Privacy Statement

Privacy Policy

PRIVACY POLICY

(Relating to Privacy Protection and Cookies)

1. WHO ARE WE ?
GALACTIC, a company registered under number BE0408321795. In accordance with applicable law, especially with the European Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation  or "GDPR"), and with the Belgian Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data, we are acting as the entity responsible for handling your data. Thus, we shall be responsible for the use we make or which might be made on our behalf of your personal data.


2. OUR COMMITMENT
Ensuring confidentiality of collected data is essential to building trust between you and us. Consequently, we take privacy policy very seriously when we conduct our business. 
The present notice relating to privacy policy is meant to explain to you how we collect and process your personal data, and applies, inter alia, to (i) our Website http://www.lactic.com (hereinafter referred to as the "Website"), and (ii) to all (business) relations existing between the Company and its customers, prospective customers, and business partners. 
It can be amended at any time, in which case the updated version will be published on our website.
The latest update of the present notice is dated January 2020.

3. THE PERSONAL INFORMATION THAT WE PROCESS 
As part of our relationship, we are required to process some of your personal data when you interact with us through our distribution channels or when you contact us with enquiries. We collect some personal data when you use our Websites or applications, for example when using technologies such as cookies.
Please note that we only process information collected from you in order to provide you with the goods and services you expect from us. 
You may exercise some control on the personal data that we collect. When personal data is collected, you may decline to provide personal information to us. However, if you choose not to provide the personal data we need in order to process an order for goods or services, we may not be able to provide you with such good or service. 

Below, you will find details of the personal data that we may collect and / or process as part of our collaboration:

Personal identification : your last name, first name, gender and signature. 
Contact details : your professional e-mail address, mailing address and phone number as well as other similar contact details such as delivery address or language preference.
Information on your contract when you enter into a contract with us as service provider/supplier or customer : information necessary to manage our business relationship. 
Financial data : data necessary to process your payment such as bank details. 
Purchases : data in connection with the offers that you are requesting, the orders that you are placing and the purchases that you are making. If you already have an account with us, we also retain information on your balance and possible outstanding payments.
Location data : information on your location for delivery and administrative management purposes. 
Your interactions with us : the content of messages (in particular via the contact form available on the Website), e-mails, correspondence that you send or phone calls that you make, or comments and opinions that you write about our products, or the questions and information that you ask/send to our customer service. 
Video monitoring. When you enter our premises or when you pass through our plant, you may be filmed by our surveillance cameras. Our video-surveillance installations are monitored directly by GALACTIC. Recordings are regularly deleted, unless they are used to investigate an alleged violation or an incident.

4. WHY DO WE USE YOUR DATA ?
We make use of your personal data within the framework of our relationship with you. This includes :
- Sales
- Improvements to our goods and services
- Products warranty
- Marketing (directory, newsletters, prospection, profiling)
- Maintenance and operation of the Website
- External communication
- Online application
- Compliance with legal requirements 
- Litigation
 The above-mentioned activities are detailed in the following sections. 

4.1 Sales 
We use your personal data for relevant activities such as :
• Delivering our goods and services : we use your personal data for order processing, delivery, invoicing and payment.
• Account opening and credit management : we use your personal data to create and activate your account, manage your contract(s) and grant credit facilities.
• Payments : we communicate payment details to banks as well as other entities that process payments or provide other financial services.
• Customer service and products returns : we use your personal data to activate product warranty when an order is placed as well as for the receipt, registration and treatment of customer complaints and/or products returns and the treatment of a complaint file.
• Customer service. we use your personal data to answer your enquiries as well as to provide the after-sale service for our goods and services.

4.2 Improvements to our goods and services
We make use of your personal data in order to :
• Conduct surveys or seek your opinion about our goods and services : your answers and opinions are used for quality control and possible improvement of our goods and services.
• Evaluate your use of our Websites, applications as well as your reaction to our communications in order to improve the goods and services that we provide.
• Keep records of our activities and services, which may include communications with you or in connection with you.

