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PRIVACY POLICY

1. WHO ARE WE?

This Privacy Policy describes how we collect, use and share any information that, used alone or in combination with other information, relates to you (called “personal data”) when you use our website www.stanleystella.com or otherwise communicate personal data to us.

We are Stanley and Stella SA (“Stanley/Stella”). We have our registered office at Delta Building, Rue Jules Cockx 8-10, floors 3-4, 1160, Auderghem, Belgium and we are registered with the Belgian companies register under company number BE 0810.580.894.

Pursuant to applicable data protection and privacy legislations, we qualify as the controller with respect to the processing of your personal data.

2. WE VALUE YOUR PRIVACY

We value your right to privacy and strive to protect your personal data in accordance with the applicable data protection legislation and more specifically with the General Data Protection Regulation 2016/679 (“GDPR”) and its Belgian implementing legislation.

By using our website and by sharing your personal data with us, you acknowledge that your personal data will be processed in the manner as described in this Privacy Policy. In this Privacy Policy we set forth how we collect your personal data, how and for what purposes we may use them and to whom your personal data may be disclosed. Further, this Privacy Policy includes important information regarding your rights with respect to the processing of your personal data.

Furthermore, this Privacy Policy includes important information regarding your right to withdraw consent (‘opt-out’) for direct marketing (e.g. promotional e-mail updates) at any moment in time.

Therefore, we encourage you to read it very carefully.

From time to time, we may need to change this Privacy Policy. If we have your e-mail address, you will be personally informed hereof.The most recent version of it is available on our website https://www.stanleystella.com/en-gb/privacy-policy-cookies. We encourage you to regularly review this Privacy Policy. If you have any questions or comments in that regard, please contact us by sending an email or a letter to the contact details indicated below.

3. WHOSE PERSONAL DATA DO WE COLLECT?

In the context of our services, we may collect personal data relating to visitors of our website or current and potential clients in the manners described below.

4. HOW DO WE COLLECT YOUR PERSONAL DATA?

We may collect information about you in the following ways:

  • directly from you when you visit our website which may include information you provide to us by means of contact forms on our website or as part of creating your online account on our website;

  • directly from you when you contact us by e-mail or otherwise communicate your personal data to us;

  • indirectly, through our commercial partners, in case they have obtained your personal data from you and have to provide us with this information in order to perform the services that you have requested or to execute an agreement between us and them (e.g. when you are an employee of one of our distributors, customers or suppliers,).
    by means of cookies used on our website (in that regard, we invite you to read carefully our Cookie Policy.

5. WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSES DO WE USE THEM?

We collect the following information about you, which we use for the following purposes:

Personal data:
Purposes and Legal Ground:
  • Your identification and contact information (name, address, telephone number, gender, language, email address, job title or other contact details). If you are a sole trader or a one-person company, information about your business (business activity, types of end customers, number of employees, distribution channels, certifications, languages supported, ownership of a showroom or print facility, printing techniques used, type of personalization)
  • For customer administration;
  • For supplier administration;
  • For the administration and management of personnel and intermediaries;
  • To deliver the services or products you or the company you work for ordered;
  • To administrate payment of invoices and to collect debts;
  • For occasional e-mails regarding significant changes in the conduct of our business.
  • This processing is based on (i) the necessity to execute a contract or to make pre-contractual preparations (if we have such contract or negotiations with you directly), or (ii) on our legitimate interests to reach out to contact persons with our (pre-)contractual counterparties in the performance of normal contract management and accounting activities (if we have a contract or contract negotiations with the company you work for). Some data will also be required for us to comply with legal (accountability) obligations.
  • Your identification and contact information (name, address, telephone number, gender, language, job title, email address or other contact details).
  • For direct marketing purposes, both electronically (e-mail and SMS) and non-electronically (telephone calls, postal mailings)
  • For responding to any informative or other query or complaint you submit to us via any communication channel.
  • For non-electronic direct marketing and for responding to your informative queries or complaints, this processing is based on our legitimate interests to promote our business and provide information on the products we sell by non-electronic means, and to engage in informative and complaint handling discussions.
  • For electronic direct marketing sent to existing, active customers, this processing is based on our legitimate interests to inform our customer contacts of promotions or new developments regarding products similar to products you already purchased from us. For electronic direct marketing sent to prospects, this processing is based on your free opt-in consent.
  • Your IP address.
  • Your website preferences (like language and country), by means of cookies stored on your device.
  • The type and version of your internet navigation system, by means of cookies stored on your device.
  • Your behaviour on our website (like the pages you clicked), by means of cookies stored on your device.
  • More information: see our Cookies Policy.
  • To ensure the technical functioning of our website for all users;
  • To help us monitor the load of our servers and general traffic of our website;
  • To help us compile statistics and use website analytics in order to improve our website.
  • To display advertising on our website or to manage our advertising on other websites (Google, LinkedIn, etc.).
  • For essential, technical cookies, this processing is based on our legitimate interests to operate a technically functional website. For all other cookies, this processing is based on your opt-in consent collected through our cookie consent banner.
  • Your e-mail address and password.
  • Your identification and contact information (name, address, telephone number, gender, language, email address, job title or other contact details, and, if applicable, www.stanleystella.com). If you are a sole trader or a one-person company, information about your business (business activity, types of end customers, number of employees, distribution channels, certifications, languages supported, ownership of a showroom or print facility, printing techniques used, type of personalization)
  • For your personal online account creation and operation.
This processing is based on the necessity to execute our contract with you when you decide to create an online account on our website.

