PRIVACY POLICY

SUMMARY: 2-MINUTE-READ

We take our obligation to protect your privacy seriously!

That is why we provide you with this 2-minute summary, containing the necessary information on how we process your Personal Data.

What you need to know:
First of all: you will always remain the sole owner of your data!

To whom does this Privacy Notice apply?

This Notice applies to any person whose Personal Data JOTERIE may collect, use, share or otherwise process, and in particular:

• Visitors and users of the JOTERIE website (www.joterie.be);
• (Representatives of) business partners working with JOTERIE in connection with JOTERIE's business activities;
• (Representatives of) Suppliers of goods or services, IT-suppliers, consultants, lawyers, accountants and other third parties in contact with JOTERIE;
• Applicants applying for a position at JOTERIE;
• All Other Persons from whom JOTERIE may process Personal Data.

What information do we collect about you?

• When you contact us or enter into a contract with us as a (prospective) business partner or supplier, we may collect and process your contact data (such as your (employer/company) name, e-mail address or telephone number); financial data (such as bank account numbers and transaction details) and contractual data (such as the date and type of our agreement).
• By applying for a position at JOTERIE, we collect the information you provide to us, such as identification details, CV and cover letter.
• If you contact us through any medium, we collect information about the communication you have had with JOTERIE, including content and technical data.
• Finally, we use cookies to collect information about your use of our Website.

Why do we collect this information?

• To establish and/or maintain our contractual relationship.
• To provide you with requested information, respond to your requests and carry out our business activities.
• To enable you to make purchases on our webshop
• To provide customer support.
• To evaluate your job application.
• Finally, to improve our Website.

Who has access to your data?

• Only that part of JOTERIE’s team that needs your data for its operations has access to your information.
• Furthermore, we use some suppliers and service providers, such as, but not limited to, those offering computer security services, digital solutions and web hosting services. These parties are required by law to ensure your privacy at all times and will only process personal data in accordance with our purposes.
• We may share your data to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
• Finally, a third party may be commissioned to process personal data. However, they can only do so for the abovementioned purposes, on our behalf and after signing a data processing agreement.

What are you in control of?

You can ask us to change or delete your data at any time. To do so, please send us an e-mail to info@morobe.com and follow the procedure described in our full Privacy Notice under article 5.7.
You can also request a copy of all the information we have collected about you at any time by sending an e-mail to the same address.

What do we do to protect your data?

• We adopted the required safety measures on a technical and an organizational level;
• Your data is stored on high-security servers within the European Union;
• In order to improve our services, JOTERIE may use the data you provided. However, at all times, JOTERIE shall use this data in a GDPR-compliant form, using state of the art software and solutions;
• We have implemented internal procedures to ensure the confidentiality of our IT-infrastructure and to make sure it is managed responsibly.

If you want to know more: we invite you to read our entire Privacy Notice as set out below, where everything is further explained in detail.

Joterie PRIVACY NOTICE

Version 1.0 – 30 August 2023

Article 1 - GENERAL

1.1. JOTERIE, (hereinafter "we", "us", "our", " JOTERIE "), with its registered office at soetestraat 3, 8840 Staden, Belgium, assumes responsibility for the processing of your Personal Data as "Controller", including the use of the JOTERIE website (www.joterie.be) (hereinafter: “Website”).

Our Privacy Notice can be subject to future amendment and modification. In this event we will notify you with an invite to take a look at these changes, which we will clearly indicate in the Privacy Notice.

1.2. In our Privacy Notice, "Personal Data" means any information relating to an identified or identifiable natural person. JOTERIE may collect, use, share or otherwise process Personal Data of individuals belonging to the following categories:

1. Visitors and users of the JOTERIE Website (hereinafter "Visitors");
2. Customers of JOTERIE who make a purchase on our webshop (hereinafter "Customers”);
3. (representatives of) Business Partners working with JOTERIE in the context of its business activities (hereinafter "Business Partners");
4. (Representatives of) Suppliers of goods or services, including Suppliers of materials, IT Suppliers, consultants, lawyers, accountants and other third parties working with JOTERIE (hereinafter "Suppliers");
5. Applicants applying for a position at JOTERIE (hereinafter "Applicants");
6. All Other Persons from whom JOTERIE may process Personal Data (hereinafter "Other Persons").

