Privacy statement

1. General information

In order to respect your privacy, VILLAS Decoration SRL (Drève de Linkebeek 40 – 1640 Rhode-Saint-Genèse Belgium) sets out the rules in this privacy statement. We are committed to protecting the privacy of our customers, subscribers, readers, surfers and users. The purpose of the privacy statement is to explain to you the process of collecting and processing data (including the collection, use and storage of data), the purposes for which we collect this data, as well as the rights of the data subjects and the control you have over your data.
When you surf on the VILLAS website, referenced at the following URL address: https://www.villasdecoration.com, or use our services or purchase our products and services, you must read, understand and accept the rules set out in this declaration.
This declaration is drafted in order to ensure compliance with European Regulation 2016/679 of 27 April 2016 on the protection of individuals with regards to the processing of personal data and on the free movement of such data, known as the General Data Protection Regulation (GDPR).

2. Data controller

VILLAS Decoration SRL, having its registered office at Drève de Linkebeek 40 – 1640 Rhode-Saint-Genèse, is responsible for processing the data used by VILLAS.
Depending on the service, we use specialised third parties acting either as subcontractors or as co-responsible for data processing. In the first case, third parties must comply with our guidelines and the privacy statement. In the second case, third parties must cooperate with us and comply with the legal provisions regarding the processing of personal data.
Subcontractors working with us only receive the data necessary to comply with legal provisions and the fulfilment of their obligations. They may not process the data sent by the controller.

3. Guiding principles for the processing of your data

According to the new regulations applicable to the processing of personal data, the following principles must be respected by VILLAS. The latter manages and executes its commitments within the framework of its activities:

– By processing your data in a lawful manner;
– By collecting and processing your data for the purposes defined in this declaration;
– By limiting the processing to the data necessary for the activities carried out;
– By collecting accurate personal data and ensuring that reasonable measures are in place to correct and/or delete incorrect data;
– By processing and storing the relevant data for the time necessary to carry out our activities and
– By implementing reasonable and appropriate technical and/or organisational measures to secure your data.

4. Processing and classification of personal data

First of all, the communication of personal data is not mandatory. Indeed, you are not required to provide your data when you use or purchase a VILLAS product or service. In other words, you have the choice of whether or not to enter your personal data. However, some products and services require the disclosure of personal data.
For example, when you want to create an account to be informed of the latest decoration trends, you must give us your email address and your agreement to receive the newsletters by ticking a box provided for this purpose. When you take a yearly subscribtion for one of our magazines, we need to collect information to deliver the magazines to you.
Usually, we collect, use, store and process the personal data necessary for the performance of our activities and the provision of our products, including data of subscribers to our magazines, customers and visitors or users of the site and services related to events, online promotion, actions, the creation of loyalty programmes and competitions with one or more prizes at stake.

a) Consensual personal data

When you purchase one or more of our products, use certain parts of our site, participate in one of our contests or actions or create a user account, or register for one of our events, you must provide some personal data.
The personal data mentioned below are provided on a voluntary basis.
The categories of personal data depend on the service used or requested. In particular, VILLAS may request the following categories of personal data:

Identification and contact data:

– Designation, last name, first name, date of birth, language preference, age or sex ;
– Company name ;
– Mailing address ;
– Billing address ;
– VAT number ;
– E-mail address ;
– Landline or mobile phone number and
– Fax number.

Banking, financial and transactional data:

– Bank account number ;
– Data relating to transfers including communication;
– Data recorded during your bank transfers;
– And if necessary, data relating to your creditworthiness.

Data on interests or preferences in registration forms, social media, actions, mobile applications, contests, etc.

Data relating to satisfaction surveys or market studies concerning our products or services or future projects.

