Version 25/05/2018. Compliance with the General Data Protection Regulation (GDPR).

1. General Disclaimer

1.1 The “Choux de Bruxelles” group, composed of the companies: “Groupe Choux de Bruxelles SA”, “A Propos Catering SPRL”, “A Propos SA”, “Fresh Belgium SA”, “RGMP SPRL”, “PBA-PSK Catering SPRL”, “Good Robinson SA”, “Ostend Sea Place SA”, “Café Georgette SPRL”, “L’Arche du Gourmet SPRL”, “EP CONCEPT SPRL”, “Gio’s Strada SPRL”, “La Chaufferie SPRL” (hereinafter referred to as “Choux de Bruxelles”), respects the privacy of its users (hereinafter referred to as “Users”).
1.2 “Choux de Bruxelles” processes personal data transmitted to it in accordance with current legislation, particularly the law of December 8, 1992, concerning the protection of privacy and its implementing decrees.

1.3 Access to the website www.chouxdebruxelles.be (hereinafter referred to as the “Site”) implies the full and unconditional acceptance by the internet user of this Privacy Charter (hereinafter referred to as the “Charter”), as well as its General Terms of Sale (hereinafter referred to as the “GTC”).

1.4 The User acknowledges having read the information below and authorizes “Choux de Bruxelles” to process, in accordance with the provisions below, the personal data that he/she communicates on the Site within the framework of the service offered by “Choux de Bruxelles” (hereinafter referred to as the “Service”).

1.5 With prior notice to Users, “Choux de Bruxelles” may be required to modify and adapt the Charter, particularly to comply with any new applicable legislation and/or regulations (such as the adoption of the new European regulation on the processing of personal data – Regulation 2016/679 of the European Parliament and the Council of April 27, 2016, concerning the protection of individuals with regard to the processing of personal data and the free movement of such data – of April 14, 2016, applicable from May 25, 2018), the recommendations of the Privacy Commission in Belgium, the guidelines, recommendations, and best practices of the European Data Protection Committee, and the decisions of courts in this matter.

1.6 The Charter is valid for all pages hosted on the Site and for the records of this Site. It is not valid for pages hosted by third parties to which “Choux de Bruxelles” may refer and whose privacy policies may differ. Therefore, “Choux de Bruxelles” cannot be held responsible for any data processed on or by these sites.

1.7 The communication of personal data is sometimes necessary to access certain parts of the Site (for example, for a request via our online quote). Without the User’s communication of this data to “Choux de Bruxelles,” access may be denied.

2. Data Controller

2.1 Access to the Site is generally possible without having to provide personal data, such as, in particular, the name, first name, postal address, email address…

2.2 However, within the scope of the Service, the User may be required to transmit certain personal data. In this case, the data controller for this data is: “Groupe Choux de Bruxelles SA– Boulevard Louis Schmidt 1 – 1040 Brussels – VAT Number: 840.411.958

2.3 We have appointed Cassandra Léonard as the Data Protection Officer (DPO), who ensures compliance with privacy legislation and the confidential processing of personal data. Any questions or requests regarding the processing of this data can be addressed to her at the email address privacy@chou.be

3.Collected Information

3.1. DATA TRANSMITTED TO CHOUX DE BRUXELLES BY THE ACTIVE INTERVENTION OF USERS
By browsing the Site, filling out forms or newsletters on the Site, through social networks linked to “Choux de Bruxelles,” the User allows “Choux de Bruxelles” to record, store, or use in its CRM software (Odoo) for the purposes mentioned in section 4, the following information:

Identification data, such as name and surname, email address, date of birth, and physical contact information
Banking information necessary for the Service, such as bank account numbers, IBAN, and BIC/SWIFT
Billing information
Communications between Users and “Choux de Bruxelles”
Additional information requested by “Choux de Bruxelles” from the User to identify them or prevent them from violating any provisions of the Charter
Any other information voluntarily transmitted to “Choux de Bruxelles” by the User for a specific purpose in the Charter, in the GTC, on the Site, or on any other communication medium used by “Choux de Bruxelles”

3.2. DATA THAT IS AUTOMATICALLY TRANSMITTED TO CHOUX DE BRUXELLES WHEN CONSULTING THE SITE
3.2.1. COOKIES

In order to facilitate navigation on the Site and optimize technical management, the Site may use “cookies.”

