1. Introduction and scope
This privacy policy (“Privacy Policy“) governs the processing of your personal data in the context of our activities (i.e. the production and sale of IPC® membranes, modules and related products, as well as the follow-up and the provision of aftersales services).
Blue Foot Membranes NV, a public limited company incorporated under Belgian law, with registered office at Gerard Mercatorstraat 31, 3920, Lommel, Belgium, registered with the Crossroads Bank for Enterprises under number 0678.595.073, RLE Antwerp, section Hasselt (“Blue Foot“, “we“, “us“), acts as data controller in the context of this processing.
Your personal data and your privacy will be protected by Blue Foot in accordance with Belgian and European data protection laws, including the EU General Data Protection Regulation 2016/679 (“GDPR”) as well as any applicable national implementing and supplementing laws.
If you are a resident of the state of California, USA and to the extent that it applies to us, we will comply fully with all requirements set forth in the California Online Privacy Protection Act (“CalOPPA”) and the California Consumer Privacy Act (“CCPA”) and nothing in this Privacy Policy can be construed as limiting any right you might have as a resident of the State of California pursuant to the CalOPPA or the CCPA or pursuant to Californian Civil Code Section 1798.83 et. sec. (“Shine the Light” requests).
If you are a resident of the state of Nevada, USA and to the extent that it applies to us, we will comply fully with all requirements set forth in the Nevada Senate Bill 220 (“SB 220”) and nothing in this Privacy Policy can be construed as limiting any right you might have as a resident of the state Nevada pursuant to the SB 220.
If you are a resident of Australia, China, Egypt, India, Indonesia, Japan, Malaysia, Qatar, Saudi Arabia or the United Arab Emirates, and to the extent that it applies to us, we will comply fully with all requirements set forth in your national or regional data protection laws, and nothing in this Privacy Policy can be construed as limiting any right you might have pursuant to your national or local data protection laws.
Please read this Privacy Policy carefully. It describes not only your rights, but also the way in which you can exercise these rights.
2. From whom do we collect and process personal data?
In the course of our activities (as described above), we collect and process personal data from contact persons with customers who purchase our products and install them at end customers, from contact persons with end customers, from contact persons with suppliers, from contact persons with administrative authorities, from visitors of our website, from prospects, and from persons who otherwise come into contact with us (e.g. when they provide their business cards or other contact information to us, or when third parties provide their contact information to us).
3. What personal data do we process and for what purposes?
Blue Foot processes the following personal data for the following purposes:
| Purpose | Type of personal data | Data subject | Legal basis |
| Customer administration and management | – Name and surname – E-mail address – Telephone number – Company or organisation, function – Work address, country | Contact persons with customers | Legitimate interests |
| Supplier administration and management | -Name and surname – E-mail address – Telephone number – Company or organisation, function – Work address, country | Contact persons with suppliers | Legitimate interests |
| (Invoice) dispute management | -Name and surname – E-mail address – Telephone number – Company or organisation, function – Work address, country | Contact persons with customers | Legitimate interests |
| Follow-up on sales and provision of aftersales services | -Name and surname – E-mail address – Telephone number – Company or organisation, function – Work address, country | Contact persons with customers and end customers | Legitimate interests |
| Management of inquiries and complaints | – Name and surname – E-mail address – Other information you provide to us | Prospects/other contacts; Contact persons with customers | Legitimate interests |
| Website management | – IP-address – Information collected via cookies (read our Cookie Policy) | Visitors of our website | Legitimate interests |
| Prospection/Public relations | – Name and surname – E-mail address – Telephone number – Company or organisation, function | Prospects | Legitimate interests |
| Electronic direct marketing | – Name and surname – E-mail address – Opt-in/opt-out for elektronic mailings | Contact persons with customers; Prospects | Your consent |
| Use of images in our advertising and for other commercial purposes | Photos and videos | Contact persons with customers, end customers and agents | Your consent |
Blue Foot may process your personal data only if it relies on an appropriate legal basis to do so. We briefly explain the applicable legal grounds below.
- The applicable legal basis for most purposes is our legitimate interests.
We base the processing of personal data for the administration and management of customers and suppliers, for the follow-up on sales and the provision of aftersales services, and for invoice dispute management on the necessity for the protection of our legitimate interests for the execution of the contract concluded with the customer/supplier (who is not the data subject). On the other hand, we also rely on this legal basis for the management of inquiries and complaints, for the management of our website, and for prospecting/public relations purposes.