VILLAS does not process personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning the sex life or sexual orientation of a natural person is prohibited.

b) Other personal data

The use of our site involves the automatic collection of data through cookies or other systems that record information. The type of data referred to in this section includes, but is not limited to, the IP address, device used, site visited or application used, language and browser type. Prior identification is sometimes required when using the website.
The categories of personal data depend on the service used. We aim, for example, at providing the following data:

1) Data from your interactions on the pages dedicated to the different social networks if you give your consent to this type of data processing.
2) When you browse our website, data relating to your behaviour and habits regarding the use of the various distribution and communication channels may be recorded, including but not limited to:

– Location data to locate you in an approximate way;
– The duration of the use of our services and products, when you use them and how often they are used;
– The way you use our website;
– How you use the articles, videos, photographs, pages that are viewed, read and shared;
– The way you came to our site (according to which referent or keyword);
– The use of antipub software and
– The device, system software or browser used.
– The other data is collected in order to give you the best possible experience on our various web media. Thanks to automated data processing, we improve our services and products so that they are personalized and adapted to your needs and desires.

5. Time and source of processing

In this section we will discuss the times and sources of processing of personal data. We collect personal data directly from VILLAS with regard to the products and services offered and the processing of data collected by the authorities or authorised third parties.

a) Personal data collected by VILLAS

There are several times during the experience offered by our magazine that data is collected about you by VILLAS.
VILLAS processes your personal data, in particular when:

– You participate in the contests of our different magazines;
– You communicate with the VILLAS company via the channels set up;
– You authorize the transmission or publication of your personal data to VILLAS;
– You become a commercial customer for VILLAS;
– On a professional or private basis, you complete a form from VILLAS;
– Professionally or privately, you enter into an agreement with our magazine and
– On a professional basis and following the signature of a contract, you use the services and/or products offered by VILLAS.

Please be aware that images recorded by surveillance cameras in and around our premises/buildings can be collected and stored by VILLAS. The processing of this data is implemented in order to secure property and people and to prevent abuse or possible fraud.

b) Personal data collected by third parties

In order to refine our offers and services, personal data may be collected via public or external sources (partners or external data providers) and authorised by the person concerned when:

– Publications or data are made accessible by official authorities;
– Personal data are made public by third parties;
– Personal data is made public by you via our website or pages of social networks such as your website or Instagram and;
– You authorize the transmission or publication of your personal data to VILLAS.

Usually, we process the personal data of our subscribers, customers and visitors or users of our site and services related to events, online promotion, actions, the creation of loyalty programs and contests with one or more prizes at stake.

6. Legal notice and reasons for use for the processing of your personal data

The respect of your privacy and the respect of the processing of your data are important to us. To do this, your personal data is collected, stored and used by us when we have either a legal authorisation (based on the general data protection regulation) or a valid reason for collecting it (called the purpose of the processing). Users who surf on our web platform must, for example, give their permission for us to collect their data and must validate the reason(s) for the processing.
Therefore, data collection is determined by a principle of minimisation. This means that we only collect the data that are useful and necessary for the processing purposes defined by VILLAS to carry out its activities.

a) Grounds invoked by VILLAS for the processing of data

On the basis of the legislation, we can collect your data:

– To perform a contract such as the delivery of an old magazine or to respond to pre-contract measures;
– To comply with the legal and regulatory provisions that apply to VILLAS, such as tax obligations;
– After you have given your consent to the processing of your data, for example for VILLAS to offer you products/services similar to the products/services purchased or which are likely to interest you and
– To meet the legitimate (economic) interest of VILLAS or a third party by balancing this interest with your fundamental rights and freedoms (including privacy); for example, data processing to prevent fraud may prevail over your legitimate interests.