A “cookie” is a small file containing information saved by a website on the User’s computer or smartphone. This “cookie” can be retrieved during a subsequent visit to the same smartphone or the same site. The “cookie” can only be read by a website other than the one that created it. The Site uses “cookies” for the proper administration of the Site, notably to record the User’s browsing preferences or to obtain information about the pages viewed and the dates and times of viewing.

Most “cookies” only function for the duration of a session or visit. Users can also configure their browser to be informed each time a “cookie” is created or to prevent their storage, individually or collectively. Disabling cookies, however, could prevent access to certain parts of the Site or make access more difficult.

Subject to the prior consent of the User, the Site may also allow the use of third-party cookies, including, notably: Facebook, Instagram, Youtube, Google+, Wordfence

“Choux de Bruxelles” uses social modules from social network providers Facebook, Instagram, and Google+ on its Site. These social modules establish a direct connection to the server of the social network via the User’s browser. The social network provider on which the User clicked receives information that the User visited the Site. If the User is registered and identified on the relevant social network, the provider can correlate the User’s profile with the visited Site. The network provider can then establish future interactions. If the User is not registered with the social network, the provider may store the User’s IP address. To prevent the transfer of this data to the social network provider, the User should not click on the corresponding button for the social network.

Google Analytics. The Site also uses Google Analytics. This service, offered by Google, analyzes the Site’s activity. For this purpose, Google collects information related to web traffic and the number of visitors. This tool allows “Choux de Bruxelles” to measure the Site’s performance in terms of navigation and to compile activity reports and other services.

3.2.2. INFORMATION STORED ON THE CONSULTED SERVERS

When the User accesses the Site, the consulted servers automatically record certain data, such as the type of domain with which the User connects to the Internet, the IP address assigned to the User (during their connection), the date and time of access to the Site, and other data related to traffic, location data, or other communication-related data, the pages viewed, the type of browser used, the platform and/or operating system used, the search engine, as well as the keywords used to find the Site…

However, no personally identifiable information about the User is collected through these records. This information is retained solely for statistical purposes and to improve the Site.

4. Processing Purposes

4.1. GENERAL PURPOSES
Without prejudice to the information provided in section 3.2 regarding automatically transmitted data, the Site collects, stores, and processes the personal data of its Users, notably for the following purposes:

To establish, execute, and manage the contractual relationship with the User
To enable the User to participate in games/contests/quizzes and, in general, to provide the Service
To incorporate the personal data of Users into one or more automated files
To analyze, adapt, and improve the content of the Site
To conduct internal statistical surveys and market studies and implement various statistical systems and studies
To allow the User to receive messages and manage their account from different devices (computer, tablet, smartphone…)
To detect and/or prevent fraud or similar activities of an illegal nature
To facilitate the provision and use of the Site and improve the Services offered by “Choux de Bruxelles” as well as the User experience
To respond to information requests
For any marketing actions and promotions offered by “Choux de Bruxelles” to Users who have subscribed to the Newsletter
To inform them about the developments of the Site and its features
For any other purposes for which the User has expressly given consent

4.2. Communication to Third Parties

“Choux de Bruxelles” considers personal data as confidential information. It will not disclose them to third parties under conditions other than those specified by the Charter or as required by law, particularly at the request of competent authorities.

Considered as partners of “Choux de Bruxelles” are all the companies that compose it: “Groupe Choux de Bruxelles SA”, “A Propos Catering SPRL”, “A Propos SA”, “Fresh Belgium SA”, “RGMP SPRL”, “PBA-PSK Catering SPRL”, “Good Robinson SA”, “Ostend Sea Place SA”, “Café Georgette SPRL”, “L’Arche du Gourmet SPRL”, “EP CONCEPT SPRL”, “Gio’s Strada SPRL” in the exercise of their missions (hereinafter the “Partners”). In this context, “Choux de Bruxelles” may communicate to its Partners the personal information of its Users, for the purposes outlined in paragraph 4.1.

