PRIVACY POLICY

WAFFLE FACTORY, located at Rue des Digitales 2, MARQUAIN 7522 (Belgium) operates the WAFFLE FACTORY.E FACTORY DEVELOPMENT website under the trade name

We take your privacy very seriously and are committed to protecting it. This privacy policy explains our policies and practices regarding the way in which we collect, use and disclose the personal data we collect on our website and in our sales outlets, branches and franchisees.

Please read this privacy policy, which explains how, why and which of your personal data is used by WAFFLE FACTORY.

In the course of accessing, consulting, browsing and using the website and the services it offers, you may be asked to provide WAFFLE FACTORY with personal data concerning you that is protected by law.

Nevertheless, you can browse the website without having to provide WAFFLE FACTORY with personal information or your identity.

This data protection policy in fact, refers to the Regulation of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (called more simply, the General Data Protection Regulation known as “RGPD”).

What is the RGPD?

RGPD stands for « “General Data Protection Regulation” ». The RGPD frames the processing of personal data on the territory of the European Union.

A “personal data” is “any information relating to an identified or identifiable natural person”, directly (surname, first name) or indirectly (a telephone number, specific elements specific to his or her physical or physiological identity…).

To whom does the RGPD apply?

Indeed, the RGPD applies to any organization, public or private, that processes personal data on its behalf or not, as long as:

• It is established on the territory of the European Union,
• Or that its activity directly targets European residents.

Consequently, the processing of your personal data will be carried out in accordance with the RGPD, any national legislation taken in application of the provisions of the RGPD and any other legislation governing the processing of personal data.

If you provide personal data, WAFFLE FACTORY acts as data controller and has implemented appropriate security measures to protect your personal data.

For example, when you apply for a position with a franchised outlet, your data is transmitted to the franchisee managing the outlet in question in order to process your application. In this case, only information relevant to the position to be filled will be collected.

If you have any specific questions, please contact WAFFLE FACTORY directly by sending an e-mail to rgpd@wafflefactory.com WAFFLE FACTORY will be happy to answer them!

1. What personal data does WAFFLE FACTORY process?

This includes all data that you enter on the website or generate when using it, as well as data transmitted when you communicate with WAFFLE FACTORY services.

The personal data processed is limited to that which is strictly necessary for the provision of the services offered on the website by WAFFLE FACTORY and for each of the purposes for which we process your data.

We may collect personal data directly from you (e.g. when you purchase our products at our points of sale) or indirectly (e.g. from your electronic devices that interact with our website).

The compulsory or optional nature of the personal data to be provided is indicated at the time of collection. If you do not wish to provide the mandatory data, we will not be able to process any requests you may make.

We make every effort to ensure that the personal data we hold is accurate at all times. We therefore encourage you to update your data should any changes occur. We may also ask you to update your data from time to time.

We recommend that you provide only the data requested or necessary for your request, with the exception of sensitive data relating to race, ethnic origin, political opinions, religious or philosophical beliefs, and data concerning health, sex life or sexual orientation. 

EXAMPLES OF DATA CATEGORIES

The following is a non-exhaustive list:

Identification data: surname, first name, contact details, e-mail address, telephone number, billing data.

Connection data: login, date and time of connection… ;

Data relating to site navigation;

Transaction and order data (products and services purchased, expenses incurred, promotional codes)…

Loyalty program data: loyalty card, number of points, rewards requested, e-mails and SMS sent….

Data relating to your franchise application: desired location for the Project, amount of your personal contribution, your motivations for opening a WAFFLE FACTORY outlet.

Data relating to your application for a job offer (head office or franchise): CV, covering letter, desired assignment.

More generally, any data that may be useful for the intended purpose.

We may combine the data you provide with data collected by automated means on our website, such as location data, with your prior consent, so that we can offer you the WAFFLE FACTORY point of sale closest to your home and/or your geographical location.

2. Why does WAFFLE FACTORY use your personal data?

WAFFLE FACTORY processes your personal data for the following purposes:

This list may change according to the needs of the WAFFLE FACTORY website and is therefore not exhaustive. Should this list be modified, we will keep you informed.

Creation and animation of a loyalty program for the execution of the contract

Keeping statistics in the legitimate interest of improving the Loyalty Program and sales promotions, measuring the site’s audience and improving its ergonomics.

Complaints management for the execution of the commercial relationship via the contact form: response to requests for information and other possible complaints..

Management of pre-litigation or litigation in the name of legitimate interests: defense of WAFFLE FACTORY’s interests and rights in the event of violation or infringement identified on the website.

Compliance with legal and regulatory obligations Compliance with legal and regulatory obligations

Localization to offer you the Waffle Factory outlet closest to your geographical location, with your prior consent.

Management of your customer account and your order history in execution of the contract that may bind us: in order to offer you the best choice with regard to your preferences.

Processing and preparation of your “Click and Collect” order and management of your invoices by virtue of the contract that may bind us (only in points of sale concerned by “Click and Collect”).

Promotional operations organized by Team WAFFLE FACTORY by virtue of our legitimate interest or the performance of a contract.

