Privacy Policy
Last modified: 22 May 2018

At Constructr, we respect and protect your privacy.
We want to earn the confidence you place in us when visiting our website and app and while using our services. We want you to feel perfectly at ease when browsing through our digital environment.
This is why we want to inform you in a transparent way of the precautions we take to process the personal data you provide us with or data that is collected when you use our website or app.

This Privacy Policy intends to comply with the following legislations in force:

- the General Data Protection Regulation (GDPR) 2016/679 of 27 April 2016, entered into force on 24 May 2016. The latter came into effect as of 25 May 2018 and aims to protect the fundamental rights and freedoms of natural persons and in particular, their right to the protection of personal data;
- Any other legislation applicable to S.A G-CONSTRUCT, hereafter ‘Constructr’, in terms of the protection of personal data.
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1. How do we use your personal data?


Constructr will not collect your data without having a legal basis to do so.

- either you have given us your consent. It may be that your consent was implied by your behavior or your actions (e.g. when you fill in a form and click on a button). By doing this, you agree that the data entered can be used to ensure our services are properly carried out.

- or the processing of your data is based on another legal basis, therefore the data is needed for the following:

· to fulfill a contract
· to comply with an obligation to which our company (S.A G-CONSTRUCT) is subject by virtue of a law, decree or an order.
· In cases where your data is needed to fulfill Constructr’s legitimate interest. If this proves to be the case, Constructr undertakes to verify that your interest or your fundamental rights do not take precedence over its own legitimate interest.

2. For what purposes do we store your personal data?


We require your personal data for the following purposes:

o To enable you to follow the information distributed on our website and app about construction, development, decoration, renovation or any other product or service relating to construction or renovation that interests you;
o To enable you, as a potential client/buyer (hereafter ‘customer’) to get in contact with potential service providers/professionals (hereafter ‘professionals’) of your choice via our website or app;
o To guide you, if you ask us to, by contacting you as part of your research;
o To keep you informed about Constructr services, surveys, competitions and events by means of electronic communications, if you ask us to;
o With your consent, to call you by phone to keep you informed about products and services, surveys, competitions and events that might be of interest to you;
o If you allow them, to enable our partners to keep you informed about their products, services and events that might be of interest to you. Communications from our partners will be sent to you by Constructr because we make a point of not sharing or selling any of your data to third parties without your specific agreement.
o To carry out market research and make it available to other website or app users;
o If you allow us, to remember your preferences in order to display the website and its content in the most efficient way for you and your computer;
o To prevent fraud and malicious behavior;
o To produce statistics based on the number of visits to the different sections of our website and app and improve them;
o To keep you informed of important changes to our website and app or to one of the Constructr services;
o More generally, to ensure the technical administration of our website and app.
By providing your personal data, you authorize Constructr to proceed with the processing as described above.
For most of these services, you are free to provide all or part of your personal data. However, certain features and characteristics on our website and app can only be used if you share certain personal data with us. The data is therefore reported as mandatory.

In the following chapter and by means of the service provided by Constructr or by partners of Constructr, you will find the data we process, the purpose of the processing, the length of time that we keep your data and the legal basis for processing your data.

2.1 DATA PROCESSING IN ORDER TO PROVIDE CONSTRUCTR SERVICES


2.1.1. Creation of your Constructr ‘user’ account

So Constructr can provide you with the services you have requested, you are invited to create an account. Here is the information that will be collected at this time:

- Data collected:

o Identification data: your e-mail;
o Your password (the latter is encrypted and we do not have access to it. If you lose it, you must reset it);
o Optionally: via the ‘My Profile’ section: your photo, telephone number, zip code;
o Optionally: your subscription to one or several of our electronic communications, your subscription to our telephone calls about the products and services offered by Constructr.

- Purposes: the data is needed

o To enable you to authenticate yourself (login and password) for secure access;
o To be able to follow, via the ‘follow’ button, the professionals you are interested in;
o According to your preferences, to receive our informational and/or sales electronic communications (by email, SMS, social media) and/or sales telephone calls;
o To save your criteria (if you want to) in your ‘Constructr’ profile;

- Legal basis:

o This data is needed to carry out the services requested and therefore fulfill the contract between you and Constructr.
o We ask for your consent to send electronic communications or to call you by telephone.

- Retention period:

o Your account data is stored for as long as you do not delete your account;
o Your consent to the sending of electronic communications is kept for as long as you do not unsubscribe to these communications. We keep proof of receipt of your consent in our database, with the time we obtained it and its source. We also keep any evidence of unsubscription.

- Data access and correction:

o This data is accessible from your account (‘My Profile’). You can correct this data at any time by editing your profile.

