2. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
The relevant entity of the Unilin Group1 that processes your personal data in the course of its activities (e.g. the entity with whom you have entered into a contract, to whom you have provided your personal data, from whom you are visiting the website, ...) is responsible for the processing of your personal data. This means that the Unilin Group determines for what purposes and with what means your personal data will be processed.
3. WHICH PERSONAL DATA DO WE PROCESS ABOUT YOU?
We collect your personal data in three ways:
3.1 INFORMATION PROVIDED BY YOU
In the first place, we receive your information when you share it with us. This is for example the case when you fill out a form on our website (for example brochure form, contact form, floor compare form) or at a fair; if you request to receive a brochure or a sample; if you request to make an appointment in one of our showrooms or with one of our dealers; if you enter into a competition; if you sign up for our newsletter or a certain offer; etc.
In these cases, we usually receive information such as your name, e-mail address, telephone number, address details (street, number, postal code, city, and country), date of birth, the date of your appointment and other personal and/or contact details.
We sometimes request you to provide us with your remarks, suggestions or other information regarding our websites, our products or services or our companies.
3.2 AUTOMATICALLY OBTAINED INFORMATION
When you browse our website or receive our newsletters, we receive data from cookie providers or social media by setting pixels (e.g. Facebook Pixel) about your activity on our website such as the webpages you visit, the products you are interested in, whether you opened an e-mail or clicked on a link, etc. - We can combine the automatically obtained information with the information provided by you to analyse your specific use of our website.
3.3 INFORMATION OBTAINED FROM THIRD PARTIES
Sometimes we also receive your information from third parties, such as information from affiliated companies, dealers, vendors, distributors, installers (e.g. through platforms such as the Quick-Step Connect webapp), data brokers or from professional data suppliers (for example Bisnode, construction fairs, etc.).
In this case, we usually receive data such as your name, e-mail address, address details, telephone number, information about your construction or renovation project, your order (of a sample) and/or your questions.
4. WHAT IS THE LEGAL GROUND FOR PROCESSING YOUR PERSONAL DATA?
In general, the Unilin Group processes your personal data for various purposes, which are further explained below. Regarding the processing of your personal data, the Unilin Group relies on:
- your consent: your consent can be expressed e.g. by ticking a box to this effect during your navigation on our site, or via another positive action from which your consent is inferred, e.g. by choosing to contact us via a contact form. In some cases (e.g. in case of personalised information) we will ask your explicit consent. You have the right to withdraw your consent for the future at all times.
- the performance of a contract: if the collection of personal data is necessary for the performance of a contract with you or to take steps prior to entering into a contract.
- a legal obligation: if processing is necessary for the fulfilment of a legal obligation to which the Unilin Group is subject.
- our legitimate interest: in some cases, the processing of your data may also be necessary to realise a legitimate interest of the Unilin Group. In this case, we will consider whether your interests or your fundamental rights and freedoms outweigh our legitimate interest.
5. FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA?
Depending on the relevant entity, the Unilin Group processes your personal data for the purposes listed below.
5.1 IN ORDER TO SUPPLY THE PRODUCTS YOU ORDERED
If you place an order via our website or via a retailer or an installer, we will process your personal data in order to supply you with the products or samples you ordered. For this purpose, we can process data such as your name, your company name, your e-mail address, your telephone number, your address, your birthday, information regarding your projects, your correspondence with the Unilin Group.
These data are processed on the basis of your request to take steps prior to entering a contract or on the basis of the performance of a contract to which you are a party or on the basis of the legitimate interest of the Unilin Group to carry out its agreement with its vendors (retailers and suppliers) and to provide you with excellent consumer services.
5.2 IN ORDER TO ANSWER YOUR QUESTIONS OR OTHER REQUESTS
We process your personal data in order to answer your questions or requests (for example requesting a brochure, to supply you with a fact sheet of your favourite Unilin Group products, to make an appointment with one of our dealers or in one of our showrooms, etc.).