4.3 Product warranty
We may communicate some personal data to manufacturers of our products within the framework of the contractual or legal warranty of the product.

4.4 Marketing
We make use of your personal data for :
• Directories : under your agreement, we may create a customers/prospects database.
• Newsletters : under your agreement, we may send you newsletters about our goods and services.
• Prospection : under your agreement, we may send you communications (including e-mails and text messages) concerning our goods and services or those of a third-party, if we think that they may be of interest to you (for example because they are similar to other goods and services that you have bought or for which you have shown interest). Under your agreement, we may also communicate your personal data to affiliates of GALACTIC for commercial purposes. Transmitted data may include your name, phone number and e-mail address in order to enable our affiliates to be able to contact you to offer goods or services. 
• Customized content : under your agreement, we may use your personal data to present content and customized advertising and/or to inform you about our events or new products and services
Should you oppose commercial activities, you may nevertheless receive requests to give your opinion, surveys as well as other communications from our customer service. 
You may withdraw your consent towards such commercial activities at any time or oppose the sending of requests to give your opinion or reply to surveys simply by responding to a commercial e-mail or by using the contact details referred to in the « How to exercise your rights ? » section below. 

4.5 External communication
We use your personal data to inform you about our business strategy, our governance or our values

4.6 (Online) application
Via the “careers” tab of our website, by e-mail or by post, you may be send us some of your personal data in order to apply for a job at GALACTIC.

4.7 Complying with our legal obligations 
We process your personal data or communicate it to third parties when required by applicable law, notably :
- Tax law
- Accounting law
- Fraud prevention law
- Credit risk mitigation law
- Insurance law
- Human resources law
- Complying with our legal obligations

4.8 Disputes and litigation
We may process your personal data to :
- resolve disputes, whether potential or in progress
- defend our legal rights
- maintain our defense within the scope of a legal proceeding
- respond to police or court requests
- and more generally, protect our rights, our confidentiality, our security or our goods.

4.9 Legal base
In general, we will only use your personal data if you have given your consent, or if this use is based on one of the legal grounds provided by law:
• The pursuit of our legitimate interests : For example : to prevent fraud, etc. When we process your information for that very reason, we always try to balance our interest in obtaining this information with your legitimate rights and expectations;
• The conclusion, negotiation and implementation of a contract which is binding on you and us : For example : to deliver goods that you have ordered. We may also need to collect your information because you would have asked us to do something before signing a contract with you, for example to provide an offer or a quote;
• Compliance with a legal obligation : In some cases, we need to retain personal data because it is required by law. For example : to ensure appropriate safety in general, for tax reasons, etc;
• The safeguarding of the public interest: for example, the collaboration wil the Police (transmission of video surveillance images);
• Your consent : For example : when you fill out a paper form or an online form and you choose to provide us with certain information.

5. COMMUNICATING YOUR INFORMATION AND OUR RELATIONSHIP WITH THIRD PARTIES 
We will not disclose your personal data to third parties, except when necessary in the context of the service requested and in particular, but without limitation, to :

5.1 Service providers 
We may have to communicate your personal data to service providers for any of the purposes listed in section « Why do we use your data ? ».
Our service providers are required to make use of your personal data in accordance with our data privacy and security requirements. They are not allowed to use the personal data they receive for any other purpose.

5.2 Our business partners
Information about the goods you are buying may be communicated to our trading partners from which you have bought some good or service, for example to schedule a delivery or to check availability of some goods. 
Our business partners will be required to make use of your personal data in accordance with this privacy policy, and are not authorized to use the personal data they receive from us for any other purpose.

5.3 Companies being part of GALACTIC Group
We may communicate your personal data to other companies that are part of GALACTIC Group. In that case, these entities are acting on our behalf and we therefore remain liable for their use of your personal data. When your personal data is forwarded outside of the European Economic Area and Switzerland, we make sure that appropriate measures are taken to protect your personal data, according to paragraph 6 below. 