2.1.2. Creation of your Constructr ‘professional’ account

Once your ‘Pro’ account is created, the following data will be collected:

- Data collected:

Your identification data: your first name and surname, your email address, name of your company, your telephone number, your profession, your company’s VAT number, how you identify yourself as a professional (reseller, producer, builder, architect, small professional, sales outlet);

o Your password (the latter is encrypted and we do not have access to it. If you lose it, you must reset it)
o Optional: the URL of the website, your expertise, your logo, the URL of the Facebook account associated with your business, the URL of the LinkedIn account associated with your business, your slogan, the address of your company’s head office, photos, videos, 360° visits and descriptions of your achievement(s) and project(s), one or more articles for publication.

- Purposes: the data is needed:

o To provide you with the service, according to the ‘package’ chosen: creation of a ‘professional’ page and publication of achievement(s) and project(s), display of your details, receipt of leads, creation of a dedicated domain name, links to the social media accounts, personalized telephone support, access to the list of resellers, publication of achievements and projects in the ‘inspiration’ section, publication of articles (see description of ‘Pro’ packages on the Constructr.be website);
o To enable you to monitor your actions and retain your history;
o To enable us to carry out analyzes for marketing purposes (market development) and sales strategies: what types of achievements and projects are published and their characteristics.

- Legal basis:

o This data is needed to carry out the services requested and therefore fulfill the contract between you and Constructr;
o We require this data to offer you the most appropriate service possible.

- Retention period:

o This data is stored for as long as you keep your account.

- Data access and correction:

o This data is accessible from your account. You can correct this data at any time by editing your ‘Professional’ profile.

2.1.3. Contact with professionals

Independently of the creation of a customer account, you can contact a professional via the contact form through which the following data will be collected:

- Data collected:

o Identification data: your name, surname, e-mail address;
o Your password (the latter is encrypted and we do not have access to it. If you lose it, you must reset it);
o Optionally: your telephone number, zip code, the receiving sales outlet, your message for the professional.

- Purposes: the data is processed:

o To enable you to get in contact with one or several professionals present on our website and app;

- Legal basis:

o This data processing is needed to provide the requested service.

- Retention period:

o This data is stored for one month to enable the professional to contact you.

- Data access and correction:

o On request.

2.2. DATA PROCESSING FOR SURVEYS, POLLS, COMPETITIONS AND EVENTS


2.2.1. Participation in surveys and polls


You can participate freely in both surveys and polls and the following data will be collected at that time:

- Data collected and processed:

o Your age, title, region, language, possibly other socio-demographic data to be able to create a segment in a representative way, your interests and preferences in the areas of construction, development, decoration, renovation or any other product or service relating to construction or renovation;
o Your answers;
o Your identification data, only if you have shared this with us. This is needed to contact you to confirm you have won a prize as offered in the description of a survey or poll.

- Purposes:

The data is needed:

o To produce statistics and organize the answers to the polls and surveys.
o Your email address is used to send you a link to the poll or survey and to manage the answers. The system then anonymizes the answers and no longer links them to the respondents’ email addresses. We only receive statistics, which is the purpose of the exercise.
o To be able to contact you, if necessary, to confirm you have won a prize as offered in the description of a survey or poll.

- Legal basis:

o You participate freely in the polls. By participating, you consent to the use of your data for the purposes listed above.
- Retention period:

o The data is anonymized and aggregated. We only keep the results of the polls.

- Data access and correction:

o We use tools for the polls which anonymize and aggregate all data. This does not allow us to identify your answers among those of other respondents. Therefore, we do not have the opportunity to give you access to your answers or to correct them once they have been sent.

2.2.2. Participation in competitions

You can participate freely in our competitions. If this should be the case, the following data will be collected:

- Data collected and processed:

o Identification data;
o Contact data;
o Other data depending on the competition (answers to questions, photos, etc.);
o Opt in (optional) corresponding to your subscription to one or more of our electronic and/or telephone communications.

- Purposes:

The data is needed to:
o Manage the competition and contact the winners.
o Send electronic and/or telephone communications if you have requested this (additional consent needed).

- Legal basis: your consent

o You participate freely in the competitions. By participating, you consent to the use of your data for the purposes listed above.

- Retention period:

o The data is kept for the duration of the competition and to manage any subsequent complaint (6 months from the end of the competition).
o Your consent to the sending of electronic communications is kept for as long as you do not unsubscribe to these communications.

2.2.3. Participation in events

You can participate freely in events organized by or with Constructr. The following data will be collected at that time:

- Data collected and processed:

o Identification data;
o Contact data;
o Other data depending on the event (number of people, etc.);
o Opt in (optional): your subscription to one or more of our electronic communications;
o During the event, photos and films may be taken for publication on the Constructr website or on its Facebook page. If you do not want your image to be published, please contact the photographer and/or the cameraman to ask them to erase the photo you are featured in.

- Purposes:

The data is needed to:

o Manage the event and its security.
o Send electronic communications if you have requested this (additional consent needed).

