Privacy policy
1. Purpose of the policy
A.S.Adventure values the right to privacy and is committed to ensure all personal data is obtained, processed and used in a safe, secure, ethical and transparent way. Your privacy is important to us, and we appreciate your trust that we will use your personal data both carefully and sensibly, in conformity with the principles laid out in this Privacy Policy, which applies when you use our Services (i.e. all activities related to our online shops and physical stores, including the sale and rental of our products).
This Privacy Policy is meant to help you understand what personal data we collect about you, why we collect it, and what we do with it. References to personal data in this Privacy Policy include any information which directly or indirectly identifies you, such as your name, surname, Explore More number, online identifiers, e-mail address, billing address and delivery address, or previous purchases.
Please note that this Policy applies in conjunction with other policies and procedures. It does not establish contractual or legal rights for any persons, but intends to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (hereinafter, the ‘General Data Protection Regulation’ or ‘GDPR’).
As your data controller, we determine why and how we process your personal data. This privacy policy outlines which personal data we collect about you (Section 3.1), what legal grounds we rely on to collect your personal data (Section 3.2), how we protect your personal data (Section 4), to whom we disclose your personal data (Section 5), if necessary outside the European Union (Section 6). In addition, we also define for how long we need to keep your personal data (Section 7) and which measures we adopt in order to securely and permanently remove your personal data when the right time comes (Section 8).
2. Who controls your personal data?
Retail Concepts nv is the controller of the personal data you submit to us and is responsible for the processing of your personal data under the applicable data protection legislation. Our registered address is Smallandlaan 9, 2660 Hoboken, Belgium. Retail Concepts nv is registered in Belgium under company number BE 0416.762.280.
3. How we collect and process your personal data
3.1. Personal data we collect about you
Because data privacy is of high importance for us, we intend to remain open and transparent about how we use your personal data. A.S.Adventure will only collect your personal data where necessary for our Services.
Depending on your use of our Services and our websites, we may thus collect, use and disclose (i.e., process) the following types of personal data about you: your contact information, such as a name, surname, address, e-mail address, IP address and telephone number. We may also collect payment, credit and order information. Moreover, if you have an existing Explore More account, we will collect and process other information that identifies or can be used to identify you for the provision of our Services and A.S.Adventure products, such as your Explore More number, your birth date, your previous purchases and shopping preferences, as well as web-browsing behaviour on our websites. For more information about the way we process personal data, we invite you to read the following sections.
Although we are technically considered ‘data controllers’, the ultimate control over your personal data remains with you at all times. Provided you give us a proof of your real identity, you have the right to request access to a copy of the personal data we currently maintain about you in a structured, commonly used and machine-readable format and obtain information regarding the processing, including whether we process your personal data for profiling purposes. In case you notice an error in your personal data, you may also request that we rectify the inaccurate personal data or complete your personal data. Following this, we will notify each third party to which we have disclosed your personal data, so that they can make sure your personal data is accurate with them too. Where technically feasible, you have the right to request that A.S.Adventure transmits your personal data to another company of your choice.
3.2. Legal grounds for processing
Under the applicable data protection legislation, personal data may only be collected and processed based on a limited number of legal grounds. At A.S.Adventure, we rely on one of the following grounds to process your personal data:
- Necessity for the performance of a contract with you (e.g. when you purchase products from us);
- Legal obligation to which A.S.Adventure is subject (e.g. when we handle your payment details);
- Legitimate interests of A.S.Adventure (e.g. when we send you marketing e-mails regarding products similar to the ones you already purchased from us);
- Your explicit and informed consent (e.g. when you subscribe to our newsletters through your marketing preferences, or if you participate to a contest).
3.3. Creating an Explore More account
When you visit one of our online or physical stores, you have the opportunity to create an individual Explore More account. When you make a purchase in our webshop, an Explore More account is automatically created. This type of account allows you to enjoy a more personalized experience and various benefits such as quick checkouts by having A.S.Adventure automatically enter your billing and delivery address, payment details and preferred shipping information.
Creating an Explore More account requires your personal e-mail address as login, first name and surname. In addition, you may also register your gender, language preferences, birthday, postal address for billing and shipping purposes and telephone number. When you create an Explore More account, you have the ability to manage your marketing preferences in your account.
