AARDEX Group Privacy Notice
Welcome to the AARDEX Group’s privacy notice.
- you visit our website,
- you purchase a product or service from us; or
- you use a product or service from us; or
- we purchase a product or service from you.
AARDEX Group Privacy Policy
1.Introduction
Welcome to the AARDEX Group’s privacy policy.
AARDEX respects your privacy and is committed to protecting your personal data. This privacy policy will :
- inform you as to how we look after your personal data; and
- tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below:
2. Purpose of this privacy policy
This privacy policy applies to the personal information we obtain through the AARDEX Group’s properties, including websites, MEMS AS platform, MEMS Mobile application and social media pages that reference this privacy policy, while offline collection are in connection with sales, marketing, partner and supplier engagement, and third-party sources, including ad networks and lead brokers (collectively, the “Channels”).
This privacy policy aims to give you information on how AARDEX collects and processes your personal data.
This privacy policy applies to our clients, suppliers, business partners, MEMS AS user, MEMS Mobile user and any other legal or physical person whose personal data we are using.
Our services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
3. We are the controller of your personal data
AARDEX Group S.A. is the controller and responsible for your personal data (”AARDEX”, “we”, “us” or “our” are references to the entity responsible for the processing of your personal information, which generally is the entity that obtains your personal information).
We are also processing some of your personal data on behalf of and on the instructions of some customers, as explained below.
AARDEX is made up of two different legal entities (“AARDEX Group”):
- AARDEX Group S.A., whose contact details can be found in paragraph 4 below; and
- AARDEX Group Switzerland S.A., avenue de la Gare, 29, 1950 Sion, Switzerland.
This privacy policy is issued on behalf of the AARDEX Group so when we mention ”AARDEX”, “we”, “us” or “our” in this privacy notice policy, we are referring to the relevant company in the AARDEX Group responsible for processing your data.
AARDEX Group S.A. has been appointed as the representative of AARDEX Group Switzerland S.A. in the EU.
4. Our contact details
AARDEX Group S.A.
Rue Bois St Jean 15/1
4102 Seraing
Belgium
info@aardexgroup.com
5. Complaints
You have the right to make a complaint for data protection issues at any time to:
- the Belgian Data Protection Authority (https://www.dataprotectionauthority.be/), or
- the Data Protection Authority of your habitual residence, place of work or of an alleged infringement of the GDPR.
We would, however, appreciate the chance to deal with your concerns before you approach the DPA so please contact us in the first instance.
6. Your duty to inform us of changes
It is important that your personal data is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
7. The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data
This data includes [first name, last name, username or similar identifier, title].
Contact Data
This data includes [billing address, delivery address, email address and telephone numbers].
Financial Data
This data includes [bank account].
Transaction Data
This data includes [details about payments to and from you and other details of products and services you have purchased from us or we have purchased from you].
Technical Data
This data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or communicate with us].
Profile Data
This data includes [your username and password, purchases or orders made by you or from you, your interests, preferences, feedback and survey responses].
Usage Data
This data includes [information about how you use our website, products and services, including anonymized adherence data].
Marketing and Communications Data
This data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
The information about your health we collect is anonymized in such a way that we are completely and irreversibly unable to identify you. This anonymized data is not considered as personal data under the GDPR. This information is considered as “De-Identified Health Information” in accordance with the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule.
We do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data).
We do not collect any information about criminal convictions and offences.
8. If you fail to provide personal data
Where we need to collect personal data by law (or under the terms of a contract we have with you) and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
9. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions.
You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when:
- You apply for our products or services;
- You create an account on our IT platform;
- You subscribe to our products, services or publications;
- We offer or deliver products or services to you;
- You request marketing to be sent to you;
- You give us some feedback ; or
- You offer or deliver your products and services to us.
Automated technologies or interactions.
As you interact with our website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies.
Third parties or publicly available sources.
We may receive personal data about you from various third parties [and public sources] as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks such as Google Adwords based outside the EU; and
- search information providers such as Google based outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as FedExbased inside and outside the EU.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly availably sources such as ClinicalTrials.gov based inside the US].
10. How we use your personal data
In general
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by info@aardexgroup.com .
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please [contact us] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer, supplier or business partner | (a) Identity (b) Contact | Performance of a contract with you Necessary for our legitimate interest (to acquire new customers) |
To process and deliver your order or our order including: (a) Managing adherence data; (b) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Usage | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
|
| To manage our relationship with you which will include: Responding to your information requests on the AARDEX Platform; Notifying you about changes to our terms or privacy policy; Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
| (a) Identity (b) Contact (c) Technical
| (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
| (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage
| Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you or to us | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop our products/services and grow our business)
|
11. Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us:
- If you requested such communications;
- if you have requested information from us or purchased goods or services from us; or
- if you provided us with your details when you entered a competition or registered for a promotion.
and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the AARDEX group of companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by info@aardexgroup.com at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or sale, warranty registration, product/service experience or other transactions.
Cookies
When a website visitor visits our website we place cookies in its browser, which allows us, by using the IP address, to track which pages the visitor views on our website and when. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
12. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 11.2 above.
- Internal Third Party. This is AARDEX GROUP Switzerland S.A. (the other company in the AARDEX Group) acting as processors and who is based in Switzerland. AARDEX GROUP Switzerland S.A. provides us with services and undertakes leadership reporting].
- External Third Parties. These are :
- Service providers acting as processors based in Belgium or Switzerland who provide [transportation, mailing, etc.].
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in Belgium and Switzerland who provide consultancy, banking, legal, insurance and accounting services.
- The tax and social security administrations, regulators and other authorities acting as processors based in Belgium and Switzerland who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
13.International transfers
We share your personal data within the AARDEX Group. This will involve transferring your data outside the European Economic Area (EEA), but only to Switzerland.
Switzerland has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
We may transfer the personal information we collect through the Channels to, and store such data in other countries, including the U.S., which may have different data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information only for the purposes described in this Privacy Policy. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information.
Please [contact us] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
14. How long will we use your personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider :
- the amount, nature, and sensitivity of the personal data,
- the potential risk of harm from unauthorized use or disclosure of your personal data,
- the purposes for which we process your personal data, and
- whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by info@aardexgroup.com.
In some circumstances you can ask us to delete your data (see below for further information).
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
15. What are your legal rights?
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data.
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where :
- you have successfully exercised your right to object to processing (see below),
- we may have processed your information unlawfully or
- we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data
You have the right to object where :
- we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, or
- we are processing your personal data for direct marketing purposes.
In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- you want us to establish the data’s accuracy;
- our use of the data is unlawful but you do not want us to erase it;
- you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please [contact us].
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
16. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
17. Third party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites. We are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
18. Changes to this privacy policy
We will only use your personal data in the manner described in this Privacy Policy in effect when the data was collected from you. However, we reserve the right to change the terms of this Privacy Policy at any time by posting revisions to our site. If we make any make any material changes to this Privacy Policy, we will either notify you or place a prominent notice on our website.