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Privacy Policy

Table of ContentsWho are we?With whom do we share personal data?How long do we retain personal data?What are your rights, and how can you exercise them?Where can you file a complaint?Note regarding children

This statement aims to inform you in a transparent and clear manner about how we process your personal data. By “personal data,” we mean any information that allows us to identify you, directly or indirectly. The “processing” of your personal data covers all operations or a set of operations related to your personal data, such as, but not limited to, collecting, storing, using, updating, or deleting. This statement specifically concerns the processing of your personal data that we collect through various forms on our website—which are provided to us by the person sharing their personal data (customer, supplier, staff member, etc.)—and/or through documents made available to us and/or through publicly accessible sources such as the KBO, the national register, and websites. We also collect data through the use of cookies and similar technologies. If you would like more information about this use, we invite you to review our Cookie Policy.

Table of Contents

  • ‍Whoare we?
  • Why, and on what legal basis, do we process your personal data?
  • With whom do we share your personal data?
  • How long do we retain your personal data?
  • What are your rights, and how can you exercise them?
  • Where can you take your complaints?
  • Note about Children
  • Applicable legislation

Who are we?

We are EUROPAL-PACKAGING NV, with registered office at 7700 MOESKROEN, Anne Francklaan 5, KBO 0467.257.413, info@europal-packaging.com, tel. 056/78.25.80 What data do we collect, why, and on what legal basis do we process your personal data? The categories of personal data that may be processed include, among others, last name, first name (or, if applicable, first names), address details (such as street name, house number, P.O. box number, ZIP code, municipality/village/city, country, etc.), contact details (e.g., email address, phone number, fax number, cell phone number, etc.), gender, date of birth, national identification number, ID card number, place of birth, shipping address, account number, professional category/position, and KBO and/or VAT number. We process, among other things, the data—primarily your contact details—that you share with us through these forms solely to respond to your requests. We specify in each of our forms the data you must provide to process your request. You are therefore free to choose whether or not to share your data with us if the fields are not marked as required. If the personal data provided to us was not provided with explicit consent, then it is necessary for the performance of the agreement to which we are a party and/or the fulfillment of the legal obligations that we and/or our client and/or our supplier and/or our staff member must comply with. All personal data that we become aware of and process within the scope of our assignment is used solely for professional purposes and is processed in a lawful, fair, and transparent manner.

With whom do we share personal data?

In general, we try to avoid transferring your personal data to third parties. We only transfer your personal data to third parties if it is necessary to fulfill your requests and to parties that need access to this personal data in order to properly execute the agreement to which we are a party and/or if required by law. When we transfer your personal data to a third-party processor, we limit that third party’s access to the data they need to fulfill their assignment. Furthermore, we require each of our processors to comply with data protection laws at all times. In addition, we ensure that the necessary measures are taken (e.g., by imposing certain contractual obligations) to guarantee an appropriate level of protection for your personal data when our subcontractor processes your data in a country that does not provide the same level of protection as the European Union.

How long do we retain personal data?

We do not retain your personal data longer than is necessary for the purposes for which we collect it, unless there is a legal obligation requiring us to retain your data for a longer period. Personal data is retained for at least the period required by law for maintaining accounting records. Personal data is retained using security measures that are appropriate and customary for a company of our size in our industry.

What are your rights, and how can you exercise them?

In accordance with data protection laws, and provided that your request meets the legal requirements—such as presenting proper identification—you may ask us at any time to:· confirm that we are processing your personal data and to receive a copy of all personal data we process about you (“right of access”)· access your personal data and, if necessary, correct it if it is incorrect or incomplete (“right of rectification”)· delete your personal data (“right to be forgotten”)· restrict the processing of your personal data (“right to restriction of processing”)· stop the processing of your personal data (“right to object”) if we process your personal data for marketing purposes· obtain your personal data in a structured, commonly used, machine-readable format for your own use or to transfer it to another data controller (“right to data portability”)

Where can you take your complaints?

