PRIVACY POLICY

FILROC BV – Hoge Mauw 740, 2370 Arendonk, Belgium  – RLE Antwerp (div. Turnhout) no. 0729.704.670  
ARODO BV – Hoge Mauw 740, 2370 Arendonk, Belgium – RLE Antwerp (div. Turnhout) no. 0436.332.922 – VAT BE0436.332.922   
Möllers Packaging Technology GmbH, Sudhoferweg 93, 59269 Beckum, Germany – registered in the Handelsregister of Amtsgericht Düsseldorf  with company registration number HRB92710 – VAT DE 342 569 226   
ALLCO FINISHING BV – Hoge Mauw 750, 2370 Arendonk, Belgium – RLE Antwerp (div. Turnhout) no. 0478.184.561 – VAT BE0478.184.561  

 (Hereinafter jointly referred to as ‘CORPAX’, ‘we’ or ‘us’)  
 

Version dated 11.09.2023

As your trust in CORPAX is paramount, your privacy is essential to us. Among other things, this Privacy Policy (Hereinafter: ‘Privacy Policy’) applies to: 
(i)    our website https://www.corpax-group.com/ (Hereinafter: ‘Website); and 
(ii)    all other commercial relationships between CORPAX and its customers, potential customers, and business partners.

This Privacy Policy contains information on the personal data that CORPAX collects and how CORPAX uses and processes these personal data.

CORPAX wishes to emphasize that it always tries to act in accordance with the ‘Privacy Legislation’, namely: 
(i)    the Belgian Act of July 30, 2018 on the protection of individuals with regard to the processing of personal data;
(ii)    Regulation (EU) 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC; and 
(iii)    other applicable special provisions on data protection.
Visiting the Website, requesting a quotation, filling out the contact form, purchasing any of CORPAX’s products or services, or communicating with CORPAX implies your explicit consent to the Privacy Policy (through communicating your personal data or opt-in) and thus to how CORPAX collects, uses, and processes your personal data.

Read this Privacy Policy in conjunction with its version history, the legal disclaimer, general terms and conditions of each individual group company, and cookie policy of CORPAX.

I.    Who processes your data?
The controller of your personal data collected on this Website are the companies: 
(i)    ARODO BV, with registered office at Hoge Mauw 740, 2370 Arendonk (Belgium), listed in the Antwerp Register of Legal Entitles, division Turnhout, under number 0436.332.922, VAT BE 0436.332.922; 
(ii)    ALLCO FINISHING BV, with registered office at Hoge Mauw 750, 2370 Arendonk (Belgium), listed in the Antwerp Register of Legal Entitles, division Turnhout, under number 0478.184.561, VAT BE 0478.184.561; 
(iii)    Möllers Packaging Technology GmbH, with registered office at Sudhoferweg 93, 59269 Beckum (Germany), registered in the Handelsregister of Amtsgericht Düsseldorf with company registration number HRB92710 , VAT DE 342 569 226; and
(iv)    FILROC BV, with registered office at Hoge Mauw 740, 2370 Arendonk (Belgium), listed in the Antwerp Register of Legal Entitles, division Turnhout, under number 0729.704.670. All contact details are included under Part X.

II.    CORPAX’s processing activities (what types, for what purposes, on what legal grounds, and for how long does CORPAX collect and process personal data? Are these data transferred to third countries)? 

A.    General
Providing certain personal data is sometimes a prerequisite to benefit from certain services (for example, to gain access to certain parts of the Website, to subscribe to newsletters, to participate in certain activities and events, to be able to receive certain goods and services by way of delivery). This policy also specifies which data are mandatory and which are optional. 
If CORPAX’s legitimate interest is the legal basis for processing, as shown in the tables below, CORPAX will always:
(i)    assess the necessity of the processing activity in relation to the purpose of the processing (proportionality test); and
(ii)    assess whether you, the data subject, could reasonably expect the specific processing operation to take place, so we can estimate the possible effects of the processing operation on your fundamental rights and freedoms.
CORPAX thus always strives to minimize the impact on your fundamental rights and freedoms as much as possible. We warrant that we will process your personal data on the basis of a legitimate interest only if we are absolutely sure that a balance can be found between your rights and freedoms and our interests. If a balance cannot be guaranteed, CORPAX:
(i)    will no longer process your personal data in that specific situation (for that specific purpose); or
(ii)    will rely on another legal ground to process your personal data (e.g. consent).

