Your privacy is our concern

Just for your knowledge we have divided our privacy policies in to two categories, for more understanding and information about which information we store for which purpose. 

Privacy policy of the site

Effective Date: 2022-03-18
Updated: 2022-03-18

GENERAL

ELTRA NV attaches great importance to the proper handling of your personal data. In this privacy policy, we wish to inform you about how we collect and process your personal data. Our policy is fully in line with the new European Regulation 2016/679 ("GDPR" or "AVG") and all other relevant legal provisions concerning the processing and protection of personal data.

WHAT PERSONAL DATA?

The list below gives an overview of the categories of personal data that we process. Depending on your situation and your relationship with us, certain personal data or categories may not apply for your case:  

  • Personal identification data, such as name and surname, address, gender,...
  • Electronic identification data, such as e-mail address, telephone number, cell phone number, ...
  • Financial identification data, such as your bank details, VAT number, solvency data, annual accounts, …                                                                                                                                                                    
  • Your contact history with us, such as e-mails, chats, completed contact forms on our website, ...
  • Products and services you purchase from us, such as your purchase history
  • Marketing and analytics data, such as your interaction with newsletters, website, app, webshop, in order to provide you with the most relevant and personalized offerings possible.

 Our website uses cookies. For more information, please check our cookie policy.

HOW DO WE OBTAIN YOUR PERSONAL DATA?

Your personal data can be collected in various ways, including:

  • The conclusion of contracts
  • Communication: in person, by email, letter, fax or telephone
  • Filling in a web form on our website
  • Analytical applications, such as Google Analytics
  • From financial institutions and other payment processors and platforms.

In other words, we may obtain your personal data directly from you or through third parties. In the latter case, we ask these third parties to confirm that the information was obtained lawfully and that we have the right to use the data obtained from them.

 WHY DO WE REQUEST PERSONAL DATA?

We use and process your personal data for the following purposes, among others:

  1. Within the framework of the existence of a contractual and/or commercial relationship (customers, prospects, suppliers, partners) for:
  • The correct execution of our contract: follow up and delivery of orders, follow up and creation of invoicing, follow up payment, ...
  • Maintaining our commercial relationship by, for example, keeping you informed of novelties or general information regarding the product range, (address) changes of branches, recall campaigns, …
  • Customer support: product inquiries, complaints, warranty questions, ...
  • Conducting satisfaction surveys to improve our services.
  • Targeted promotions or information campaigns related to our products.
  • Invitations to events, trade shows, or similar activities.
  1. Outside the existence of a contractual relationship, when you show interest in our products:
  • Inquiries by phone, mail, in person or via the website: to allow us to answer your inquiry.
  • To inform you by sending newsletters.
  • To inform you about activities, events, products, services, special offers related to our company.

If we need to use/process data for purposes other than those mentioned above, we will contact you before using it, so that you will be able to refuse its use.

ON WHAT LEGAL BASIS?

We may collect and process your personal data:

  • To the extent that it is necessary for the execution of an agreement that you have concluded with us or in order to take the necessary steps to obtain this agreement.
  • Based on your consent (which is always revocable)
  • For the protection of legitimate interests (such as sending targeted promotions, inviting you to events, conducting satisfaction surveys). We always keep in mind that our interests must be in balance with your interests and we always provide the possibility of opting out.
  • Where legislation requires us to do so.

WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We do not share your personal data with third parties except in the following cases:

  • When it is necessary for our services. Some of our databases are accessible to third parties that we contract with for the provision of our goods and services. When external service providers receive your information, we remain responsible for the use of your personal data. We take appropriate steps to ensure that such third parties treat your personal data with the same care as we do.
  • From time to time, we may be required to disclose your personal data to law enforcement agencies, regulators, agencies or third parties pursuant to a legal obligation or court order. We will act responsibly and take your interests into account when responding to such requests.

We wish to emphasize that the various companies that are part of ELTRA NV are not considered as third parties and that your personal data may be shared with them.

We do not sell your personal data to third parties.

GUARANTEE OF LAWFUL AND SECURE PROCESSING OF PERSONAL DATA

Your data is considered as strictly confidential. ELTRA NV has developed technically and organizationally appropriate security measures in order to avoid the destruction, loss, falsification, alteration, unauthorized access or accidental notification to third parties of personal data as well as any other unauthorized processing of these data.

HOW LONG DO WE KEEP YOUR DATA?

We will keep your data for as long as necessary for the purposes of the processing, as stated in this policy.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA?

You always have the right :

  • To access and copy the personal data processed by us.
  • To have inaccurate, incomplete, inappropriate or outdated data corrected.
  • To request in certain circumstances that your personal data will be erased ('right to be forgotten').
  • To restrict the processing of personal data that applies to you.
  • To object to the processing of your personal data or to withdraw your previously given consent to the specified processing of personal data. This right to object only applies if there are sufficiently justified and weighty reasons for doing so. No objection is possible to the processing of your personal data, if this is necessary for the performance of contractual obligations/legal obligations.
  • To obtain the personal data provided to us and to transfer it to another controller.

HOW CAN YOU EXECUTE YOUR RIGHTS?