By “legitimate interest” we mean any direct marketing operation for prospecting purposes and/or for promotion by e-mail, telephone, mail, advertising or other channels.
Customers, users and subscribers receive actions or promotions, offers or benefits, invitations to events related to the magazine as well as offers for similar products or services or that may be of interest to them.
It is also in VILLAS’ legitimate interest to collect and assemble personal data explicitly or automatically to create profiles of subscribers, users or customers based on characteristics defined as their interests or preferences. This allows us to customize the offers of our products and services on our distribution channels by creating targeted advertising campaigns, for example.
Note that VILLAS provides customer-partners with reports including commercial and statistical aspects in which anonymous data are used. Anonymity does not allow data to be linked to a specific individual and is not covered by the new regulation.
Note that by validating the “Opt-ins”, the data subjects express their will in a free, specific, informed and unambiguous way as to the acceptance of the processing of their data.

b) Reasons for use for the processing of personal data

The main reasons why VILLAS collects and uses your data are as follows:

– In order to assist you and answer any requests for information or complaints;
– In order to advise you and inform you about our products and services;
– In order to properly execute the contracts concluded;
– In order to manage the administration of sales-related files such as sending magazines to the subscriber’s address;
– In order to manage requests for products or services on our site as a request for a newsletter by email;
– In order to manage registrations for events or conferences;
– In order to keep you informed of VILLAS’ new products and services;
– In order to inform you of the advantages, promotions, actions, offers and contests of VILLAS;
– In order to manage contest entries and select winners;
– In order to carry out satisfaction surveys or market studies in order to improve our products or services or our future projects;
– In order to carry out studies, tests and statistics on the use by Internet users of the VILLAS site;
– In order to create usage/subscriber profiles with regard to interactions on the pages dedicated to our various social networks and/or according to your behaviour and habits regarding the use of our various communication and distribution channels, provided that you have given your prior consent;
– In order to carry out information and/or promotional operations on our products or services or on products and services as a result of commercial collaboration(s) concluded with VILLAS;
– In order to test, prevent, detect and fight against (possible) abuses and (possible) frauds of our site;
– In order to process and manage contact and security data when using a card reader on our site to validate, track and ensure the security of communications and transactions via our remote channels;
– To ensure the provision of services and products when we use subcontractors;
– To ensure proper management of commercial customer files and equipment;
– In order to maintain the financial and accounting management of VILLAS;
– In order to ensure the management of VILLAS’ personnel and activities;
– In order to comply with the legal obligations/requests of duly authorized public or judicial authorities and
– In order to transfer the assets, including VILLAS’ personal data, to a third party company in the event of a merger, acquisition or any other legal transaction involving such a transfer.
The data processed may be combined with each other to improve our offers, products or services in relation to your own needs.
In the event of new objectives or significant changes to them, we will keep you informed, via the website or by e-mail, of any adaptations or additions to this declaration. On this occasion, you will be free to accept or reject these changes.

7. Access to and recording of personal data

a) Access to personal data

The personal data provided are integrated and processed in the “Personal Data” file of VILLAS, Drève de Linkebeek 40 – 1640 Rhode-Saint-Genèse (Belgium).
Access to your data is only granted to people authorised by VILLAS (referred to as “authorised people”) for the purpose of carrying out the tasks mentioned in point 6(b) of this declaration.
Authorized people are defined as people who, in the course of their duties, have access to relevant personal data or to whom the processing of such data is permitted in accordance with their activities and VILLAS instructions.

b) Deadline for recording personal data

The registration policy applies to data of customers, subscribers, readers, registered people, users, surfers or anyone receiving our newsletters concerning one of our publications.
The length of time for which personal data are kept varies according to the purpose of the processing. The personal data collected are kept for as long as necessary to satisfy the requested service(s).

To meet our legal obligations, we save your data for a period of 5 years, mainly for accounting and tax purposes.

We preserve your data beyond the duration of the supply of the product or service for a specific period of time in order to offer you similar offers or offers that may be of interest to you.
Our databases are analysed to determine the usefulness and justification for recording each data and to decide whether to keep it, delete it and/or make it anonymous for statistical studies, for example.

