We understand that your trust in us is the most important asset of The Sunshine Club BV (hereinafter referred to as “SC” (trade name), “we” or “us”). Your privacy is therefore our priority.
This privacy statement (hereinafter referred to as the “Privacy Statement”) is applicable, among others, to (i) our website http://www.thesunshineclub.be (hereinafter referred to as the “Website”) and (ii) all (commercial) relationships between SC and its customers, prospects, and business partners.
This Privacy Statement contains, among other things, information on the personal data collected by SC, as well as on the manner in which SC uses and processes such personal data.
SC wishes to emphasise that it will at all times endeavour to act in accordance with the “Privacy Acts”, these being (i) the Belgian Privacy Act of 8 December 1992 on the protection of privacy in relation to the processing of personal data, (ii) the EU Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC, and (iii) Belgian legislation on the implementation of the aforementioned Regulation, both at present and in the future.
- Visiting this Website
- Making use of the services offered by SC
- Purchasing goods and/or products
- Registering for the newsletter
- All forms of communication with SC
- Registering for seminars, webinars, events, and similar
- Downloading blogs, e-books and similar
implies your explicit acceptance (through communication of your personal data or opt-in) of the Privacy Statement and thus of the manner in which SC collects, uses, and processes your personal data.
I. Types of personal data
SC can collect and process the following personal data:
- First name
- Email address
- Telephone number (landline and/or mobile)
- Residential address
- National registry number
- Date of birth
- Bank account number
- Driving license
- Account name
- Customer number
- Company name
- Company address
- Invoice address
- Communication preferences
- IP address
- All personal data included in the elective field on the contact form.
- All other personal data voluntarily provided to us (e.g. in your correspondence).
SC also collects anonymous information concerning your use of the Website automatically. SC will automatically keep a record of which parts of the Website you visit, for example, or which web browser you use, and which website you visited before accessing the Website. We cannot identify you on the basis of these data, but it allows SC to compile statistics on the use of the Website.
II. Manner in which personal data are collected
The following personal data are collected in relation to:
- Visiting this Website
- Collaboration with SC
- Creating an account
- Correspondence with SC (incoming or outgoing)
- Requesting a quote
- Subscription to the newsletter (whether or not via the Website)
- The use that you make of SC’s services, possibly through the Website, and possibly using a mobile device
- Registration for webinars, events, seminars, etc.
- The exchange of business cards
- The verification of your identity (e.g. when you contact the Customer Service Department)
The personal data collected by SC are expressly and voluntarily provided by you.
The provision of certain personal data may serve as a condition for the enjoyment of specific services (e.g. to have access to certain parts of the Website, to subscribe to newsletters, or to participate in certain activities and events). A clear distinction is made, in this case, between data provided on a compulsory and a voluntary basis.
III. Use of personal data
SC may use your personal data for the following purposes:
- The execution of an agreement with SC (including any follow-up with regard to this agreement)
- Answering questions (potentially submitted using the contact form)
- Optimising the quality, management, and content of the Website
- Sending newsletters
- For statistical purposes
- The creation of an account and its confirmation
- Follow-up after a meeting
- The preparation of an offer (and its submission)
- Providing support/assistance (e.g. in case of problems)
- Sending targeted marketing and advertising, updates, and promotional offers based on your communication preferences and – if applicable – subject to your explicit approval
- Conducting customer satisfaction or other surveys and other market research studies
- Confirming your registration for a webinar, seminar, event, etc.
Personal data are processed on the following legal grounds, as appropriate:
- You have given your consent to the processing of your personal data for one or more specific purposes.
- The data must be processed to facilitate the performance of your agreement with SC or to take action at your request prior to concluding an agreement.
- The data must be processed to facilitate compliance with a statutory obligation imposed on SC.
- The data must be processed in order to protect your vital interests or those of another natural person
- The data must be processed for the performance of a task carried out in the public interest.
- The data must be processed in order to protect the justified interests of SC or a third party, unless your personal interests or the fundamental rights and liberties that call for the protection of your personal data outweigh these interests (particularly if you are a minor).
