A-Dugast Privacy Policy

pursuant to Art. 13 of the GDPR relating to the processing of personal data.

The company A-Dugast B.V., with registered office at Textielstraat 46, 7575CA Oldenzaal, Netherlands (“Company”), is committed to protecting the personal data of the user (“User”) of its website https://www.a-dugast.com/ (“Site”) and, as data controller, is required, pursuant to Article 13 of EU Regulation No. 679/2016 (General Data Protection Regulation, “GDPR”), to provide the User with certain information regarding the processing of personal data. This privacy notice does not apply to other websites owned by third parties, which can be reached through links on the Site. Please read the privacy policies of these websites of third parties in relation to their processing of personal data. If you are providing personal data on behalf of someone else, you should ensure in advance that they have read this Privacy Policy. 

Types of collected data 

Through the Site, the following types of User’s data (hereinafter jointly also “Personal Data”) can be processed. 

A) Navigation Data and Cookies 

The computer systems and software procedures, aimed at the functionality of the Site, acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified subjects, but by their own nature could, through processing and association with data held by third parties, allow the identification of Users. This category of data includes the IP addresses of the computers used by the Users, who connect to the Site, the URI addresses (Uniform Resource Identifier) of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system used. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning and they are deleted immediately after processing. The data could be used to ascertain responsibility in case of any computer crimes against the Site. 

In addition, the Site uses cookies, in accordance with our Cookie Policy. 

B) Personal data provided intentionally by the User 

The Company processes certain Personal Data that may be provided voluntarily by Users through a specific form on the Site: 

  • for the request of information through the “Contact” section (information that can be provided: name, surname, email, telephone, message); 

  • for subscription to the Company’s newsletter with marketing content (information that can be provided: email address); 

  • for the purchase of Company’s products through the “Shop” section (information that can be provided: name, surname, address, city, country, region, postal code, phone email, payment details); or 

  • other Personal Data that may be possibly sent to the Company using the contact details on the Site. 

 

Purposes and legal basis of the processing 

A) Performance of a contract or of pre-contractual measures in relation to orders for the Company’s products or related to User’s requests. 

The Company may process the User’s Personal Data in order to execute a contract or pre-contractual measures: (i) to manage orders for the Company’s products placed through the Site and to provide information and/or pre and post sales assistance; (ii) to respond to requests for information forwarded through the “Contacts” section. 

Legal Basis: fulfilment of a contractual obligation or execution of pre-contractual measures. The provision of Personal Data is necessary; otherwise, the Company will not be able to process the order received, provide information and/or pre and post sales assistance or respond to the User’s requests. 

B) Sending marketing communications through Newsletter. 

The Company may process the email address communicated by the User for marketing purposes in order to provide information on events and on commercial and promotional initiatives relating to the Company’s products through automated contact methods (i.e. email). 

Legal Basis: the User’s consent, which can be revoked at any time, using the contact details below. Refusal to provide consent has no consequences other than the impossibility for the User to receive promotional communications through newsletter. 

C) Sending email communications promoting products and services similar to those purchased. 

The Company – pursuant to and within the limits allowed by Article 11.7 paragraph 4 Dutch Telecommunications Act – may process the User’s email address to promote its own products or services similar to those purchased. The User has the right to object to this processing activity at the moment of collection of User's personal data or in every email that is sent to User.  

Legal Basis: legitimate interest of the Company to maintain an effective contractual relationship with the User. The provision of the email address is optional and refusal to provide it does not have any consequences on contractual relations. 

D) Purposes related to obligations provided for by laws, regulations or EU legislation, by provisions/requests of authorities legitimized by law and/or by supervisory and control bodies. 

The Company may process the User’s Personal Data in order to fulfil its obligations to which it is bound. 

Legal Basis: compliance with a legal obligation. The provision of Personal Data for this purpose is necessary, otherwise, the Company will not be able to comply with specific obligations. 

E) Defence of rights during judicial, administrative or extra-judicial proceedings, and in the context of dispute arising in relation to the services/activities offered. 

The Company may process Personal Data in order to defend its rights or to act or even make claims against the User or against third parties. 