For this purpose, we can process data such as your name, your company name, your e-mail address, your telephone number, your address, your birthday, information regarding your projects, your correspondence with the Unilin Group.
These data are processed on the basis of the Unilin Group’s legitimate interest to handle your questions and requests in the best possible way and to communicate with you.
5.3 IN ORDER TO SEND DIRECT MARKETING OF THE UNILIN GROUP
General direct marketing
We process your personal data in order to keep you informed of new information, campaigns and promotions regarding our brands, entities, services and products, activities or other promotional offers, to ask your opinion about our products and services, to hear your feedback, or to manage your participation in our competitions. We can send you direct marketing via e-mail, text message or mail, telephone, social media (including but not limited to Facebook, WhatsApp, LinkedIn), our websites and affiliated websites or SMS. For this purpose, we can process personal data such as your name, your address, your e-mail address, your telephone number, our preferred language and the project or the region in which you are interested.
We can send you direct marketing based on your consent when you subscribe to our direct marketing via our website. In this case, you are free to choose to provide us with your personal data for direct marketing purposes. You have the right to withdraw your consent for the processing of your personal data for direct marketing purposes at any time (see point 10).
We send you direct marketing based on our legitimate interest to keep you informed of our products when you purchase our products. In each e-mail, you have the opportunity to unsubscribe in case you prefer not to receive such information any longer. We send direct marketing via social media to persons with similar profiles based on our legitimate interest to promote our products. You have the right to object to the processing of your personal data for direct marketing purposes at any time (see point 10).
Personalised direct marketing
Moreover, we may process your personal data to provide information regarding the services and products of the Unilin Group or to send you personalised information or advertisements. For this purpose, we process personal data such as your name, your e-mail address, your telephone number and your address.
We may develop a profile based upon your online behaviour or upon your purchase behaviour. In this profile, we take your preferences and interests into account, for example with respect to the pages you visited, the links you clicked, the products you viewed and the products you have purchased and other products, which might interest you. We receive this information through cookies set on our website or through your previous purchase behaviour as reflected in your customer profile. Based upon the information collected in the profile, we can send you information and advertisements, information and advertisements concerning products that fit your profile or that might interest you. Further, we can make use of the services of third parties, such as Facebook, to identify targeted and lookalike audiences in order to advertise our products to persons with a similar profile. For this purpose, we can process personal data such as your name, telephone number, address, email address, date of birth, age, gender, your job, your company name, your preferred language, and specific products and services in which you are interested.
5.4 IN ORDER TO ORGANISE CONTESTS AND TO KEEP YOU INFORMED OF THE RESULTS
The Unilin Group can process your personal data when you participate to a contest organised by the Unilin Group in order to keep you informed of the results.
For this purpose, we normally process personal data such as your name, e-mail address or other contact details, financial data (such as the invoice of your purchase), photographs, videos and other personal data that is relevant to determine the results of the contest.
We process your data in the context of the organisation of the contest based on your consent when you fill out the form to participate to the contest. You have the right to withdraw your consent for the processing of your personal data at any time (see point 10).
5.5 IN ORDER SUPPORT YOU WITH YOUR RENOVATION PROJECTS THROUGH OUR VENDOR PLATFORMS
If you visit a vendor (retailer of installer distributing our products), the vendor can create a consumer project for you on the platforms we put at the disposal of our vendors, such as the Quick-Step Connect webapp. These platforms allow vendors (i) to provide you with information on the products you are interested in, (ii) to add your contact information to keep you informed on the project, (iii) to upload pictures of the room you want to renovate in order to show you what it might look like after installing the products, (iv) to order a sample for you, (v) to suggest matching accessories, (vi) to automatically calculate the materials needed for the project and (vii) to provide advice on the finishing or preparation of the project.
The vendors create a consumer project via the platform and provide your personal data regarding the consumer project to Unilin based on your consent. You have the right to withdraw your consent for the processing of your personal data for direct marketing purposes at any time (see point 10).
