Cookie policy SOMEX SA (Societe Des Marches Exterieurs SA)

1. GENERAL

1.1 This cookie policy (“Cookie Policy”) governs the use of cookies and similar technologies as part of your use of our website ( www.danielhechterwax.com/dhwax.com (the “Website”)). This processing is undertaken by SOMEX SA (Societe Des Marches Exterieurs SA) as responsible party, with registered office at Avenue des Arts, 1/8, 1210 Bruxelles, BELGIUM (“Company”, “we”, “us”, “our”), registered under the number BE402.178.232 in compliance with applicable data protection legislation.

1.2 Cookies are small text files that are stored on a device’s hard drive and contain certain information and sometimes personal data. When you use our website, we also collect and process other personal information other than through cookies and similar technologies. If you want to know more, please read our Privacy Policy (Link to Privacy Policy: [to be added]).

1.3 By continuing to use our website or by clicking “Agree” after you have been notified of the use of cookies and similar technologies, you acknowledge that you have read this Cookie Policy carefully and that you agree to it without reservations. As set out in this Cookie Policy, you can change your cookie preferences at any time.

1.4 We reserve the right to change, supplement or replace this Cookie Policy from time to time. Such changes, additions or substitutions will be brought to your attention via our website. If you do not agree with these changes, additions or substitutions, we ask you to send an e-mail to eric.touati@somex.be. If we do not receive notice from you within three (3) working days after the changes, additions or substitutions have been notified via our website, you will be deemed to have accepted all changes, additions or substitutions.

2. WHAT TYPES OF COOKIES ARE THERE?

2.1 There are different types of cookies. Some are necessary to enable the proper functioning of a website, others serve to improve and/or simplify its use:

2.1.1 Strictly necessary cookies;

2.1.2 Functional cookies;

2.1.3 Authentication cookies;

2.1.4 Performance cookies;

2.1.5 Targeting/Third-party cookies;

2.2 Strictly necessary cookies are necessary for the functioning of the websites of SOMEX SA (Societe Des Marches Exterieurs SA). These cookies do not collect any information about the user that can be used for marketing purposes and are essential to enable use the websites of SOMEX SA (Societe Des Marches Exterieurs SA). Such cookies are exempt from the requirement for consent, in accordance with article 129 of the law of 13 June 2005 on electronic communications.

2.3 Functionality cookies make it possible to memorise the user’s connection data, secure the user’s connection to the websites of SOMEX SA (Societe Des Marches Exterieurs SA) and provide live assistance. These cookies do not collect any information about the user that can be used for marketing purposes. These cookies are also exempt from the consent requirement.

2.4 Authentication cookies enable users to identify themselves and access secure content. These cookies do not collect any information about the user that can be used for marketing purposes. These cookies are also exempt from the consent requirement.

2.5 Performance cookies enable SOMEX SA (Societe Des Marches Exterieurs SA) to collect information about how users browse the websites of SOMEX SA (Societe Des Marches Exterieurs SA), and to adapt and improve its websites if necessary. SOMEX SA (Societe Des Marches Exterieurs SA) is not able to identify the users using this type of cookie, and all the data collected by these cookies is processed anonymously. These cookies do not collect any information about the user that can be used for marketing purposes. These cookies are placed and used with the user’s consent.

2.6 Targeting/Third-party cookies. SOMEX SA (Societe Des Marches Exterieurs SA) sometimes conducts advertising campaigns, often using third parties who can sometimes place cookies (or similar technologies) to assess with the success of the campaign or to display a targeted advert t tailored to a user’s interests or to limit the number of views per user. For example, links to the social networks or to videos on YouTube -who are third parties- can, if appropriate, place cookies on the websites of SOMEX SA (Societe Des Marches Exterieurs SA). These cookies are placed and used with the user’s consent.

2.7 If a user refuses the use of this type of cookie, only those pages and services that do not need these cookies can be displayed, viewed and used. The parts of the website of SOMEX SA (Societe Des Marches Exterieurs SA) that allow the inclusion of third-party content – and therefore of third-party cookies – will no longer be accessible and a message will inform users of this.

2.8 A distinction must also be made between:
2.8.1 Session cookies; and
2.8.2 Permanent cookies.

2.9 Session cookies are automatically deleted from the computer’s hard disk or the memory of a user’s browser when they disconnect and/or close the browser.
2.10 Permanent cookies are stored on the computer’s hard disk or the memory of a user’s browser for a limited time (minutes, days or years) after the disconnection or the closure of the browser.

