Privacy Statement
The Importance of Data Protection
De Vlaamse Instelling voor Technologisch Onderzoek (VITO) and Recupel highly value the proper protection of the data they process, particularly personal data. In this privacy statement, VITO and Recupel wish to explain how personal data is processed and protected and what rights you have as a data subject. In the context of establishing a data register with repair companies, VITO and Recupel act as data controllers.
Scope of this Privacy Statement
This privacy statement applies only to the entire lifecycle of information stored in the register, from obtaining information to the final deletion of information within the organization.
For certain domains or processes, additional guidelines or procedures may be developed that detail the measures taken to achieve the desired level of data protection. This privacy statement aims to inform you as fully as possible and to explain how and why VITO and Recupel, as data controllers, collect, use, and retain your personal data, as well as to inform you about your rights and how you can exercise them.
Data Controller
As data controllers, VITO and Recupel process your personal data as specified in this privacy statement. This means that VITO and Recupel determine the purposes and processing methods of these personal data and serve as the point of contact not only for you but also for the supervisory authority for any questions about the use and processing of your personal data.
As a unique point of contact within VITO for all your questions and comments regarding the protection and processing of personal data by VITO, we have appointed a Data Protection Officer (DPO). You can reach the DPO at the following address and email:
VITO
Data Protection Officer
Boeretang 200
2400 Mol
Assist-dpo@vito.be
Recupel is not required to appoint a Data Protection Officer (DPO) under applicable data protection laws. However, to fulfill its data protection obligations, Recupel has a central point of contact for all privacy-related questions and requests: privacy@recupel.be.
Nature, Purpose, Legal Basis, and Retention Period
VITO and Recupel collect general personal data in the context of the register, specifically from:
The Information Provider:
- Contact details (email)
- Session timestamp (start and close)
Companies with Repair Services:
- Location (address, geographical coordinates) of the repair company and any branches
- Contact details (phone number, email, website link, social media link – Facebook) of the repair company and any branches
The legal basis for collecting and processing these personal data is the consent of the data subject. The data subject provides consent via the form, and these data are recorded.
The purpose is to facilitate matchmaking between consumers and repairers. We create an accessible and up-to-date register that includes all repairers of electrical and electronic appliances in Belgium. The repairers are then displayed on a publicly available digital map on the Recupel website. Recupel thus aligns with its new strategy and serves as a forerunner for new "Right2Repair" regulations.
We only use the personal data that are relevant and necessary for the intended purpose of processing.
Your personal data are retained as long as necessary to achieve the purposes, comply with contractual and legal requirements, and establish, exercise, or defend our legal rights. Based on these requirements, a retention period is determined per category.
Data Transfers
To protect your privacy, VITO and Recupel staff and employees have access to your personal data only if and to the extent necessary to perform their duties.
In the context of the register, your data is shared only with our subcontractor/processor, Inoopa. They are engaged for supporting the development and updating of the repair register. This party processes personal data solely on behalf of VITO and Recupel and according to our instructions.
Recupel does not pass on your data to third parties for commercial use. VITO may possibly pass on your personal data to a third party, the new owner of the tool, in case the tool is transferred/sold to this party. In case the tool gets a new owner, the data subjects will be informed by VITO that the personal data is being passed on to this party.
VITO and Recupel do not transfer the data obtained within the register of repair companies to countries outside the European Economic Area (EEA).
Information Security
VITO and Recupel are committed to ensuring the confidentiality and security of personal data. We have taken various technical and organizational measures to protect personal data against loss, unauthorized alteration, unauthorized access, and unauthorized processing. More specifically, Recupel and VITO implement a comprehensive information security policy, which is regularly evaluated and communicated. The responsibilities for information security are clearly defined, and there are procedures for contact with authorities and external parties. Employees and contractors are made aware of security risks and must adhere to strict contractual agreements. Access control, physical security, and operational security measures, such as network segmentation and malware protection, are implemented. Additionally, suppliers and IT systems are strictly monitored, and there is a formal incident management process in accordance with GDPR guidelines.
Your Rights
Right to Information
As a data subject, you have the right to information. Through this privacy statement, we aim to provide you with information about what data we process, what we do with this data, on what legal basis we process it, and with whom we share it.
Right of Access
You have the right to request access to the data that VITO or Recupel holds and processes about you. You may request a copy. Access to certain data via VITO will only be possible on-site, and an appointment will be scheduled in consultation with VITO's DPO.
Right to Rectification
You have the right to have your data corrected if they contain errors.
Right to Erasure
You can request the deletion of your personal data by VITO and Recupel if there is no longer a valid reason to process them.
This right is not absolute and may only be enforced when:
- The personal data are no longer necessary for the intended purpose;
- The personal data were obtained without explicit consent and are thus unlawfully processed;
- There is a legal obligation to delete them;
- The given consent for processing is withdrawn;
- Personal data provided while you were a minor may be deleted at any time.
Right to Restriction
The right to restriction means that your personal data, except for its storage, may only be processed with your consent for the establishment, exercise, or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of public interest.
In general, you can exercise your right to restrict the processing of personal data in cases where it is unclear if and when your personal data should be deleted. You can then request that your data not be processed until all necessary adjustments are made, but also that your data be retained and not used further.
Right to Object
If we process your personal data based on a legitimate interest or a public interest task, you can object to the processing, and we will assess whether our legitimate grounds override your rights and freedoms. During this assessment, processing is suspended.
For objections to direct marketing, we will automatically stop processing your personal data for this purpose.
Right to Data Portability
You may request to have your data transferred from VITO and/or Recupel to another organization.
Right Not to Be Subject to Automated Decision-Making
You may request that VITO and/or Recupel stop using your data unless there are compelling reasons to do so.
How to Exercise Your Rights
To exercise your rights, you can send your request by letter or email to the addresses below:
For VITO:
VITO
Data Protection Officer
Boeretang 200
2400 Mol
Assist-dpo@vito.be
For Recupel:
Recupel VZW
privacy@recupel.be
Depending on the subject of the request and to prevent us from sharing personal data with the wrong people through fraudulent requests, we may need to verify your identity. To this end, we may ask you to send us a copy of your passport or identity card with proof of your full name, date, and place of birth; the other parts can be made unreadable. The copy must be detailed enough to identify you. After handling your request, we will delete this copy unless otherwise required by law.
For on-site access, you will also need to identify yourself.
VITO and Recupel have one month to respond to a request to exercise your rights. If necessary, this period can be extended by a maximum of two months.
If you believe that the processing of your personal data violates privacy legislation, you also have the right to file a complaint with the "Vlaamse Toezichtscommissie" or the "Gegevensbeschermingsautoriteit":
The complaint procedure with the "Vlaamse Toezichtscommissie" can be found at the following link: https://overheid.vlaanderen.be/klachtenprocedure-vtc. A part of the procedure involves filling in a complaint form, which can be found at the aforementioned link.
The complaint procedure with the "Gegevensbeschermingsautoriteit" can be found at the following link: https://www.gegevensbeschermingsautoriteit.be/burger/acties/klacht-indienen. A part of the procedure involves filling in a complaint form, which can be found at the aforementioned link.
Changes to This Privacy Statement
This privacy statement may be modified or updated to reflect changes in our personal data processing practices or applicable laws. The updated version will be published on this website. We invite you to regularly consult the online version of this privacy statement.