1.3. The collection and processing of Personal Data is governed by strict conditions, enforced by the law. JOTERIE acts in accordance with :

1. the EU Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC; (hereinafter “GDPR”); and/or
2. all (future) Belgian applicable laws regarding the implementation of the GDPR or regarding the processing of Personal Data.

1.4. Accessing or using our Website implies your full and unreserved understanding of this Privacy Notice. This means that you are fully aware of how JOTERIE collects, uses and processes your Personal Data in accordance with the provisions of this Privacy Notice and for the purposes set out in this Privacy Notice.

1.5. This Privacy Policy applies only to the pages hosted on our Website and to the business activities conducted by JOTERIE. It does not apply to the pages and websites of third parties to which JOTERIE may refer or link and whose privacy policies may differ. JOTERIE will therefore not be responsible for the data contained on or processed by these third-party websites.

Article 2 – CATEGORIES OF PERSONAL DATA PROCESSED

2.1. JOTERIE may process the following categories of Personal Data for the purposes set out in Article 3:

Data Category	Relevant Data Subjects	Details	Context
Category 1 (Professional) identification data	Business partners Suppliers Applicants Other persons	First name, surname, phone number, e-mail address, address and country; Information about your employer or company, such as company name, business address, billing details and VAT number; Where applicable: social media information, such as your (company) username/names on your social media; Information about our/your communications, including content, IP address and technical details.	By contacting us, via phone, e-mail or any other communication channel; By subscribing to our newsletter By (considering) entering into a business relationship with us (e.g. when you enter into a contract with us as a business partner, supplier, etc.); By giving out your business card; Through social media (for example, when you follow us or contact us on LinkedIn).
Category 2 Billing & purchase information	Customers	First name, surname, e-mailadres, billing address, shipping address; Telephone number (otional); Company name (optional); VAT number (optional) ; Payment status (paid / unpaid); (Credit) card status (valid / not valid / almost expired).	By making a purchase via the webshop on our Website
Category 3 Contractual data (to the extent that it constitutes Personal Data)	Business partners Suppliers	Data relating to agreements you have entered into with JOTERIE (e.g. date and type of agreement, financial data and other Personal Data relating to the agreement ).	By entering into an agreement with us.
Category 4 Your data as an applicant	Applicants	First name, surname, phone number, e-mail address, address, (optional) photo and country; CV and cover letter.	By applying for a position or internship at JOTERIE.
Category 5 Your communication via our business relationship or Website, or in the context of customer support	Visitors Business partners Suppliers Customers	Information about your communications with JOTERIE, through our Website or as a result of our business relationship, including technical details and content; Information about your communications with JOTERIE, in the context of customer support, including technical details and content.	By contacting us, by phone, e-mail or any other communication service; By (considering) entering into a business relationship with us and communicating with us in that context.
Category 6 Information about your visit and use of our Website	Visitors	By visiting our Website, the accessed servers automatically record certain data, through log files and by setting cookies. Such data may include: Version of webbrowser; IP address; Cookie information; How you interact with the site;	By setting cookies (see Article 8 - Cookies) and keeping log files of our Website.

 

Article 3 - LEGAL BASIS AND PURPOSE OF PROCESSING

We process your Personal Data only when we have a specific purpose and a lawful basis for doing so. Moreover, we only process what is relevant to pursue each specific purpose in question, and in particular:

3.1. General purposes

Data Category	Lawful basis	Target
Category 1 (Professional) identification data	Necessary for the performance of the contract we have entered into or are considering entering into with you and/or Your consent and/or Our legitimate interests	Personal Data is processed by JOTERIE to provide our services, conduct our business activities, manage the contractual relationship we may have with you, answer your queries, provide information, advise you on our services, etc. Depending on the specific circumstances, some of these processing activities will be necessary for the performance of a contract we have entered into or will enter into with you. Others will be necessary to pursue our legitimate interests. Finally, if required by law, we will seek your prior consent before processing certain of your Personal Data.
Category 2 Billing & purchase information	Necessary for the performance of the contract we have entered into or are considering entering into with you and/or Your consent	Billing and purchase information will be processed by JOTERIE in order to enable Customers to make a purchase on our webshop. Any optional information provided by Customers will be processed on the basis of their consent.
Category 3 Contractual data (to the extent that it constitutes Personal Data)	Necessary for the performance of the contract we have entered into or are considering entering into with you	Contractual data will be processed by JOTERIE to manage the commercial and contractual relationship we have with you (e.g. for invoicing purposes).
Category 4 Your data as an applicant	Necessary for the performance of the contract we have entered into or are considering entering into with you and/or Our legitimate interests and/or Your consent.	Applicant data is processed by JOTERIE to evaluate your application and pursue a recruitment policy. Depending on the specific circumstances, some of these processing activities will be necessary for the performance of the contract we are considering entering into with you. Others will be necessary to pursue our legitimate interests related to the improvement of our recruitment policy and process. Finally, if required by law, we will seek your prior consent before processing certain of your Personal Data.
Category 5 Your communication via our business relationship or Website, or in the context of customer support	Necessary for the performance of the contract we have entered into or are considering entering into with you and/or Your consent	Your communication may be processed by JOTERIE if necessary in connection with the performance of the agreement we have entered into, are considering entering into with you or to provide customer support JOTERIE may also process your communication based on the consent you have given by actively contacting us through our Website.
Category 6 Information about your visit and use of our Website	Your consent and/or Our legitimate interests	Information about your visit and use of our Website is processed by JOTERIE in order to: facilitate the availability and use of the Website; analyse, adapt and improve the content of the Website; personalise your experience on the Website; maintain and improve the security of our Website; generate statistics. For more information, please refer to Article 8 – Cookies.

 

3.2. Direct marketing

If JOTERIE has obtained your Personal Data in the context of providing products or services, JOTERIE may use your Personal Data to send you, via e-mail, promotional material regarding similar services we may offer. This is based on JOTERIE legitimate interest.

Other promotional material, concerning non-similar services we may offer, will only be sent to you if you have given us your prior consent to do so.

We may also transfer some of your Personal Data to its Data Processors, for direct marketing purposes relating to JOTERIE services.

We will at all times offer you a GDPR-compliant way to opt out of receiving such emails at any time, free of charge and without motivation, for example by clicking the unsubscribe button at the end of every promotional email or by sending an email to info@morobe.com.

3.3. Transfer to third parties

JOTERIE treats Personal Data as confidential information and will not disclose or communicate it to third parties under any condition or for any purpose other than those stated in this Privacy Notice, or under the conditions under which the law requires us to do so.

JOTERIE may disclose your personal data to third parties to the extent necessary to carry out our business activities, including but not limited to Suppliers and service providers offering accounting, IT support, hosting, computer security or other specific services.

These third parties have provided JOTERIE with guarantees as to the application of appropriate technical and organizational measures so that the processing of your Personal Data would comply with the applicable data protection regulations.

JOTERIE will not sell, rent, distribute or otherwise make your Personal Data commercially available to third parties, except as provided in this Privacy Notice, or when you have given your explicit prior consent.

In the event of total or partial reorganization of JOTERIE, transfer of JOTERIE’s activities or in the event of JOTERIE being declared bankrupt, your Personal Data may be transferred to new entities or third parties. JOTERIE will inform you in advance of the fact that JOTERIE transfers your Personal Data to such third parties.

3.4. Legal requirements

In extraordinary circumstances it may occur that JOTERIE is obliged to transfer your Personal Data following a court order, or in order to comply with imperative laws and/or regulations. JOTERIE will, if reasonably possible, try to inform you beforehand of such obligation to transfer your Personal Data, unless revealing this information is subject to legal constraints.

Article 4 – DURATION OF THE PROCESSING

JOTERIE will retain your Personal Data for the duration necessary to fulfil the purposes listed in Article 3 of this Privacy Notice, including for as long as it is essential to the contractual relationship between you and JOTERIE.

JOTERIE may also retain your Personal Data to comply with applicable legal requirements, including requirements to retain your Personal Data further after termination of the contractual relationship between you and JOTERIE. These include applicable limitation periods for billing, payment, accounting, tax and regulatory compliance purposes. The retention periods set out below may therefore be deviated from if such legal obligation applies.

