Privacy Policy
1. Parties and Purpose
Pomone Collection SRL, under the trade name Pomone Collection (hereinafter "Pomone Collection" or the "Data Controller")
Avenue de la Sapinière, 50A, B-1180 Brussels
BCE / VAT: BE 1010 520 363
Email: pomonecollection@gmail.com
Phone: +32 (0) 495 29 54 04
Pomone Collection issues this Privacy Policy with the aim of transparently informing users of the website hosted at the following address: www.pomonecollection.be (hereinafter the "Site"), of how personal data is collected and processed by Pomone Collection.
The term "User" refers to any user, whether a natural or legal person, who visits or interacts in any way with the Site.
As such, Pomone Collection determines all technical, legal, and organizational means and purposes of the processing of users' personal data. Pomone Collection SRL undertakes to take all necessary measures to ensure that the processing of personal data complies with the Law of July 30, 2018, on the protection of natural persons with regard to the processing of personal data (hereinafter the "Law") and the European Regulation of April 26, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "Regulation").
Pomone Collection is free to choose any natural or legal person who processes users' personal data at its request and on its behalf (hereinafter the "Processor"). Where applicable, Pomone Collection undertakes to select a Processor offering sufficient guarantees regarding the technical and organizational security measures for the processing of personal data, in accordance with the Law and the Regulation.
2. Processing of Personal Data
Use of the Site by Users may result in the communication of personal data. The processing of such data by Pomone Collection, in its capacity as Data Controller, or by service providers acting on behalf and for the account of Pomone Collection, shall comply with the Law and the Regulation.
Personal data will be processed by Pomone Collection in accordance with the purposes listed below:
• Create a customer database
• Ensure the follow-up of the services offered.
3. Purpose of Processing Personal Data
In accordance with Article 13 of the Regulation, the purposes of processing personal data are communicated to the User as follows:
• Ensure the monitoring of the execution of the services offered.
In accordance with Article 6 of the General Data Protection Regulation (GDPR), Pomone Collection processes personal data based on the following legal grounds:
• Contract performance: for order management, delivery, and invoicing
• Consent: for sending commercial communications and newsletters, with the option to withdraw at any time
• Legal obligation: to comply with tax and accounting requirements
• Legitimate interest: to ensure site security, prevent fraud, and improve services.
4. Personal Data That May Be Processed
The User consents, during visits and use of the Site, that Pomone Collection collects and processes, according to the methods and principles described in this Privacy Policy, the following personal data:
• Last name
• First name
• Email address
• Phone number
• Postal address
5. Consent
By accessing and using the Site, the User declares that they have read and freely, specifically, informedly, and unequivocally agree to the processing of their personal data concerning them. This consent covers the content of this Privacy Policy.
Consent is given by the positive act by which the User checks the box presenting the Privacy Policy via hyperlink. This consent is a prerequisite for performing certain operations on the Site or for allowing the User to establish a contractual relationship with Pomone Collection.
Any contract between Pomone Collection and a User relating to the services and goods offered on the Site is subject to the User's acceptance of the Privacy Policy.
The User consents to the Data Controller collecting and processing their personal data submitted on the Site or in relation to services provided by Pomone Collection for the purposes stated above.
The User has the right to withdraw their consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on prior consent.
6. Retention Period of User Personal Data
In accordance with Article 13 of the GDPR and applicable legislation, Pomone Collection SRL retains User personal data only for the period strictly necessary to achieve the purposes for which they were collected.
Applicable retention periods are as follows:
• Data related to order management and customer relations: 10 years from the last order, due to accounting and tax obligations
• Data used for commercial prospecting: until consent is withdrawn or 3 years max from last active contact
• Data collected via cookies and other trackers: between 6 and 13 months, depending on the type of cookie. For more information, please see our Cookie Policy.
• Data from contact forms: 1 year from the last contact
• Data related to the exercise of a right (GDPR request): 6 years for legal proof
After these periods, the data are securely deleted or anonymized unless a longer retention is required by law or regulation.
7. Data Recipients and Disclosure to Third Parties
Personal data may be transmitted to employees, collaborators, subcontractors, or suppliers of Pomone Collection who offer adequate data security guarantees and who collaborate with Pomone Collection in the marketing of products or service provision. They act under Pomone Collection's direct authority and are responsible for collecting, processing, and subcontracting this data.
In any case, the recipients and those to whom the data is disclosed respect the contents of this Privacy Policy. Pomone Collection ensures they will process the data solely for the intended purposes and in a confidential and secure manner.
If data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed in advance and asked to consent to such use.