In order to execute the above-mentioned rights, or in case of further inquiries or complaints regarding the processing of your personal data please contact us:

  • By e-mail: privacy@eltra.be
  • By letter: ELTRA NV, To the person responsible for data processing, Pachtgoedstraat 2, 9140 Temse, Belgium

We kindly ask you to add a copy of your identity card (preferably the front) with your request in order to avoid any unauthorized disclosure or processing of your data. We strongly recommend that you make your passport photo invisible when doing so and to state that it is a copy.

You also have the right to file a complaint to the Data Protection Authority.

We reserve the right to amend our privacy policy on a regular basis. We therefore recommend that you review this policy periodically.

Privacy policy of our app

Effective Date: 2022-03-18
Updated: 2022-03-18

GENERAL
“Ceezam” is an application by Eltra nv – Pachtgoedstraat 2, 9140 Temse (Belgium)
Eltra nv, its affiliates and subsidiaries (“we”, “us”, “our”, “Eltra”) are committed to protecting your privacy. This Privacy Policy (“Policy”) describes our practices in connection with information privacy on Personal Data we process through your individual use of the following services, products, and related mobile applications (collectively, the “Products”):

 “Qnect home” application

In this Privacy Policy, “Personal Data” means information that can be used to identify an individual, either from that information alone, or from that information and other information we have access to about that individual. “Smart Devices” refers to those nonstandard computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc. “Apps” refers to those mobile applications developed by Eltra nv that provide end users remote control to Smart Devices and with the ability to connect to qnect home IoT Platform.
For other branded mobile applications powered by Eltra nv, our Clients control all the Personal Data collected through our Products. We collect the information under the direction of our Clients and the processing of such information shall be limited to the purpose of providing the service for which our Clients has engaged us. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly.
What Personal Data do we collect
In order to provide our services to you, we will ask you to provide necessary Personal Data that is required to provide those services. If you do not provide your Personal Data, we may not be able to provide you with our products or services.

Information You Voluntarily Provide Us

•    Account or Profile Data: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with our Products, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account.
•    Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

Information We Collect Automatically

•    Device Information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.
•    Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.
•    Log Information: When you use our app, the system and exception log may be uploaded.
•    Location Information: We may collect information about your real-time precise or non-precise geo-location when you use our specific Products or Services, such as robot cleaner and weather service.
3.    Smart Devices Related Information:
•    Basic Information of Smart Devices: When you connect your Smart Devices with our Products or Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.
•    Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with our Products or Services, we may collect different information reported by your Smart Devices. For example, smart weights or fitness trackers may report your height, weight, body fat mass (BFM), BMI and skeletal muscle mass (SMM); smart cameras may report images or videos captured by it.
Purposes and legal basis for processing Personal Data
The purpose for which we may process information about you are as follows:
•    Provide You Services: We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Products and Services that you have requested or purchased. The legal basis for this processing is to perform our contract with you according to our Terms of Use.,
•    Improve Our Services: We process your device information, usage data, location information and Smart Device related information to ensure the functions and safety of our Products, to develop and improve our Products and Services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
•    Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
•    Marketing Communication: We may process your Personal Data to provide marketing and promotional materials to you on our Products and Services. If we do so, each communication we send you will contain instructions permitting you to opt-out of receiving future communications of that nature. The legal basis for this processing is your consent. Additionally, if you consent to participate in our lottery, contest or other promotions, we may use your Personal Data to manage such activities.
•    Personalization: We may process your account and profile data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of our Products. The legal basis for this processing is your consent.
•    Legal Compliance: We may process your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Who do we share Personal Data with?

At Eltra nv, we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:
•    To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.
•    To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our Sites and Services.
•    To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of your Personal Data, and choices you may have regarding your Personal Data.
•    As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
•    To subsidiaries or affiliates within our corporate family, to carry out regular business activities.
Except for the third parties described above, to third parties only with your consent.

International Transfer of Information Collected

To facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live. Laws in these countries may differ from the laws applicable to your country of residence. When we do so, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches:
•    an agreement on the basis of approved EU standard contractual clauses per GDPR Art. 46.  For more information, see here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-….

If you would like further detail on the safeguards we have in place, you can contact us directly as described in this Privacy Policy.
Your Rights Relating to Your Personal Data
We respect your rights and control over your Personal Data. You may exercise any of the following rights:
•    Via the “Me – Your nickname – Account and Security” in our Products (for Product version 3.2 and later)
•    By emailing us at privacy@eltra.be (for Product version before 3.2)
You do not have to pay a fee and we will aim to respond you within 30 days. If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.
You may:
•    Request access to the Personal Data that we process about you;
•    Request that we correct inaccurate or incomplete Personal Data about you;
•    Request deletion of Personal Data about you;
•    Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you;
•    Request transfer of Personal Data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; and
•    Opt-out or object to our use of Personal Data about you where our use is based on your consent or our legitimate interests.

Security

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. Eltra nv provides various security strategies to effectively ensure data security of user and device. As for device access, Eltra nv proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization. As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported. As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing privacy@eltra.be.

Data Retention

We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data. When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.
Dispute Resolution
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Changes to this Policy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

For European Union data subject, you have the right to lodge a complaint with a supervisory authority concerning Eltra nv data processing activities. For questions, or to exercise your rights as an EU data subject, please contact our EU Representative here:
Eltra nv - Pachtgoedstraat 2 - 9140 Temse - Belgium
Email: privacy@eltra.be 

We reserve the right to amend our privacy policy on a regular basis. We therefore recommend that you review this policy periodically.