Legal Basis: legitimate interest of the Company in protecting its rights. In this case, a new and specific provision of data is not required, because the Company will pursue this further purpose, if necessary, by processing the data collected the other above-mentioned purposes, which are considered compatible with this one (also because of the context in which the data were collected, the nature of the data themselves and the appropriate guarantees for their processing, as well as the link between the other above-mentioned purposes and this further purpose). 

How we keep personal data secure and where 

The Company takes appropriate security measures to ensure the protection, security, integrity and accessibility of Users’ Personal Data. The appropriate security measures are designed to prevent unauthorised access, disclosure, modification or destruction of Personal Data. 

All Personal Data is held on the Company’s secure computer systems (or appropriately stored hard copies) or those of our suppliers, and may be accessible and usable in accordance with our standards and security policies (or equivalent standards for our suppliers). 

The Company informs you that Personal Data will be processed, for the purposes set out in this policy, exclusively within countries belonging to the European Union (EU) or the European Economic Area (EEA). 

When the Company transfers Personal Data in countries that do not belong to the European Union (EU) or the European Economic Area (EEA) (“Third Countries”), it uses any appropriate measure to guarantee an adequate protection of the Personal Data including also the adoption of standard contractual clauses (SCC) issued by the EU Commission, possibly supplemented by additional technical/organizational/legal measures so that the safeguards contained in the transfer tool can ensure an essentially equivalent level of protection for Personal Data transferred in the Third Country. The Users can write to the Company at any time to receive a copy of the safeguards adopted for the transfer. 

How long we store personal data 

We only retain Personal Data for as long as it is necessary for the purposes for which it was collected or for any other legitimate related purposes. Therefore, if Personal Data is processed for two different purposes, we will keep those data until the purpose with the longer retention period ends. In any event, we will no longer process Personal Data for that purpose whose retention period has expired. 

Personal Data that is no longer needed, or for which there is no longer a legal basis for its retention, will be irreversibly anonymised (being in this case stored) or safely destroyed. 

Navigation data is not stored, unless the judicial authorities need to ascertain whether a crime has been committed. 

Data processed in order to fulfil any contractual obligation may be stored for the entire duration of the contract and, in any case, for no longer than the following 10 years, in compliance with the legal statute of limitations. 

Data processed for marketing purposes may be stored for 120 months from the date we last obtained your consent for this purpose. 

Data processed for judicial purposes will be kept for the term in which possible claim may be pursued according to applicable law. 

Who can access personal data 

The Personal Data of the Users may be accessed by duly authorised employees of the Company, as well as by external suppliers (including consultants), appointed, if necessary, as data processors. You may contact the Company using the contact details provided below (“Contacts”) if you wish to request to see the list of data processors and other entities to whom the Personal Data is disclosed. 

 

 

Personal data protection rights 

Each User, subject to the existence of the legal basis for the request, has the right to obtain from the Company: 

  • the access to and the rectification of Personal Data; 

  • the cancellation of Personal Data; 

  • the rectification of Personal Data; 

  • the revocation of consent, in cases where processing is based on such legal basis; 

  • the limitation of the processing of Personal Data; 

  • the copy of Personal Data provided by the Users to the Company, in a structured, commonly used and machine-readable format (portability) and the transmission of such Personal Data to another data controller. 

Right to object: Users have the right to object, in whole or in part, to the use of their Personal Data processed by the Company, if the conditions set out in the GDPR are met, for example if the Personal Data is processed for marketing purposes or if the legal basis for the processing is the Company’s legitimate interest. 

In the event that the User exercises any of the above-mentioned rights, it will be the responsibility of the Company to verify that the User is entitled to exercise such rights, and the feedback shall normally be given within one month. 

If the User considers that the processing of his/her Personal Data is in breach of the provisions of the applicable legislation on the protection of Personal Data, he/she has the right to lodge a claim before the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or to take appropriate legal action. 

Contacts 

A-Dugast B.V.’s contact details, for questions and for exercising the rights inherent in the processing of Personal Data, are as follows: 

Address: Textielstraat 46, 7575CA Oldenzaal, Netherlands 

Telephone: +31 (0) 541 356 003 

Email: info@a-dugast.com 

 

 

Last update: October 2022