- Legal basis: your consent

o You participate freely in the events. By sending us your request to participate, you consent to the use of your data for the purposes listed above.

- Retention period:

o The data is kept for the duration of organizing the event.
o Your interest in the event is kept in order to send you communications about similar events (only sent if you have agreed to receive our electronic communications).
o Your consent to the sending of electronic communications is kept for as long as you do not unsubscribe to these communications.

· Data access and correction:

o You can access your data or ask us to erase it on request (see point 7).

3. DIRECT MARKETING


3.1. Direct marketing and communication to third parties


We consider your personal data as confidential information that we do not share with third parties and which is not used for direct marketing purposes, except if you have given us your prior consent (“opt-in”) by checking the various boxes available in your ‘Constructr’ account, on our website or in our electronic communications.

- Data collected and processed:

o Email address;
o Consent and time of consent (for Constructr offers, offers from Constructr and partners or telephone communication);
o Withdrawal of consent and the time of withdrawal;
o Preferences related to your account which have been derived from the professionals followed (“My Favorites”) (which enables offers that are of interest to be sent to you)
o Preferences derived from your use of the website (which enables offers that are of interest to be sent to you)

- Purposes: If you give us your consent, here are the purposes for which we use your data:

o To inform you about our new products and services, to invite you to our events, to offer surveys, competitions and actions and to provide you with information about the preferences you have selected in your account (if you have checked the box “I agree to receive electronic communications from Constructr about its products and services, events and surveys”);
o To inform you about offers from our partners active in the areas of construction, development, decoration, renovation or any other product or service relating to construction or renovation (if you have checked the box “I wish to receive electronic communications from partners* selected by Constructr relating to their products and services as well as their events”);
o To call you by telephone to keep you informed of products and services that might be of interest to you (if you have checked the box “I agree to be contacted by telephone about the products and services offered by Constructr");

- Legal basis:

o Your consent.

- Retention period:

o Once you have given us your consent, you are free to withdraw this consent at any time. All of our communications contain a link to unsubscribe. You can also uncheck the necessary boxes in your Constructr profile. If you experience a problem via these channels, you can send your request to the following address: privacy@constructr.be.
Constructr may share your data with a limited number of third party partners. This will only be done if the data needs to be shared for one of the following reasons:
o To manage its database;
o To help us carry out marketing actions, competitions, polls or events (sub-contractors);
o At the request of the authorities or police forces as part of actions under the law;
o To prevent physical or financial harm as part of an investigation into suspected or proven fraud or illegal activities.

· Data access and correction:

o You can access your data or ask us to erase it on request (see point 7).

4. DATA PROCESSING SPECIFIC TO THE WEBSITE


4.1. Website management and security

We collect certain data to ensure our website and app are well-managed, to prevent fraud and malicious behavior and to produce statistics on the use of these. This information also enables us to keep you personally informed of any changes to our website and app in order to improve their quality and/or security.

- Data collected and processed:

o Your IP address when accessing the website;
o Your Constructr ID when you log in to your “Constructr” account;
o The way you browse the website (pages visited, time, links followed);
o The type of device and browser used to access our services;
o The emails that you send from the website or our app.

- Purposes:

o Website security management;
o To prevent fraud and malicious behavior;
o Produce statistics based on the number of visits to the various sections on our website and app and to improve them;
o To keep you informed of important changes to our website and app or to one of the Constructr services;
o Ensure the technical administration of our website and app.

- Legal basis:

o Security (legal obligation under the GDPR regulation);
o Legitimate interest in Constructr (management, statistics).

- Retention period:

o This data is stored for 12 months.

4.2. Sharing your data abroad:


Some of your data may be shared on servers that are located outside of your country of residence or with third parties who may (do) process this data abroad in our name and following our instructions, to ensure you are provided with the service requested. By sharing your data with Constructr, and more particularly by using our website or app, you consent to us sharing this data abroad, often as part of the contract we have with you. We act in accordance with the terms and conditions of this Privacy Policy, the Privacy Act and the General Regulation for the Protection of Personal Data (Regulation (EU) 2016/679).

4.3. Tracking, monitoring and segmentation


In order to improve the relevance of the services we offer you, we cross some of your data to avoid sending communications that are of no interest to you.

- Data collected and processed:

o Your IP when accessing the website;
o Your Constructr ID when you log in to your “Constructr” account;
o The way you browse the website (pages visited, time, links followed);
o The type of device and browser used to access our services;
o The emails that you send from the website or our app.

- Purposes:

o This data is used to improve the relevance of the electronic communications to which you have subscribed. It may also be used for statistical purposes once anonymized.

- Legal basis:

o Improvement of our services and the relevance of our communications.

- Retention period:

o Non-anonymized data is stored for as long as the consent (opt-in) to one or more of Constructr’s electronic communications is active.