8. Minors of age

VILLAS respects the privacy of minors. By minors we mean children under 16 years of age.
If you are a minor, you must ask your parent(s) or legal or legal representative(s) to use our products and services.
VILLAS strongly encourages parents of minors to carefully read the terms and conditions as well as VILLAS’ privacy and cookie policy. Reading the mentioned texts with the minors concerned is more than advisable. They will thus be able to ask any questions they may have and in this way will be able to have explanations or clarifications on this declaration.
The parent(s) or legal representative(s) of children may oppose the processing of their personal data on their behalf, request that the processing be limited, viewed, deleted, modified or portable. They may also refuse to allow VILLAS to offer or send information about their children to third parties in relation to VILLAS products and services.
We recommend the use of pseudonyms for minors’ e-mail addresses (avoid using their first and last names).
If you notice the use or purchase of our products or services without your consent to your minor child, we ask you to email us on the following address: info@villasdecoration.com so that we can delete, within a reasonable time, your child’s personal data.
VILLAS suggests that parents take care of their children’s activities on the Internet.

9. Security and confidentiality of personal data

VILLAS shall adopt such technical, physical and organisational security measures as are deemed necessary and appropriate for the protection of personal data and respect for privacy against unauthorised access and processing, unlawful processing, loss, accidental damage and unauthorised modification or destruction of the information collected.
In the course of their duties, VILLAS employees and collaborators have access to the company’s personal data in order to properly carry out their duties. These people are selected and limited by their number.
We use reasonable technical and organisational measures such as encryption of our data, pseudonymisation or anonymisation, controlled access to the data or the limitation of employees with access to personal data,…
The measures put in place are regularly evaluated and updated in order to offer maximum protection to personal data.
We are in the presence of an obligation on the part of the company VILLAS. This obligation is an obligation of means and not of result. We do not guarantee absolute protection of personal data and we are not liable in the event of malicious or fraudulent intrusion. We will inform you within a reasonable time if such a situation should occur.
Links to third party websites on our site such as business partners’ sites, social media platforms do not fall within the scope of this privacy statement. VILLAS asks you to be vigilant and invites you to read their policy regarding respect for privacy and your personal data. VILLAS is not responsible for the privacy policies and practices of other sites even if the link to the third party site in question is on our website.

10. Transfer of personal data

When we process your data, VILLAS is obliged to inform you of the processing of your data, the distribution, destination and purpose of the transfer of your data.
The European Regulation distinguishes between the transfer of personal data within and outside the European Economic Area. We will also do this in order to clearly distinguish the obligations of the controller.

a) Transfer within the European Economic Area

The principle is the prohibition to sell and/or give personal data to business partners or third parties.
There are exceptions to this principle:
♣ Our assigns and VILLAS-owned companies may receive personal data for the same purposes as those indicated in this privacy policy.
♣ We employ subcontractors to perform certain activities. The latter are led to use your data according to the mission(s) entrusted to them. It is important to note that subcontractors are not allowed to use your data for their own purposes. The post office receives, for example, the delivery data of our subscribers for paper magazines. The reasons for transferring your data are the same as those found in the VILLAS Terms of Use. We are careful to ensure that data management by third parties or subcontractors is done in a respectful, secure and caring manner.
♣ The law also provides for exceptions to the prohibition to sell and/or give personal data. In the event of non-payment, your personal data will be transferred to third parties in order to initiate a debt collection procedure.
♣ Your agreement to the transfer and/or sale of your data gives us the legal right to do so. For example, by purchasing one of our magazines, you can indicate that you want to receive by email promotional offers and actions from third parties.
We would like to point out that the email is written either by us or by the advertiser, subject to prior validation by VILLAS.
Please note that if you are no longer interested in the actions or promotions of our advertisers, you can always unsubscribe by using a link at the bottom of our emails.
We also share anonymous data with third parties to provide them with information such as the number of clicks on a particular ad. Please note that it is not possible to identify yourself via anonymous data.

b) Transfer outside the European Economic Area

The transfer and processing of data by a third party outside the EEA is carried out in accordance with the applicable legislation and the general data protection regulation.
We use Google Doubleclick’s Adserver ad server to present ads on our website and Google Analytics to analyze our website’s audience. The servers used by Google are located outside the EEA and the European Union. For example, to ensure that the presentation of ads is correct, we transfer location data so that ads in French are received by French-speaking readers. The data exchanged with Google is anonymous. The use of anonymity prevents the data from being linked to the data subjects.
In addition, Google guarantees an adequate level of protection as required by the European Union. Google is bound by and follows the rules of the “Privacy Shield Framework” that has been concluded between the EU and the USA (EU-US Privacy Shield Framework (https://www.privacyshield.gov/welcome)).

