PREAMBLE: The company International Merchandising, Promotion and Services SA (hereinafter "IMPS") is the publisher of the site www.smurf.com.
IMPS respects the privacy of its users (hereinafter the "Users"). Any processing of personal data carried out by IMPS complies with the legislation in force in Belgium and in Europe. More specifically, IMPS assures its Users of compliance with the principles contained in the new European General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016, hereinafter the "GDPR").
1. Data controller
When the User accesses the site, he/she should in principle not provide personal data such as his/her last name and first name, postal address, e-mail address, etc.
In the context of the services offered by IMPS, and in order to be able to take advantage of some of the purposes of the Site, the User may however be required to provide certain personal data. In this eventuality, the data controller is as follows:
International Merchandising, Promotion and Services SA (IMPS S.A.)
Rue du Cerf, 85,
BCE no.: 0426.198.796
Any request for additional information or request concerning the processing of personal data may be addressed to the following address: firstname.lastname@example.org
2. Data processed
2.1 The personal data provided by the User
IMPS processes the Users' personal data only when they are necessary for the provision of the services offered.
Thus, when the User wishes to become a member of the Site, take part in a competition or register for the newsletter, he/she will be requested, separately for each of these functionalities, to provide identifying data such as his/her last name and first name, e-mail address, country of origin, gender and date of birth. These data are provided to IMPS with the User's consent.
When the User contacts the Site or IMPS via any other communication medium, IMPS processes the data related to the content of the communications.
IMPS processes all information that may be provided to it voluntarily by the User for a specific purpose on the Site or on any other communication medium used by IMPS.
2.2 The personal data collected automatically when the User accesses the Site and uses the services of IMPS
When the User accesses the Site, some electronic identification data are recorded automatically. These data include the identifier of the device (including mobile devices) and the type of device with which the User accesses the Site, the type of domain with which the User connects to the Internet, the User's IP address (at the time of his/her connection) and the date and time of accessing the Site, as well as other traffic-related data, geolocation data or other data relating to the communication, the pages viewed, the type of browser used, the platform and/or operating system used, the search engine used, the key words used to find the Site, etc.
However, these recorded data are unnamed and do not make it possible at any time to identify the User precisely. This information is retained only for statistical purposes and makes it possible to improve the Site and the User's experience.
IMPS uses social modules such as Facebook, Instagram, Twitter and Google + on its Site. These social modules allow the User to access certain functionalities of the Site through the use of his/her user account on these social networks. The modules establish a direct connection to the social network's server via the User's browser. The provider of the social network will receive the information that the User has visited the Site. When the User uses these social modules, IMPS will automatically receive data related to the User's account on the social network used, such as his/her last name and first name, date of birth, e-mail address, gender and country of origin.
2.4 Google Analytics
The Site also uses Google Analytics, a service offered by Google that makes it possible to analyse the activity on the Site. For these purposes, Google collects information relating to Web traffic and the number of visitors. Using this information, IMPS can measure the performance of the Site in terms of navigation.
3. Purposes of the processing
IMPS processes the Users' data only for the purposes listed below, and guarantees to the Users that it will not use these data for any other purpose without first informing the Users and, where appropriate, requesting their permission.
IMPS processes the Users' personal data for the following purposes:
- To keep them informed about developments linked to the Site and any marketing actions, competitions and promotions offered by IMPS, e.g. via the Newsletter or the pages of the social networks linked to the Site (Facebook, Twitter, Instagram), when they have indicated their consent to receive this Newsletter.
- So that they can participate in games/competitions.
- So that they can use the services provided by IMPS.
- To perform statistical studies relating to the use of the Site.
- To improve the services offered by IMPS and the Users' experience.
- For any other purpose for which the User has indicated his/her express consent.
Depending on the type of processing applied and the data concerned, IMPS processes Users' personal data on the basis either of their consent or of the legitimate interest of IMPS or a third party. When the processing is based on a legitimate interest, IMPS ensures at all times that the User's interests and fundamental rights and freedoms are taken into account and respected.
Users below the age of 13 years must obtain parental authorisation in order to validly indicate their consent. IMPS undertakes to make all efforts that might be reasonably expected of the data controller to adopt measures to ensure the protection of children when their consent is required in order to process data concerning them.
4. Communication of personal data
IMPS values its Users' privacy and regards personal data as confidential information.
IMPS does not pass any information on to third parties, except in cases where the User has expressly indicated his/her agreement or where this is required by law, for example at the request of the competent authorities.
5. Duration of retention
IMPS stores the personal data provided by the User via this Site in a database that it owns.
IMPS retains Users' personal data for the duration necessary for the achievement of the intended purposes (see point 3).
6. Security standards
IMPS undertakes to implement the necessary and adequate technical and organisational security measures to protect the data against unauthorised access, disclosure, use or modification, as well as their illegal destruction or accidental loss.
7. Rights of the data subjects
In the context of the protection of the User's privacy, and by virtue of the applicable legislation, every User has the following rights:
- The right of access to his/her personal data (right to obtain confirmation that his/her data is being processed; to access those data and obtain additional information about such processing. This request can be made free of charge, provided that the request is reasonable. Any subsequent request will entail only administrative charges).
- The right to rectification of his/her personal data (the User can at any time modify or supplement the data concerning him/her, or request that IMPS modify such data when it is inaccurate or incomplete).
- The right to request the erasure of personal data when the processing of those data is no longer justified by the purpose for which they were collected.
- The right to withdraw his/her consent, at any time and for the future. The withdrawal of consent must form the subject of an unequivocal written request (see Article 8 in this regard) (IMPS will not process personal data for which it has not obtained the consent of the data subject, when such consent constitutes the basis for the processing of the data).
- The right to portability of the data, which entails the right to receive the data in a structured and machine-readable format.
- The right to object to processing of his/her personal data for direct marketing purposes, as well as for statistical purposes when the refusal is based on legitimate interests.
- The right to erasure (in certain cases, and subject to exceptions, the User can request that the controller erase his/her personal data).
- The right to restriction of processing (the processing will then be restricted to simple storage of the data insofar as the data are inaccurate or such restriction is justified by a legitimate interest).
8. Right to lodge a complaint
Any User who wishes to exercise his/her rights or to lodge any complaint or protest can do so by contacting the data controller, either via e-mail at the following address: email@example.com or by sending a letter to the following postal address: IMPS SA, Rue du Cerf, 85, 1332, Genval, Belgium.
The User can also contact IMPS in the event of any suspected leak of data concerning him/her.