B.    Processing activities concerning the use of the Website

(*) For more information on the use of cookies, we refer to the cookie policy available on our Website.

CORPAX also automatically collects anonymous information regarding your use of the Website. For example, CORPAX will automatically log which parts of the Website you visit, which web browser you use, and which website you visited when you accessed the Website. Although we cannot identify you on the basis of these data, they allow CORPAX to compile statistics on the use of the Website. 

III.    With whom do we share your personal data?  
CORPAX will not disclose your personal data to third parties unless necessary for performing and optimizing the contract. For this purpose, we may disclose your personal data to payment providers, software suppliers, cloud partners, transport partners, external IT consultants, external marketing consultants, and CORPAX’s affiliates within the meaning of Section 1:20 of the Belgian Corporations Code. 

If CORPAX has to disclose your personal data to third parties for this purpose, the third party concerned must use your personal data in accordance with the provisions of this Privacy Policy and the data processing or transfer agreement that will be concluded with this party, if applicable. 

Besides the above, CORPAX may disclose your personal data: 
- to the competent authorities (i) if it is obliged to do so by law or in the context of current or future legal proceedings and (ii) to safeguard and defend its rights; 
- if it or most of its assets are acquired by a third party, in which case your personal data that CORPAX has collected will be one of the transferred assets.

Except in the cases mentioned in this article and insofar as necessary to achieve the purposes summarized in this privacy policy, CORPAX must not sell, rent out, or transfer your personal data to third parties unless it has (i) obtained your consent for this purpose and (ii) concluded a data processing or data transfer agreement with the third party concerned that includes the necessary warranties on confidentiality and privacy-compliant treatment of your personal data.

IV.    Cross-border processing of personal data 
Any transfer of personal data outside the European Economic Area (EEA) to a recipient residing or having its corporate domicile in a country not covered by an adequacy decision issued by the European Commission will be governed by the provisions of a data transfer agreement, which will contain:  
(i)    the standard contractual clauses as stipulated in the ‘European Commission Decision of February 5, 2010 (Decision 2010/87/EC)’; and/or  
(ii)    binding corporate rules. If the standard contractual clauses are used in this case, the recipient of the personal data/CORPAX’s processor in the third country must guarantee to CORPAX that an adequate level of privacy compliance is ensured in the third party’s country; and/or 
(iii)    provide appropriate guarantees by any other mechanism under the Privacy Legislation or any other regulation governing the processing of personal data.

V.    How long do we retain your personal data? 
Unless a longer retention period is required or justified (i) by law or (ii) through complying with any other statutory obligation, CORPAX will retain your personal data only for the period needed to achieve and fulfill the purposes as described in the tables of this Privacy Policy under ‘II. CORPAX’s processing activities’.

VI.    What are your privacy rights? 
You have these privacy rights in relation to the processing of your personal data: 
Right to access your personal data      
You may always access and inspect your personal data that CORPAX has processed. CORPAX will provide a copy of these personal data on your request. 
Right to rectify, supplement, or update your personal data 
You may always have incorrect, incomplete, inappropriate, or outdated personal data removed or rectified.  
Right to erasure of your personal data (‘right to be forgotten’)     
In this context, CORPAX wishes to point out that certain services will no longer be accessible or can no longer be provided if you delete or have certain necessary personal data deleted. 
Right to restrict the processing of your personal data     
You may restrict the processing of your personal data if: 
o    you dispute the accuracy of the data, for a period that allows CORPAX to verify the accuracy; 
o    the processing is unlawful, and you oppose the erasure of your personal data and request the restriction of their use instead; 
o    CORPAX no longer needs your personal data for processing purposes, but still needs them to institute, exercise, or substantiate legal claims; 
o    you have objected to a processing operation and are waiting for an answer on whether your objection is well-founded.  
Right to portability of your personal data 
You may obtain the personal data that CORPAX has processed in a structured, commonly used, and digital format so they can be saved for personal use or reuse, or to send them directly to another controller. This right applies insofar as it is technically possible for the controller to do this. 
Right to object to/oppose the further processing of personal data 
o    You may always object to the processing of your personal data for reasons relating to your specific situation. 
o    The controller will immediately cease processing your personal data, unless it puts forward compelling legitimate grounds for the processing that override your interests, rights, and freedoms or that relate to instituting, exercising, or substantiating legal claims.

