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This privacy policy aims to explain to you clearly and transparently :

• Which data we collect
• Why and how we use them
• How long they are retained
• What your rights are and how to exercise them

We process your data in strict compliance with applicable legislation, in particular the General Data Protection Regulation (GDPR).

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01 | Purposes of Personal Data Processing

Win4Led places great importance on respecting your personal data and protecting your privacy, in accordance with European Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (GDPR).

Whether you are a client, partner, supplier, subcontractor, contractual partner, and/or simply a visitor to our websites and/or a user of our applications, this Privacy Policy aims to inform you about the collection and processing of your personal data by Win4Led, as well as the rights you have in this regard.

By continuing to use our services, you consent to this Policy and its terms.

Certain data disclosures may be mandatory for the performance of contracts or to comply with applicable legislation.

This Policy may be amended at any time. It applies to all Win4Led activities.

02 | Scope of Application

This Policy covers the collection and processing of your personal data within the framework of our commercial, contractual, or technical relationships, particularly in the field of LED lighting.

Personal data refers to any information that makes it possible to directly or indirectly identify a natural person, whereas non-personal data does not allow such identification.

This Privacy Policy applies exclusively to our interactions with natural persons. Where legal entities (companies, public authorities, etc.) are concerned, it covers only the personal data of individuals acting on their behalf, such as legal representatives, agents, employees, or primary contacts.

Non-personal data, on the other hand, refers to information that does not make it possible to identify a natural person, either directly or indirectly.

03 | Personal Data Controller

The controller of personal data processing is the Data Protection Officer (DPO) of Win4Led.

You may contact them with any questions relating to the protection of your personal data :

Alexandre Dauvister

a.dauvister@win4led.be

Rue de l'Informatique 9a, 4460 Grâce-Hollogne, Belgique

04 | Nature of the Personal Data Processed

Win4Led collects various personal data that you voluntarily provide to us or that we collect when you use our services, including data obtained from third parties.

The information we collect is provided voluntarily by you, whether when registering for services, requesting a quotation, or contacting us by message. This information may include identification and contact details such as your last name, first name, postal address, email address, telephone or mobile number, date of birth, age, gender, language, as well as professional data such as company or VAT number, profession, company name, and role within the company, etc.

In addition, financial or billing data such as bank account number, BIC code, account holder’s name, and billing or delivery address may also be collected.

Finally, we also collect other types of data, such as comments, suggestions, testimonials, any other feedback, texts, images, résumés/CVs, etc.

Information resulting from the use of our websites, applications, and other online services (in particular through the use of cookies – see below): this includes the pages, websites, and applications visited or used, as well as searches performed and data entered on these platforms, to which Win4Led may have access (for example, IP address, location, date and time of access, etc.).

Data originating from third parties: this data results from its acquisition or rental from providers specialized in this field, within the framework of agreements with partners, or from data that is publicly accessible and/or available on social networks or other platforms, subject to the applicable conditions and restrictions governing the data held by these providers. Such data is generally of the same nature as those mentioned above or constitutes an update thereof.

Your personal data is retained only for the period necessary to achieve the purposes set out in this Policy, and this period may vary depending on the data and the purposes concerned.

05 | Purpose of Personal Data Processing

Win4Led only initiates the collection and processing of your data after obtaining your consent or on the basis of a valid legal justification, such as when required for compliance with a legal obligation, the conclusion or management of a contract, or within the framework of a legitimate interest of Win4Led or a third party.

 This mainly aims to achieve the following purposes :

• Provision of services or products and management of contracts and customer relations, including administrative tasks particularly tax and accounting matters order tracking and fulfillment, invoicing, possible payment collection, as well as creditworthiness checks, with or without the assistance of third parties;
• Communication of information about the LED lighting products, services, or solutions offered by Win4Led;
• Commercial prospecting, including advertising and direct marketing, through the sending of targeted or general communications (emails, newsletters, SMS, social media messages, or postal mail) concerning Win4Led’s activities, offers, new products, or events, with your consent and/or within Win4Led’s legitimate interest in promoting its services to clients, partners, or prospects;
• Communication of promotional offers from Win4Led or its partners, and invitations to participate in competitions;
• Conducting satisfaction surveys, market studies, statistics, maintenance, and continuous improvement of our products, services, websites, and applications, including service personalization, user profile creation, and optimization of Win4Led’s commercial and marketing strategies;
• Creation and management of user accounts, loyalty programs, targeted promotions, and other personalized services;
• Verification of the minimum age required for certain services;
• Continuous optimization of our services, products, websites, and applications;
• Securing our platforms, services, and digital solutions
• And finally, compliance with all applicable legislation.

06 | Persons with Access to the Collected Personal Data

Win4Led generally does not share your data with third parties, except in the following cases:

• With partner companies or affiliates of Win4Led, where applicable, and only insofar as these companies use your data for the same purposes as those described in this Policy. The list of such partners may be provided upon request;
• With subcontractors who process data on behalf of Win4Led, acting under its responsibility and in accordance with its instructions (for example: technical service providers, hosting providers, marketing agencies, CRM providers). These subcontractors are required to ensure the confidentiality, security, and legal compliance of data processing;
• If you have given your prior and explicit consent to such sharing;
• In cases provided for by law, pursuant to a legal or regulatory obligation, or at the request of the competent administrative or judicial authorities.

If your authorization is legally required, or if Win4Led considers it necessary for the sake of transparency, we will request it before any sharing or transfer of your personal data to a country located outside the European Economic Area.

07 | Personal Data Security

The personal data you provide to us, whether explicitly or automatically, is stored in Win4Led’s secure systems.