Certain personal data may be transferred outside the European Economic Area (EEA):
• Shopify: data hosted in Canada (adequate under EU law)
• Mailchimp: newsletter services, data transferred to the USA
• Google Analytics & Ads: may involve data transfers to the USA
These transfers are governed by EU-approved standard contractual clauses or other appropriate safeguards to ensure adequate data protection under the GDPR.
8. User Rights
At any time, the User may exercise their rights by sending an email to: pomonecollection@gmail.com or a letter by post with a copy of their identity card to: Avenue de la Sapinière, 50A - B-1180 Brussels.
8.1. Right of Access
In accordance with Article 15 of the Regulation, Pomone Collection guarantees the User's right to access their personal data. The User has the right to access such personal data as well as the following information:
- The purposes of the processing;
- The categories of personal data concerned;
- The recipients or categories of recipients to whom the personal data have been or will be disclosed;
- Where possible, the envisaged retention period or, if not possible, the criteria used to determine that period;
- The existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and consequences of such processing.
The Controller may charge a reasonable fee based on administrative costs for any additional copy requested.
If the User makes the request electronically, the information shall be provided in a commonly used electronic format, unless otherwise requested.
The copy of the data shall be provided to the User no later than one month after the request.
8.2. Right to Rectification
Pomone Collection guarantees the User's right to rectify and delete their personal data.
In accordance with Article 16 of the Regulation, incorrect or irrelevant data may be corrected or deleted at any time. Users may make changes via their account, or by contacting Pomone Collection if not possible independently.
Under Article 19, the Controller notifies each recipient of any rectification unless this proves impossible or involves disproportionate effort. The Controller shall inform the data subject about such recipients upon request.
8.3. Right to Erasure
The User has the right to obtain the erasure of their personal data without undue delay under Article 17 of the Regulation.
Where the Controller has made the data public, they shall take reasonable steps to inform other Controllers processing such data that the data subject has requested the erasure of any links or copies of the personal data.
The above does not apply to processing necessary for freedom of expression, compliance with legal obligations, or legal claims.
Under Article 19, recipients of erased or restricted data will be informed unless it is impossible or requires disproportionate effort.
8.4. Right to Restriction of Processing
The User has the right to restrict processing in cases provided under Article 19 of the Regulation.
Under Article 19, recipients will be informed of such restrictions unless it proves impossible or involves disproportionate effort.
8.5. Right to Data Portability
Under Article 20 of the Regulation, Users have the right to receive their personal data in a structured, commonly used, machine-readable format, and to transmit it to another controller without hindrance from Pomone Collection.
Where technically feasible, the User may request direct transmission between controllers.
This right does not affect the right to erasure and does not apply where processing is necessary for a public interest task.
This right must not adversely affect the rights and freedoms of others.
8.6. Right to Object and Automated Decision-Making
The User has the right to object to processing based on their specific situation, including profiling. Under Article 21 of the Regulation, Pomone Collection shall cease processing unless legitimate compelling grounds override the User's interests, rights, and freedoms.
If data is processed for direct marketing, the User has the right to object at any time. Once an objection is made, data will no longer be processed for such purposes.
8.7. Right to Lodge a Complaint
The User has the right to lodge a complaint regarding the processing of their personal data with the Data Protection Authority (DPA) in Belgium. More information is available at:
https://www.autoriteprotectiondonnees.be
Complaints can be submitted to:
Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Tel. +32 2 274 48 00
Fax +32 2 274 48 35
Email: contact@apd-gba.be
The User may also file a complaint with the court of first instance of their residence.
9. Limitation of the Data Controller’s Liability
The website may contain links to third-party websites not related to Pomone Collection. Pomone Collection is not responsible for the content or compliance of these sites with the Law or Regulation.
Parental consent is required for minors under 16 to disclose personal data. Pomone Collection encourages responsible internet use by parents. Pomone Collection is not liable for collecting data from minors under 16 without verified parental consent.
Pomone Collection is not liable for data loss, corruption, or theft due to viruses or cyberattacks.
10. Amendments
This Privacy Policy may be modified or supplemented by Pomone Collection at any time to comply with legal, regulatory, jurisprudential, or technical changes.
Any changes will be posted on the Site and, where appropriate, communicated via email.
11. Governing Law and Jurisdiction
This Privacy Policy is governed exclusively by Belgian law.
Any dispute shall be submitted to the courts of the judicial district of Pomone Collection’s registered office.
12. Contact
For any questions or complaints regarding this Privacy Policy, Users may contact the Data Controller at: pomonecollection@gmail.com