Unilin Group will process your personal data for its own purposes in order to provide you with home delivery of samples if you request so (see purpose 5.1).
For these purposes, we can process personal data such as your data name, company name, telephone number, e-mail address, address, details about the consumer project and additional notes regarding the project.
The processing of your personal data by Unilin in the context of creation of a consumer project via the webapp is necessary to take steps prior to entering into a contract at your request and is based on the legitimate interest of the Unilin Group and its vendors to provide accurate information about the products to the consumers. You have the right to object to the processing of your personal data for visiting registration purposes at any time (see point 10).
5.6 IN ORDER TO REGISTER VISITORS TO OUR BUILDINGS OR SHOWROOMS
The Unilin Group can process your personal data when you visit one of our buildings or showrooms. We register visitors to our buildings and showrooms to provide them with the Wi-Fi password via e-mail, for safety purposes (i.e. to provide them with a visitor’s guide including information re safety and what to do in case of an emergency) and to count how many visitors are visiting our buildings and showrooms.
For this purpose, we can process personal data such as your name, email address or other contact details and the name of the Unilin employee you are visiting.
We process your data for visitor registration purposes based on our legitimate interest to keep our visitors safe, to know who is visiting our building in case of an emergency, to enhance the visit and to keep track of how many persons are visiting our buildings and showrooms. You have the right to object to the processing of your personal data for visiting registration purposes at any time (see point 10).
5.7 IN ORDER TO ANALYSE DATA AND CREATE STATISTICS
The Unilin Group can process your personal data for analytic and statistical purposes. Statistical purposes mean any operation of the collection and processing of personal data necessary for statistical surveys or for the production of statistical results. The Unilin Group makes use of different analytic tools in order to connect personal data and retrieve insights from different data sources.
For this purpose, we can process personal data such as your name, email address or other contact details or personal information.
Depending on the individual case, these data are processed on the basis of the Unilin Group’s legitimate interest to evaluate and improve our marketing campaigns, to gain insights in our sales reports and to visualise our e-commerce data.
The result of the processing for statistical purposes are aggregate data. We do not use the aggregate data or your personal data in support of measures or decisions with regard to you.
5.8 FOR THE TECHNICAL AND FUNCTIONAL MANAGEMENT OF OUR WEBSITES
We process personal data obtained through cookies and other technologies for the technical and functional management of our websites, in order to personalise the websites and to ensure that the websites are easy to use. By using your data, we can check how our website is used and we can improve its content and layout (e.g. A/B-testing). These data also allow us to adequately secure our website. For this purpose, we can process data such as your IP address, the pages you visit, the browser you use, the websites you visited earlier, geographical data such as your location, your preferred language and the time and duration of your visit.
The processing of these data is based on your unambiguous consent (captured via our cookie banner) or based on the Unilin Group’s legitimate interest in providing a well-functioning and secure website and in providing pages with content relevant to you.
6. WHO HAS ACCESS TO YOUR PERSONAL DATA?
The Unilin Group is selective in the parties to whom it discloses your personal data and chooses them carefully. In all cases, we will ensure that sufficient safeguards for the protection and confidentiality of your data are in place.
In the following cases, we may share your personal data with third parties:
- Processors who act on our behalf, such as for example marketing agencies, communication companies, web hosting companies, mailing vendors, software providers, analytics providers, tracking companies (e.g. Lead Forensics), …. Unilin Group concludes a processing agreement with the parties that have access to personal data for the performance of their services.
- Business partners such as third parties with whom we carry out joint promotions or programs.
- IT service providers that provide technical support.
- Payment service providers.
- Attorneys and external advisors: in certain cases, the Unilin Group may transfer your personal data to attorneys and external advisors if this is necessary to give us advice or to defend our rights.
- Public authorities: in certain cases, the Unilin Group may transfer your personal data to supervisory authorities or police, judicial or other authorities if we believe that we are required to do so based upon the applicable legislation or regulation or based upon another lawful request or order.