Win4Led implements all necessary administrative, technical, and organizational measures to prevent the destruction, loss, accidental alteration, damage, unauthorized access, or any other unlawful processing of your personal data.

For certain specific services (e.g. technical maintenance, hosting, CRM management, etc.), Win4Led may use external service providers. These companies have access to your data only to the extent strictly necessary for the performance of their tasks and are contractually required to ensure its security and confidentiality.

The number of employees authorized to access your personal data is limited, and such access is strictly restricted to authorized persons within the scope of their duties at Win4Led.

08 | Use of Cookies

Win4Led uses cookies to collect information intended to improve navigation on its website or the use of its digital services, as well as to provide commercial or marketing information to its users.

A cookie is a small text file stored on your device’s hard drive (computer, tablet, smartphone, etc.) when you visit our website. This standard technology makes it possible to store certain information about the visitor, such as language preference, pages visited, duration of the visit, session identifiers, etc.

Cookies may be placed either by our website’s server or by third-party partners (e.g. analytics tools, advertising platforms, social networks) working with Win4Led. Some cookies may also be placed by social media platforms integrated into the website (e.g. links to Facebook, LinkedIn, Instagram, etc.).

During your first visit, you are invited to give your explicit consent to the use and storage of cookies on your device.

You can enable or disable these cookies at any time by adjusting your browser settings. With regard to any mobile applications we may offer, cookie management can also be carried out via the application settings or by uninstalling the application.

To the extent that certain cookies may contain personal data, such data may be accessed, modified, or deleted under the conditions set out in this Policy.

08.1 | Cookies Used

Win4Led uses Google Analytics cookies on its website in order to better understand and improve the user experience.

These cookies allow us to collect information on how visitors interact with our website, such as the number of visits, the most viewed pages, and the average time spent on each page. Based on this data, we can analyze browsing trends and identify areas of the site to improve.

The use of Google Analytics cookies therefore enables us to continuously improve our content, provide smoother navigation, and offer a more relevant user experience.

These cookies also help us assess the effectiveness of our marketing and advertising campaigns by providing valuable insights that allow us to better target our efforts and reach our audience more accurately.

In summary, Google Analytics cookies are essential to ensuring the quality of our website and to continuously improving the services offered to Win4Led users.

09 | Links to Other Websites

If Win4Led provides links to other websites, this is done for informational purposes only.

We recommend that when you access these external websites, you carefully review their own privacy and personal data processing policies. Win4Led cannot be held liable for the content, practices, or data processing carried out by the owners or operators of these third-party sites.

10 | Your Rights Regarding the Personal Data We Collect

Your personal data is always processed in accordance with the legitimate purposes mentioned above. It is collected and processed in an appropriate, relevant, and proportionate manner, and is not retained longer than necessary to achieve the intended purposes.

You have several rights regarding your personal data, including the right to object, access, rectification, erasure, restriction of processing, data portability, and withdrawal of consent. You may exercise these rights by contacting us.

If you believe that the processing of your personal data does not comply with applicable legislation, you have the right to lodge a complaint with the Data Protection Authority.

10.1 | Right to Object to Use for Prospecting Purposes

You have the right to object, without providing any justification, in whole or in part, to the use of your personal data by Win4Led for commercial prospecting purposes (direct marketing), including any related profiling.

To exercise this right, simply inform us :

– By email at the following address :info@win4led.be

You may also contact the data controller directly (see contact details in section 03).

10.2 | Right of Access to Your Data

Subject to proof of your identity, you may obtain information about the processing of your data, in particular the purposes, categories of data, recipients, retention periods, and the rights you may exercise.

10.3 | Right to Rectification

If your personal data is inaccurate or incomplete, you may request its correction either via your user account (where applicable) or by directly contacting the data controller.

10.4 | Right to Erasure (or “Right to Be Forgotten”)

You may request the deletion of your personal data in the following cases :

• (a) the data is no longer necessary for the purposes for which it was collected ;
• (b) you withdraw your consent and there is no other legal basis justifying their processing ;
• (c) you validly exercise your right to object ;
• (d) the data has been processed unlawfully ;
• (e) the data must be erased in order to comply with a legal obligation.

Win4Led will assess whether these conditions are met before proceeding with the deletion.

10.5 | Right to Restriction of Processing

In certain circumstances, you may request the restriction of the processing of your personal data, for example in the event of a dispute regarding their accuracy, unlawful processing, or if you need the data for legal proceedings, or during the time required by Win4Led to examine a request for erasure.

10.6 | Right to Object

You may object at any time to the processing of your personal data. Win4Led will then cease such processing unless it demonstrates compelling legitimate grounds overriding your interests, rights, and freedoms.

10.7 | Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request their direct transfer to another data controller, where technically feasible.

10.8 | Right to Withdraw Your Consent

You may withdraw your consent to the processing of your personal data at any time. Such withdrawal does not affect the lawfulness of processing carried out prior to the withdrawal.

10.9 | How to Exercise Your Rights

To exercise your rights, please send a written request to the data controller :

Win4Led – Alexandre Dauvister

Rue de l'Informatique 9a, 4460 Grâce-Hollogne

a.dauvister@win4led.be

Do not forget to include proof of identity if required. We will respond as soon as possible, and no later than within one (1) month of receipt of your request.

10.10 | Right to Lodge a Complaint

If you are not satisfied with the way Win4Led processes your personal data, or if you believe that your rights have not been respected, you have the right to lodge a complaint with the Data Protection Authority.

Autorité de Protection des Données

Rue de la Presse 35, 1000 Bruxelles

https://www.autoriteprotectiondonnees.be