Privacy policy

We are committed to the security and confidentiality of your personal data that we collect and use. This privacy policy is relevant to you if you are a visitor to our website, enter into an agreement with us, register or participate in an event or communicate with us. 

In the context of your use of a payment button, the sender of the invoice (also) acts as the data controller of your personal data and we also refer you to the privacy policy of the sender of the invoice for more information on the processing of your personal data.

This privacy policy informs you about the processing of your personal data and was last updated on 21 April 2023.
We also use cookies on our website. For more information on this, please kindly refer to our cookie policy.

1. WHEN DOES THIS PRIVACY POLICY APPLY?

1.1. We collect and use your personal data when you:
  • our website (www.pom.be) or use the contact form;
  • enter into an agreement with us or communicate with us in that context; 
  • registers for or participates in an event;
  • communicate with us via email, phone or any other digital communication channel.
1.2. This privacy policy may be amended as provided in article 8.

2. WHO ARE WE?

2.1. "We" in this privacy policy refers to POM:
  • Name: POM nv
  • Address: Lange Gasthuisstraat 29A, bus 8, 2000 Antwerp
  • Company number: 0560.816.683
  • E-mail: siska@pom.be
2.2. We are responsible for collecting and using your personal data in the manner explained in this privacy policy. If you have any questions about this, please contact us by email (siska@pom.be).

2.3. In certain circumstances, third parties may (also) be responsible for processing your personal data, e.g. the sender of an invoice. In that case, we recommend consulting the privacy policies of these third parties.

3. WHAT PERSONAL DATA DO WE PROCESS AND WHY?

We process your personal data only for a specific purpose and to the extent permitted by law. Below, we will further explain in which cases we collect and use your personal data. If we do not receive your personal data directly from you, we will also inform you of this below.

3.1. WHEN YOU VISIT OUR WEBSITE OR REGISTER FOR OUR NEWSLETTER OR AN EVENT

3.1.1. When you visit our website (www.pom.be), register for our newsletter or register for or participate in an event, we collect and use the following personal data.
What personal data? Why? Legal basis?
Technical information (e.g. server log files) about your visit and the device you use (e.g. IP address and time of day ). We cannot identify you from this information, but third parties may be able to (e.g. your internet service provider). To ensure the most trouble-free operation of our website and to detect and prevent malware, illegal content and behaviour and other forms of potential abuse. Our legitimate interest in keeping our online presence safe.
Information about your browsing behaviour, how you use our website and the device you use. We cannot identify you from this information, but third parties may be able to. We collect this information through cookies. For more information on this, please refer to our cookie policy. To improve the content of and overall experience on our website. Your consent. You can withdraw your consent at any time as stipulated in article 7.
Your e-mail address. To send you our newsletter or other electronic communications. Your consent. You can withdraw your consent at any time as stipulated in article 7.
Identity and contact details or other data related to your participation in the event (e.g. profession). To handle your registration and manage your participation in the event. For the performance of the agreement we have with you in connection with your registration for and participation in the event.

3.2. WHEN YOU ENTER INTO AN AGREEMENT WITH US


3.2.1. When you enter into an agreement with us, we collect and use the following personal data.

What personal data? Why? Legal basis?
Identity and contact details or other data related to your invoice that we obtain in the context of the agreement with us or a sender. If you are a sender of invoices, we collect: data concerning your company (such as the name of your company, company and VAT number); personal identification data (such as your name and e-mail address); financial information (such as your bank account number and the amount to be paid); details regarding your invoice (such as the amount, content and date of your invoice, who should pay to you, the date of payment made and the payment method) and; date and time of registration. To fulfil our contractual obligations and to provide and communicate our services to you or the sender. To conduct our normal business administration (e.g. invoicing and customer relationship management). When you as an individual are our customer or supplier, we rely on the necessity of processing your personal data for the formation and performance of the contract we have with you. However, if you are acting on behalf of a company or other legal entity, or if you use our services through a shipper, we rely on our legitimate interest to perform the contract with our customers or suppliers or to further improve our services (e.g. benchmarking of average payment terms based on anonymised data).

3.3. WHEN YOU COMMUNICATE WITH US


3.3.1. When you communicate with us via email or any other digital communication channel, we collect and use the following personal data.

What personal data? Why? Legal basis?
Identity and contact details you provide to our customer service department (e.g. via the contact form), as well as your question or complaint. To deal with your query or complaint and communicate with you in this regard. Our legitimate interest in responding to your query or complaint, proactively contacting you in this regard, and striving to achieve a high level of satisfaction.

3.4. IN ALL THE ABOVE CASES


3.4.1. However, for all personal data we collect in the above circumstances, we would like to clarify that we will also process your personal data in the following cases.

What personal data? Why? Legal basis?
Personal data listed above. To fulfil our legal obligations (e.g. in the context of fraud prevention) or to comply with a reasonable request from competent police forces, judicial authorities, government institutions or bodies, including competent data protection authorities. Applicable legal obligation.
Personal data listed above. To support and defend our legal interests (e.g. possible breach of applicable terms of use or in the context of and legal dispute). Our legitimate interest to enforce applicable terms of use, safeguard our services from abuse and illegal activities, and defend ourselves in a legal dispute.
Personal data listed above. To inform a third party in the context of a possible merger with, acquisition of/by or demerger by that third party, even if that third party is located outside the EU. Our legitimate interest to enter into business transactions.

4. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?


4.1. In principle, we do not share your personal data with anyone other than the people who work for us, as well as the suppliers who help us process your personal data. Anyone who has access to your personal data will always be bound by strict legal or contractual obligations to keep your personal data safe and confidential. This means that only the following categories of recipients will receive your personal data:

  • You;
  • Your employer or business partners, but only when necessary for the purposes mentioned above (e.g. when your employer is our supplier or customer);
  • Our employees and suppliers; and
  • Government or judicial authorities to the extent that we are obliged to share your personal data with them (e.g. tax authorities, police or judicial authorities).


4.2. Your personal data will be processed and stored on servers in the EU of a service provider based in the EU. However, should the US-based parent company of our service provider demand access to the servers in the EU, we will take all possible measures to protect your personal data. Indeed, in that case, there may be a transfer of personal data outside the European Economic Area (the European Economic Area consists of the EU, Liechtenstein, Norway and Iceland).


5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?


5.1. Your personal data will be processed in identifiable form only for as long as necessary to fulfil the purposes described above or, where we have asked you for your consent, until such time as you withdraw your consent. 


5.2. As a general rule, we will de-identify your personal data when it is no longer needed for the purposes described above or when the retention period, as in this article 5 explained, has expired. However, we cannot delete your personal data if there is a legal or regulatory obligation or a court or administrative order that prevents us from deleting it.


5.3. We will retain all personal data we collect through our website for as long as necessary to fulfil the purposes set out in clause 3.1, the legitimate interests referred to in article 3.1 or until you withdraw your consent. We retain technical information such as our server log files for up to 1 year after your visit to our website, after which they are deleted or de-identified. We will retain information about your surfing behaviour (e.g. user ID) for no longer than 26 months after your visit to our website, after which it will be deleted or de-identified.


5.4. Messages you send us via the contact form will be kept for as long as necessary to deal with and follow up on your query. Questions are deleted or de-identified no later than 5 years after your question.


5.5. All personal data in the context of an event will be deleted or de-identified no later than 2 years after the end of the event.


6. HOW DO WE SECURE YOUR PERSONAL DATA?


The security and confidentiality of the personal data we process is very important to us. We have therefore taken measures to ensure that all personal data processed is kept secure. These measures include technical and organisational measures to secure our systems, applications and processes. We have also taken other measures such as adopting internal policies, limiting processing to the personal data necessary to achieve the purposes and minimising the processing of personal data.


7. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA


7.1. When we collect and use your personal data, you enjoy a number of rights which you can exercise in the manner described below. Please note that if you wish to exercise a right, we may ask you for proof of identity.


7.2. You have the right to access your personal data, which means you can ask us to provide you with information about the personal data we hold about you. You can also request a copy of your personal data.


7.3. You have the right to request that we correct your personal data if you can demonstrate that the personal data we process about you is inaccurate, incomplete or out of date. Please indicate the context in which we use your personal data so that we can assess your request quickly and accurately.


7.4. If we request your consent to collect and use your personal data (e.g. to send you newsletters), you have the right to withdraw this previously given consent.


7.5. You can ask us to delete your personal data if it is no longer necessary for the purposes for which we collected it, if its collection was unlawful or if you have successfully exercised your right to withdraw your consent or your right to object to the processing of your personal data.


7.6. You can ask us to restrict the processing of your personal data in certain circumstances.


7.7. If we process your personal data based on our own interests, you have the right to oppose this. Where our interest relates to direct marketing, we will grant your request immediately. For other interests, we will ask you to describe your specific circumstances giving rise to a request.


7.8. Where we have collected your personal data based on your consent or because it was necessary for the performance or fulfillment of a contract with you, you have the right to obtain a copy from us in a structured, commonly used and machine-readable format.


7.9. If you wish to exercise any of these rights, please email siska@pom.be. The above rights may be subject to certain legal conditions. If the request proves to be well-founded, we will notify you no later than 30 days after receiving the request.


7.10. If you repeatedly make the same request, causing obvious inconvenience, we may refuse these successive requests or charge you an administrative fee to cover the costs.


7.11. If you have a complaint about the processing of your personal data by us, you can always contact us at the e-mail address mentioned article 7.9. If you are not satisfied with our response, you can file a complaint with the competent data protection authority.


8. CHANGES TO THIS PRIVACY POLICY


8.1. We may change this privacy policy on our own initiative and at any time. If material changes to this privacy policy may affect the processing of your personal data, we will communicate these changes to you in a way that we normally communicate with you (e.g. via e-mail or via a notice on our website).


8.2. We invite you to review the latest version of this privacy policy on our website (www.pom.be).


9. STILL HAVE QUESTIONS?


Should you have any further questions regarding the processing of your personal data, please do not hesitate to contact us via e-mail: siska@pom.be.



Last update: 21-04-2023 

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