Revision date: November 2022
The public limited liability GRENAT srl (hereinafter “Sara Esther Jewellery”), with registered offices at Rue du Prince Royal 7, 1050 Brussels, Belgium and registered with the Crossroads Bank for Enterprises under the number 0726.995.796, acting as data controller, processes and uses personal data pertaining to its customers or prospective customers, as well as visitors of its website saraesther.be (hereinafter collectively referred to as “Customers”), in compliance with the applicable data protection laws, in particular the European Regulation 2016/679 of 27 April 2016 called the General Data Protection Regulation (hereinafter referred to as “GDPR”).
This privacy notice sets out why and how Sara Esther Jewellery collects personal information about its Customers (hereinafter referred to as “Customer Data”), which Customer Data is collected/processed, where it comes from, who has access to it, to whom it may be transferred, how long it is stored, how Sara Esther Jewellery protects it and what are the rights of the Customers concerned by the processing activities. This privacy notice is without prejudice to specific provisions in other documents, if any.
1. Why does Sara Esther Jewellery process Customer Data?
Sara Esther Jewellery keeps and processes Customer Data, in electronic or non-electronic form, for administrative, marketing and customer management purposes, including for the following non-exhaustive activities: (i) responding to any communication, enquiry or request which a Customer submits to Sara Esther Jewellery (including via the website: tabs "learn more" or "make an appointment"), (ii) processing information relating to the purchase (actual or potential) of Sara Esther Jewellery’s products and/or services (including via the website: addition of products in the "selection" and "contact form" to be filled in), (iii), sending statements and invoices to Customers, (iv) providing Customers with newsletters and marketing communications, (v) conducting surveys and market research, (vi) improving Sara Esther Jewellery’s products and/or services and (vii) dispute resolution.
2. What are the legal grounds for processing Customer Data ?
Customer Data is processed on one or more of the following legal grounds:
- To enter into and managing the performance of a sales related contract with a Customer, including the invoicing procedure
- To comply with Sara Esther Jewellery’s legal obligations or requirements (e. g. Article 67, §2, paragraph 3 of the Law of 18 September 2017 on the prevention of money laundering and terrorist financing and on the restriction of the use of cash)
- Processing is necessary for the legitimate interests of Sara Esther Jewellery and/or a third party, but which, in Sara Esther Jewellery's opinion, also benefit Customers, such as, but not limited to, direct marketing and data analysis
- The consent of the Customer concerned (e.g. to respond to a survey). The Customer concerned may withdraw his/her consent at any time, it being understood that such withdrawal will not affect the lawfulness of the processing carried out before such withdrawal on the basis of such consent
3. What are the categories of Customer Data processed?
Customer Data is all personal information relating to an identified or identifiable natural person. For the abovementioned purposes, the processing of Customer Data may include the following categories:
- personal identification data, such as name and address;
- electronic identification data, such as email address and phone number;
- personal details, such as date of birth or age, language, nationality, gender, marital status and profession;
- photos and audio-visual recordings;
- consumption habits (volume of purchase, purchase history, etc.);
- financial data, such as information about the type of payment;
- connection data, such as IP address;
- participation to events (including family members as the case may be);
- survey data.
4. Where does Customer Data come from?
When a Customer contacts Sara Esther Jewellery, the initial data is likely to come from the individual concerned. Sara Esther Jewellery may also contact a Customer for prospective purposes. During the course of the Customer relationship, the individual concerned will provide Sara Esther Jewellery with further information (e.g. information needed for the purchase order). If the Customer does not provide Sara Esther Jewellery with information that is required by law or contract, the Customer may lose benefits or Sara Esther Jewellery may decide not to enter into the contract or end the sales relationship. For instance, if a Customer contact does not wish to share with Sara Esther Jewellery his/her email address, he/she will not receive any of the Sara Esther Jewellery’s electronic newsletters.
Sara Esther Jewellery may also receive or generate data relating to the Customer from other customers, suppliers or those to whom the Customer communicates by email or other systems.
5. Who has access to the Customer Data?
For the abovementioned purposes, Customer Data may be disclosed to, and possibly even processed by:
- the individuals themselves or relatives or family members;
- Sara Esther Jewellery’s personnel who have a need-to-know about the Customer Data at stake;
- the personnel of affiliates of Sara Esther Jewellery and who have a need-to-know about the Customer Data at stake;
- the public authorities in accordance with the applicable laws and regulations, such as the tax administration;
- Sara Esther Jewellery’s service providers who have a need-to-know about the Customer Data at stake, such as the agents and IT service providers, in particular for the analysis and optimisation of the website; and
- other professional advisors of Sara Esther Jewellery who have a need-to-know about the Customer Data at stake.
