Privacy Statement

Version 16 May 2023

 

1.    General information

Your privacy is very important to us. This privacy policy (hereinafter ''Privacy Policy'') has been created to inform you about how we handle your personal data, being any information relating to an identified or identifiable person (hereinafter ''Personal Data''), and how you can exercise control over it. Please read this Privacy Policy carefully as it contains your (hereinafter: "you", "your") rights and obligations towards Marrenco (hereinafter also: "we", "us").

This Privacy Policy is addressed to any person sharing Personal Data with us in one way or another, including customers, job applicants, suppliers, business partners, visitors of our Websites, users of our App and ORDO platform or other persons contacting us.

Marrenco NV

Lindeveldstraat 28, 9308 Hofstade, Belgium

email address: info@ordo-key.com

Phone no.: +32 53 51 02 60

Company registration number: 0861.807.980.

The data protection officer can be reached through the following email address:

service@ordo-key.com

+32 53 51 02 60

The collection and processing of Personal Data is subject to strict conditions. We act in accordance with:

1. The European Regulation 2016/679 of 27 April 2016 on the protection of personal data; and/or

2. all (future) Belgian laws implementing this Regulation.

This Privacy Policy may be revised from time to time. Please consult this page frequently to stay informed of changes. To inform you about such changes, we will update the revision date with every change, which is also the date on which these changes will take effect. Furthermore, we will proactively notify you about important changes to this Privacy Policy. In particular, with every update of the Privacy Policy, your consent will again be requested in the App.

 

2.  Collected personal data

We may access or use your data, either

1. With your explicit consent. Access to or use of the Websites or the App implies your explicit consent (by providing your Personal Data, or through the opt-in clause) to this Privacy Policy. This means that you agree with the way in which we collect, use and process your Personal Data. In particular, when using the App, you will be asked to carefully read and then accept the provisions of this Privacy Policy. If you do not accept this Privacy Policy, you may not ("no longer") use the Websites and the App; or 

2. because this is necessary for the performance of an agreement; or

3. based on our legitimate interests; or

4. based on relevant provisions of law.

Data communicated by you to us:

Activity	Personal data		Legal basis	Context
Use of the App	Identification data and security data ·       Full name ·       e-mail address ·       Phone number ·       Security code ·       Fingerprint ·       Usage data ·       Device data ·       Location ·       Camera images		It is necessary for the performance of an agreement	We process data when you use the App. Through the App, you can create an account. During the subsequent use of the App, for instance when giving people access to or while operating devices, we may collect and process personally identifiable data, including data about your devices and the devices that you access.
Visits of our Websites	·       IP address ·       Cookies  ·       Usage data (connection times, browser, operating system, web pages and click behaviour, the external website that referred you to our website, ...)		Consent Strictly necessary cookies	We may collect and process usage data and other data about your interactions in connection with the Websites. We do this through the use of cookies (consult art. 11 Cookies) and logs on our web servers.
Establishing contact with us	·       Name ·       e-mail ·       Company name ·       Information regarding the communication with us		It is necessary for the performance of an agreement	When you contact us using the contact form on our Websites or through any other means of communication or in person, we collect and process the information you provide to us.
Doing business with us	·       Name ·       e-mail address ·       Phone number ·       Invoicing data		It is necessary for the performance of an agreement Legitimate interests	We collect and process data of customers, suppliers and/or business partners in order to provide the requested services or execute an agreement. We collect and process contact data of contact persons working for a (potential) customer or a (potential) supplier of ours for the purpose of providing the requested services. Another example is when a contact person hands over a business card at a trade fair or event.
Applying for a job		·       Name ·       Phone number ·       e-mail ·       Application details (CV, motivation letter...)	Consent	We may collect and process this information when you apply for a job with us.
Use of our social media ("liking", commenting, contacting us)		Information from social media, e.g. user name(s)	It is necessary for the performance of an agreement	When you use our social media, such as Facebook, we collect the information you provide to us.
Subscribing to our newsletter		·       Name ·       e-mail address	It is necessary for the performance of an agreement	We collect and process data when you subscribe to our newsletter.
Purchases on our websites		·       Name ·       e-mail address ·       Phone number ·       Security code ·       Invoicing data ·       Payment details ·       Device data	It is necessary for the performance of an agreement	We collect these data when you buy something on our website and create an account or when you use that account to log in.