Retention periods:

Data	Retention period
Category 1 (Professional) identification data	We keep your identification data for as long as necessary to communicate with you, i.e. never longer than two (2) years after the first request or contact. In case of a contractual relationship, we will not retain your identification data for longer than necessary for the purposes set out in this Privacy Notice, which may be up to seven (7) years after the end of the contractual relationship.
Category 2 Billing & purchase information	We keep your contractual data for as long as necessary for the purposes set out in this Privacy Notice, i.e. for seven (7) years after the end of the contractual relationship.
Category 2 Contractual data (to the extent that it constitutes Personal Data)	We keep your contractual data for as long as necessary for the purposes set out in this Privacy Notice, i.e. for seven (7) years after the end of the contractual relationship.
Category 3 Your data as a job applicant	We do not retain your data as an Applicant for longer than six (6) months after the last qualitative contact with you as an Applicant.
Category 4 Your communication via our business relationship or Website, or in the context of customer support	We keep your communications through our business relationship for as long as necessary to communicate with you, i.e. never longer than two (2) years after the first request or contact. In case of a contractual relationship, we do not retain your communications through our services for longer than seven (7) years after the end of the contractual relationship.
Category 5 Information about your visit and use of our Website	With regard to cookies, please refer to our Cookie Notice (as set out in Article 8)..

 

Article 5 - YOUR RIGHTS

5.1. Right of access and right to obtain a copy

You have the right to request access to your Personal Data at any time and to be informed about the purpose of processing by JOTERIE.

5.2. Right to rectification, erasure or restriction

You always have the right to ask us to rectify your Personal Data if you think it is incorrect.

You can also request to restrict the processing of your Personal Data if you believe your data is inaccurate and you have subsequently informed us accordingly.

In addition, you have the right to ask us to delete your Personal Data to the extent we have not been able to anonymize it.

Furthermore, you acknowledge that a refusal to share data or a request to erase your data will make the delivery of several JOTERIE services impossible.

5.3. Right of objection

You have the right to object to the processing of your Personal Data if you have legitimate reasons to do so and communicate them to us.

You also have the right to object to the use of your Personal Data for direct marketing. In this case, you do not need to provide a specific reason for your objection.

5.4. Right to data portability

You have the right to request to obtain your Personal Data processed by JOTERIE in a structured, commonly used format and/or to transfer such data to another controller.

5.5. Right to withdraw consent

Where the processing of your Personal Data by JOTERIE is based on your prior consent, you have the right to withdraw this consent at any time.

5.6. Automated decisions and profiling

You have the right to request that we do not subject you to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you.

5.7. Exercising your rights

You can exercise your rights by contacting us with a copy of the essential parts of your proof of identity, such as name and date of birth, attached:

Either through email to info@joterie.be

Or by mail to,
JOTERIE OBJECTS,
Soetestraat 3
8840 Staden
Belgium

5.8. Right to file a complaint

You have the right to lodge a complaint with the data protection supervisory authority:

Data protection authority,
Drukpersstraat 35, 1000 Brussels, Belgium
Tel: +32 (0)2 274 48 00, Fax: +32 (0)2 274 48 35,
E-mail: contact(at)apd-gba.be

This is without prejudice to proceedings before the civil courts. If you are from an EU member state other than Belgium, you can also complain to your national data protection authority (a list of the data protection authority for each EU member state can be found here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm).

If you have suffered damages as a result of the processing of your Personal Data, you may file a claim for compensation.

Article 6 - SAFETY AND CONFIDENTIALITY

JOTERIE has taken security measures that are appropriate on a technical, organizational and physical level to prevent the destruction, loss, falsification, modification, unauthorized access or notification of Personal Data accidentally to a third party, as well as the unauthorized processing of such data.

If these events should nevertheless occur and affect your Personal Data, JOTERIE will, where appropriate and permitted by law, notify you of the breach without undue delay, including a brief description of the potential consequences and a recommendation for measures to mitigate the potential negative impact of the breach.

JOTERIE is in no way liable for any direct or indirect damage caused by an unlawful or improper use of the Personal Data by a third party.

At the same time, you also share responsibility for maintaining your privacy, for example by not allowing third parties to see your confidential communication(s).

Article 7 - APPLICABLE LAW AND JURISDICTION

This Privacy Notice is administered, interpreted and implemented in accordance with Belgian law which is exclusively applicable to any potential dispute.

The courts and tribunals of Antwerp shall have exclusive jurisdiction to settle any dispute arising out of or in connection with the interpretation or implementation of this Privacy Notice.