Recruitment of future franchisee Waffle Makers (in the “recruitment” section) for pre-contractual measures.

Recruitment of future Franchisor employees and Waffle Makers (in the “recruitment” section) for pre-contractual measures.

Constitution of a CV database in the name of the legitimate interests of WAFFLE FACTORY teams and if you agree, in order to contact you at any time in the event of recruitment.

3. Who can access the personal data you have entrusted to WAFFLE FACTORY?

As data controller, WAFFLE FACTORY may need to call upon “processors” in order to process all or part of your personal data, to the extent necessary to perform the tasks entrusted to them.

By definition within the meaning of the RGPD, a processor is a natural or legal person who processes personal data at the request and on behalf of the data controller.

In this sense, the categories of recipients of personal data are as follows:

WAFFLE FACTORY and its staff: management of the website and provision of services (e.g. processing of orders, response to requests made via the contact form, etc.).

Various subcontractors (host, IT maintenance provider, etc.): For technical and logistical performance issues

Miscellaneous advice: Management and handling of pre-litigation and litigation, provision of miscellaneous advice

Judicial and administrative authorities: For the administration and management of an express request from an administrative or judicial authority.

WAFFLE FACTORY franchisees: for recruitment purposes at our various sales outlets.

Data is allocated to service providers under conditions that may involve the transfer of data outside the European Union (such as the United States). Where applicable, such transfers will be secured by the signing of standard contractual clauses with the parties concerned.

4. What safeguards has WAFFLE FACTORY adopted to protect your data?

In accordance with the General Data Protection Regulation, WAFFLE FACTORY has implemented appropriate technical and organizational measures to protect your personal data and guarantee the protection of your rights against any possible breach or violation that could lead, accidentally or unlawfully, to the destruction, loss, alteration, unauthorized access or disclosure of your personal data.

Access to your personal data is strictly reserved to persons who need access to personal data for professional reasons, who are subject to a duty of confidentiality towards WAFFLE FACTORY.

WAFFLE FACTORY also guarantees that it has taken the necessary measures to ensure the availability, integrity and confidentiality of the personal data it processes, both with respect to its employees and to any person or company duly authorized by WAFFLE FACTORY to process your personal data.

WAFFLE FACTORY ensures that the partner complies with commitments as binding as its own in terms of security and compliance with legislation on personal data and that it offers appropriate guarantees to protect your privacy.

Nevertheless, WAFFLE FACTORY draws your attention to the risks associated with the operation of the Internet and the existence of possible risks in terms of occasional loss of data or breach of confidentiality of data transiting via this network. In addition, the information provided on the website may be interrupted in cases of force majeure or events beyond the control of WAFFLE FACTORY.

In this respect, in the event of a breach of security and/or confidentiality of your personal data collected during consultation and browsing of the Website, you will be notified of such breach as soon as possible.

5. How long does WAFFLE FACTORY keep your personal data?

Your personal data will only be kept for the period necessary to meet the purposes for which your data was collected and/or to comply with legal or regulatory archiving requirements, for example.

With some exceptions:

Data collected in the context of a request for information, a complaint or a franchise application are kept for the time required to process and close the request for information or complaint;

Connection data is kept for twelve (12) months.

Data deleted via cookies is kept for a maximum of thirteen (13) months.

Data collected in connection with your application for a job is kept for two (2) years from the date of your last contact with WAFFLE FACTORY, unless you request that your file be destroyed before this period;

Data collected in connection with your franchise application is kept until it has been fully processed.

Data relating to the management of the loyalty program is kept for the duration of the commercial relationship, plus three (3) years.

Geolocation data is stored for 24 hours, subject to your consent.

More generally, beyond the above period, your personal data is kept for: five (5) years for data kept for evidentiary purposes, in particular the personal data of the company’s employees such as pay slips; ten (10) years from the close of the financial year for data kept for accounting purposes, as well as for commercial documents (invoices, commercial correspondence, etc.).

6. What rights do you have over your personal data? How long will WAFFLE FACTORY keep your personal data?

You have the right to access, rectify, object to, delete and communicate information and data held by WAFFLE FACTORY.

WAFFLE FACTORY undertakes to delete from its databases the personal data of users who have been inactive for 2 years in order to comply with the right to erasure provided for by the RGPD.

You also have the right to portability of your data, the right to limit processing, the right to define directives concerning the fate of your personal data after your death, the right to have your personal data transmitted in a structured format and the right to lodge a complaint with a supervisory authority.

The exercise of your right will depend on the legal basis for the processing of your data.

In the absence of a response, or if the response is unsatisfactory, the data subject may refer the matter to the Data Protection Authority: https://www.privacycommission.be/fr.

You can exercise your rights by writing to the designated Data Protection Officer, providing proof of your identity by email (rgpd@wafflefactory.com) or by post to the following address: Rue des Digitales 2 in MARQUAIN 7522 (Belgium)

In the absence of a reply or an unsatisfactory response, the person concerned may refer the matter to the Data Protection Authority: : https://www.autoriteprotectiondonnees.be/citoyen

(Last updated: 26/04/2023)