 

·       Invoicing data

·       Address data

·       Payment details

·       Information from social media, e.g. user name

·       Other personal data that you actively provide in correspondence or by phone

 

3.  Processing purposes

We collect and process your data primarily to be able to offer you a safe, comfortable and personalised experience every time you visit our Websites, use our App or use our services. That said, we may additionally use your Personal Data for the purposes stated in this section.

·       The management, operation and improvement of the App and Website;

·       Providing our services and the functionalities offered by the App in the best possible way;

·       Sending informative messages and notifications (such as "push notifications") related to the functionalities of the App;

·       Making every effort to ensure an appropriate level of security of the App and the connected devices;

·       Getting to know your preferences so that we can better understand how you use our App or our services;

·       Handling a payment;

·       Sending you our newsletter and/or promotional flyers;

·       Calling or emailing you if this is necessary to perform our services;

·       Evaluating your application and enabling us to implement a recruitment policy;

·       Informing you of changes to our services or products

·       Delivering or installing goods or services

 

The App only uses live camera footage and no stored footage from, for instance, a photo album. Images are only processed on your smartphone and are not sent to or stored on our network infrastructure.

The App allows you to use biometrics (such as fingerprints or Face ID) to authenticate yourself ("biometric recognition").

Biometric data are not transmitted to us and are therefore not processed by us. The processing of data in the context of biometric recognition is defined in the privacy policy and/or general terms and conditions of the manufacturer of the device.

 

4.  Duration of processing

Personal Data will be kept and processed by us for the period during which we are legally compelled to do so or for as long as is essential for the stated processing purposes. 

This is for as long as the account is not deleted and cooperation is ongoing and up to 30 years later. We may decide to anonymise or delete data at any time.

5.  Your rights

Right of access and verification

You have the right to verify your Personal Data and the use we make of your Personal Data at any time.

Right of rectification, deletion and restriction

You are free to communicate or not communicate certain Personal Data to us.  

You are at all times entitled to ask us to adjust your Personal Data.

You may also request that the processing of your Personal Data be restricted if you believe that your data are inaccurate and subsequently inform us accordingly.

In addition, you have the right to request us to delete your data insofar as we are unable to make them anonymous.

However, if you refuse to provide certain Personal Data or if you ask us to delete them, we may no longer be able to offer our services in an optimal manner. 

Right of objection

You also have the right to object to the processing of your Personal Data when you have serious and legitimate reasons to do so.

You also have the right to object to the use of your Personal Data for direct marketing purposes. No specific justification is needed for this.

 

Right of free data portability

You have the right to obtain your Personal Data that are processed by us in a structured, common and machine-readable form and/or to have them transferred to other controllers.

Right of withdrawal of consent

You have the right to withdraw your prior consent to the processing of your Personal Data.
 

Automatic decisions and profiling

You have the right to ask us not to be subject to decisions based solely on automated processing, including profiling, to the extent that such decisions generate legal effects relating to you or have a significant impact on you.

Exercising your rights

You can exercise your rights by sending an email to service@ordo-key.com, attaching a copy of your identity card as annex.

Rights to lodge a complaint

You have the right to lodge a complaint with the Belgian Data Protection Authority by e-mail (contact@apd-gba.be), telephone (+32 (0)2 274 48 00), fax (+32 (0)2 274 48 35) or by post (Data Protection Authority, Rue du Printing Press 35, 1000 Brussels).

This does not affect your right to seek a remedy before a civil court.

Should you suffer damage as a result of the processing of your Personal Data, you may bring a claim for damages.

7. Place of storage

We use specialised IT service providers to store your Personal Data. This data centre is located in the European Economic Area.

In addition, we also use an e-mail marketing platform, amongst others to contact you by e-mail, for instance in connection with our newsletter (if you opt for this). This data centre is located in the US.