Given the nature of the personal data, Blue Foot considers that the processing will not adversely affect your fundamental rights and/or freedoms. You can always object to processing based on this legal ground by contacting us at info@bluefootmembranes.com. - For sending our electronic newsletters and for the use of your images in our advertising or for other commercial purposes, we rely on your consent.
The consent you give is always free and you have the right to withdraw it at any time. You may withdraw your consent by contacting us at info@bluefootmembranes.com, or by unsubscribing via the appropriate link in each newsletter. A withdrawal of consent does not affect the processing of personal data prior to such withdrawal.
4. With whom do we share your personal data?
In connection with our activities (as described above), we may sometimes share your personal data with third parties:
- With our service providers (‘processors’): We may sometimes share your personal data with our service providers who act as ‘processors’ for us, such as IT/hosting service providers, PR/marketing agencies, sales service providers, etc.
- With governmental authorities and our law firms: Blue Foot may also disclose your personal data to third parties (including judicial authorities and our law firms) if required to do so by law or if Blue Foot believes that such disclosure is necessary to comply with a court order or to protect the rights of Blue Foot, its employees and/or customers. The applicable legal basis will be either Blue Foot’s legitimate interest or, if applicable, the need to comply with a legal obligation.
- In the context of a transaction: Finally, your personal data may be disclosed to third parties in the context of a collaboration or corporate transaction (acquisition, merger, sale of shares or assets, joint venture, etc.) and to the relevant professional advisors of the parties involved (lawyers, consultants, etc.). Blue Foot relies on its legitimate interests for this purpose.
Blue Foot will only share personal data that is relevant and necessary. We always ensure that appropriate protective measures are taken when we transfer your personal data to third parties. For example, we will, where appropriate, enter into a transfer agreement or a processor agreement, which sets out restrictions on the use of your personal data and obligations in relation to the security of your personal data.
Your personal data and your profile will not be lent or sold to third parties for electronic direct marketing purposes without your prior express consent.
5. Will your personal data be transferred to countries outside the EEA?
The European Economic Area (“EEA“) includes the countries of the European Union and Norway, Liechtenstein and Iceland. The GDPR requires additional safeguards if Blue Foot transfers your personal data to countries located outside the EEA.
Certain third parties that Blue Foot relies on may process your personal data in countries outside the EEA. For example, in the context of Google Analytics, Google may store and process certain data in the United States. For more information, see https://privacy.google.com/businesses/processorterms.
Such transfers will only take place in accordance with applicable law. The additional safeguards that Blue Foot takes include the conclusion of agreements based on the Standard Contractual Clauses of the European Commission.
You can always contact us to obtain a full overview of the appropriate safeguards.
6. How do we protect your personal data?
Blue Foot takes appropriate technical and organizational security measures to ensure a level of security appropriate to the specific risks we have identified.
We thus protect your personal data against destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed.
Furthermore, we always try to ensure that we keep your personal data accurate and up-to-date. We therefore kindly request that you notify us of any changes to your personal data (such as a change in your contact details).
Despite the aforementioned measures taken by Blue Foot, you should be aware that there are always risks involved in transmitting personal data over the Internet. The security and protection of your personal data can never be fully guaranteed.
More information about our security measures is available upon simple request.
7. How long do we store your personal data?
Your personal data will not be stored for longer than is necessary in relation to the purposes for which we process them (as listed above). Afterwards it is still possible that they can be found in our back-ups or archives, but they will no longer be actively processed in a file.
More specifically, the following retention guidelines are applied by us:
- personal data included in accounting, financial or other official documents will be retained for as long as such documents legally need to be kept;
- personal data required for the execution and follow-up of a contractual relationship will be kept for the entire duration of that relationship and for 10 years following termination thereof;
- personal data obtained in the context of complaint handling will be deleted (or anonymised) as soon as the complaint is closed; and
- any personal data used for marketing purposes will be retained for as long as we are sending you relevant mailings and for a maximum of 1,5 years thereafter. As soon as we note that your contact details are no longer accurate or active, or whenever you decide to use your unsubscribe right, we will no longer keep your personal data for these purposes.