If you wish to exercise your privacy rights, contact hello@corpax-group.com or send your request by post (see contact details under Part X).  
If there is reasonable doubt about your identity, CORPAX may request the front of your identity card/passport for identification purposes before being able to answer your question or request. However, CORPAX expressly acknowledges that it will not systematically request a data subject’s identity card/passport in this context and that it will only use the evidence to establish whether you are actually the data subject whose personal data are being processed. Once both parties are satisfied with the answer to your question, CORPAX will destroy the evidence.

In principle, you can exercise these rights free of charge using the above form, except when the controller considers the request to be manifestly unfounded or excessive (for example, if you make repeated requests).  
If and insofar as permitted under the applicable law, CORPAX may process your contact data for direct marketing purposes. If you no longer wish to receive newsletters or information about CORPAX’s products or services, you can always unsubscribe by clicking the ‘unsubscribe’ button at the bottom of each email from CORPAX. 

VII.    Security of personal data  
CORPAX undertakes to implement appropriate and reasonable physical, technological, and organizational security measures to prevent (i) unauthorized or unlawful access to your personal data, and (ii) the loss, misuse, or alteration of your personal data.

CORPAX will keep all personal data collected on-site and in the cloud with data centers in the EU.

Despite (i) CORPAX’s security policy, (ii) the controls it performs, and (iii) the actions it takes in this regard, an infallible level of security cannot be guaranteed. As no method of transmission or transfer via the internet or any electronic storage method is 100% secure, CORPAX cannot guarantee absolute security in this context. 

VIII.    Updates to Privacy Policy 
CORPAX may update this Privacy Policy by posting a new version on the Website. We therefore strongly recommend that you regularly consult the Website and the relevant page of the Privacy Policy to ensure that you are aware of any amendments. 
The most recent version of this Privacy Policy is always available on the Website. Any updates and corresponding change date will be explained and displayed in the Privacy Policy version history, which can be accessed using this Link. 

IX.    Links to other websites 
The Website may contain hyperlinks to other websites. When you click on one of these links, you could be directed to another website or internet source that might collect information about you intentionally or through cookies or other technologies. CORPAX has no responsibility, liability, or ability to control these other websites or internet sources, or their collection, use, and dissemination of your personal data. You should check the privacy policies of these other websites and internet resources to determine whether they comply with the Privacy Legislation.

X.    Contacting CORPAX 
If you have questions about the Privacy Policy or about how CORPAX collects, uses, or processes your personal data, contact us: 
-    by e-mail: hello@corpax-group.com  
or  
-    by post: FILROC BV, Hoge Mauw 740, 2370 Arendonk, Belgium

If you are dissatisfied with how CORPAX deals with these questions or comments, or if you have concerns about how CORPAX collects, uses, or processes your data, you may lodge a complaint with the competent supervisory authority. This may be the supervisory authority of (i) your usual place of residence, (ii) your place of work, or (iii) the location of the alleged breach of the Privacy Legislation.

Contact details of the Belgian Data Protection Authority:

Data Protection Authority 
Rue de la Presse/Drukpersstraat 35, 1000 Brussels, Belgium 
Tel.: +32 (0)2/ 274 48 00     
Email: contact@apd-gba.be