Introduction
This Privacy Policy is designed to inform you about the personal data relating to you which DRS Belgium SRL/BV, with registered office at Rue Joseph Stevens 7, B-1000 Brussels (Belgium) and registered with the Crossroad Bank for Corporations (BCE/KBO) under number 0452.511.928, and Deminor Recovery Services (Luxembourg) SA, with registered office at 1, Rue Jean-Pierre Brasseur, L-1258 Luxembourg and registered with the Register of Commerce of Luxembourg under number B175299, (acting as joint data controllers and hereinafter collectively referred as “Deminor”, “We”, “Our” and “Us”) collect via the websites https://www.mydeminor.com and https://www.deminor.com (referred to hereinafter as the “Website”) or by other means, including other websites managed by Us or other means of communication (e-mails, registration forms, etc.), why We collect such personal data, on which basis, and how We will handle personal data you provide Us with and personal data We learn about you from your visit to the Website.
Legal basis
We process your personal data either on the basis of your specific consent granted via our Website, other websites managed by Us, other means of communication (e-mails, registration forms, etc.) or on the basis of the contract of services (referred to hereinafter as the “Contract”) you have chosen to enter into with Us.
Whenever the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of such processing before the withdrawal of consent.
Personal data collected
We collect personal data (referred to hereinafter as “Personal Data”) relating to you in three ways:
- In the course of the conclusion of the Contract.
- Through registration and sending of information that you choose to enter on certain pages of the Website, other websites managed by Us or other means of communication (e-mails, registration forms, etc.). The information marked with the “*” symbol must be provided, in order to enable Us to fulfill the processing purposes, as mentioned below. Such Personal Data directly collected from you include your first and last name; personal address; company; profession; title; mobile or other phone number; login of the website account; logs; IP address; fax number; transaction data; VAT number; two-sided copying of the identity card; remarks; language; date of birth; place of birth, country of birth; household composition; interest in a case; registration to a case; any other information that We will need to process in order to enter into and/or execute the Contract.
- Through cookies. For more information about cookies, please see below.
Use of Personal Data
Your Personal Data will exclusively be used to the extent necessary for allowing you to:
- register to the Website or other websites managed by Us in order to obtain or share certain information
- enter into and sign the Contract
- execute the Contract
- and, subject to your explicit consent given via our Website or other websites managed by Us, to inform you about Our activities, events and/or the evolution of a case for which you have shown interest.
We may combine the Personal Data you submit with other data We have obtained about you for the same purposes from other sources, including if you have provided your information to Us in other places or through another medium.
We may use your Personal Data for internal statistical purposes.
We may not use your Personal Data for new purposes, which are as yet unforeseen in this Privacy Policy except on the basis of an applicable legal provisions or your consent. In any event, prior to using Personal Data for other purposes, We will inform you about such change to this Privacy Policy and in case of consent-based activities, We will offer you the chance to decline participation in these changes.
Special category of personal data
We will not collect or process any special category of personal data relating to you unless you have explicitly provided Us with such data. The special categories of Personal Data concern information relating to race or ethnical origin, political opinions, religious or philosophical beliefs or other beliefs of a similar nature, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health, sex life or sexual orientation.
Direct marketing
We will not use your Personal Data for direct marketing purposes without your explicit prior consent.
If at any time you decide not to receive any commercial or promotional information from Us, You may, free of charge and without having to provide any justification, opt-out of any direct marketing campaigns and oppose to the future processing of your Personal Data for such purposes by sending an email to Us at drs@deminor.com and mention “opt-out” in the subject of your email. Alternatively, you may use the opt-out procedure provided in any promotional message you receive from Us.
Please note that opting out from receiving promotional messages from Us will not exclude you from receiving information that relates to any Contract you may have entered into with Us.
Automated decision-making
We will not make use of automated decision-making processes, including profiling, unless you have explicitly authorized us to do so. In such case we would inform you about the logic involved in the decision, as well as the significance and the envisaged consequences of such processing for you.
