Privacy policy

Introduction

At Epic Blue we attach great importance to the protection of your personal data. This privacy policy sets out how we protect your personal data and who you can turn to for more information or to invoke your legal rights.If you provide us with personal data of other persons, such as your collaborators, please do inform these persons of our privacy policy before entrusting us with their personal data. From our side we will use all opportunity we have to inform and reassure you and these persons that personal data are safe with us.We reserve our right to amend our privacy policy from time to time, if legislation or our internal practices so require. At all times you can find the current version of our privacy policy on our websiteII.

Content of our privacy policy

1. The controller of the processing

2. Purposes and legal basis for the processing of personal data

3. The personal data processed and the case being, the necessity of the provision thereof

4. Duration of the processing and retention of data

5. Categories of recipients and transfer of personal data

6. Your rights in relation to the processing of your personal data

7. Technical and organizational measures

8. Infringements

9. Contact Epic Blue in relation to data processing

1. The controller of the processing

1.1 The legal entity controlling the processing of your personal data is Epic Blue BV, a Belgian company whose registered offices are located at Asstraat 5, 3000 Leuven, Belgium. Epic Blue is registered with the Register for Legal Entities in Belgium under number 0659.871.697.Epic Blue BV is the controller of the processing of your personal data because it has determined the purposes and means of the processing, and this although this processing may be performed for the benefit of Epic Blue BV.

1.2 Epic Blue BV and the affiliated companies are hereafter referred to as “Epic Blue”, “us” or “we”.

2. Purposes and legal basis for the processing of personal data

2.1 Epic Blue processes personal data of its customers and suppliers, as well as of contact persons of its customers and suppliers for the following purposes:

1. The purpose of executing contractual relationships (including in the context of e-commerce) as well as legally required purposes that are linked to that purpose;

2. the purpose of providing support or other services;3. for direct marketing;Epic Blue processes personal data of visitors of its websites for the following purposes:1. responding to the visitor’s request sent to us via the contact page.

2. evaluating and responding to the visitor’s job application and for the management of our human resources database.Additionally, on our website we may use cookies. For more information in relation to cookies, please revert to the cookie policy to be found at said website.

2.2 The legal basis for these processing operations is respectively:

1) the purpose of executing contracts and services

1. the necessity for the performance of our contract with you.

2. the legitimate interests pursued by Epic Blue and its contract party to organize, and interact in relation to, the conclusion or performance of a contract. In our view, given the limited use made of your contact details, such interests are not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please revert to title VI below on Your legal rights in relation to privacy.

3. legal reasons (such as after sales warranty), compliance or tax and accounting reasons. The legal basis of our processing is then to be found in European or national law.

2) the purpose of direct marketing

1. the legitimate interests pursued by Epic Blue to promote sales, reinforce the relationship with the customers, enhance customer loyalty, etc.For processing activities which are in general considered little intrusive (e.g. promotion sent by regular mail), such interests are in our view not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please revert to title VI below on Your legal rights in relation to privacy.We may also invoke the same legal basis of our legitimate interest, for newsletters sent by e-mail to our own customers if your e-mail contact details were received directly from you in the context of a sale, and are only used for the promotion of Epic Blue’s own similar products. Every newsletter however carries a link allowing you to unsubscribe from the newsletter.

2. your consent.For marketing initiatives such as calling you or sending you text messages, we will always first ask your consent. The same is true for e-mail newsletters that do not comply with the aforementioned conditions.Your consent will be asked at the moment that we receive your personal data (e.g. on the website or if you visit a shop). You may revoke your consent at any moment in accordance with title VI below.

3) the purpose of responding to the visitor’s request on our websites

1. the legitimate interests pursued by Epic Blue to treat and give follow up to your request.

2. the legitimate interests pursued by Epic Blue to treat and give follow up to your job application and manage a useful and pertinent human resources database.Given your initiative to send your request via the contact page (which we assume you want us to reply to) and the limited use made by us of your contact details to reply, such interests are in our view, not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please revert to title VI below on Your legal rights in relation to privacy.

3. The personal data processed and the case being, the necessity of the provision thereof

1) The personal data you submit to Epic Blue (when placing an order, closing a contract, filing a request on the contact page of our website, visiting our offices or any other form of contact with Epic Blue, are:

Name

Address

Contract related information

Information about the company you are representing

E-mail address

Telephone and/or mobile number

Language

And the case being:

Identification number

Location data

Account number

Kind of contact person (professional customer, retail customer, student, direct sales customer) and justification thereof (e.g. VAT number, declaration of employer, diploma or certificate, student card)*

For direct customers: closing days* and times visited

Ticket information linked to customer account number

Customer wishes in relation to direct marketing

Analysis data based on purchases

Date of birth

Customer participation to trainings , services or promotions

Recordings of telephone calls to customer services

The aforementioned personal data indicated with a * have to be provided, if the customer wants to benefit from the status of a professional customer, student or direct sales customer or wants to obtain a loyalty card or purchase online. For (other) retail customers that purchase in a store, the provision of personal data is entirely on a voluntary basis.

Epic Blue may reserve specific promotions to segmented customers, e.g. based on history of purchases, kind of customer, date of birth or customer wishes.