We process personal data for these purposes because it is in our legitimate interests to provide Services to our customers. Under the GDPR, you have the right to object at any time to the use of your personal data by A.S.Adventure. While this means we will no longer be able to process your personal data, we may still store your personal data until you explicitly request we erase it.
3.4. Purchasing products through our websites
If you purchase products through our online stores, A.S.Adventure will require your personal data to manage your payments, handle your orders, and make sure the products you have bought are delivered to the right address by our external delivery partners.
In order to purchase products through our websites, A.S.Adventure will collect personal data such as your name, surname, e-mail address, Explore More number, telephone number, billing and shipping information, and limited payment card information. We process your personal data for the purposes explained above because it is necessary for the performance of the contract with you.
We may also need to process other personal data such as your navigation and browsing behaviour with a view to for example save items in your shopping basket, provide you with relevant product recommendations, or offer you size recommendations. Moreover, processing this personal data allows us to keep track of your purchasing history, for example in case you change your mind following your purchase, or if you need to return a product according to the applicable return policy.
3.4[bis]. Personal shopping
A.S.Adventure processes the preferences provided by you via the online questionnaire, in combination with your customer data (surname, first name, contact details, customer card number, e-mail address and purchase history), to enable one of our advisers to propose a personalised, manually compiled shopping basket to you, in connection with our “personal shopping” service. For the aforesaid processing, A.S.Adventure relies on its need to implement the required measures for concluding a purchase agreement according to your request as contained in your answers to the personal shopping questionnaire. A.S.Adventure will only process your answers and preferences for the abovementioned purpose, without automatic decision making or profiling for marketing purposes. We will also not retain your data for longer than is required in order to create your personalised shopping basket.
If you wish to buy the offered products via our websites, A.S.Adventure will process your personal data as stipulated in Clause 3.4, in order to fulfil our contract with you.
3.5. Marketing e-mail newsletters
Some of our Customers might be genuinely interested in receiving newsletters about our latest products and Services. However, we understand not everyone feels the same way. Therefore, the processing of your personal data for marketing purposes is based solely on your explicit prior consent, which means we will never send you marketing communication if you don’t want to, unless you have already bought products from us.
If you wish to receive newsletters regarding our latest products and Services, you are able to opt in to our e-mail newsletters through our websites, in which case we will process your e-mail address. If you already benefit from the Explore More experience, you have the possibility to modify your existing marketing preferences through your account settings in order to get more personalised newsletters. In that case, we will process your personal data submitted in relation to your Explore More account, such as your name, e-mail and postal address, age, shopping history, as well as the way you navigated on our websites.
Once subscribed, you may object at any time to the use of your personal data for profiling by A.S.Adventure or any of the third-party recipients we have shared your personal data with, provided that we process your personal data based on our legitimate interests. If we process your personal data for direct marketing purposes, such as sending you newsletters, you have the right to object at all times to the use of your personal data for that purpose by contacting our data protection officer using the contact details below, without any additional cost.
3.5[bis]. Mail ‘Your desired item is available again’
As part of our service to keep you informed about the availability of our products, A.S.Adventure will only use the given email address to inform you that the desired item is available yet again. The provided email address will not be used for marketing and other commercial purposes, nor will it be shared with third parties. The data provided with this request will be kept for a period of 6 months. After that, we delete all data.
3.6. Information we collect in our stores
When you buy products in our stores, we may process personal data such as your name, contact details and limited payment details because this information is necessary for the performance of the contract with you.
If you already have a registered account, we may use information from your previous online and in-store purchases, as this will help us facilitate purchases, process payments, manage product returns and for marketing purposes. In such case, we process personal data because it is in our legitimate interest to gather insights about our customers who buy our products, both in stores and online.
Since we process your personal data based on our legitimate interests, you have the right to object at any time to the use of your personal data for profiling by A.S.Adventure or any of the third-party recipients we have shared your personal data with. You can do so by contacting our data protection officer by using the e-mail address mentioned below this Policy.
3.7. Events and competition forms
A.S.Adventure regularly hosts competitions for its customers. Because we need to identify our contestants and touch base with the winners, we need your contact information as well as your age (to verify you are legally allowed to participate) and any additional information you might want to provide to us. The processing of your personal data is based on your explicit and informed consent. Moreover, your personal data may be shared with third parties, in order for them to deliver and follow up on prize deliveries.