Finally, we use an online EPR system, the data centre of which is also located in the European Economic Area.

In some cases, your Personal Data may be transferred to third countries or organisations outside Europe. In such cases, we ensure that adequate measures are in place to guarantee an adequate level of protection.

 

8. Access to data

Users of the App

Through the App, multiple users can simultaneously use or access information from certain devices or channels. This shared access is achieved through a mechanism of invitations. 

You agree that by sending an invitation to other users, these users will have access to your full name as well as the devices and channels that have been selected while creating the invitation. These other users may also control devices and channels within the limits set at the time of the invitation.

You also explicitly agree that, after having accepted an invitation, we may show your full name to the user who invited you.

Our employees

Our employees only have access to your Personal Data to the extent that they need them to perform their duties.
All our employees must sign a non-disclosure agreement ("NDA") by which they are contractually bound to treat Personal Data as strictly confidential.

Third parties

We engage third parties to assist us in carrying out our activities and in rendering and optimising our services. Examples of such suppliers and service providers are IT suppliers and other third parties who assist us in the execution, management and control of our activities, including reporting, support, marketing, computer security or offering services and products.

To the extent that third parties collect, process and/or analyse your Personal Data when providing services, they do so in the capacity of data processors. We have implemented both technical and organisational measures to ensure that these data processors only use your data  to provide the services we have entrusted them with, and according to our instructions. The data processors only receive the necessary data from us and are bound by a data processor agreement that compels them to use, process and protect personal data correctly. You explicitly acknowledge and agree that we may transfer your Personal Data to such data processors.

Furthermore, we will not sell, let, distribute or otherwise make your Personal Data commercially available to third parties, except as provided in this Privacy Policy, or after you have given your explicit prior consent.

In the event of a full or partial reorganisation or transfer of our business involving the reorganisation, transfer or assignment of our activities, or in the event that we are declared bankrupt, your Personal Data may be transferred to new entities or third parties. We will inform you in advance if we intend to transfer your Personal Data to a third party. 

Competent authorities

On rare occasions, we may have to disclose your Personal Data as a result of a court order or to comply with other mandatory laws or regulations. We will make reasonable efforts to inform you in advance, unless this is subject to legal restrictions.

9. Security and confidentiality

Your data are adequately secured in accordance with the applicable privacy laws and regulations. We have developed security measures that are reasonably adapted on a technical, administrative and organisational level in order to prevent the destruction, loss, falsification, modification, unauthorised access or unauthorised disclosure to third parties of your Personal Data, as well as any unauthorised processing of these data, taking into account the current state of the art.  Upon request, you can receive – within a reasonable period of time – an up-to-date description of the applied protection measures.

To ensure optimal security, it is important as a user of the App to always install the latest version of the App and device firmware and to install all updates as soon as possible.

In the event that we become aware of a breach that would concern your Personal Data, we will inform you about this breach, including a description of the potential impact and a recommendation to mitigate the potential negative consequences of the breach.

Under no circumstances can we be held liable for any direct or indirect damage resulting from an erroneous or unlawful use by a third party of your Personal Data.

10. Applicable law and competent court.

This Privacy Policy is governed, interpreted and implemented in accordance with Belgian law, which is exclusively applicable.

The courts of the district in which we have our registered office have exclusive jurisdiction to hear any dispute that might arise from the interpretation or implementation of this Privacy Policy.

11. Cookies

What are cookies? 

A "cookie" is a small file sent by a web server, which is then placed on the hard disk of your computer. Subsequently, the data contained in a cookie on your computer will accompany every subsequent request for the same domain name, until the cookie expires or is deleted. A server can only send you a cookie when you make a request to that server. Cookies are only stored in your browser/client if it has been configured to store cookies.

More information on cookies can also be found through the following link: https://www.allaboutcookies.org/.   

More information on online behaviour-based advertising and online privacy can be found through the following link: https://www.youronlinechoices.eu/.  

Why do we use cookies? 

