Personal Data: Respect of Private Life Policy (app)

Users agree and are cognizant of the fact that Internet is not a fully secure information transfer method and that consequently a total guarantee of the respect of their private life cannot be assured. Repos/Sombreros, however, gives the full attention required in regard to the respect of applicable law as to the respect of private life within the bounds of electronic communication, as detailed in the General Data Protection Regulation (hereafter “GDPR”).

Only the personal data given by Users of their own free will are collected by Repos/Sombreros. Data collected by Repos/Sombreros include family names, first names, and email addresses of users. These are collected according to the use for which the user has given their consent (art. 6.1.a. GDPR) or in the measure necessary to the execution of the agreement between the user and Sombreros (art. 6.1.b. GDPR). In some cases, the data of users may be used by Repos/Sombreros to send newsletters or promotional information on its activities or products, in the measure where this use would be in accordance to its legitimate interests, which consists in keeping its clients informed about new products, its participation in fairs or contests, of prizes won through games, etc. (art. 6.1.f. GDPR). The use can unsubscribe from this mailing list at any point.

Data is stored on servers located in the European Union or in third-party countries which provide an adequate level of protection according to article 45 GDPR or by virtue of a contract granting appropriate guarantees according to article 46 GDPR. Repos/Sombreros takes all useful measures to ensure the security and confidentiality of private data, notably by ensuring the security of their servers.

In accordance with the applicable regulations, users whose data are treated by Repos/Sombreros have the following rights:

  • The right to access allows users to be informed of and to request access to personal data by receiving a copy.
  • The right of rectification allows users to request a change or to update incorrect or incomplete personal data.
  • The right of erasure allows users to request a permanent deletion of personal data, except when the data is required by the execution of a still-valid agreement between the parties.
  • The right of refusal allows users to refuse the collection of personal data, without it causing issue to collection made prior to this refusal. The right of refusal can be applied to certain communication categories and may not be applied when the collection is required by the execution of a still-valid agreement.
  • The right to data portability gives the user the right to ask for a copy of personal data in electronic format (ex: pdf document).

No data is recorded without the User’s knowledge, or destined to be shared with a third party, or used for commercial purposes, or to draw up a statistical profile of the Users.

When Users’ data are communicated upon consent, they are kept by Repos/Sombreros for as long as that consent has not been rescinded. When collecting said data has been made necessary by the execution of the current contract. Finally, when the collection of data is based on the legitimate interest of Repos/Sombreros, the data is kept for as long as that legitimate interest continues, unless you’ve notified your desire to no longer be contacted for this purpose.

For any questions with regards to the protection of private data, or if the User believes that their rights or private data are not respected, those responsible for the treatment of said data can be reached: Repos Production sprl, 22 rue des Comédiens 1000 Brussels, Belgium, (BCE 0863.606.935), and Sombreros Production sprl, 511 rue Saint Léonard in 4000 Liège (BCE0535.709.224): info@rprod.com. Moreover, Users have the option of making a claim at the Data Protection Authority via phone +32 (0)2 274 48 00 or by e-mail contact(at)apd-gba.be (www.autoriteprotectiondonnees.be).