11. The rights of the people concerned

Depending on the applicable law, you have and can exercise different rights:

− The right to request access to personal data, the right to rectification and the right to erase data;
− The right to object, to limit the processing and the right to withdraw consent and;
− The right to data portability.

a) Right of inspection, correction and deletion

Right of access: you have the right to access your data free of charge and to request the data processed by VILLAS.
Right of correction: you may request to complete or correct the personal data stored on you if they are incomplete or incorrect.
Right to erase: you can request the erasure of your data according to the case in hand and in accordance with the general data protection regulations. The right to erasure concerns in particular:

– Data that are no longer useful in relation to the purpose for which they were collected or processed by VILLAS;
– The data for which you withdraw your consent provided that the consent is the only legal basis for the processing of personal data;
– The data for which you have a legitimate reason;
– Personal data that have been unlawfully processed;
– Or when required by law.

We may not be able to delete your data, for example, when VILLAS must enforce the right to freedom of expression and information in a specific case or when the company must retain the data for tax reasons.
You guarantee that the information you provide is accurate, up-to-date and complete. If necessary, you undertake to update this information as soon as possible so that it remains accurate. If it is found that the data provided is inaccurate or incorrect, VILLAS reserves the right to refuse, temporarily or permanently, all or part of some or all of our products or services.

b) Right to object, limit processing and withdraw consent

Right to object to processing, in particular the right to object to the use of your data for direct or commercial marketing purposes
You have the right to object to the processing of your data for specific reasons. Depending on the case, we will balance the interests.
In particular, we target situations in which data of the concerned people are shared between VILLAS and the VILLAS Decoration Publishing Group or given to third parties, or processed for personalised offers or combined in the context of profiling or used to receive information and offers.
If you no longer wish us to process your personal data, please send us an email at info@villasdecoration.com and specify your exact name and address as well as the type of information you no longer wish to receive. You can also unsubscribe via the link at the end of each of our emails.

Right to limit processing
You also have the right to limit the use of your data for certain processing operations that you no longer wish VILLAS to carry out.

Right to withdraw consent
You may withdraw your consent at any time for the data for which you have given your consent.

c) The right to data portability
The data subject has the right to receive the personal data held by VILLAS in a structured, commonly used and machine-readable form. With regard to what is technically possible, the data subject may ask VILLAS to transfer this data directly to a third party of his choice.
The right to portability concerns personal data provided by the data subject via automated processes and which concern him/her on the basis of the processing operation(s) based on consent or on the performance of a contract.

d) Complaint to VILLAS or a Belgian Personal Data Protection Authority

Data subjects are always entitled to lodge a complaint with VILLAS or a Belgian Personal Data Protection Authority known in Belgium as the ‘Data Protection Authority’.

e) Department of Privacy and Personal Data Protection

To exercise one of the rights mentioned above, the data subject may contact us:

– By email: info@villasdecoration.com
– By mail: VILLAS to the attention of the Privacy Protection Department,Drève de Linkebeek 40 – 1640 Rhode-Saint-Genèse.
– Using the contact tab on the website https://www.villasdecoration.com/en/contact/.