5.4 Other recipients
Your personal data may possibly be made public to webmasters, payment partners, software providers, cloud partners, our insurance company as well as various providers whom GALACTIC may appeal in the context of provision of its services.
If it is necessary that, in this context, GALACTIC discloses your personal data to third parties, the third party concerned will be required to use your personal data in accordance with the provisions of this privacy policy.
We may also have to communicate your personal data to the following third parties : 
• Legal or regulatory authorities
• Relevant stakeholders to legal proceedings, such as lawyers, applicants, defendants, etc. in order to ensure our defense or exercise our legal rights.

6. INTERNATIONAL TRANSFERS OF PERSONAL DATA 
In principle, we will not transmit your personal data outside the European Economic Area (EEA).
However, in the case of certain services, GALACTIC is forced to process your personal data outside the EEA with a recipient whose domicile or registered office is in a country which does not fall under a similar decision, promulgated by the European Commission, this treatment will be subject to the provisions of a data processing agreement, which will contain (i) the standard contractual clauses as defined in the "European Commission Decision of 5 February 2010 (Decision 2010/87/EC)", or (ii) any other mechanism on the basis of privacy legislation or any other regulation relating to the processing of personal data.
In particular, some of your personal data can be exchanged with our subsidiary located in Moldova, Galactic International SRL. GALACTIC guarantees that its subsidiary is subject to the same conditions of personal data protection as the Belgian companies of the Group, and will use your personal data in accordance with the provisions of this privacy policy.

7. RETENTION OF YOUR PERSONAL DATA 
Unless a longer retention period is required or justified (i) by law or (ii) by compliance with another legal obligation, we will only keep your personal data for the period that is necessary to reach and fulfill the purpose for which they were collected as described in this Policy. The retention period may vary from one type of personal data to another since it will depend upon : 
• The need for the company to retain such personal data 
• Contractual obligations or requirements from trading partners
• Legal requirements (data protection, insurance, taxes, human resources...)
• Rules and recommendations published by the authorities in charge of data protection.
GALACTIC may retain some personal data beyond this time period, for example to settle disputes and, for the needs of ongoing or expected legal proceedings, to keep records of its departments, fulfil its legal obligations and defend its legal rights.

8. SECURITY OF YOUR INFORMATION
We regularly review the technical and organisational measures put in place to protect our information and communication systems so as to adapt them to the risks involved and prevent any loss, abusive use or unauthorised modification of your personal data.
We accept no responsibility for prejudice caused by the access or use of our Website, including in case of a virus infecting your computer or any other property damage.
While every effort has been made to ensure the accuracy and veracity of the information on our Website, we shall not be liable for any mistake, omission or any result that could have been obtained, transmitted, relayed or collected while using that information.

9. YOUR RIGHTS
You may exercise any of the rights granted to those concerned. You are informed that you have the following rights : 

Right of access. You have the right to know if we retain personal data about you. You have the right to obtain a copy of the personal data we retain about you, as well as other information on how we process such data ;

Right of rectification. You have the right to obtain a rectification of your personal data if found to be inaccurate, and in some cases to obtain a deletion or limitation in the processing of your personal data; 

Right to object. You may oppose the use of your personal data for some purposes (for example for commercial purposes) ;

Right of limitation of data processing. You have the right to ask us to limit our use of your personal data in some specific cases, for example while we are investigating a complaint linked to inaccurate personal data (under certain conditions) ;

Right to erase data. You have the right to ask us to erase your personal data (under certain conditions) ;

Right to data portability. As the case may be, you have the right to receive a copy of the personal data that you have given us (in machine-readable form) or to ask us to forward such data to another company ;

Right to withdraw your consent. You have the right, at any time, to withdraw the consent you have given concerning the use of your personal data.  This includes your consent regarding prospecting activities (see « Why do we use your data ? » under section « Marketing »).

If you wish to exercise your rights relating to the protection of privacy, please contact privacy@lactic.com or complete the form for the exercise of your rights and send it to GALACTIC by e-mail or by post.
You will find more information about your rights on the website of the Data Protection Authority(‘DPA’) via the following link https://www.dataprotectionauthority.be/.