3. WHAT & WHY WE PROCESS
3.1 The table below shows in detail the cookies used on the website of SOMEX SA (Societe Des Marches Exterieurs SA) and the cookies used by third parties.
3.2 When visiting and using our website, we place cookies or use similar technologies through which we collect and process personal data pertaining to you. Such cookies and similar technologies include:

NAME	TYPE	ORIGIN	DURATION	LIFESPAN
[to be filled in by Digitag]	Necessary/Functional/Authentication/Performance/Marketing	First party/Third party	Session/Permanent	1 minut(s)

3.3 You can prevent cookies from being placed, or delete already placed cookies, by adjusting your settings in your browser. Help with adjusting these settings can be found on the website of the browser you use. Keep in mind that not allowing cookies when visiting the website may lead to some or all of the website functions not working properly.

4. TO WHOM WE SEND
4.1 We will share your personal data only with the following categories of recipients: services d'hébergement/storage services et/and service de livraison/delivery serviceWe may rely on third party processors to provide you the website. We will ensure that third party processors are only allowed to process your personal data on behalf of us upon written instruction of us. We warrant that all third-party processors are selected with due care and are trained to be aware of the safety and integrity of your personal data.

4.2 We may send anonymized and/or aggregated data to other organizations that may use those data for improving products and services as well as tailor the marketing, displaying and selling of those goods and services.

5. WHERE WE PROCESS
5.1 We may transfer your anonymized and/or aggregated data to organizations outside of the EEA. Should such transfer take place, we will ensure that there are appropriate safeguards in place to ensure the safety and integrity of your personal data as well as all rights with respect to personal data you might enjoy under applicable mandatory law.
5.2 Should a transfer of your personal data and/or anonymized and/or aggregated data take place, the following legal safeguarding mechanism is put in place:

RECIPIENT	COUNTRY	DATA	LEGAL BASIS
Transporteurs et partenaires commerciaux	Pays Africains (50)	· Your contact data Any other personal data you choose to provide to us	Model contract clauses from the EU Commissions
Transporteurs et partenaires commerciaux	USA	· Your contact data Any other personal data you choose to provide to us	Model contract clauses from the EU Commissions
Transporteurs et partenaires commerciaux	Canada	· Your contact data Any other personal data you choose to provide to us	Model contract clauses from the EU Commissions

6. HOW WE PROCESS

6.1 We will do our utmost best to process only those personal data which are necessary to achieve the purposes listed in this Privacy Policy. We will process your personal data in a lawful, fair and transparent manner. We will do our utmost best to keep the personal data accurate and up to date.

6.2 Your personal data are only processed for as long as needed to achieve the purposes listed in this Privacy Policy or up until such time where you withdraw your consent for processing them. Note that withdrawal of consent may imply that you can no longer you the whole or part of the website. If you have registered with our website, we will delete your personal data if you delete your profile, unless a legal or regulatory obligation or a judicial or administrative order prevents us to do so

6.3 We will take the appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access by our personnel or personnel of our third-party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only which can never be guaranteed.

7. YOUR RIGHTS

7.1 You have the right to request access to all personal data processed by us pertaining to you. Subsequent requests for access addressed to us that are manifestly submitted for causing nuisance or harm to us, will not be dealt with.

7.2 You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If you have registered with our website, you can correct a lot of these data yourself via your profile. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.

7.3 You have the right to withdraw the permission you have given us, but this withdrawal will not affect the data that we have already collected through cookies or similar technologies based on your prior consent. If you no longer want us to collect data via cookies or similar technologies, you can change your browser settings at any time or delete your cookies.

7.4 If the intended processing is qualified as direct marketing, you have the right to oppose such processing free of charge and without justification.

7.5 You have the right to request that personal data pertaining to you be deleted if they are no longer required in light of the purposes outlined in this Privacy Policy or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by us against legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

7.6 Instead of deletion you can also ask that we limit the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes listed but you need them to defend yourself in judicial proceedings.

7.7 If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to eric.touati@somex.be. Such request should clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated, signed and accompanied by a digitally scanned copy of your valid identity card proving your identity.

7.8 We will promptly inform you of having received this request. If the request proves valid, we shall honour it as soon as reasonably possible and at the latest thirty (30) days after having received the request.

7.9 If you have any complaint regarding the processing of your personal data by us, you may always contact us via the e-mail address eric.touati@somex.be. If you remain unsatisfied with our response, you are free to file a complaint with the competent data protection authority (list of DPA per country: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080).

7.10 Where your personal data is processed based on consent or on a contract and the processing is carried out by automated means, you will have the right to receive the personal data concerning yourself, which you provided to us, in a structured, commonly used and machine-readable format and, where technically feasible, you will have the right to directly transmit those data to another service provider.