In addition to this, A.S.Adventure also organises events in collaboration with third parties. When you register for these events, we will process your contact details for invitations and lists of attendees, based on the performance of a contractual relationship. Under no circumstances will A.S.Adventure sell your personal data to the third parties we collaborate with.
Under the GDPR, you have the right to object at any time to the use of your personal data by A.S.Adventure or any of the third-party recipients we have shared your personal data with for this purpose. While this means we will no longer be able to process your personal data, we may still store your personal data until you explicitly request we erase it.
3.8. Customer service
It is in our legitimate interest to make sure technical support as well as complaints and queries relating to product warranties are handled quickly and efficiently. In order to do so, we may process details such as your name, contact information, Explore More number, date of birth, gender, bank account number (e.g. for refunds), purchasing history, and browsing activity. Where you contacted our Customer support through social media, we may also process some of your social media account information.
You may also request A.S.Adventure access to a copy of the personal data we currently maintain about you in a structured, commonly used and machine-readable format and obtain information regarding the processing, including whether we process your personal data for profiling purposes. In case you notice an error in your personal data, you may request that we rectify the inaccurate personal data or complete your personal data. In such case we will notify each third party to which we have disclosed your personal data, so that they can make sure your personal data is accurate with them too.
3.9. End-user testing program
To make sure we develop relevant content for our users, we have set up a dedicated user test program. Based on a subscription into the program, we periodically request users to participate voluntarily in specific test cases for new website designs, new functionalities or new concepts for our stores. These test cases can take place online and offline, in a dedicated interview or through an interactive session in a demo environment.
To make sure we provide you with relevant test cases and optimize the value of the detailed user tests, we want to get to know you better.
After getting the basics – your contact information – right, we ask more personal questions to ensure that we can provide you with relevant test cases and make sure we get appropriate feedback from a diverse group of individuals based on age, gender, family situation, education and shopping experiences. This information is only used for the purpose of the test cases, to determine a target audience and to report the results based on specific audiences and preferences. None of this personal information will ever be used directly in our commercial environment.
To capture all relevant input from the tests we set up with the participating users, we record all interviews and record all user sessions, including the user’s screen, video recording and sound recording.
All this information is captured and stored in cooperation with carefully selected third parties and the information systems and tools that they provide us with. We have agreements in place with all these third parties and make sure these parties adhere to our data protection standards. If the information is processed outside of the European Economic Area, we made sure to have relevant protective measures in place to ensure compliance with applicable data protection regulations.
The information we collect during our test sessions will only be stored for the period relevant to the test case. This means that – after the test session – the information will exist until the functionality has finished final development or until we decided not to go forward with this functionality.
4. How we protect your personal data
A.S.Adventure is committed to the processing of your personal data in a lawful, fair and transparent manner. Accordingly, we will only use your personal data if we have a valid reason for doing so and provided you have been informed of the processing purposes beforehand, at the time we collected your personal data.
Moreover, A.S.Adventure guarantees that any processing of your personal data will be limited to what is necessary, adequate and relevant in order to achieve the purposes for which personal data is collected. Whenever possible and technically feasible, A.S.Adventure will use anonymized or pseudonymized data, e.g. for our internal statistics and financial reporting purposes.
Because the protection of your personal data is of the upmost importance to us, A.S.Adventure is also dedicated to protect your personal data and the systems it is held in. We have defined and implemented adequate technical and organisational measures against any unauthorised access, unlawful use, accidental loss, corruption or destruction. This way, A.S.Adventure is confident that your personal data will be processed on a strictly ‘need to know basis’, when and where appropriate and necessary.
As we are fully aware threats evolve and diversify and we wish to sustain your trust throughout the years, we regularly review and update our security measures and infrastructure, with a view to mitigate operational risks and maintain our security programs up to the latest industry-accepted standards and best practices.
5. External parties with whom we may share your personal data
Where relevant and necessary for the purpose of the processing activity, we may occasionally need to disclose your personal data to other appropriate organisations who have a need to know (so-called ‘third party recipients’), based on our legitimate interest.
