We, ACE srl, a company incorporated under Belgian law, with registered address at Rue de Renory 499, 4031 Liège, Belgium and registered in the Belgian Crossroads Bank of Enterprises under the number 0413.199.511, may process personal data that relates to you and qualify as a data controller. The protection of your personal data is very important to us. We would therefore like to inform you of what personal data we collect during your visit to our website, the purpose and means of the processing of personal data collected, and your rights. This Privacy Statement also contains a specific section regarding the use of cookies (see section 12).

1. What personal data we collect

We will collect the following personal data about you insofar as this information is relevant for the purposes for which we need it, as explained further in this Privacy Statement. Anytime certain information is mandatory and other information is optional, this shall be clearly indicated as such, so that you can choose whether or not to provide us such information.

2. How we collect personal data

We collect your personal data:

• directly from you when you complete a contact form on our website and provide us with your personal data in the context of our commercial activities (for example relating to inquiries or complaints), or in the context of contractual negotiations or the conclusion of an agreement; and
• via the use of cookies and similar technologies (for more information see our Section 12 on cookies below).

3. Purposes of personal data processing and legal grounds on the basis of which we process personal data

We use the collected data for the following purposes (depending on the nature of your visit to our website):

• to provide you with information requested by you;
• for handling inquiries and complaints;
• for supplier and customer management;
• for production planning or follow-up of orders/deliveries;
• to comply with legal obligations (e.g. with respect to legal or commercial product warranties or product recalls);
• for contact purposes in the context of our aftersales services;
• for the management and proper technical functioning of our website;
• for statistical purposes and to gain insight into the way visitors navigate through our website; and
• for the management of (invoice) disputes and claims.

For your perfect information, you can find hereinafter the legal grounds applicable to these processing activities

• for the processing of your personal data for for handling customer inquiries and complaints, supplier and customer management, production planning and follow-up of orders/deliveries, aftersales services, or in the context of managing (invoice) disputes and claims, we rely upon the necessity for the performance of a contract;
• for the processing of your personal data in the context of complying with legal obligations (e.g. with respect to legal or commercial product warranties or product recalls), we rely upon the necessity for compliance with our legal obligations as a producer;
• in all other cases, the processing of your personal data is based on our legitimate business / commercial interests (i.e. our interest of obtaining information about our customers in order to establish marketing strategies, our interest in knowing how or website is perceived and used by visitors, and our interest in communicating with and providing requested information to (prospective) customers).

4. With whom we share your personal data

We will only pass on your data to the following third parties if this is legally permissible or if you have explicitly consented to this in advance.

• With our service providers (‘processors’): In the context of our activities as described above, we may share your personal data with third parties, in particular with service providers (IT/cloud service providers, PR/marketing agencies who organise mailing campaigns for us, sales service providers or creative agencies) that act as our ‘data processors’.
• With our external law firms and advisors: Further, we may share your personal data with law firms and other advisors in case of (threatened) litigation.
• With government authorities: Finally, we may share your personal data with the government, police authorities or the judiciary in case we have a legal obligation to do.

When passing on data to third parties, we take adequate technical and organisational measures to ensure that data protection regulations are observed.

5. Duration of personal data storage

We delete or block your personal data as soon as the purpose of the data processing ceases to apply, unless we are obliged by European or national law to store this data. Afterwards it is still possible that they can be found in our back-ups or archives, but they will no longer be actively processed in a file.

More specifically, the following retention guidelines are applied by us:

• personal data included in accounting, financial or other official documents will be retained for as long as such documents legally need to be kept;
• personal data required for the execution and follow-up of a contractual relationship will be kept for the entire duration of that relationship and for 10 years following termination thereof;
• personal data obtained in the context of complaint handling will be deleted (or anonymised) as soon as the complaint is closed, and

More information on our retention periods is available upon simple request.

6. How we protect your personal data

We will implement the necessary administrative, technical and organisational measures for ensuring a level of security appropriate to the specific risks that we have identified.

We protect your personal data against destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed.

Further, we seek to ensure that we keep your personal data accurate and up to date. In view thereof, we kindly request you to inform us of any changes to your personal data (such as a change in your contact details).

More information on our protection measures is available upon simple request.

7. Withdrawal of consent and right of objection

You can withdraw your consent to the collection, processing and use of your personal data for electronic direct marketing purposes at any time. You also have the right to object at any time to the processing of your personal data for reasons arising from your particular situation. In the latter case, your personal data will no longer be processed in the future unless there are compelling grounds for processing worthy of protection which outweigh your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims.

8. Other rights of data subjects and possibility to file a complaint

As a person affected by the storage or processing of personal data, you have the right to obtain as to whether or not personal data concerning you is being processed by us and the right to access to your personal data stored by us. You also have the right to request restriction of processing your personal data, obtain the rectification of incorrect data, supplement incomplete data or, if necessary, delete information about you, unless we are legally obliged to store your personal data. You also have the right to receive your personal data in a structured, commonly used and machine readable format and to (have) transmit(ted) your personal data to another organisation.

In principle you may exercise these rights free of charge. Only where requests are manifestly unfounded or excessive, we may charge a reasonable fee. We aim to respond as quickly as possible to your requests or questions. We might request a proof of identity in advance in order to double-check your request if we have reasonable doubts about your identity. Further information and advice about your rights can also be obtained from the data protection authority in your country (for Belgium: www.dataprotectionauthority.be).

If you feel that your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority, which can be found here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

9. Changes

From time to time, we may need to change this Privacy Statement. The most recent version of this Privacy Statement is at all times available on our website. We will inform you of significant changes through a pop-up when visiting our website and/or by sending you an e-mail.

10. Contact information

You are welcome to address your questions or concerns to our privacy contact.:
ACE srl
Christoph Lentz | privacy@ace-films.be | +32 472 45 00 90

11. COOKIES

We use Cookies. Cookies are small text files that are stored on your computer and enable an analysis of the use of the website. Cookies also increase the user-friendliness and security of websites.

For the use of non-functional cookies, we rely on your consent. You may accept or refuse the use of non-functional cookies by selecting the appropriate settings in our cookie banner. For the use of functional cookies, we rely on our legitimate (commercial) interest to offer and promote our products and to promote our business in general. Some of these cookies may process personal data, to which our Privacy Statement applies.

We use the following cookies:

Please note that you can at any time withdraw your cookie consent and delete these cookies by following the steps provided in the links below:

• Firefox
• Firefox (mobile)
• Chrome
• Chrome (mobile)
• Safari
• Safari (mobile)
• Internet Explorer
• Microsoft Edge

For more information regarding your rights, see sections 7 and 8 above.

More information on Google Analytics

As a web analysis tool we use Google Analytics, a service of Google Inc. “(“Google”). Google Analytics uses “cookies”, which enable an analysis of the use of the website.

The information generated by the cookies is usually transferred to a Google server in the USA and stored there. However, if IP anonymisation is activated when you visit our website, Google will reduce your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the website. On the basis of this evaluation, reports on website activities are compiled and further services connected with the use of the websites and the Internet are provided to us. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.

In addition, you can prevent Google from collecting the data generated by the cookie and relating to your use of the website – including your IP address – and from processing this data by Google by downloading and installing the browser plug-in available under the following link http://tools.google.com/dlpage/gaoptout?hl=de

For more information on how Google uses your data, please follow this link: https://support.google.com/analytics/answer/6004245?hl=de