Last updated : (23/02/2022)
MEMOLUB offers a wide range of quality class single-point automatic lubrication and multi-point automatic lubrication systems to help extend equipment life, increase productivity, and provide a safer work environment.
In accordance with privacy and personal data protection regulations, in particular EU Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation or “GDPR”), you will find below information on the processing operations we carry out in the course of our activities.
If you have any questions about our Privacy Policy or if you wish to exercise any of your rights concerning your personal data, you can contact us by postal address mentioned below or by e-mail at the following address :
MEMOLUB International SA
Bollinckxstraat 43
1070 Brussels, Belgium
Tel.: +32 2 559 77 22
Fax: +32 2 522 47 22
e-mail: contact@memolub.be
1. The data controller
Your personal data are processed by MEMOLUB, whose head office is located Rue Bollinckx 43, 1070 Brussels, Belgium. MEMOLUB is registered to the “Banque Carrefour des Enterprises” under the number 0462.320.311.
2. Personal data collected
MEMOLUB process personal data of users who share information through MEMOLUB’s websites (for ex. through a contact form or the contact address), opens newsletters, downloads MEMOLUB materials, or uses MEMOLUB’s products or services.
MEMOLUB may collect and use the following information about you :
– Contact details
– Browsing activity
– Preferences
– IP address
– Geographical location
– Requests concerning Memolub’s products and tools
3. Purposes, legal basis and duration
The personal data you provide to MEMOLUB may be processed for the purposes listed below and on the legal basis indicated.
(i) Managing and executing MEMOLUB’s obligations and rights under, or when entering into, a contractual relationship.
The legal basis of this processing is: the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6.1.b GDPR).
This data is kept until the end of the period of prescription of the obligations in relation to the contract or the precontractual phase.
(ii) Managing enquiries or other requests regarding MEMOLUB’s products and services :
The legal basis of this processing is: processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (art. 6.1.f GDPR). It is the legitimate interest of MEMOLUB to be able to answer to enquiries and requests of clients in order to give them the relevant information regarding MEMOLUB’s business.
This data is kept for 2 years.
(iii) Ensuring compliance with legal obligations
The legal basis of this processing is: processing is necessary for compliance with a legal obligation to which the controller is subject (art. 6.1.c GDPR), such as for tax reasons or in order to comply with accounting norms.
This data is kept according to the duration set out by the relevant legal acts.
(iv) The enforcement of contractual agreements and/or of MEMOLUB’s rights (i.a. intellectual property rights) and interests in justice
The legal basis of this processing is: the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (art. 6.1.f GDPR). It is the legitimate interest of MEMOLUB to be able to defend itself in justice, especially in front of courts and/or arbitral tribunals or in the context of a mediation.
This data is kept for the duration of the relevant procedure.
(v) Managing the security of MEMOLUB’s products and services.
The legal basis of this processing is: the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (art. 6.1.f GDPR). It is the legitimate interest of MEMOLUB to be able to ensure the security of its business operations.
This data is kept for 2years.
(vi) Marketing surveys and inquiries.
The legal basis of this processing is: processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (art. 6.1.f GDPR). It is the legitimate interest of MEMOLUB’s business to better understand its markets and the needs of its users.
This data is kept for 2years.
(vii) Communication such as newsletters
The legal basis of this processing is: consent of the data subject (art. 6.1.a GDPR).
This data is kept as long as the consent of the data subject is not withdrawn; this consent will be refreshed periodically.
(viii) Analytical purposes:
Compiling statistics related to patterns and trends of browsing on MEMOLUB web pages or use of MEMOLUB’s App.
The legal basis of this processing is: processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (art. 6.1.f GDPR). It is MEMOLUB’s legitimate interest to collect personal data necessary for analytical purposes to improve the user’s experience and the MEMOLUB’s app and website.
This data is kept for 2 years.
4. Disclosure and categories of recipients
When needed, MEMOLUB will share your personal data with our partners, such as accountants, lawyers, business consultants and counsels in order to fulfill one of the purposes listed above. We may also share the data with our data processors such as IT-firms working for us.
Please note that MEMOLUB may be obliged by law to disclose personal data as an effect of a request by competent authorities.
5. Transfers
Any transfer of personal data to a third party inside the EU/EEA will only take place if the recipient is compliant with European privacy and personal data protection regulations.
Any transfer of personal data to a third party outside the EU/EEA will be made to a country benefitting from and adequacy decision by the Commission or, if this is not the case, will be made on the basis of the EU model clauses or similar constructions such as binding corporate rules.
6. Your rights
According to the chapter 3 of GDPR, when applicable, you are entitled to :
(i) withdraw your consent from the personal data processing at any time ;
(ii) access to the information processed ;
(iii) rectify the inaccurate personal data without undue delay ;
(iv) erase all your personal data processed without undue delay ;
(v) restrict the processing of personal data ;
(vi) exercise the right to data portability ;
(vii) object to the processing of your personal data;
(viii) not be the object of automated individual decision-making.
When the processing is based on our legitimate interest for direct marketing purposes, you have the right to object at any time to the processing of personal data.
You can exercise your rights by sending your demand to our postal address : Rue Bollinckx 43, 1070 Brussels, Belgium or to our e-mail address : contact@memolub.be.
7. Complaints
You may contact the competent Data Protection Authority, if you consider that the personal data processing by MEMOLUB is not compliant with data protection rules.
The Belgian DPA can be contacted on the following website: https://www.dataprotectionauthority.be/citizen