With the purpose of helping us understand more about your interests and preferences, offer you more relevant advertisements, we may for example share your personal data with data analytics companies and advertisers based on our legitimate interest. Additionally, we may share some of your personal data with external parties when you provide us with feedback and review about our products or our service.
We are also required to share some of your personal data with delivery couriers, such as when you order a product online, and with financial institutions in order to verify your payment details, based on the performance of a contract.
Each time your personal data is shared externally, this will be covered by strict data processing agreements, where A.S.Adventure remains the data controller and the third parties involved act as data processors. A.S.Adventure shall restrict the access and transfer of your personal data to trusted third party recipients who demonstrate an adequate level of data protection. Moreover, these third-party recipients will be required to delete or return all the personal data to A.S.Adventure after the end of the provision of Services relating to the processing and delete existing copies, unless the law requires storage of the personal data.
6. International transfers of your personal data
Insofar as your personal data needs to be transferred from the European Economic Area to a country outside of it which does not offer adequate protection of personal data, appropriate safeguards will be put into place to protect personal data to standards which are equivalent to the standards contained in this Privacy Policy. In other words, A.S.Adventure will remain responsible for the processing of your personal data and will take the necessary measures to protect the processing thereof by relying e.g. on the EU-U.S. Privacy Shield.
7. How long we keep your personal data
As a general rule, A.S.Adventure only keeps your personal data for as long as necessary to fulfil the purpose for which we initially collected it. However, because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly. In addition, there are laws and regulations that apply and which set minimum periods for retention of personal data.
A.S.Adventure will always ensure you are kept informed of the criteria used to determine the effective retention period as well as the underlying reasons thereof, which will depend on whether we process your personal data in the context of a contractual relationship with you or based on your explicit consent; whether we process the personal data for our own legitimate interest, or whether A.S.Adventure is legally obligated to retain the personal data for a specific period or to comply with specific legal obligations.
For general customer data, this retention period will be 7 years after the last order, unless there is still active engagement from the customer towards us by reading (and clicking on links in) emails.
8. How we erase your personal data
Under certain circumstances, and provided you give us a proof of your real identity, you may exercise your right to request the erasure of your personal data and have us inform third-party recipients to whom we provided your personal data of this request. Please be aware that this is only possible to the extent that the personal data is no longer necessary for the initial purpose (i), if the processing was based on your consent and you withdrew it (ii), or where you have already objected to the processing based on our legitimate interest (iii).
Except when we need to keep a copy of your personal data for statistical purposes, to establish, exercise or defend legal claims (e.g. regarding the warranty period applicable to products sold by A.S.Adventure or insofar as we are legally required to retain a copy of your personal data, you can rest assured A.S.Adventure shall either securely dispose of or permanently anonymize your personal data once we have fulfilled the initial processing purpose and when further retention of your personal data is not necessary anymore.
9. Your rights as data subjects
You have the right to be informed at any time, free of charge, about your personal data and the use of that personal data. You have the right to request us to correct, supplement or delete your personal data. You may also request that the processing of your personal data be restricted in a number of cases listed in the GDPR. You have the right to object to the processing of your personal data if you have serious and legitimate grounds for doing so that exceed our need to process your data. You also have the right to object at any time to the use of personal data for direct marketing purposes, even without having to provide a reason for doing so. You have the right to request your personal data in digital and readable form and/or to have them transferred to another service provider of your choice. Insofar as our processing is based on your prior consent, you have the right to withdraw such consent. You can exercise your rights by sending an e-mail to dpo@asadventure.com.
If you are not satisfied with the way we handled your request, you have the right to request the restriction of our use of your personal data and lodge a complaint with the supervisory authority responsible for the protection of personal data in your country of residence. Although we sincerely hope this won’t be necessary, we have provided the contact details of the relevant data protection authorities below.
Belgium
Autorité de protection des données - Gegevensbeschermingsautoriteit
Rue de la Presse 35 / Drukpersstraat 35
1000 Bruxelles / 1000 Brussel
Tel. +32 2 274 48 00
Fax +32 2 274 48 35
e-mail: contact@apd-gba.be
This is without prejudice to a remedy before a civil court.
If you suffer damage as a result of the processing of your personal data, you can claim for compensation.
