CUSTOMER PRIVACY NOTICE

Aaxe Titres-Services* whose offices are located at Avenue de Tervueren 124, 1150 , Brussels, Belgium, (hereinafter, referred to as “Aaxe Titres-Services”) acting as data controller, processes and uses personal data relating to its prospects and customers (hereinafter, collectively referred to as the “Customers”), in accordance with applicable data protection regulations, in particular European Regulation 2016/679 of April 27, 2016 referred to as the General Data Protection Regulation (hereinafter, referred to as the “GDPR”). This privacy notice aims to explain why and how Aaxe Titres-Services collects personal data from its Customers (hereinafter, referred to as “Customer Data”), how it protects it and how long this information is kept. It is without prejudice to any specific provisions that may appear in other documents.

(*Aaxe-titres-Services: the “Group” of AAXE -T.S. sprl, company no. 885.284.455; AAXE sprl, company no. 879.869.479; AAXE – A.M. sprl, company no. 887.999.168; AAXE-CLASS sprl, company no. 811.628.197; AAXE-CLEAN sprl, company no. 897.264.945; AAXE-NET sprl, company no. 897.265.143; AAXE-PROP sprl, company no. 811.627.506; AAXE-PUR sprl, company no. 834.893.450; Brightnet, sprl, company no. 847.582.238)

Why does Aaxe Titres-Services process customer data?

Aaxe Titres-Services stores and processes customer data, in electronic or non-electronic form, for administrative, marketing and customer management purposes, specifically in light of the following non-exhaustive activities: processing and responding to any communication, request or query that Customers submit to Aaxe Titres-Services (including via the website) or following initial contact with Aaxe Titres-Services, processing information relating to the sale (actual or potential) of Aaxe Titres-Services products and/or services and sending statements and invoices to Customers, providing Customers with newsletters and other marketing communications, conducting surveys and market research, improving Aaxe Titres-Services products and/or services, and resolving disputes.

What is the legal basis for processing customer data?

Customer data is processed on one or more of the following legal bases:

• For the purpose of concluding and managing the performance of a sales contract or other contract with a Customer, including the billing procedure,
• In order to comply with legal obligations applicable to Aaxe Titres-Services (e.g. concerning tax matters, etc.),
• Within the framework of the legitimate interests of Aaxe Titres-Services and/or a third party but which, in the opinion of Aaxe Titres-Services, also benefit Customers, such as, but not limited to, direct marketing and data analysis,
• The consent of the Customer concerned (e.g. to respond to a survey). The Customer concerned may withdraw his consent at any time, it being understood that such withdrawal will not affect the lawfulness of processing carried out prior to such withdrawal on the basis of such consent.

What categories of customer data are processed?

Customer data is any personal information relating to an identified or identifiable natural person. For the aforementioned purposes, the processing of personal data may include the following categories: personal identification data, such as name and address, electronic identification data, such as e-mail address and telephone number, personal details, such as date of birth, language, nationality and gender, Sodexo identification number, financial identification data (bank account numbers), consumption habits (volume of products and services, promotional actions, claims handling, etc.), event participation (including family members, if applicable), survey data.), event attendance (including family members, if applicable), survey data.

Where does customer data come from?

When a customer contacts Aaxe titres-services, the initial data most often comes from the individual concerned. Aaxe titres-services may also contact a customer for prospecting purposes when the initial data has not been obtained from the customer but from other people who have given Aaxe titres-services their contact details. As part of the relationship with Aaxe titres-services, the customer will provide additional information (e.g. information required for the services to be provided). If the customer does not provide Aaxe titres-services with the information required by law or by contract, Aaxe titres-services may decide not to enter into the contract or to terminate it. Likewise, if the customer fails to provide other information, he or she may not be entitled to the benefits associated with it. For example, if a customer does not wish to share his/her e-mail address with Aaxe titres-services, he/she will not receive any electronic newsletters from Aaxe titres-services. Aaxe titres-services may also receive data relating to a customer from other customers, from suppliers of Aaxe titres-services or, more generally, from other persons with whom the customer may exchange such data in the course of his/her relationship with Aaxe titres-services.

Who has access to customer data?

For the above-mentioned purposes, personal data may be disclosed to, and even possibly processed by :

• The Customers themselves or the persons they have appointed to do so,
• Aaxe Titres-Services personnel who have a need to know the personal information involved,
• Individuals and legal entities who have direct contact with Aaxe Titres-Services, such as its subsidiaries and service cheque publishers,
• Public authorities in accordance with applicable regulations, such as tax authorities,
• Service providers and other professional advisors of Aaxe Titres-Services who have a need to know this information, such as insurance companies and IT service providers.

Is customer data transferred outside their country of residence ?

In general, this data is kept in Belgium, but we may transfer certain customer information abroad but always in connection with the management of Aaxe Titres-Services’ activities. If this involves a transfer of data outside the European Union, Aaxe Titres-Services will have put in place appropriate safeguards in line with the GDPR.

How long are customer data stored at ?

Customer data will not be stored for longer than is necessary for the above-mentioned purposes. Personal data concerning a person who may become a customer will not be kept longer than the normal duration of such procedures, which is generally a maximum of one year after the end of such procedures. Typically, and subject to what would otherwise be provided for certain specific data, customer data will be retained for the duration of the contract as well as after expiration or termination of the contract for as long as Aaxe Titres-Services may have a legal responsibility for which the use of customer data may be relevant, taking into account applicable statute of limitations and legal retention obligations.

How is customer data protected ?

Aaxe Titres-Services uses its best efforts to preserve and protect customer data against loss, unauthorized disclosure or access.

What rights do individuals have and whom can they contact ?

Individuals whose personal information is collected and processed as customer data have, at any time and provided they provide sufficient proof of their identity, the right to contact Aaxe Titres-Services if they wish to:

• Access, rectify or delete their personal data,
• Restrict or object to the processing of their personal data (e.g. for direct marketing purposes),
• Receive the data they have provided, in a structured, commonly used and machine-readable format, and pass it on to another data controller if they so wish, when it has been processed on the basis of their consent and/or the performance of the contract,
• Receive additional information on guarantees for international data transfers,
• File a complaint with the Belgian Data Protection Authority or another EU supervisory authority, if they believe that Aaxe Titres-Services has not acted in accordance with applicable data protection regulations.
• The contact person within Aaxe Titres-Services is the Coordinator for RGPD regulations and data protection Mr. DELANDER Bruno

The coordinator can be reached on :

• by letter or prearranged appointment to Mr DELANDER Bruno c/o AAXE, Avenue de Tervueren 124, 1150 Woluwe-Saint-Pierre – Brussels
• by e-mail to the following address: delander@aaxe.be
• by telephone on the following number Extension 148 on 02 770 70 68

The data subject may contact the data controller to obtain further information or if he or she wishes to assert his or her rights relating to the protection of personal data processed by the data controller.

Modifications

Aaxe Titres-Services may modify this privacy notice at any time when necessary, in particular to comply with changes in regulations or requirements introduced by data protection authorities.