In case of a postal request from you, we will ask you to attach the following information to your request:

– Your first and last name;
– Your address;
– Your message;
– A double-sided copy of your ID card, making sure to hide your national registry number and photograph, and
– Your signature

We need your first and last name to know your identity and the related file. The address allows us to answer you. The message identifies with certainty the information you are asking us for or the requests we have to respond to. Your ID card allows us to verify the real identity of the person concerned and to avoid any unauthorized publication.
We may ask you for additional information in order, for example, to identify the request you are sending us.
We have 30 days to respond to your request. Please be aware that this period begins once VILLAS has received your request and has all the information necessary to respond to your request, including any additional information that may be required.
We will take all practical and reasonable steps to process your request in accordance with applicable legislation and professional standards.
f) Reasons for refusal
We will not respond to your request if:
– It does not concern (only) you;
– It concerns the modification of data that are found not to be incorrect or that do not correct them;
– It concerns the total deletion of data, but the law requires that certain data, such as tax legislation, be kept.

12. The policy regarding cookies used by VILLAS websites

When You browse our website, a web banner is displayed to inform you of the use of cookies. This same banner allows you to control your user experience through the cookie management offered on the website.
VILLAS uses three types of cookies:

1. Functional cookies[non-removable]

These cookies are essential. Indeed, they allow for an efficient and convenient connection that also guarantees your security in the online environment.
As part of these cookies, anonymous data is processed and collected, in particular on the way in which you use the website, in order to facilitate your overall use on the website.

2. Comfort cookies[to select]

Comfort cookies facilitate your experience and use of our website by retaining your personal preferences. Cookies record, for example, that you navigate on our Site using the French language and the next time you visit the website, it will be displayed directly in French. Through these cookies, we may also encounter your relevance and interests with the information and offers on the website.

3. Commercial cookies[to select]

We place the customer experience at the heart of our company policy. In order to meet your expectations regarding your interests, collected on our website but also on other websites, and social networks, the content of VILLAS ads is customized according to your desires. Cookies based on the cross-referencing of aspects of your custom are implemented by VILLAS and third parties for commercial purposes but also on social media.
The web banner, which appears when you visit our website, gives you the option to select comfort cookies as well as commercial cookies. By accepting cookies on the website, You also accept our cookie policy as to their use, which is described within it. Regarding your preferences related to the use of cookies, You may, at any time, modify them. With regards to functional cookies, it is not possible to refuse them since they are essential to establish an adequate and efficient connection.
If you wish to disable cookies, web beacons, log files and other files and technologies used by VILLAS or third parties, please follow the instructions for disabling these elements depending on the browser used:

♣ Google Chrome link: https://support.google.com/chrome/answer/95647?hl=en
♣ Mozilla Firefox link: https://support.mozilla.org/fr/kb/cookies-informations-sites-enregistrent
♣ Internet Explorer link: : https://support.microsoft.com/fr-fr/kb/260971
♣ Safari link: http://support.apple.com/kb/PH5042
♣ Opera link: http://help.opera.com/Windows/12.10/fr/cookies.html

The website http://www.youronlinechoices.com/be-fr/ allows you to disable cookies by giving the data subject the choice of processing.
The total or partial deletion of cookies, web beacons, log files or tools to detect anti-advertising technologies may interfere with the optimal use of the website.
For more information, please read the cookie policy.

13. Privacy statement and its evolution over time

VILLAS reserves the right to change its privacy statement and cookie policy at any time. We therefore invite you to regularly consult this statement and the policy on the subject of cookies.
In the event of a substantial change, we will notify you, for example, with a banner on the website or by e-mail. The adaptations to the Declaration are applicable once the modifications are published on the VILLAS website.

14. Applicable law

The processing of personal data within VILLAS is subject to Belgian law.

15. Contact us for more information

If you have any questions about the use of your data or about this privacy statement, you can contact us:

– By email: info@villasdecoration.com
– By mail: VILLAS to the attention of the Privacy Protection Department, Drève de Linkebeek 40 – 1640 Rhode-Saint-Genèse.
– Using the contact tab on the website https://www.villasdecoration.com/en/contact/.

In case of a postal request from you, we will ask you to attach the following information to your request:

– Your first and last name;
– Your address;
– Your message;
– A double-sided copy of your ID card, making sure to hide your national registry number and photograph, and
– Your signature.

This Privacy Statement and the Cookies Policy are effective as of May 25, 2018.