PRIVACY POLICY

This policy contains the guidelines that CLASSICA INTERNATIONAL applies in processing personal data, in accordance with the objectives and obligations arising from the General Data Protection Regulation, i.e. Regulation (EU) 2016/679 of 27 April 2016 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (‘GDPR’).

CLASSICA INTERNATIONAL, hereinafter CLASSICA INTERNATIONAL, with registered office at De Merodelei 1 , 2600 Antwerp, Belgium registered under VAT number 00152239992, acts as data controller.

CLASSICA INTERNATIONAL asks you to read this privacy policy carefully, as this document contains essential information about how your personal data are processed.

I. General

CLASSICA INTERNATIONAL confirms that it complies with the current legislation, namely the Law of 8 December 1992 on the protection of privacy and its implementing decisions and the European General Data Protection Regulation of 27 April 2016.

II. Definitions

(a) “Personal data”: all information about an identified or identifiable natural person (“the data subject”). A natural person is regarded as identifiable if he or she can be identified directly or indirectly, in particular by means of an identifier such as a name, an identification number, location data, an online identifier or one or more elements characterising the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person. Appendix 1 lists the Personal Data that the Processer will process in accordance with this agreement and the purposes for which the data are processed.

(b) “Processing”: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

(c) “Controller”: a natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of personal data.

(d) “Processor”: a natural or legal person which processes personal data on behalf of the Controller.

(e) “Sub-processor”: the subcontractor appointed by the Processor to carry out part of the processing on behalf of the Controller.

(f) “Personal data breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed, also known as a “data leak” ;

(g) “GDPR”: The General Data Protection Regulation, i.e. Regulation (EU) 2016/679 of 27 April 2016 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC.

III. Processing of personal data

Below is a summary of the personal data which are processed and the purposes for which CLASSICA INTERNATIONAL processes them, as well as the legal basis for doing so.

• In connection with the provision of services by CLASSICA INTERNATIONAL, the following personal data are processed:
  
  - Your surname and first name
  - Your address
  - Your telephone number
  - Your email address
  - Your bank account number
  - Your purchase history
  - Credit card number
• The above data are processed with a view to the performance of the agreement that you have concluded with CLASSICA INTERNATIONAL. The processing of your personal data takes place more specifically in connection with delivery to the agreed location, as well as invoicing and the monitoring of invoice payments.
• In connection with your accessing and use of our website, the following personal data will be processed:
  
  - Your IP address
  - Your browsing behaviour
  - Your email address
  CLASSICA INTERNATIONAL processes the above data with a view to optimising the content and functioning of the website, in accordance with the needs of the visitor.
  CLASSICA INTERNATIONAL justifies this processing of personal data on the basis of the legitimate interest that CLASSICA INTERNATIONAL has in offering a readily accessible, understandable, appropriate, comprehensive and relevant website.
  For more information regarding the use of CLASSICA INTERNATIONAL’s website, please refer to the cookie policy
• In connection with sending electronically newsletters, the following personal data are processed:
  
  - Your surname and first name
  - Your email address
  The above data are processed with a view to inform you about current promotions and special offers.
  CLASSICA INTERNATIONAL justifies its processing of these personal data on the legitimate interest it has in providing high-quality information about its products.
  You may object to the use of your personal data for direct marketing purposes free of charge at any time. To do so, simply send your request to privacy@victrix.be.

CLASSICA INTERNATIONAL undertakes not to use your personal data for any purpose other than those mentioned above, unless you have given your express consent to do so. CLASSICA INTERNATIONAL guarantees that your personal data will not be retained if it no longer requires them for the provision of services, or if it is no longer subject to a statutory retention obligation.

You are not obliged to transfer your personal data to CLASSICA INTERNATIONAL. However, you should be aware that a refusal to provide certain basic data to CLASSICA INTERNATIONAL may result in it being unable to provide you with certain services.

IV. Retention period

Your personal data which are processed by CLASSICA INTERNATIONAL will be kept for as long as you are registered as an active customer.