You can direct all your complaints regarding our handling of your personal data to our data controller: Europal-Packaging NV, Anne Francklaan 5, 7700 MOESKROEN (BELGIUM), VAT BE 0467.257.413. Data controller: Email: info@europal-packaging.com. Additionally, you can always direct your complaints to the Belgian Data Protection Authority.

Note about Children

This website and the services offered are not intended for individuals under the age of 16. In accordance with Article 12 of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, 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, you will find below the text of Articles 15 through 22, as well as Article 34, of the aforementioned Regulation:

Article 15 (Right of access of the data subject): “1. The data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning him or her is being processed and, where that is the case, to access such personal data and the following information: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; (d) where possible, the period for which the personal data are expected to be stored, or, if not possible, the criteria used to determine that period)e) that the data subject has the right to request from the controller rectification or erasure of personal data concerning him or her, or restriction of processing concerning him or her, as well as the right to object to such processing)f) that the data subject has the right to lodge a complaint with a supervisory authority)(g) when the personal data are not collected from the data subject, all available information regarding their source; (h) the existence of automated decision-making, including profiling as referred to in Article 22(1) and (4), and, at least in those cases, useful information about the underlying logic, as well as the significance and the expected consequences of such processing for the data subject. 2. When personal data are transferred to a third country or an international organization, the data subject has the right to be informed of the appropriate safeguards in accordance with Article 46 regarding the transfer. 3. The controller shall provide the data subject with a copy of the personal data undergoing processing. If the data subject requests additional copies, the controller may charge a reasonable fee based on the administrative costs. When the data subject submits his or her request electronically, and unless otherwise requested, the information shall be provided in a commonly used electronic format. 4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.”

Article 16 (Right to Rectification): “The data subject has the right to obtain from the controller, without undue delay, the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to obtain the completion of incomplete personal data, including by means of providing a supplementary statement.”

Article 17 (Right to Erasure (“Right to be Forgotten”)): “1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; b) the data subject withdraws consent on which the processing is based pursuant to Article 6(1)(a) or Article 9(2)(a), and there is no other legal basis for the processing; c) the data subject objects to the processing pursuant to Article 21(1), and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2); d) the personal data have been processed unlawfully; e) the personal data must be erased to comply with a legal obligation under Union or Member State law to which the controller is subject; f) the personal data have been collected in connection with the provision of information society services referred to in Article 8(1). 2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking into account available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers processing the personal data that the data subject has requested the erasure of any links to, or copies or replicas of, those personal data. 3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary: a) for the exercise of the right to freedom of expression and information; (b) to comply with a legal obligation that requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; (c) for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i), and Article 9(3); d) for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1), to the extent that the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; e) for the establishment, exercise, or defense of legal claims.”

Article 18 (Right to restriction of processing): “1. The data subject has the right to obtain from the controller the restriction of processing where one of the following applies: a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of its use; c) the controller no longer needs the personal data for the purposes of processing, but the data subject needs them for the establishment, exercise, or defense of legal claims; d) the data subject has objected to processing pursuant to Article 21(1), pending verification of whether the controller’s legitimate grounds override those of the data subject. 2. When processing has been restricted under paragraph 1, personal data shall, except for storage, only be processed with the data subject’s consent or for the establishment, exercise, or defense of legal claims, or to protect the rights of another natural or legal person, or for important reasons of public interest for the Union or for a Member State. L 119/44 EN Official Journal of the European Union May 4, 2016 3. A data subject who has obtained a restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted. “

Article 19 (Obligation to Notify Regarding Rectification, Erasure, or Restriction of Processing of Personal Data): “The data controller shall inform every recipient to whom personal data has been disclosed of any rectification, erasure, or restriction of processing in accordance with Article 16, Article 17, paragraph 1, and Article 18, unless this proves impossible or involves a disproportionate effort. The data controller shall provide the data subject with information about these recipients if the data subject requests it.”