IV. Disclosure of your personal details to third parties
SC will not disclose your personal data to third parties, unless this is necessary in the context of the performance of the agreement and its optimisation. In this context, your personal data may be disclosed to payment providers, software suppliers, cloud partners, shipping partners, security companies, insurance companies, external IT consultants, and external service providers.
If it is necessary for SC to disclose your personal data to third parties in this context, the third party in question will be obliged to use your personal data in accordance with the provisions of this Privacy Statement.
However, without prejudice to the foregoing, SC may disclose your personal data:
- to the competent authorities (i) when SC is obliged to do so by operation of law or within the context of judicial or future legal proceedings, and (ii) in order to safeguard and defend SC’s rights;
- if SC or virtually all of its assets are acquired by a third party, in which case your personal data collected by SC will be one of the transferred assets; in all other cases, SC will not sell, rent, or transfer your personal data to third parties, unless (i) it has obtained your consent and (ii) it has concluded a data processing agreement with the third party concerned, which includes the necessary guarantees regarding confidentiality and the treatment of your personal data in compliance with privacy legislation.
V. Cross-border processing of personal data
Every transfer of personal data outside the European Economic Area (EEA) to a recipient residing or having its registered offices in a country not covered by an adequacy decision issued by the European Commission shall be governed by the terms of a data transfer agreement, which shall contain either (i) the standard contractual clauses set out in the “Decision of the European Commission of 5 February 2010 (Decision 2010/87/EC)” or (ii) appropriate safeguards provided by any other mechanism under the Privacy Act or any other regulation governing the processing of personal data.
VI. Storage of personal details
Unless a longer retention period is required or justified (i) by law or (ii) to ensure compliance with any other legal obligation, SC will retain your personal data only for the period necessary to achieve and fulfil the purposes as described in this Privacy Statement under “Article III. Use of Personal Data”.
VII. Your rights
In connection with the processing of your personal data, you have the following privacy rights:
- The right to consult your personal data
- The right to correct, complete, or update your personal data
- The right to be forgotten (in this context, SC reminds you that certain services will no longer be accessible or can no longer be provided if specific necessary personal data are deleted)
- The right to impose restrictions on the processing of your personal data
- The right to have your personal data transferred;
- The right to lodge an objection against the processing of your personal data
Should you wish to exercise your privacy rights, we kindly ask that you contact us by sending an email to firstname.lastname@example.org.
As a rule, you can exercise your rights free of charge.
If you no longer wish to receive newsletters or information about SC’s services, products and/or goods, you may unsubscribe at any time by clicking the “unsubscribe” button provided at the bottom of each email sent by SC.
VIII. Protection of personal data
SC undertakes to take appropriate and reasonable physical, technological, and organisational security measures in order to prevent (i) unauthorised or unlawful access to your personal data, as well as (ii) the loss, misuse or modification of your personal data.
SC will store all personal data it has collected in the cloud with data centres in the EU and Onsite.
Notwithstanding (i) SC’s security policy, (ii) its inspections and (iii) the actions it takes in this regard, an infallible level of security cannot be guaranteed. No method of transmission or transfer via the Internet or any method of electronic storage is fully secure. Therefore, SC cannot guarantee absolute security within this context.
IX. Update Privacy Statement
SC has the right to update this Privacy Statement by publishing a new version on our website. We highly recommend that you check the Websites and the relevant page of the Privacy Statement on a regular basis to ensure that you are always aware of any changes.
X. References to other websites
The Website may contain hyperlinks to other websites. When you click on one of those links, you may be directed to another website or Internet resource which could collect information about you, either deliberately or by means of cookies or other technologies. SC does not bear any responsibility or liability or have any power of control over those other websites or Internet resources, or over their collection and use and/or the dissemination of your personal data. We recommend that you review the privacy policies of other websites and Internet resources, as referred to above, to determine whether they comply with the Privacy Act.
XI. Contacting SC
If you have any questions about the Privacy Statement or about the way in which SC collects, uses, or processes your personal data, please contact us:
- By email: email@example.com
- By post: The Sunshine Club BV, Everselstraat 141, 3580 Beringen, Belgium
If you are dissatisfied with the way in which SC has dealt with these questions or comments, or if you have any complaints about the way in which SC collects, uses, or processes your data, you may lodge a complaint with the Privacy Commission.