In addition, all of the personal data listed above can – where necessary – also be used for the handling of inquiries and complaints, and for the management of our legal disputes. This is based on our legitimate interests to defend our legal rights both inside and outside of court proceedings.

You have the possibility to refuse that your personal data are used for electronic direct marketing purposes at the moment we collect these data from you or any time after, by clicking the 'unsubscribe’ link at the bottom of our marketing e-mails or by sending us an e-mail or a letter at the contact details indicated below.

6. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In the context of the purposes as listed above, we can share your personal data with third parties. The third parties to which we can communicate some of your personal data are the following:

  • Our third party suppliers, service providers and partners who provide a data processing service to us, or who process personal data for purposes described in this Privacy Policy, or who are notified to you at the time of collection of your personal data. This may include communications to our partners who decorate or resell our clothing, to transport & logistics providers and other service providers that we use in connection with the services they provide to us, including to support us in areas such as IT platform management or support services, infrastructure or application services, credit rating, marketing, and data analysis;
  • Any appropriate law enforcement agency, regulator, government agency, court, or other third party, when such disclosure is necessary (i) under applicable laws, (ii) to exercise, establish, or defend our rights, or (iii) to protect your vital interests or those of any other person;
  • Our auditors, advisors, legal representatives and similar agents in connection with consulting services they provide to us for legitimate business purposes and pursuant to a contractual prohibition on the use of personal data for other purposes;
  • Any prospective purchaser (and its agents and advisors), in connection with a proposed purchase, merger or acquisition of a portion of our business;
  • Any other person when you have given your prior consent to the disclosure.

We will ensure that, where relevant, contractual safeguards are implemented to ensure the protection of your personal data when disclosing them to a third party. For example, we will enter into data processing agreements with relevant parties providing for restrictions on the use of your personal data and obligations with respect to the protection and security of your personal data and will only disclose your personal data to recipients we trust.

The parties to whom we may disclose your personal data may be located in countries outside the European Economic Area (EEA), which countries may offer a lower level of data protection than in the country in which we are established. For example, such could be the case for some of our IT service providers or when your order requires that we resort to transport & logistics providers outside the EEA.

In such case, measures are taken to ensure adequate protection of your personal data in accordance with the applicable data protection legislation. Generally, we will enter into Standard Contractual Clauses (as approved by the European Commission) with the recipient of your personal data. You may contact us by sending an email or a letter to the contact details indicated below, if you wish to obtain a copy of the Standard Contractual Clauses entered into or insight into other adequate measures taken.

7. HOW LONG DO WE STORE YOUR PERSONAL DATA?

Your personal data will not be stored for longer than what is necessary in relation to the purposes for which we process them (we refer to the purposes as listed above in clause 5). Only when we are legally obliged to, or when this is necessary for defending our interests in the context of judicial proceedings (e.g. in case of a dispute), we will store the personal data for longer periods.

