Privacy Policy

Version of November 2023

Delphine VANDERSTEENE places great importance on the protection of your data and makes every effort to protect it. Below you will find her commitment to the protection of personal data as well as her data protection policy.

This Privacy Policy applies to the processing of personal data carried out through the “VANDERSTEENE Jewellery” webshop (hereinafter referred to as “the webshop”).

Delphine VANDERSTEENE reserves the right to modify this Policy at any time. In the event of a modification, she will inform you by any means of the substantial changes made to this Policy.

Her commitments regarding personal data protection:

  • When she has to use external service providers, she rigorously selects them and ensures that they are also informed and committed to data protection;
  • Your data is used solely for explicit, legitimate, and determined purposes;
  • Only the data necessary for the execution of her services is collected;
  • Delphine communicates your data only to authorized partners, providers, or professional organizations that need it for her activities;
  • Delphine respects your rights as clients, which is why she makes every effort to enable you to exercise them;
  • Delphine also respects your privacy and your choices, which is why the communications you receive from her can be terminated at any time.

Your personal data is collected by Delphine VANDERSTEENE, an independent natural person (hereinafter “Delphine” or “we” or “our”) registered with the Banque Carrefour des Entreprises under number 0864.694.820 and whose registered office is at Avenue Louise 500, 1050 BXL.

Delphine VANDERSTEENE should be understood as the “data controller” within the meaning of Article 4.7) of the General Data Protection Regulation of the European Parliament and Council of 27 April 2016, hereinafter “GDPR.”

For further information on the protection of personal data, you can also consult the website of the Belgian Data Protection Authority: https://www.autoriteprotectiondonnees.be/citoyen.

1. Your rights regarding your personal data

In accordance with Articles 15 to 21 of the GDPR, any individual using the webshop has the ability to exercise the following rights:

  • Right of access: As a data subject, you can ask if we hold personal data about you, and if so, request that we provide you with this information. Such access to your personal data will be provided upon simple request.
  • Right of rectification: If personal information is inaccurate or incomplete, you can request that it be corrected. If your data is incomplete, you can also request that it be completed, insofar as it is relevant to the purpose of the processing in question. In the event of rectification, we will notify each recipient to whom your data is communicated unless such communication proves impossible or requires disproportionate efforts on our part.
  • Right to object: You have the right to object at any time to the processing of your personal data when we process it for legitimate interests.
  • Right to erasure (“right to be forgotten”): You can obtain from us, under certain conditions, the erasure of certain of your personal data as soon as possible. This right to erasure can only be obtained in certain cases, especially for public interest reasons, archival purposes, or to comply with legal obligations. We will also have the obligation to notify this erasure to the recipients to whom your personal data has been communicated unless such communication proves impossible or requires disproportionate efforts on our part.
  • Right to restriction of processing: You can obtain from us the restriction of the processing of your data, especially when you object to this processing, when you contest the accuracy of the data, or when you believe that their use is unlawful.
  • Right to data portability: Under certain conditions, you can request to receive all your personal data to transfer it to another data controller of your choice.
  • Right to withdraw consent: When we base the processing of your data on your consent, you have the right to withdraw, at any time and without justification, your consent. The withdrawal of this consent will stop the processing.

2. How to exercise your rights?

To exercise these rights, please address your correspondence to Delphine VANDERSTEENE, Avenue Louise 500, 1050 BXL or the email address info@vandersteene.jewelry.

Your requests to exercise rights must be accompanied by a document proving your identity. We have a period of 30 working days from the receipt of your request to respond to you. Some demanding requests may take longer; in this case, the period will be extended to 60 working days, and you will be informed.

We may refuse your request to exercise your rights if:

  • We are unable to identify the person making the request;
  • The requests are manifestly unfounded or excessive, particularly due to their repetitive nature or technical difficulty in structuring the data. In this case, we may also require the payment of reasonable administrative fees.

3. What information do we collect?

For the purposes outlined below, we only process the following data when they are relevant and strictly necessary for the processing. Depending on the case, the data may directly concern you or concern third parties and/or parties involved in the contract.