6. Is Customer Data transferred abroad?
In general, these data are stored in Belgium but we may transfer some data abroad but always in connection with Sara Esther Jewellery's activities. In the case of a data transfer outside the European Union, Sara Esther Jewellery will have put in place appropriate safeguards in line with the GDPR.
Sara Esther Jewellery never resells Customer Data.
7. How long is Customer Data kept?
Customer Data will be retained no longer than necessary for the purposes described above.
Typically, and subject to what would otherwise be provided for in other documents in this regard regarding specific data, and/or to the exercise by Customers of their rights to object or withdraw consent, Customer Data will be retained for the period necessary to organize the sale, as well as after the expiry or termination of the sale as long as Sara Esther Jewellery may have legal liability for which the use of Customer Data may be relevant (including after-sales service), taking into account the applicable statutory periods of limitation and legal retention obligations. Contact data will be used to keep the Customers concerned informed of Sara Esther Jewellery's activities as long as they do not object.
8. How is Customer Data Protected
Sara Esther Jewellery keeps the Customer Data as safe and secure as reasonably possible, protecting it against loss and unauthorized disclosure or access. Sara Esther Jewellery nevertheless draws the attention of Customers to the fact that no absolute guarantee of security, particularly on the Internet, can be guaranteed.
9. What are the individuals’ rights and who can they contact?
Individuals who have personal information collected and processed as Customer Data have the right, at any time and provided that they provide sufficient proof of their identity, to contact Sara Esther Jewellery to:
- access, rectify or erase their Customer Data;
- restrict or object to the processing of their Customer Data (e. g. for direct marketing purposes);
- receive the data they have provided, in a structured format, commonly used and readable by a machine and transmit them to another controller if they so wish, when these data have been processed on the basis of their consent and/or the performance of the contract;
- receive more information about the safeguards in case of international data transfers; and
- lodge a complaint with the Belgian Data Protection Authority or another EU supervisory authority if the individual thinks Sara Esther Jewellery has not acted in line with any applicable data protection laws.
The contact at Sara Esther Jewellery for any further information about these rights is: Founder & Creative Director, Sara Esther Touijar, +32 474 44 32 52, firstname.lastname@example.org.
Sara Esther Jewellery uses "cookies" to improve the functioning of its website and to collect statistical information.
What are cookies ?
A cookie is a small text file that can be stored on your computer when you visit websites. Information is saved in this text file, such as your choice of language on a website. When you visit the website later again, this cookie returns to the concerned website. In this way, the website recognizes your browser and can for example retain your choice of language.
Cookies usually also have an expiration date. For example, some cookies are automatically deleted when you close your browser (so-called session cookies), while others can be stored longer on your computer, sometimes until you delete them manually (so-called permanent cookies)
How to disable cookies?
It is possible to configure your browser to prevent the use and storage of cookies on your device and/or to have you asked each time you visit the site to enable cookies. You can also delete cookies that have been reactivated at any time. Consult the help section of your browser to find out how to do this. Please note that the global deactivation of cookies may lead to malfunctions on our site.
What cookies do we use?
The table below details the cookies used on the Sara Esther Jewellery website and the cookies used by third parties of which the Sara Esther Jewellery website is aware.
Name of the cookie
|Domain with the cookie||
Purpose of the cookie
Sara Esther Jewellery
This cookie is used to record the online consent of the user.
Logs a unique identifier that is used to generate statistical data on how the visitor uses the site.
11. Data relating to children
The Website is intended for people over 13 years of age. Sara Esther Jewellery does not knowingly collect personally identifiable information from children under the age of 13. If a parent or guardian knows that their child has provided Sara Esther Jewellery with personal information, contact Sara Esther Touijar at email@example.com.
If Sara Esther Jewellery becomes aware that it has collected personal information from a child under 13 years of age without verifying parental consent, Sara Esther Jewellery will take steps to remove this information from its servers.
Sara Esther Jewellery may amend this privacy notice from time to time as needed, notably to comply with changes in any applicable laws, regulations or requirements introduced by data protection authorities.
Sara Esther Jewellery will inform its Customers of any changes by posting the new notice on its website. It also recommends that its Customers regularly consult this notice.
Changes to the notice are effective as soon as they are published on the website.