More specifically, the following storage periods apply:

Personal data:
Your identification and contact information (name, address, telephone number, gender, language, email address or other contact details).
Personal data are generally erased after 4 years of inactivity, unless the personal data are included in accounting, financial or other official documents, in which case they will be retained for as long as such documents legally need to be kept.When these contact details concern retail clients who contact us through the website, and which we directly refer to our retail partners, such data are erased after 2 years.In addition hereto, as soon as we note that your contact details are no longer accurate or active, or whenever you decide to use your unsubscribe/opt-out right, we will no longer keep your personal data for the relevant purposes.
Any personal data collected by cookies used on our website.
As indicated per cookie in our cookie consent banner and in our Cookies Policy.

8. HOW DO WE PROTECT YOUR PERSONAL DATA?

We use appropriate technical and organizational measures to protect the personal data we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data. Specific measures we use may include data anonymisation and encryption where appropriate (notably, when transferring your personal data or when the objectives of our processing can be reached with anonymised personal data).

Further, we seek to ensure that we keep your personal data accurate and up to date. In view thereof, we kindly request you to inform us of any changes to your personal data (such as a change in your contact details).

9. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

You have the following data protection rights, subject to the conditions and restrictions set out in Articles 12-22 of the GDPR:

Rights:
Description:
Right to information and right to access your personal data
You may at any time request more information on our processing activities and your personal data that we are keeping, as well as a copy hereof.
Right to rectification of inaccurate or incomplete personal data
You have the right to require us to, without undue delay, rectify or complete any of your personal data that is inaccurate or incomplete.
Right to deletion of your personal data (‘right to be forgotten’) 
You may request us to delete your personal data or part of your personal data in the following situations:
  • when the processing is no longer necessary for achieving the purposes for which they were collected or otherwise processed;
  • when the processing was based on your consent and you have decided to withdraw that consent;
  • when you object to the processing of your personal data within the limits of the exercise of your right to object;
  • in the event we would unlawfully process your personal data; or
  • when your personal data have to be erased in compliance with a legal obligation imposed on us.
Note that we may refuse to delete your personal data: (i) if it is justified by the exercise of the right of freedom of expression and information; (ii) for compliance with a legal obligation; or (iii) for the establishment, exercise or defence of legal claims.
Right to restriction of processing   
You may request us to permanently or temporarily restrict the processing of your personal data in the following situations:
  • when you have contested the accuracy of your personal data, for a period enabling us to verify their accuracy;
  • in the event we would unlawfully process your personal data and you would request the restriction of the use of your data instead of the deletion of your data;
  • when we no longer need the personal data for the purposes of the processing, but you need them for the establishment, exercise or defence of legal claims; or
  • pending verification whether our legitimate grounds override yours within the framework of an objection.
Right to object to the processing of your personal data (free of charge) 
When we process your personal based on our ‘legitimate interests’, you may object to the processing of your personal data, provided that you invoke ground relating to your particular situation. We will then no longer process your personal data, unless we have compelling legitimate grounds to do so, or if such processing is necessary for the establishment, exercise or defence of legal claims.When we process your personal data based on our legitimate interests for direct marketing purposes or based on Article 1 of the Royal Decree of 4 April 2003, you may at any time object to this processing without any justification. You also have the right not to be subject to profiling for direct marketing purposes.
Right to data portability 
In some cases, you have the right to receive all your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. This right applies:
  • in case the processing is based on consent or on the necessity for the performance of a contract; and
  • in case the processing is carried out by automated means.  

Finally, you have the right to lodge a complaint with the Belgian Data Protection Authority relating to the processing of your personal data by us. You can find the contact details of this authority on www.dataprotectionauthority.be.

Please find a list of other EU supervisory authorities here: https://edpb.europa.eu/about-edpb/board/members_en.

In principle you may exercise these rights free of charge. Only where requests are manifestly unfounded or excessive, we may charge a reasonable fee. Further information and advice about your rights can also be obtained from the data protection authority in your country (if you are not located in Belgium). We might (if deemed necessary) request a proof of identity in advance in order to double-check your request.

10. CONTACT

If you have any questions, comments, requests or complaints in relation to this Privacy Policy or the processing of your personal data by us, please feel free to contact us by sending an e-mail to privacy@stanleystella.com or by sending a letter to the address of our principal place of business at Delta Building, Rue Jules Cockx 8-10, floors 3-4, 1160, Auderghem, Belgium.

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