Privacy Policy

1. Who we are

1.1

‘We’ and ‘us/our’ refer to AV Drop (Frame Rental System S.L.), with its registered business address at Maracaibo street 28, 08030 Barcelona, Spain and with enterprise number B66082801. We are the administrator of the personal data we collect, as described in this privacy policy.

1.2.

Your privacy is important to us and that is why we developed this privacy policy clarifying how we collect, disclose, transfer and use the personal information you share with us, and what your rights are. Please take the time to read this policy.

1.3.

If you have any questions, concerns or complaints regarding this privacy policy or the way we handle your personal data or if you wish to submit a request to exercise your rights, as set out in Article 4, you can contact us:
(a) By post, via the aforementioned address, for the attention of our Data Protection Officer;
(b) By e-mail, via info@av-drop.com, for the attention of our Data Protection Officer.

1.4.

This privacy policy was last revised on 05-04-2018.

2. How we collect and use your personal data

2.1.

In this document personal data means all data relating to an identifiable natural person. Identifiable refers to identification data (such as name, ID number, location data, etc.) that can be used to identify you directly or indirectly (as a natural person).

2.2.

Your data will be used to execute the agreements concluded with you. In addition to this, we can use your data to keep you informed of interesting information, tips and advice, events and/or offers. Your data will not be sold or passed on to a third party. We enter your data, including name, address and telephone number in a database/data file and use the collected personal data for the following purposes:

(a)

You might be an existing customer, contact or one of our suppliers. In this case, we use your personal data to communicate with you about either (the status of) our, or your own products and services. We may also use your personal information for the purposes described in (b).

(b)

You may be interested in our products or services (opt-in). That is why we use your personal information for direct marketing campaigns including digital newsletters and messages about our company, the products, services and planned events. In this case, we use your personal data to inspire and inform you in order to stimulate your interest in us and to promote our business relationship. The frequency of this is limited to a maximum of one weekly direct marketing campaign.

(c)

You may be interested in working for or with us. That is why we use your personal data for direct marketing or to communicate with you about possibilities and to request quotes.

(d)

You used our website’s contact form to ask a specific question about our products, services or our website. You can also use our website to subscribe to our newsletter or to request a printed copy of our catalogue. For this purpose, we use your personal data to respond correctly to your request and we may use your personal for (b) or (c).

(e)

We collect and process your personal data to support our website and to improve your user experience. This includes ensuring the security, availability, performance, capacity and condition of the website.

(f)

We may use your personal data to exercise or enforce the rights we have, according to the applicable law, such as those for recording, exercising or defending legal claims. We may also use your personal information to meet our obligations, as set out in the applicable legislation.

• The data you provide will be used to process your requests, by ourselves or by others involved in the processing.
• For establishing contact with you, for customer satisfaction surveys or market research or in connection to certain transactions.
• To support products or services that you have purchased from us.
• By AV Drop for marketing purposes, if this has been authorised by you.
• For a person-oriented focus on your interaction with our sites, to simplify navigation and to compile statistics on the use of websites.

2.3.

You can opt out of receiving messages at any time as set out in objective 2.2. (b) or 2.2. (c) for direct marketing, through the procedure stated in our information.

2.4.

In terms of personal data, the distinguishable categories are:
(a) Contact details (directly provided by you): We can receive your personal data directly when

• You request information in order to explore the ways our services can be used, other than through the contact form,
• You use our services,
• We ask you for information in relation to the possible use of your services or
• We use your services.

Whenever this takes place we receive and process the following personal data: your name, telephone number, e-mail address, address, language and other details that we have requested. This personal data is processed for the objectives set out in Article 2.2. (a), 2.2. (b) and/or

2.2.

(c). In order to meet our obligations, as applicable to our potential or actual working relationship and/or contractual connection, we must process personal data such as this.

(b) Contact details (provided by a third party): We can receive your personal data

• Through a third party that we have contracted in order to acquire your personal data or
• Through statistics/reports from Google

Whenever this takes place we receive and process the following personal data: your name, telephone number, e-mail address and address. This personal data is processed for the objectives set out in Article 2.2. (b) and/or 2.2. (c). Before we use personal data that we have not received directly from you (other than for storage), we will provide you with this Privacy Policy as soon as possible and request your permission to use your personal data.

(c) Data in information requests: We collect personal data when you use our website contact form to contact us, subscribe to our newsletter or to request a catalogue: your name, telephone number, e-mail address and all personal information you include when filling in the form. These are personal data that are provided to us directly by you and that are used for the objectives set out in Article 2.2. (b), 2.2. (c) and/or 2.2. (d). Your consent constitutes the legal basis for processing such personal data.