Our Websites use cookies and similar technologies to distinguish your usage preferences from those of other users of our Websites. This helps us to provide you with a better user experience when you visit our Websites and also allows us to optimise our Websites. For example, cookies help us to optimise your visit to our Websites, to remember technical choices (e.g. choice of language, newsletter, etc.) or to show you more relevant services and offers.

Following the European e-Privacy Directive, all websites targeting certain parts of the European Union are under the obligation to seek your consent for using or storing non-essential cookies and similar technologies on your computers or mobile devices. This Cookie Policy gives you clear and comprehensive information about the cookies that we use, including their purpose. 

The cookies we use are secure. The information that we collect using cookies helps us to identify any errors or to show you specific services that we think may be of interest to you. 

Types of cookies

There are many different cookies that can be distinguished according to functionality, origin or retention period. Below, you’ll find a general description of the types of cookies. We will then give a detailed overview of the different cookies used on our Websites.  

 

Type	Function
Essential/Strictly necessary cookies	These cookies are necessary to keep the website operational and cannot be disabled in our systems. They are usually set only in response to actions taken by you, such as setting your privacy preferences, logging in or filling in forms. They are necessary for effective communication and facilitate navigation (e.g. returning to a previous page, etc.).
Functional cookies		These cookies increase the user-friendliness of the website by remembering your choices (e.g. language preference) and provide improved functionality and personalisation to visitors. For example, these cookies allow certain settings to be personalised at your request. If you do not accept these cookies, it may affect the performance and functionality of the website and limit access to content on the website. These cookies may be set by us or by the third-party service providers listed below.
Performance/ Analytical cookies		These cookies collect data about the use of a website such as the number of visitors, the time visitors spend on a webpage and any error messages. They help to improve website performance. These cookies do not identify you as an individual.
Advertisement cookies		These cookies are used to deliver content that is more relevant to you. They can be used to deliver targeted ads or limit the number of times you see an ad. They also help us measure the effectiveness of advertising campaigns on our website. We may use these cookies to remember websites you have visited and we may share this information with other parties, including advertisers. These cookies may also be set by our advertising partners through our websites. They may be used by those companies to compile a profile of your interests and show you relevant ads on other sites.
Third-party cookies		First-party cookies are cookies sent from our servers or domains, from which the requested service is provided. Third-party cookies are cookies sent to your browser from a server or domain that is not managed by us but by a collaborating organisation. Only these third parties have access to those cookies and the information collected by them. If you would like to know more about these cookies, please refer to the policies offered by these parties on their respective websites. Please note that we have no influence on the content of these policies or on the content of these third-party cookies.
Cookies on our Websites
Name of cookie			Type of cookie	Description	Retention period
Google Analytics			Analytical	Google Analytics provides insights into statistics and behavior on the website and its applications through the use of cookies.	26 months
Meta-Pixel			Analytical, Advertisement and third-party	Meta-pixel retains contact information for the purpose of matching contact IDs with the retained event data for analytical services and targeted advertising. This contact information includes names, email addresses, phone numbers, and other voluntarily provided details. The event information includes actions such as visits to our site(s), installations of our app(s), and purchases.	24 months
LinkedIn Insight Tag			Analytical, Advertisement and third-party	This browser cookie collects metadata such as IP address, time stamp and page events. This enables us to know the total number of users who click on one of our advertisements and who have been taken to a page	6 months

 

Your consent

On your first visit to our Website, you will be asked to accept or refuse the different types of cookies. With this consent, you give your consent for the different types of cookies we use.  You can change your cookie settings for our Website at any time.

You can reject or block these cookies by changing the configuration parameters of your navigation device. Disabling cookies may prevent you from using certain functionalities of the Websites. More information on how to set your browser can be found through the following links: 

·       Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

·       Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac

·       Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

·       Mozilla Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox

 

Currently, some browsers offer a "do not track" or "DNT" option that sends a signal to visited websites to indicate a visitor's tracking preference. We do not currently respond to these signals because no common industry standard for DNT has been adopted by industrial sectors, technology companies or regulators. The third parties that place cookies on our Websites may or may not do anything in response to this signal.

Please note that changing settings may cause the Websites to stop working as expected.