4.4. Data which is shared with us automatically: “Cookies”

Other data about you is shared with us automatically via cookies or other technology which is likely to collect or store personal data.
Cookies are small computer files sent by our servers and stored on your computer’s hard disk drive. They are used to record personal and non-personal data about the way you browse our website. Cookies may be permanent (and stay after you log out of our website and app, in order to be used during your subsequent visits) or temporary (and disappear as soon as you log out of our website or app).
The first time you browse the Constructr.be website and app, you are informed that Constructr cookies and ‘third party’ cookies exist. By accepting this information, you automatically agree to the use of such cookies by Constructr and its third party partners. During your next visits, these are enabled by default and the data can be read or stored locally on your computer.

4.4.1 Constructr cookies:

These cookies contain information which can only be accessed by Constructr and its employees and only when you visit our website and app. These cookies enable you to browse our digital environment in a more enjoyable way. For example, you avoid having to indicate in which language you want to browse each time.

Some cookies also enable traffic and data on our website and app to be analyzed in order to evaluate the number of service users and to ensure we are able to respond to your requests, but also to help Constructr understand the way in which users interact with our services in order to improve them.
Therefore, we record the following via cookies:

  • Your choice of language;
  • Your access code;
  • Your password (but we do not save it ‘in plain text’);
  • Your preferences.
What are ‘mandatory’ cookies?

For security reasons (particularly to prevent fraud and malicious behavior), we also automatically record your TCP/IP address, the brand and version of your browser and the last webpage visited. You cannot refuse this installation.

4.4.2 ‘Third party’ cookies:

Our company may also use the services of third party service providers (e.g. Google Analytics, Facebook, LinkedIn, etc.) to carry out the following actions on our behalf and for our account:

- analyze your browsing habits and evaluate our website and app’s audience or to offer you adapted products/services;
- analyze your areas of interest and offer deals to meet your expectations;
- enable you to share content from the Constructr website and app with other people on social networks (e.g. ‘Like’ button on Facebook).
In this case, pixel tags and cookies provided by these third party service providers may be used and stored. When information generated by these cookies is shared, the cookie settings ensure that your IP address is anonymized before geolocation and being stored. Our service providers will use this information for the purposes explained above. They will not associate your IP address with any of their data.
You can refuse the installation of these cookies by modifying the options of your browser software on the website.
The cookies collected in a known-manner on the Constructr website and app are described in detail by clicking on our Cookie Policy. This list is monitored and updated regularly. However, it is possible that despite our vigilance, cookies installed by trusted third parties are beyond our control.

If this proves to be the case, please let us know at the following address: privacy@constructr.be

4.5 ADMINISTRATIVE PROCESSING

Some data must be stored to meet our legal, financial and administrative obligations. This mainly involves evidence of contracts and financial and accounting data. This data is stored for the duration imposed by law.

5. How do we protect the confidentiality of your personal data?


We have implemented confidentiality and security policies for all our partners.
Your personal data is hosted on servers which prevent, wherever possible:

· unauthorized access or modifications to your data
· inappropriate use or disclosure of your data
· illegal disposal or accidental loss of your data

Lastly, our employees who have access to your data, are contractually subject to a strict confidentiality obligation.

6. Who is responsible for processing your personal data?


S.A G-CONSTRUCT (previously referred to as ‘Constructr’), whose headquarters is located in Belgium at 1190 Bruxelles Avenue Général Dumonceau 56, is responsible for the processing of personal data collected on our website and app.
For any questions relating to your personal data, you can contact us by sending an email to the following address: privacy@Constructr.be.

7. When and how can you access your personal data?


You have the opportunity to access your personal data and correct it at any time. For the Constructr.be website and our mobile app, this can be done via the “My Profile” section if you are a customer and “Pro” if you are a professional, using your access code and password.

You can also ask us, free of charge, to send you your personal data or to stop all or part of the processing of this data. Lastly, and free of charge as always, you can ask for your personal data to be erased from our database, except in the case where Constructr is obliged to keep it as part of a legal obligation.
For all requests listed above, you simply need to send your request, accompanied by proof of your identity (e.g. a copy of your identity card) to our Data Protection Officer:

- either by email, to this address: privacy@Constructr.be ;
- or by postal mail to the following address:
To the attention of Constructr’s Customer Service CONSTRUCTR S.A. Avenue Général Dumonceau 56, 1190 Bruxelles, Belgique
We will then do what is necessary to satisfy your request as soon as possible.

If you are not satisfied with our response, please note that you also have the right to file a complaint with the Data Protection Authority.

8. Note concerning minors


If you are a minor (under 18 years of age), you are not authorized to use our website or app and we kindly ask you not to contact us with your personal data.

9. Additional information


Please note that we assume no responsibility for the privacy policies of websites to which our website is linked.

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