(d) Business cards:

If you provide us with a business card during an event or meeting, we may process your personal information: your name, telephone number, e-mail address, address, and all other personal data stated on your business card. In this case, to be able to answer your question, we will use your personal data. If for this purpose, you explicitly gave your consent, your data may also be used for the objectives set out in Article 2.2. (b) and / or 2.2. (c). The legal basis for such processing is formed by our legitimate interest, namely to foster your interest in us and our business relationship by keeping you informed of relevant information about our services and our company.

(e) Usage data:

We may collect personal data about your activities on our website: IP address, device ID and type, referral source, language settings, browser type, operating system, geographic location, duration of visit, page views or information about the timing, frequency and pattern of your use of our services. This information can be collected and used to help us provide useful information about the use of our website. If the usage data happens to be completely anonymous (and for this reason untraceable to you personally), then these will not be regarded as personal data for the purpose of this Privacy Policy. These are personal data that we can register through the use of your device and that are used for the objectives set out in Article 2. (e).

The legal basis for collecting such personal information is formed by our legitimate interest, namely checking and improving our website and remembering your preferred settings to provide you with a better user experience. If a cookie is used to collect such personal data, you will be asked to give your consent for the use of that cookie.

2.5.

We may also use your personal data for the objectives set out in 2.2. (f), as may be necessary to comply with a legal obligation or our legitimate interest.

2.6.

If the legal basis for processing such personal data is formed by your consent, you will always have the right to withdraw your consent at any time. However, this has no consequences for the lawfulness of data processing executed before the withdrawal of your consent. If the legal basis for the processing of data is formed by our legitimate interest, then you have the right to object to such processing, as set out in Article 4.12 of this Privacy Policy.

3. Storage and removal of your data

3.1.

Your personal data will be stored no longer than is necessary for a specific purpose. As we are unable to specify such a period in advance, the storage period is determined as follows:

(a) Personal data used either by us for the provision of services to you or for your services to us, as set out in Article 2.2 (a), will be stored, saved and used for as long as necessary for the provision of the services.

(b) Proprietary information that are used by us for direct marketing, as set out in Article 2.2. (b) or 2.2. (c), will be saved, stored and used for as long as we think our messages are beneficial to you.

(c) Personal data that we receive through the contact form will be saved, stored and used only for the period required by us to respond to your request.

(d) Usage data is saved and stored for as long as such data is useful for the purpose of website support.

3.2.

If you withdraw your consent or object to our use of your personal data and such an objection is justified, we will delete your personal data from our databases. Please note that we retain personal data to ensure your preferences are respected in the future and only to ensure that you do not receive any further messages from us.

3.3.

However, the preceding will not prevent us from saving information and content for legal purposes such as, but not limited to, the exercise or defence of a legal claim, evidence objectives, backup, administration and the execution of other legal rights and obligations that we possibly have.

4. Your rights

4.1.

This article states your main rights under the data protection law. We have tried to summarise these in a clear and readable way.

4.2.

If you wish to exercise your rights, you should send us a written request in accordance with Article 1 of this Privacy Policy. We will respond to your request without undue delay, but in any event within one month after receipt of the request. If an extension of the deadline for responding to your request is required, or if we take no action in relation to your request, we will notify you about this.
The right to access

4.3.

You have the right to receive confirmation from us about whether we do or not process your personal data. If this is the case, you have the right to access such personal data, together with additional information that is also stated in this Privacy Policy.

4.4.

As regards the personal data we have about you, you have the right to receive a digital copy from us, provided this has no detrimental effects on the rights and freedoms of others.
The right to rectification

4.5.

If the personal data we have about you is inaccurate or incomplete, you have the right to rectify this information or, taking the processing objectives into account, to supplement it.
The right to have data deleted (the right to be forgotten)

4.6.

In certain circumstances you have the right to delete your personal data without undue delay. These circumstances are as follows:
(a) The personal data is no longer necessary as regards the purposes for which it was collected or otherwise processed;
(b) You withdraw your consent and no other legal basis exists;
(c) The processing is for the purpose of direct marketing;
(d) The personal data has been processed unlawfully; or
(e) Data deletion is obligatory in order to comply with EU or Belgian legislation.

4.7.

There are certain exceptions applicable to the right to have data deleted. These exceptions include cases where processing is necessary
(a) for exercising the right to freedom of speech and freedom of information;
(b) for the compliance with a legal obligation; or
(c) establishing, exercising or defending legal claims.
The right to limit data processing

4. 8.

You have the right to limit the processing of your personal data (this means that the personal data may only be stored and used by us for limited purposes), if:
(a) you dispute the accuracy of data (and only as long as it takes to verify the accuracy);
(b) the processing is unlawful and you request the introduction of a limitation (as opposed to exercising the right to delete data);
(c) we no longer need the personal data for processing, but you require personal data for establishing, exercising or defending legal claims; or
(d) you have objected to the processing, pending the verification of that objection.