If your user profile shows no activity for an uninterrupted period of five years, the profile, including all associated personal data, will be deleted by CLASSICA INTERNATIONAL.

V. Rights

As a data subject whose personal data are processed, you have a number of rights with regard to the processing operations carried out by CLASSICA INTERNATIONAL.
To exercise these rights, you should contact us at privacy@victrix.be.

CLASSICA INTERNATIONAL is obliged to respond to this request within a period of one month. You will only receive a response within the set period if you send your request for the exercise of your rights to privacy@victrix.be using the above-mentioned procedure.

You have the following rights:

• Right of inspection and access
  
  You have the right to access your personal data and the right to check how they are being used via privacy@victrix.be. You may request a free copy of your available personal data at any time by sending an email to the address mentioned above, provided you include proof of identity by attaching a copy of your identity card to your request.
• Right to correction, erasure and restriction
  
  Except for those personal data that must be processed in connection with the performance of an agreement, in connection with the services we provide or in connection with storage because of a legal obligation, you may indicate which personal data may not be processed at all or may only be processed for a limited number of processing operations. In addition, you may request that personal data which you do not wish to be processed in whole or in part, be deleted. You may also ask to check and, if necessary, correct your personal data.
• Right to object, automated decisions and profiling
  
  You may oppose the processing of your personal data at any time if your objection is based on serious and legitimate reasons. If you wish to oppose the use of your personal data for direct marketing purposes, you do not have to give any reasons for this.
  
  The processing of personal data by CLASSICA INTERNATIONAL is not carried out on the basis of automated decisions; in other words it is not carried out without human intervention.
  
  CLASSICA INTERNATIONAL does not engage in profiling on the basis of the available personal data.
• Right to portability
  
  Under the conditions stipulated in the GDPR, you have the right to obtain your personal data in a structured, commonly used and machine-readable form. You may ask CLASSICA INTERNATIONAL to transfer your data in this way to another Controller.
• Complaints
  
  If you believe that your rights as a data subject are being infringed by or during the processing of your personal data, you have the right to make a complaint to the Data Protection Authority, Drukpersstraat 35, 1000 Brussels, email: contact@apd-gba.be, tel. +32 (0)2 274 48 00, fax +32 (0)2 274 48 35), without prejudice to any other possibility of initiating a judicial review or seeking a judicial remedy.

VI. Transfer to third parties

CLASSICA INTERNATIONAL may pass on your personal data to subcontractors or suppliers in connection with the performance of the agreement, if it considers this necessary for its services and/or continuity.

CLASSICA INTERNATIONAL in other respects undertakes not to sell, rent, distribute or otherwise disclose your personal data to third parties, unless the communication is made to the third party under a legal obligation. In exceptional cases, mandatory laws oblige CLASSICA INTERNATIONAL to transfer your personal data to the competent government authorities. Likewise, a court order may require CLASSICA INTERNATIONAL to communicate personal data to people authorised by the order to inspect the personal data concerned.

CLASSICA INTERNATIONAL makes an exception to its non-disclosure undertaking in the event of a partial or complete reorganisation or a transfer of the company’s business operations. In such cases, your personal data will be conveyed along with the business operations to the third parties involved in the transfer and in the confidential negotiations prior to the transfer.

As far as possible, CLASSICA INTERNATIONAL will inform you of the transfer to the aforementioned third parties.

VII. Security and confidentiality

CLASSICA INTERNATIONAL guarantees that the processing of your personal data will take place in an appropriate, correct and secure manner. If you wish, you will be informed in a transparent manner about the processing procedures and the technical and organisational measures taken to prevent any loss, falsification or unlawful alteration of or unlawful access to your personal data

VIII. Modifications

CLASSICA INTERNATIONAL reserves the right to change this policy.

If substantial adjustments are made, CLASSICA INTERNATIONAL will take all reasonable measures to notify you before the changes take effect.