Article 20 (Right to data portability): “1. The data subject has the right to receive the personal data concerning him, which he has provided to a data controller, in a structured, commonly used, and machine-readable format, and he has the right to transmit those data to another data controller, without being hindered by the data controller to whom the personal data was provided, if: a) the processing is based on consent pursuant to Article 6, paragraph 1, point a), or Article 9, paragraph 2, point a), or on a contract pursuant to Article 6, paragraph 1, point b); and b) the processing is carried out by automated means. 2. In exercising his right to data portability under paragraph 1, the data subject has the right to have the personal data, where technically feasible, transmitted directly from one data controller to another. 3. The exercise of the right referred to in paragraph 1 of this article does not affect Article 17. This right does not apply to processing that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller. 4. The right referred to in paragraph 1 does not prejudice the rights and freedoms of others. Section 4 Right to Object and Automated Individual Decision-Making”

Article 21 (Right to Object): “1. The data subject has the right at any time to object to the processing of personal data concerning him or her on grounds relating to his or her particular situation, based on Article 6, paragraph 1, subparagraphs (e) or (f), including profiling based on those provisions. The data controller shall cease processing the personal data unless he or she demonstrates compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject or that relate to the establishment, exercise, or defense of legal claims. 2. When personal data are processed for the purpose of direct marketing, the data subject has the right at any time to object to the processing of personal data concerning him or her for such marketing, including profiling related to direct marketing. 3. When the data subject objects to processing for the purpose of direct marketing, the personal data shall no longer be processed for these purposes. 4. 5.2016 EN Official Journal of the European Union L 119/454. The rights referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject no later than at the time of the first contact with the data subject and shall be presented clearly and separately from any other information. 5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object through automated procedures using technical specifications. 6. When personal data are processed in accordance with Article 89, paragraph 1, for scientific or historical research or statistical purposes, the data subject has the right to object to the processing of personal data concerning him or her on grounds relating to his or her particular situation, unless the processing is necessary for the performance of a task carried out in the public interest.”

Article 22 (Automated individual decision-making, including profiling): “1. The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning him or her or similarly significantly affects him or her. 2. Paragraph 1 does not apply if the decision: a) is necessary for the conclusion or performance of a contract between the data subject and a data controller; b) is authorized by a Union or Member State law applicable to the data controller and which also provides for suitable measures to safeguard the rights and freedoms and legitimate interests of the data subject; or c) is based on the explicit consent of the data subject. 3. In the cases referred to in paragraph 2, points a) and c), the data controller shall implement appropriate measures to safeguard the rights, freedoms, and legitimate interests of the data subject, including at least the right to obtain human intervention from the data controller, the right to express his or her point of view, and the right to challenge the decision. 4. The decisions referred to in paragraph 2 shall not be based on the special categories of personal data referred to in Article 9, paragraph 1, unless Article 9, paragraph 2, point a) or g) applies and suitable measures to safeguard the legitimate interests of the data subject have been implemented.” Article 34 (Notification of a personal data breach to the data subject: “1. When a personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the data controller shall notify the data subject of the personal data breach without undue delay. L 119/52 EN Official Journal of the European Union 4.5.2016 2. The notification referred to in paragraph 1 of this article to the data subject shall include a description, in clear and plain language, of the nature of the personal data breach and at least the information and measures referred to in Article 33, paragraph 3, points b), c), and d). 3. The notification referred to in paragraph 1 to the data subject is not required if any of the following conditions are met: a) the data controller has implemented appropriate technical and organizational protection measures, and those measures have been applied to the personal data affected by the personal data breach—in particular, measures that render the personal data unintelligible to unauthorized persons, such as encryption; (b) the data controller has taken subsequent measures to ensure that the high risk to the rights and freedoms of data subjects referred to in paragraph 1 is no longer likely to materialize; (c) the notification would involve a disproportionate effort. In that case, a public announcement or a similar measure shall be taken instead, whereby data subjects are informed just as effectively. 4. If the data controller has not yet notified the data subject of the personal data breach, the supervisory authority, after considering the likelihood that the personal data breach poses a high risk, may require the data controller to do so or may decide that one of the conditions referred to in paragraph 3 is met.”