2) The visitors of our websites additionally submit the following personal data

Data filled out on the contact page

Response to request

Curriculum Vitae and cover letters (job applicants)

other information that you provide to us

your IP address

your browser type

your mobile network provider

the following information:

uuid

the producer

the model

the platform

OS versione

OS language

OS users language

application ID’s

cookie information

information about your use of the website, including the pages you visited;

4. Duration of the processing and retention of data

1) For contract partiesWe process your personal data as long as necessary in the context of the contracts entered into with you. After termination of our active collaboration with you, your personal data are retained for as long as necessary for legal, compliance or tax and accounting reasons.We process your personal data for direct marketing purposes until you oppose or withdraw your consent to the processing of your personal data for that purpose.

2) For visitors to the website that fill in the contact page:We process your personal data as long as necessary to deal with and give follow up to your request. The data are not retained afterwards (unless the case being, in the context of another processing for another purpose as detailed in this privacy policy).Personal data that was provided by job applicants will be kept in the human resources database for a period of six months as of the date of collection. If we were to decide to keep your personal data for a longer period, we will contact you to obtain your consent.

5. Categories of recipients and transfer of personal data

5.1 Personal data retained by Epic Blue may be shared within affiliated companies for the purposes of Epic Blue set out under title II:

1. As indicated under title I, if Epic Blue BV is the controller of the processing of personal data for itself and a number of affiliated companies. To the extent that these affiliated companies participate in some of the processing operations, they do so under Epic Blue BV’s control (unless the affiliates qualify as joint controllers for legally required processings).

2. Epic Blue may communicate some personal data to affiliated companies as the affiliated companies collaborate closely on a management level. This communication is limited to what is necessary for the purposes.

5.2 To the extent that this communication of personal data would entail a transfer outside of the European Union to a country where there is no adequate level of data protection, Epic Blue will make sure that there are adequate contractual safeguards in place to protect your privacy.

5.3 Apart from the communication of personal data with affiliated companies, Epic Blue may work with the following categories of third party processors: suppliers of IT and hosting services, consultants and providers of direct marketing services. Epic Blue will make sure that all its processors have entered into appropriate processor contracts.

6. Your rights in relation to the processing of your personal data

6.1 In relation to the personal data that are processed by Epic Blue, you have a number of legal rights:•

You have a right to get access to your personal data and to have these data corrected.

You may ask Epic Blue to erase your personal data, or to restrict the processing thereof.

To the extent that the processing is based on the legal basis of a legitimate interest or the processing is done for direct marketing purposes, you have the right to oppose to that processing.

To the extent that the processing is based on your consent, you have the right to revoke your consent at any time.

You may ask to receive the personal data which you have provided to us, in a structured, commonly used and machine-readable format and transmit these to another controller.

6.2 Within a duration of maximum 1 month after receipt of your request, we will act upon your request and reply. If for some reason we cannot accommodate your request, we will inform you of the reasons thereof. If we are not in a position to identify you properly, we may ask you to provide a proof of your identity as a prerequisite to accommodating your request.

7. Technical and organizational measures

7.1 Epic Blue will take all technical and organizational measures needed to ensure the safety and confidentiality of your personal data against unwanted, unlawful and unauthorized (i) destruction, modification, adaptation or loss of personal data and/or (ii) communication of or access to personal data and/or (iii) means of processing.These measures will be in accordance with the applicable law and the risks related to the processing and the kind of personal data being processed, taking into account the state of the art and the costs they involve.

7.2. Epic Blue will implement all measures needed to conform its collaborators and personnel to its obligations concerning your personal data and shall submit a written confidentiality obligation to these collaborators who need to access the personal data.

7.3. The website may include links to other websites. Epic Blue is not responsible or liable for the privacy policy or guidelines of these other websites.

8. Infringements

8.1 Epic Blue shall inform you in case of an infringement on your personal data that causes a high risk for your rights, unless a legal prohibition would apply. More specifically Epic Blue will inform you about (i) the kind of infringement, (ii) the facts that were communicated to the competent authority and (iii) the measures taken.

9. Contact Epic Blue in relation to data processing

9.1 In order to invoke your rights under title VI, please contact us at our dedicated privacy e-mail address: info@epic.blue, or send us a letter at Epic Blue BV, Privacy, Asstraat 5, 3000 Leuven, Belgium.

Alternatively, If your sole aim is to give or revoke your consent in relation to direct marketing or modify your direct marketing preferences, you can turn to your usual shop and ask the shop manager to adjust your privacy settings.

Alternatively, if your sole aim is to unsubscribe from a newsletter, text messages or live calls, you can also click the unsubscribe link in the newsletter, reply with “stop” on a text message or ask the live caller not to call you again.

9.2 If on the other hand you have any questions, remarks or complaints in relation to our privacy policy or how we process your data, do not hesitate to contact us, either by telephone or e-mail.Compliance managerE-mail: info@epic.blue

9.3 If you have any complaints in relation to how Epic Blue processes your personal data, you may file a complaint with the Supervisory Authority: www.gegevensbeschermingsautoriteit.be