10. OTHER WEBSITES
The Website may contain hyperlinks to other websites. When you click on one of these links, you may be redirected to another website or internet source that may collect information about you via cookies or other technologies. The Company does not have any responsibility, or authority of control over these other sites or internet resources, nor the collection, use and distribution of your personal data. You must check the privacy policies of these other websites and internet sources yourself, to assess whether they act in accordance with privacy legislation. 

11. COOKIES
Cookies are very small text files that are placed and stored on your computer when you visit some websites. Cookies can be persistent or non-persistent. A persistent cookie remains stored on your computer until it reaches a defined expiration date. Non-persistent or session cookies will be deleted from your computer as soon as you close your browser.

This website uses cookies to help identify your computer so we can track shopping basket contents and remember where you are in the order process. In addition, the Site also uses cookies to allow us to improve the quality of the Site.

You can decline cookies or disable any cookies already stored on your computer, but these may stop the Site from functioning properly. For declining/disabling cookies, you have to check the settings of your browser. For more information on managing and deleting cookies, please visit: https://www.autoriteprotectiondonnees.be/faq-themas/cookies.
Like most websites, this Website uses cookies, which can be classified into the following categories: 
- Strictly necessary cookies : these are cookies essential for the proper functioning of our Website;
- Functionality cookies and / or session cookies: these cookies are used to optimize and simplify your user experience. For example, they can remember your previous choices of your password;
- Analytical and performance cookies: these cookies are used for internal purposes to help us provide you with a better user experience, for example to assess the performance of a website or test different interfaces for the Website. We often use research firms to provide these services, therefore these cookies may be placed by a third party;
- Targeting and advertising cookies: these cookies are used to present you with content (including advertising content) personalized and interesting for you, and also to evaluate the effectiveness of this content. This content may be presented on our websites or on third party websites. We often instruct third party providers to distribute this content, therefore some of these cookies may be placed by a third party.

Below you will find a detailed description of the cookies placed and stored on your computer by the Site:

The following cookies are  strictly necessary in the operation of our web site:

Purpose

Expire date

. ASPXANONYMOUS

Session and basket cookie

This is a persistent cookie which will be deleted after a period of 7 days. 

ASP.NET_SessionId

Session cookie

This is a session cookie which will be deleted from your computer as soon as you close your browser.

language

Keep information about language preference

This is a session cookie which will be deleted from your computer as soon as you close your browser.



12. UPDATE OF THE POLICY
The Company is entitled to update the present Charter by installing a new version on the website. In this context, it is recommended that you regularly consult the website and the page in question on which the Charter is published, in order to be certain that you are aware of any changes. 
The most recent version will always be available via the following link : https://www.lactic.com/en-us/privacystatement.aspx

13. CONTACT GALACTIC
To exercise the aforementioned rights or obtain additional information on these rights, you can contact us using the following contact details:
- By e-mail : privacy@lactic.com;
Or
- By post: Place d’Escanaffles 23, 7760 Celles (Belgium)

14. TREATMENT OF APPLICATIONS
Information communicated by applicants (identity, address, phone number, e-mail address, date of birth, level of education, required profile, etc.…) are meant to be used by the Sales & Marketing or Human Resources Departments of GALACTIC, as well as, when appropriate, by external service providers acting exclusively on behalf of our company. 
The collected information is necessary for the treatment of the application files. 
Pursuant to the Belgian Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data , any applicant has the right to oppose personal data processing, to ask to have access to the collected data and to ask for rectification (see section 9 « YOURS RIGHTS » above).

15. WHAT DO WE EXPECT FROM YOU ?
For your part, we expect you to ensure that the information you have provided to us is relevant and up to date. You must also inform us immediately of any significant change in your situation. If you are required to provide us with information about a third party, we invite you to make sure that the third party has given you its consent to do so. 


This Privacy policy was last updated on January 2020.