We collect:

  • Your identification data (name, first name);
  • Your electronic contact data (email address);
  • Your electronic identification data (IP address, cookies, connection times, pre-registered cart, etc.);
  • The postal address for delivery/billing;
  • Your phone data (phone number);
  • Your banking data (bank account number, credit card number, etc.), including encryption data;
  • Any information you may voluntarily communicate to us.

These personal data are collected at four collection points:

  • When the user creates their client account;
  • When finalizing their order;
  • During payment;
  • The deposit of cookies.

4. For what purposes do we collect your personal data and on what legal basis?

The GDPR allows the processing of personal data provided it is based on one of the legal grounds provided by the GDPR and for specific purposes.

We collect and process your personal data for the purposes described below. We ensure that only necessary and relevant personal data is subject to processing, in compliance with the data minimization principle.

In general, we base the processing of your personal data on the following legal grounds:

  • To comply with our legal obligations;
  • To take preliminary measures and execute the contract that binds us when you benefit from one of our products or services;
  • To realize our legitimate interest (in this case, we always ensure a balance between our legitimate interests and your rights and freedoms);
  • Finally, based on your free and informed consent.

In cases where we may carry out processing not yet provided for in this Policy, we may use your personal data as long as these purposes are compatible with the purposes for which we initially collected your data. We consider any link between the initial and subsequent purposes as well as the context in which the data is collected. In cases where we consider that the purposes are incompatible with the initial purposes, we will contact you before using your personal data. This contact will then aim to inform you about this processing and, if necessary, to ask for your consent for this subsequent processing.

4.1. Compliance with our legal obligations

In some cases, we are obliged to process your personal data in the context of legal obligations or when we cooperate with the competent authorities. In these cases, we transmit your personal data to comply with our legal obligations.

4.2. In the context of executing the contract that binds us or pre-contractual measures taken at your request

  • Placing an order on our webshop

Concerning orders placed through the webshop, the personal data we process mainly fall within the scope of the contractual relationship that binds us or pre-contractual measures taken at your initiative.

More specifically, the purposes for which we process your personal data are as follows:

  • Creation of the client account;
  • Placing an online order;
  • Management of product delivery;
  • Billing management;
  • Customer relationship management and maintenance;
  • Management of claims, complaints, orders, after-sales service.

4.3. In the context of our legitimate interests

In some cases, it is in our legitimate interest to process your personal data. For this purpose, we always ensure to maintain a fair balance between the need to process your personal data and the respect of your rights and freedoms.

This is the case when we pursue a legitimate interest, i.e., not contrary to the law, and that the processing of personal data is necessary to achieve this legitimate interest. For example, we have a legitimate interest in preventing fraud or ensuring network security or its IT systems.

Additionally, we process your personal data based on our legitimate interests, particularly for:

  • Identification and management of people on our webshop;
  • Commercial prospecting;
  • Preservation of the security of property and people, network and IT systems security, prevention of fraud or attempts of intrusion, abuse, or other offenses;
  • Improvement of existing services and user experience on the site;
  • Maintaining a list of users/prospects who no longer wish to be contacted;
  • Management of your requests related to exercising your rights under the GDPR;
  • Assertion, exercise, defense, and preservation of our rights;
  • Analysis of your previous searches to better personalize our services to match you;
  • Preparation of studies, models (risk, marketing, and others), and statistics, using anonymization and/or pseudonymization techniques whenever possible;
  • Management of user reviews on our services.

In the case where you are only browsing our webshop, without logging in, without creating a user account, and without placing an order, no personal data will be processed except for your electronic identification data collected through our cookies.

5. Retention period for your data

In general, we ensure not to retain your personal data beyond the necessary time concerning the purposes for which they were collected.

More specifically, several situations should be distinguished to determine the retention period for your personal data:

5.1. In the case of concluding a sales contract

  • Identification and billing data

In general, your identification and billing data are retained for the entire duration of the contractual relationship and for a period of 60 days from the deletion of your client account.