- Social media: social media may have access to the information collected through cookies and other technologies (possibly via the plug-ins embedded on the Unilin websites).
- Possible acquirers of the company: in the unlikely event that all or part of our business would be acquired by a third party, your information will be transferred to the acquirer.
7. DOES THE UNILIN GROUP PROCESS YOUR DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (“EEA”)?
In some cases, your data may be shared with a third party outside the EEA for the purposes described in point 5 above. The Unilin Group forms part of Mohawk Industries Inc., which has its headquarters in the United States.
In this respect, the Unilin Group is committed to ensuring an adequate and sufficient level of protection for your data, in particular by making sure that we can rely on a an adequacy decision under article 45 GDPR, by concluding standard contractual clauses under article 46.2 GDPR or via any other appropriate safeguard as provided for by Chapter V GDPR.
If you have any questions or would like more information about the transfer of your personal data outside the EEA, you can send a dated and signed request to Unilin – Data Privacy Counsel. You can find our contact details in point 13.
8. HOW ARE YOUR PERSONAL DATA PROTECTED?
The Unilin Group strives to protect your personal data as good as possible by means of administrative, technical and organisational measures. To this end, the Unilin Group has developed several procedures which are implemented by our employees.
The Unilin Group furthermore has committed to ensure that the service providers that process personal data on behalf of the Unilin Group also implement sufficient technical and organisational measures.
9. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
If no legal retention period applies, the Unilin Group will process your data at least as long as it has a (contractual) relationship with you.
10. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?
Under the GDPR, you have a number of rights with regard to your personal data. Some of these rights have a very specific scope or are subject to special conditions or exceptions.
10.1 RIGHT OF ACCESS
This means for example that you can ask us whether we process your personal data and for what purposes we do this. For more information, please consult article 15 GDPR.
10.2 RIGHT TO RECTIFICATION
You also have a right to obtain the rectification of inaccurate personal data. For more information, please consult article 16 GDPR.
10.3 RIGHT TO ERASURE
In some cases, you can request us to erase your personal data for example when personal data is no longer required for the purposes for which we have collected it, when the personal data is processed based upon your consent and you withdraw your consent, etc. In some exceptional cases, the Unilin Group is not obliged to grant your request to erase your personal data. For more information, please consult article 17 GDPR.
10.4 RIGHT TO RESTRICTION OF PROCESSING
You may request a restriction of your personal data for example if you dispute the accuracy of your personal data, if the processing activity is unlawful, etc. A restriction of the processing means that we may only store your data temporarily, except in case you nevertheless consent to the processing of your data, in the context of legal proceedings or in the public interest. A restriction can be terminated afterwards. For more information, please consult article 18 GDPR.
10.5 RIGHT TO DATA PORTABILITY
If we process your personal data based upon your consent or based upon the performance of a contract, you can ask us to transfer your data to yourself or to another controller (if this is technically possible). In exceptional cases, the Unilin Group is not obliged to follow up on your request. For more information, please consult article 20 GDPR.
10.6 RIGHT TO OBJECT
You can inform us of the particular reasons why you wish to object to the particular processing activity based upon the Unilin Group’s legitimate interest or in the context of the public interest. If these particular reasons outweigh our legitimate interests, we will terminate the processing activity. The Unilin Group cannot follow up on your request when we process your personal data for the purposes of a legal claim. For more information, please consult article 21 GDPR.
10.7 RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES
If we process your personal data for direct marketing purposes, you can always request us to stop processing your personal data without you having to give up a special reason. This right includes the right to object to profiling to the extent that the profiling is related to such direct marketing. For more information, please consult article 21 GDPR.
10.8 RIGHT NOT TO BE SUBJECT TO PROFILING
10.9 RIGHT TO WITHDRAW YOUR CONSENT AT ANY TIME
If the processing of your data is based on your consent, you also have the right to withdraw your consent at any time, without this affecting the legitimacy of the processing done prior to the withdrawal of your consent.
