep it safe. By communicating personal data to us, knowing our Confidentiality Policy, you accept its terms and conditions. Any significant change which reduces the protection of your rights will only be effective after your explicit consent has been received.
Your personal data is processed by STW (enterprise number: 0733.900.515).
To contact us:
Address: Avenue Winston Churchil 82, 1180 Brussels, Belgium
E-mail of the Data Protection Officer : firstname.lastname@example.org
Tel.: +32-(0)2 850 64 44
2. What are the categories of personal data that we can process?
It is any information such as first name, family name, sex, mother tongue, date of birth, postal address (for delivery and billing), telephone number, e-mail address, bank card information, order/purchase history, repair history, IP addresses, preferences you have transmitted to us at the time of: (i) an online purchase, (ii) your registration to receive the newsletter, promotional offers and participation in contests, (iii) your voluntary communication, (iv) the participation in contests. We also store the date on which the personal data has been communicated and, where appropriate, the date on which a change was made. Ensure that you do not send or communicate to us any personal data of third parties or sensitive data (e.g. social security number, information about ethnic and racial origin, political views, religious beliefs or other, health, criminal history or trade union membership). Any information relating to persons under 16 years of age must have the consent of their parent or legal guardian. STW reserves the right to require, at any time, proof of parental consent to allow the processing of personal data relating to minors.
Information about your interests or your preferences
The personal data stored can also contain other information, such as your product preferences and information about areas of interest you have communicated to us in the promotional campaigns, contests, etc.
Information relating to your purchases – recommendations
The personal data stored can contain transaction information relating to your purchases, such as the items purchased, the date of purchase, the returns, if any.
We can also store the replies or comments about purchased products which we receive from you as part of satisfaction surveys or any complaint, recommendation you send us.
Information relating to cookies and to similar techniques
When you visit our website or our web shop, we can store certain non-personal information on the basis of the cookies we place.
For more information, please refer to our “Cookies Policy”.
3. For what purpose do we use your personal data and what is the legal basis of this processing?
The personal data provided by you to us prior to 25th May 2018 is kept by STW because there is a legitimate interest to provide you with information that may be of interest to you regarding our products/services, promotional offers, direct marketing and contests (legal basis: article 6.1.f) of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereafter “GDPR”). You are, of course, able to object at any time by contacting us.
STW uses your data:
• with your consent (legal basis: article 6.1 a) of the GDPR):
◦ when you contact us by any means whatsoever, for example for a question relating to our products, to help you find a shop near you, to subscribe to our newsletter and to receive promotional offers, direct marketing and contests and/or to offer you customer service;
◦ to send you important information relating to the website and/or any other administrative information;
◦ when you connect to our social networks;
◦ to allow you to receive information that may be of interest to you regarding our products/services, website, newsletter, promotional offers, direct marketing and contests, and to manage these activities;
◦ to facilitate our internal activity, specifically data analysis, checks, development of new products, improvement of our website and of our services, identification of utilisation trends and the effectiveness of our promotional campaigns based on information you freely provide to us.
You can withdraw your consent at any time (see below, point 8).
• because there is a legitimate interest (legal basis: article 6.1 f) of the GDPR)
◦ when you added product(s) in your basket but did not finalize the order, we will remind you the same
• as part of the performance of your order, purchase or repair contract (legal basis: article 6.1 b) of the GDPR):
◦ for following up on and processing your order;
◦ for following up on, repairs and handling complaints and returns;
◦ for general client management, including accounting.
If this data is not provided to us, we won’t be able to process your order/repair.
• to fulfil the legal obligations to which we are subject (legal basis: article 6.1 c) of the GDPR):
We are also subject to tax and accounting obligations requiring the storage and transmission of certain personal data of public authorities and governments.
• to the extent we deem necessary or appropriate (legal basis: article 6.1 f) of the GDPR): a) to submit to any judicial proceeding; b) to enforce compliance with our terms of service; c) to protect our activities; d) to protect our rights, our privacy, security or property, yours or that of third parties; and e) to allow us to bring any actions or to limit the loss we might suffer.
4. Can your personal data be transmitted to a third party?
Your personal data can be communicated to our subcontractors as part of work done by them on our behalf (customer service, marketing service, conducting of a survey, applications of social networks for advertisements, order fulfilment including delivery service and carrier, execution of payment by card, fraud check, repair of products, processing of payment cards, e-mail delivery services, IT providers, accommodation, audit service, etc.) only on the basis of our instructions, to the exclusion of any other use (notably for the benefit of a third party). These subcontractors are contractually obliged to keep your personal data confidential and to take measures to protect your personal data. The subcontractors we use may send you information to promote or improve the services provided.
Your personal data may also be communicated to third parties (i) as long as STW is empowered and/or required to do so by law and/or another regulation, or is invited to do so by a public institution or any other regulatory authority (ii) in case of reorganisation, merger, sale, joint venture, assignment, transfer or any other disposal of all or part of our business, our assets or shares (including as part of a bankruptcy or all similar proceedings) in a confidential manner.
Please note that when you freely share data, information or documents on the Internet and social networks (e.g. personal data contained in photos, stories, comments and videos), these will no longer be private and can become public information, accessible to the general public.
5. Transfer of personal data outside the European Union
Your personal data is transmitted inside and outside the European Union. However, your personal data is protected by specific contractual obligations, in accordance with the requirements of the GDPR (standard contractual clauses of the European Commission) in order to ensure that your personal data has a level of protection equivalent to that of the European Union.
6. How long do we keep your personal data?
Your personal data is kept for the time necessary to achieve the objects set out in the Confidentiality Policy, with a maximum of three years, except if a longer retention period is permitted or required by law.
7. How do we protect your personal data?
STW has put in place technical and organisational measures to protect the personal data you provide to us against any unauthorised access and use. Your personal data is processed confidentially and only by the people necessary to achieve the purpose required. The transactions that occur on the site www.starwatch.watch are protected by an encrypted system SSL. However, please note that no data transmission over the Internet is 100% safe and that all information communicated online can potentially be collected and used by persons other than the intended recipient.
STW will notify any personal data breach to the Privacy Protection Commission in accordance with the GDPR.
8. What are your rights? How can you exercise them?
In accordance with the GDPR, you have, free of charge, a right of access, a right to rectification, a right to erasure and a right to restriction of processing of your personal data (without prejudice to the lawfulness of the processing prior to the withdrawal thereof and to the legal obligations that would oblige us to keep your data). You have a right to portability of your personal data.
Your Right to Object
You have the right, at any time and without justification, to object to the processing of your personal data for direct marketing purposes.
To exercise these rights, you must send us a written request, accompanied by a copy of your identity card, to this address: Place Mc Auliffe 34, 6600 Bastogne, Belgium or to the e-mail address www.starwatch.watch. We will reply to your request to exercise your rights as soon as possible.
Additionally, you may at any time appeal to the Privacy Protection Commission at email@example.com if you believe personal data is processed wrongly.
9. Third-Party Sites – Links
STW proves links to other websites/organisations. The Confidentiality Policy does not cover, and STW is not responsible for the gathering, the use or the communication of information by third parties on other websites, including social networks, or offline. We advise you to carefully review the confidentiality and cookies policies of the third-party websites and to contact their operators if you have any questions concerning the use of your information.
If you make a purchase on our website, you will be directed to the webpage of Ingenico FS, and your financial information is managed by the financial institution Ingenico FS and their own confidentiality/cookies policy applies.