Sharing Personal Data and transferring Personal Data to third countries
We will not make your Personal Data available to any third party and shall not publicly disclose the Personal Data unless such transfers are based on your specific consent, necessary for the performance of the Contract (such as the transfer of Personal Data to a court, to a regulatory authority or to the adversary parties), or when such transfer of Personal Data is compulsory by law or by order of an administration or judicial authority.
Please note that whenever your Personal Data are transferred to processors or third parties located outside the European Economic Area in countries which are not considered by the European Commission to guarantee an adequate level of personal data protection, We will ensure that appropriate measures are implemented according to the applicable national and European legislation relating to data protection. You may obtain a copy of the appropriate safeguards taken by sending an email to Us at drs@deminor.com.
General information about the cookies used
How to delete/deactivate cookies
In order to delete/deactivate all cookies set on your computer, the majority of web browsers allow you to disable completely the use of cookies, or to delete cookies created by specific domains/websites. To find out how to do it, please refer to your browser’s help page:
- Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Internet Explorer: http://windows.microsoft.com/en-US/internet-explorer/delete-managecookies#ie=ie-11-win-7
- Firefox: http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-websitepreferences
- Safari: http://support.apple.com/kb/ph5042
- Safari on IOS: https://support.apple.com/en-us/HT201265
- Opera: http://www.opera.com/help/tutorials/security/cookies
You can specifically prevent Google’s collection and use of data (cookies and IP address) for any website you visit by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
You may also specifically refuse the use of Google Analytics on this Website by clicking on the following link. An opt-out cookie will be set on the computer, which prevents the future collection of your data when visiting this Website:
<a href="javascript:gaOptout()">Disable Google Analytics</a>.
Links to third parties websites
On certain areas of this Website, We may provide links to third parties websites. These links are provided as a convenience to you; however please be aware that We do not control the third parties or their websites and that those third parties will have a different privacy policy applying to information collected from you when you are on those third parties’ websites. You should read the privacy policies of all websites carefully before providing personally identifiable information.
Storage duration
We will retain your Personal Data only as long as necessary for the fulfilment of the purposes described above or as required by law
Security and confidentiality
We have implemented technical and organisational measures in accordance with standard industry practices to ensure an appropriate level of security of the Personal Data processed. Nevertheless, security requires efforts from all actors involved. We thus encourage you to contribute to these efforts by taking appropriate security measures yourself, including using strong passwords and keeping all user names and passwords confidential.
Children on the Website
This Website is not intended for or directed to children under 16. We do not knowingly collect any information from such individuals. Parents, if you believe your child has provided Us with Personal Data, please contact Us at drs@deminor.com.
Your rights
At any time, you may exercise your right to request access to or rectification of and, as the case may be, erasure of any Personal Data relating to you, or to object to processing, or restriction of processing, as well as your right to data portability, in compliance with applicable data protection law, by sending a signed request form with a copy of your ID card, passport or other proof of identity to drs@deminor.com or in writing to DRS Belgium SRL/BV (Attn: Back Office), 19th Floor - Sablon Tower – Rue Joseph Stevens 7, B-1000 Brussels - Belgium.
As a data subject, you have a right to lodge a complaint with a supervisory authority if you consider that the processing of Personal Data relating to you infringes the applicable legislation relating to data protection.
Effective date and changes
This Privacy Policy was created on and has been in effect since 10 February 2017. We reserve the right, at Our complete discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. You should check back periodically at this page to read the most recent version of this Privacy Policy as your continued use of this Website following the posting of changes to these terms will mean you accept these changes. Notwithstanding the foregoing, We will not retroactively make material changes to Our use of your Personal Data without your consent.
Thank you for visiting this Website. This policy was last updated on 25 February 2020.
Data Protection Officer
If you have any question/remark, or if you want to make a complaint related to our Privacy Policy, you can reach out to our Data Protection Officer by email : dpo@deminor.com