If applicable, the deletion of your client account must be done manually via your client account.

However, to comply with our legal obligations and/or activate our rights in court, we may be required to retain your personal data for a period of 10 years from the end of the contract binding us, this period corresponding to the legal prescription periods.

5.2. In the absence of concluding a sales contract

In the case where you create a client account but do not place an order on our webshop, the personal data linked to your client account will be retained as long as you do not manually delete your client account (in your client area) and for a period of 60 days from deletion.

Without creating a client account on our webshop, no personal data, except those listed in point 5.3, will be collected.

5.3. Cookies

Unless deleted by you, personal data collected through cookie implementation are retained for 13 months from the cookie’s implementation on your terminal.

These electronic identification data are collected regardless of whether or not you place an order on our webshop. They are collected as soon as you enter our webshop.

5.4. Commercial prospecting

If you do not respond to any solicitation 3 years after the last contact from you, the information concerning you will be deleted.

At the end of these 3 years, we commit to contacting you again to determine if you wish to continue receiving commercial solicitations. If not, we will do everything possible to ensure your personal data is made unavailable and inaccessible.

6. To whom is your data transmitted?

In some cases, we may transmit your personal data to other third parties.

6.1. Internal recipients

Access to your personal data is strictly limited to people whose role requires it. Access to data will only occur within the scope of their duties. These accesses to your personal data will be controlled by Delphine VANDERSTEENE, who ensures that only authorized persons are aware of them.

6.2. Subcontractors

To enable you to access, improve, and use our webshop, we work with subcontractors who may have access to your personal data when necessary in the context of our services.

For example, this may involve subcontractors responsible for maintaining our infrastructure, external IT consultants, software suppliers, and any other partner we may call upon in the context of managing the webshop.

If this is the case, we ask them to comply with the legal and regulatory provisions in force and to strictly respect the confidentiality of the information they may process in the course of their intervention.

6.3. Transmission due to a legal obligation or by order of a competent authority

In some cases, we may be required to transmit your personal data to comply with a legal obligation, a court decision, or a request from any competent authority.

6.4. Third-party cookies

Third-party cookies refer to cookies not generated by us but by a third party displaying advertisements on our website. Third-party cookies are used by our partners (advertisers or advertising servers) on our website, using pixels or tags, to target your preferences and offer you personalized advertisements. To do this, these cookies will collect information related, in particular, to your behavior on the website.

7. Security measures in place around your data

We implement appropriate technical and organizational measures to ensure an adequate level of security regarding the processing of your personal data. This security level is established based on the risks presented by the processing and the nature of the data to be protected.

We have implemented appropriate security measures to protect your personal data, particularly against loss, theft, misuse, alteration of received information, unauthorized disclosure, or use of your personal data.

In the event that your personal data under our control is compromised due to a security breach, we commit to act promptly to identify the cause of this breach and take appropriate and necessary measures to remedy it.

If necessary and by applicable law, we will inform you of this incident.

8. Questions, complaints, and grievances

For any questions and/or complaints regarding this Policy, do not hesitate to contact us directly to see how we can assist you:

If you are not satisfied with our response, please know that you can also file a complaint with the Belgian Data Protection Authority, whose contact details are:

Data Protection Authority
Rue de la Presse, 35
1000 Brussels, Belgium
Tel. + 32 2 274 48 00
Fax. + 32 2 274 48 35
contact@apd-gba.be

Additionally, you can always file a complaint before the Brussels Court of First Instance. For more information on complaints and possible remedies, we invite you to consult the information available on the Data Protection Authority’s website: https://www.autoriteprotectiondonnees.be

9. Applicable law and competent jurisdiction

This Policy is governed by Belgian law.

Any dispute will first be subject to an attempt at amicable discussion and resolution. In case of failure of amicable discussion, any dispute relating to the interpretation or execution of this Policy will be subject to Belgian law and falls under the exclusive jurisdiction of the courts of the judicial district of Brussels.

10. Modification of this Policy

We reserve the right to modify the provisions of this Policy at any time. We will post the changes directly on our webshop.