Only where we are legally obliged to, or where this is necessary for defending our interests in the context of judicial proceedings (e.g. in case of a dispute), we will store the personal data for longer periods.
More information on our retention periods is available upon simple request.
8. What are your rights and how can you exercise them?
Within the limits defined in Articles 15-22 of the GDPR, you have the following legal rights in relation to your personal data:
- Right of access: you have the right to obtain confirmation from us as to whether or not we are processing your personal data, to access that personal data and how and why it is being processed, as well as to receive a copy of that data.
- Right to rectification: you have the right to obtain a rectification of your personal data or to request that we complete your personal data when you become aware that we are processing incorrect or incomplete data about you.
- Right to erasure (‘right to be forgotten’): you have the right to obtain erasure of your personal data in certain specific cases.
- Right to restriction: You have the right to have the processing of your personal data restricted in certain specific cases.
- Right to portability: You have the right to obtain the personal data you have provided to us in a structured, commonly used and machine-readable form, and to transfer (have transferred) that personal data to another controller.
- Right to object: You have the right to object to the processing of your personal data on the basis of our legitimate interest for reasons relating to your specific situation.
- Right to object to direct marketing: You also have the right to object to the processing of your personal data for direct marketing purposes. This right is absolute – Blue Foot will therefore always act upon it.
| You can exercise the above rights by sending an e-mail to info@bluefootmembranes.com, or in case of the right to object to direct marketing also via the opt-out link included in the marketing e-mails. |
The exercise of these rights is in principle free of charge. Only in the event of unreasonable or repeated requests we may charge a reasonable administrative fee.
We always try to answer your requests or questions as quickly as possible. It is possible that we will first ask you for proof of identity in order to verify your identity.
You can find more information and advice on the above right on the website of your national Data Protection Authority (“DPA”). In addition, you also have the right at any time to lodge a complaint with your DPA in connection with the processing of your personal data by us.
Belgian residents can visit the website of the Belgian DPA via the following link: www.gegevensbeschermingsautoriteit.be. They can reach the authority via contact@apd-gba.be or by regular mail at the following address: Gegevensbeschermingsautoriteit, Drukpersstraat 35, 1000 Brussels, Belgium.
If you are a resident of California, USA, you can contact the Office of the Attorney General of the State of California Department of Justice. To submit a question or comment, please visit the following webpage: https://oag.ca.gov/contact/general-comment-question-or-complaint-form. If you believe our business has violated the CCPA, we would like to have the opportunity to deal with any issues, but you may report a complaint at: https://oag.ca.gov/contact/consumer-complaint-against-business-or-company.
If you are a resident of Nevada, USA, you can contact the Nevada Attorney General’s Office. Please visit the following webpage for contact details of the Attorney General’s Office: https://ag.nv.gov/Complaints/File_Complaint/.
If you are a resident of Australia, China, Egypt, India, Indonesia, Japan, Malaysia, Qatar, Saudi Arabia or the United Arab Emirates, you can contact your local Authority (e.g. to submit a question or comment or to report a complaint) using the contact details provided on your local Office website which can be find below:
| Country | Local Authority |
| Australia | Office of the Australian Information Commissioner |
| China | Cyberspace Administration of China |
| Egypt | Personal Data Protection Centre |
| India | n/a |
| Indonesia | n/a |
| Japan | Personal Information Protection Commission |
| Malaysia | Malaysia Personal Data Protection Commissioner |
| Qatar | Compliance and Data Protection Department |
| Saudi Arabia | Saudi Data and Artificial Intelligence Authority |
| United Arab Emirates | The Commissioner of Data Protection |
If you believe our business has violated your national or regional data protection laws, we would like to have the opportunity to deal with any issues, so we kindly ask you to contact us first before contacting your local Authority.
9. Changes to the Privacy Policy
Blue Foot may modify this Privacy Policy at any time. The date of the last amended version is listed at the bottom of the Privacy Policy. Changes will be published on our website and, if applicable, will be submitted for approval.
10. Liability
If Blue Foot has lawfully provided your personal data to a third party (other than a processor), it will not be liable for the unlawful processing or use by that third party.
11. Contact
If you have any questions or concerns regarding this Privacy Policy or the processing of your personal data by us, please do not hesitate to contact us by sending an e-mail to info@bluefootmembranes.com or by submitting a request via the contact form on our website.
Latest update: 13.02.2022