4.9.

Besides our right to store your personal information, we can still process it in other ways, but only:
(a) with your consent;
(b) for establishing, exercising or defending legal claims;
(c)  protecting the rights of other natural or legal persons; or
(d) for reasons of important public interest.

4.10.

We shall inform you prior to the removal of the limitation on data processing.
The right to data portability

4.11.

If your consent forms the legal basis for the processing of your personal data and processing such as this is carried out automatically, you have the right to receive your personal information from us in a structured, widely used and machine-readable format. However, this right does not apply if this would result in detrimental effects on the rights and freedoms of others.

4.12.

You also have the right to have your personal data transferred directly to another company, if this is technically possible, and/or to store your personal data on your own device for further personal use.
The right to object to processing.

4.13.

You have the right to object to the processing of your personal data on the grounds of your specific situation, but only in so far as the legal basis for processing is that the processing is necessary for:
(a) the execution of a task for public interest or for exercising the public authority assigned to us;
(b) legitimate interests that are pursued by us or a third party.

4.14.

If you make such an objection, we will stop processing personal data unless we can show that there are compelling legitimate grounds for processing that outweigh your interests, rights and freedoms or that the purpose of the processing is to establish, exercise or defend legal claims.

4.15.

You have the right to object to the processing of your personal data for the purpose of using this in direct marketing (including profiling for the purpose of direct marketing) If you make such an objection, we will stop processing your data for this purpose.
The right to submit a complaint to a supervisory authority.

4.16.

If you believe that the way we process your data violates the Data Protection Act, you have a legal right to file a complaint with a supervisory authority that is responsible for data protection. You can do this in the EU Member State of your usual place of residence, your work location or the location where the alleged violation took place.

5. Making your personal data available to others

5.1.

In order to be able to provide you with our services and to maintain a database with your contact details, we work with external service providers to process and store your personal data. For example, we use a third party for:

• providing the internet environment (webhosting);
• providing the IT infrastructure;
• getting ready (and distributing) newsletters and invitations.

To guarantee the security of your personal data, we never pass on personal data to other parties if we have not concluded a Processor’s Agreement with them.

5.2.

If you are one of our clients, we may pass on your personal data to the suppliers we have contracted, or wish to contract, in order to be able to provide our services to you. If you are one of our suppliers, we may provide your personal data to our clients in order to introduce you as a possible supplier, or during the supply of the services.

5.3.

We may also disclose your personal data if this should be necessary to comply with a legal obligation. We may also disclose personal data to protect your vital interests or those of another natural person.

5.4.

As such, we do not disclose any personal information to our social media partners. We do however use social media plugins to refer you to our social media channels and to give you the opportunity to use our content. These social media channels are Facebook, Instagram, LinkedIn, Twitter, Google+, Vimeo, Youtube and Pinterest. When you share an item via Twitter, LinkedIn or Google+, click on an item using “Like” on Facebook, watch a video embedded on our website via Vimeo or Youtube, or click on a link to our profile on a social media channel, such a social media service provider may collect personal information about you and link this information to your existing profile on such a channel. In such a case, the social media service provider acts as administrator.

5.5.

We are not responsible for the use of your personal data by such a social media service provider. Please take sufficient time to become familiar with the Privacy Policy of the aforementioned companies. For information purposes, we have listed the relevant links (these may be amended occasionally by the relevant service provider):

(a) Facebook: http://facebook.com/about/privacy;
(b) Instagram: https://help.instagram.com/155833707900388;
(c) LinkedIn: http://linkedin.com/legal/privacy-policy;
(d) Twitter: http://twitter.com/privacy;
(e) Google+: https://www.google.com/intl/en/policies/privacy/;
(f) Vimeo: https://vimeo.com/privacy;
(g) Youtube: https://www.youtube.com/static?template=privacy_guidelines;
(h) Pinterest: http://policy.pinterest.com/en/privacy-policy.

6. International data transfer

6.1.

We will ensure that any transfer of data to countries outside the European Economic Area is executed in accordance with appropriate security measures. We use Google Services, for that reason your personal data may be transferred outside of the European Economic Area.

6.2.

On the date this Privacy Policy is published, Google is in possession of a Privacy Shield Certification. If for any reason the Privacy Shield is declared invalid or Google no longer fulfils the obligations of the Privacy Shield, then we will ensure that other security measures, such as those of the standard contract provisions provided by the European Commission, are used to protect your personal data.

6.3.

You hereby authorise us to transfer your personal data outside the European Economic Area.

7. Cookies

7.1.

Our website uses cookies. Please see our Cookie Policy for further information on our use of cookies.

8. Amendments to the Privacy Policy

8.1.

We reserve the right to change this Privacy Policy. Since each change directly affects you, we will send you the Privacy Policy again and request your consent where necessary.