1. In general
1.1. Your personal data are processed by TWERES vzw, Peter Benoitlaan 7, box 0301, 8450 Bredene, Belgium (hereinafter: “TWERES”, “we”, “us”, “our”). You can contact us via e-mail at firstname.lastname@example.org
1.3. Where reference is made to certain laws or regulations, such reference shall also include any change, replacement or annulment of said laws or regulations, including any related executive decisions.
2. Types of personal data we process
2.1. Whenever you use our Website, Webshop and Social Media Channels, we may collect technical information associated with the device you use, such as your IP address, browser type, geographical location and operating system;
2.2. When you fill out a contact form on our Website, or contact us via e-mail, telephone or Social Media Channels, we collect:
1. the basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, the type of second residence you own, the channel which brought you into contact with us;
2. the content of your communication and the technical details of the communication itself (with whom you correspond at our end, date and time, etc.);
3. any other personal data you choose to provide to us.
2.3. When you fill in your membership data and payment information in our Webshop, we collect:
1. the basic identity information we require to process your order, such as your name, postal address, e-mail, telephone number, the type of second residence you own and the channel which brought you into contact with us;
2. details pertaining to the membership fee transaction itself.
3. Purposes for processing
3.1. TWERES processes your personal data to provide you in a personalized and efficient way with the information, products and services related to your membership of TWERES or related to a request from you via the Website, e-mail, telephone or Social Media Channels.
3.2. TWERES processes your personal data for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of selected part3ners.
However, TWERES will only send you communications, promotions, offerings, newsletters and other advertisements from selected partners for direct marketing purposes via e-mail or other person-to-person electronic communications channels if you have explicitly consented to receiving such communications, promotions, offerings, newsletters and other advertisements.
3.3. TWERES processes your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
Your personal data may be transferred upon TWERES own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website, Webshops, our Social Media Channels or other communication with us.
3.4. TWERES may be required to collect and transfer your personal data to the financial institution or payment service provider to allow your financial institution and the payment service provider to comply with their legal obligations, such as obligations under applicable anti-money laundering and counter-terrorism financing legislation.
3.5. TWERES processes your personal data to perform statistical analyses so that we may improve our Website, Webshops, products and services or develop new products and services.
4. Legal basis for processing your personal data
4.2. The processing of your personal data for the purpose of fulfilling an order you have placed via our Webshop is necessary for performing the agreement between you and TWERES.
4.3. The processing of your personal data for the purposes outlined in clauses 3.3 and 3.4 is necessary to allow TWERES to comply with its legal obligations.
4.4. The processing of your personal data for the purposes outlined in clauses 3.2, 3.5 and 3.6 is necessary for the purpose of the legitimate interests of the TWERES, which are:
1. continuous improvements to TWERES’s Website, Webshops, Social Media Channels, products and services to ensure that you have the best experience possible;
2. keeping our Website, Webshops, Social Media Channels, products and services safe from misuse and illegal activity;
3. marketing and promotion of our products, services, brands an overall successful commercialization of our products and services.
5.1. TWERES does not send your personal data in an identifiable manner to any third party without your explicit permission to do so. You understand, however, that if you use our Social Media Channels, your personal data is also processed by the social media providers. If you purchase anything via our Webshop, a financial institution or payment service provider may also receive your personal data in order to provide their services.
5.2. TWERES relies on third party processors to provide you the Website and Webshop as well as to process your personal data on our behalf. These third party processors are only allowed to process your personal data on behalf of TWERES upon explicit written instruction of TWERES. TWERES warrants that all third party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.
6. Location and transfer
6.1. TWERES processes your personal data within the EEA.
6.2. TWERES may transfer anonymized and/or aggregated data to organizations outside of the EEA. Should such transfer take place, TWERES will ensure that there are safeguards in place to ensure the safety and integrity of your data as well as all rights with respect to personal data you might enjoy under applicable mandatory law.
7. Quality assurances
7.1. TWERES does its utmost best to process only those personal data which are necessary to achieve the purposes listed under article 3.
1. an overriding interest of TWERES, your financial institution, the payment service provider, or any other third party in keeping your personal data identifiable;
2. a legal or regulatory obligation or a judicial or administrative order that prevents TWERES from de-identifying them.
7.3. TWERES will take the appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access by personnel of TWERES or its third party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only which can never be guaranteed.
7.4. If you are registered to receive communications, promotions, offerings, newsletters and other advertisements of third parties via e-mail or other person-to-person electronic communications channels, you can change your preferences for receiving such communications, promotions, offerings, newsletters and other advertisements by contacting us via email@example.com.
8. Your rights
8.1. You have the right to request access to all personal data processed by TWERES pertaining to you. TWERES reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to TWERES.
8.2. You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.
8.3. You have the right to withdraw your earlier given consent for processing your personal data, in which case clause 6.2 will apply.
8.4. You have the right to request that personal data pertaining to you be deleted if they are no longer required in light of the purposes outlined in article 3 or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by TWERES against:
1. overriding interests of the TWERES, your financial institution, the payment service provider or any other third party;
2. legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
Instead of deletion you can also ask that TWERES limits the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes listed under article 3 but you need them to defend yourself in judicial proceedings.
8.5. You have the right to oppose the processing of personal data if you are able to proof that there are serious and justified reasons connected with his particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.
8.6. You have the right to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.
8.7. If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to firstname.lastname@example.org. An e-mail requesting to exercise a right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, TWERES may ask you for your signed confirmation and proof of identity.
TWERES will promptly inform you of having received this request. If the request proves valid, TWERES shall honour it as soon as reasonably possible and at the latest thirty (30) days after having received the request.
If you have any complaint regarding the processing of your personal data by TWERES, you may always contact TWERES via the e-mail address listed in this clause 8.7. If you remain unsatisfied with TWERES’s response, you are free to file a complaint with the competent data protection authority, i.e. the Belgian Data Protection Authority at https://www.dataprotectionauthority.be/citizen