“Choux de Bruxelles” may transmit to third parties the personal information of its Users to the extent that such information is necessary for the execution of a contract with its Users (for example, a restaurant to confirm a reservation made through the Site or an event venue to organize its services). In this case, these third parties will not disclose this information to other third parties, except in one of the following two situations:

the disclosure by these third parties of this information to their suppliers or subcontractors to the extent necessary for the performance of the contract, and
when these third parties are required by applicable regulations to disclose certain information or documents to competent authorities in the fight against money laundering, and, in general, to any competent public authority.

The disclosure of this information to the aforementioned persons shall, in all circumstances, be limited to what is strictly necessary or required by applicable regulations.

In order to introduce new products to Users that may interest them, “Choux de Bruxelles” may also disclose the personal information of its Users to third-party companies, provided that Users have explicitly consented.

4.3. Direct Marketing

Personal data will not be used for direct marketing purposes for products or services other than those to which the User has already subscribed. The User retains the right to oppose such use at any time, upon request and free of charge. The User can do this by unsubscribing using the corresponding link in each newsletter or by clearly communicating the request to privacy@chou.be. The User shall be responsible, in all cases, for the accuracy of the provided data and undertakes to inform CHOUX DE BRUXELLES of any changes to this information. Choux de Bruxelles reserves the right to use this data to communicate information related to services issued and distributed within the legitimate interest of the company in promoting these services to its clients.

5. Security

5.1 “Choux de Bruxelles” has implemented appropriate measures to ensure that the servers hosting the processed personal data prevent, to the extent possible: unauthorized processing, access, or modification of this data; improper use or disclosure of this data; and illegal destruction or accidental loss of this data.

5.2 In this regard, employees of “Choux de Bruxelles” who have access to this data are subject to strict confidentiality obligations. However, “Choux de Bruxelles” cannot be held responsible in any way for the diversion of this data by a third party despite the security measures adopted.

5.3 Users undertake not to engage in actions that could be contrary to this Charter, the General Terms and Conditions (CGV), or, in general, the law. Offenses against the confidentiality, integrity, and availability of computer systems and data stored, processed, or transmitted by these systems, or the attempt to commit any of these offenses, are punishable by imprisonment for three months to five years and a fine of twenty-six euros to two hundred thousand euros, or one of these penalties alone.

6. Data Retention Period

“Choux de Bruxelles” will normally retain the personal data of its Users for the entire duration necessary to achieve the purposes pursued (see point 4). “Choux de Bruxelles” may also continue to hold personal data concerning the unsubscribed User, including any correspondence or assistance requests addressed to “Choux de Bruxelles,” in order to respond to any questions or complaints that may be addressed to it, and to comply with all applicable laws (including tax matters), including the retention of information related to payments made.

7. Rights of the Data Subject

7.1 The User may at any time request access, rectification, or, if applicable, the deletion of their personal data, except for those for which “Choux de Bruxelles” has a legal obligation to retain, by sending a written request, accompanied by a copy of their identity card or passport, to the data controller at the following postal address: “Choux de Bruxelles,” Legal Department, Boulevard Louis Schmidt 1, 1040 Brussels; or at the email address privacy@chou.be.

7.2 “Choux de Bruxelles” will then take the necessary steps to fulfill this request as quickly as possible.

8. Note Regarding Minors

Individuals under the age of 18 and those who do not have full legal capacity are not authorized to disclose their personal data to “Choux de Bruxelles.”

9. Applicable Law and Competent Jurisdiction

9.1 The Charter is subject to Belgian law, to the extent permitted by the rules of private international law.

9.2 In the event of a dispute regarding the validity, application, interpretation, or enforcement of the Charter, the courts of the judicial district of Brussels (Belgium) have exclusive jurisdiction, to the extent permitted by the rules of private international law.

9.3 Before initiating any legal proceedings to resolve a dispute, the User undertakes to attempt to resolve it amicably by directly contacting “Choux de Bruxelles,” possibly through mediation, before resorting to arbitration, litigation, or any other method of dispute resolution.