10.10 EXERCISING THE AFOREMENTIONED RIGHTS
Exercising the abovementioned rights can easily be done in different ways, such as by e-mail, by mail, by filling in the contact form on our website or by contacting our customer service in your favourite Unilin Group store. For privacy and safety reasons, we may request proof of your identity. You can find our contact details in point 13.
10.11 COMPETENT SUPERVISORY AUTHORITY
In accordance with article 77 of the General Data Protection Regulation (GDPR), you have the right to lodge a complaint with the supervisory authority of your habitual residence, your place of work or the place of an alleged infringement of the GDPR. The Belgian Data Protection Authority is the supervisory authority for the headquarters of the Unilin Group located in Belgium and can be contacted at email@example.com.
Other local supervisory authorities can be contacted at:
Autoriteit Persoonsgegevens (AP)
(+31) - (0)70 - 888 85 00
National Commission for Data Protection (NCDP) / Commission Nationale pour la Protection des données (CNPD)
(+352) 26 10 60 -1
Commission Nationale de l'Informatique et des Libertés (CNIL)
+33 (0)1 53 73 22 22
Agencia Española de Protección de Datos (AEPD)
+34 901 100 099
+34 91 266 35 17
Garante per la Protezione dei dati personali (GPDP)
Information Commissioner’s Office (ICO)
+44 (0)303 123 1113
Data Protection Commission (DPC)
+353 (0)76 110 4800
+353 (0)57 868 4800
Different per Bundesländer
Contact details of the different authorities can be found at: https://www.datenschutzkonferenz-online.de/datenschutzaufsichtsbehoerden...
The Data Protection Agency (Datatilsynet)
+45 33 19 32 00
The Office of the Data Protection Ombudsman
For private persons: +358 (0)29 566 6777
For controllers: +358 (0)29 566 6778
The Data Protection Authority
+47 22 39 69 00
Integritetsskyddsmyndigheten / Swedish Authority for Privacy Protection (IMY)
+46 (0)8 657 61 00
11. WHAT ABOUT LINKS TO OTHER WEBSITES AND SOCIAL MEDIA?
The websites of the Unilin Group can contain references (for example via hyperlinks, social plug-ins, links to social media operators) to other websites, which are offered by other companies or by social media. The Unilin Group always advises you to check the privacy policies of those websites.
11.1 SOCIAL MEDIA PAGES OF THE UNILIN GROUP
For the scope and purpose of data collection as well as the further processing and use of data by social networks and information on rights and settings to protect your privacy, please refer to the privacy policies of these social networks (available here: Facebook, LinkedIn, Twitter and Instagram).
11.2 SOCIAL MEDIA SHARING OPTIONS
Our website allows you to share content with LinkedIn, Twitter, Facebook, Instagram, Pinterest, YouTube, Whatsapp and Snapchat. When using these social plugin functions (e.g. “share” button, …), information about your usage is transmitted directly from your browser to the corresponding social network. If you are already registered with a social network while visiting our website, the operator of that social network may be able to assign the visit to your personal account through the social plugins. If you are not yet a member of a social network, it is still possible for the social networks to receive and store your IP address and information about the browser and operating system you are using through the social plugins.
If you share content from our website on the social media page directly, your personal data will be visible for the visitors of these social media. For the scope and purpose of data collection as well as the further processing and use of data by social networks and information on rights and settings to protect your privacy, please refer to the privacy policies of these social networks (available here: Facebook, LinkedIn, Twitter, Instagram, Pinterest, YouTube, Whatsapp, and Snapchat).
13. WHO CAN YOU CONTACT IN ORDER TO EXERCISE YOUR RIGHTS?
Via the contact form available on our website ;
By e-mail at firstname.lastname@example.org;.
By mail to:
UNILIN – Data Protection Counsel