Privacy policy
Privacy notice
Effective date: 17.04.2019 - Last updated on 16.12.2020
EXTENT OF THIS NOTICE
Please read this privacy notice ("Notice") carefully to understand our policy and practices
regarding your Personal Information and how we will treat it.
This Notice explains how your Personal Information is collected, used and disclosed by
Nawhal's entities as listed in the Data Controllers and Contact Information section
(Section 11) ("Nawhal's", "We"). It also tells you how you can access and update your
Personal Information and how you can make certain choices about how your Personal
Information is used.
This Notice covers both our online and o.line data collection activities, including
Personal Data that We collect through our various channels such as websites, mobile
applications, third party social networks, Consumer Services, shops, retail outlets and
events.
Please note that We combine Personal Data that We collect via one method (e.g. a
Nawhal's website) with Personal Data that We collect via another method (e.g. a Nawhal's
o.line event). In this context, We combine Personal Data that was originally collected by
di.erent Nawhal's entities. Please see Section 10 for more information on how to object
to this.
If you do not provide us with the necessary Personal Information, we may not be able to
o.er you our products and/or services (we will tell you if this is the case, for example by
highlighting this information on our registration forms).
This Notice may change from time to time (see Section 11).
This Notice provides important information in the following areas:
1. SOURCES OF PERSONAL DATA
2. PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
3. CHILDREN'S DATA
4. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
5. USES MADE OF YOUR PERSONAL DATA
6. DISCLOSURE OF YOUR PERSONAL DATA
7. RETENTION OF YOUR PERSONAL DATA
8. STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA
9. YOUR RIGHTS
10. YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
11.CHANGES TO OUR NOTICE
12.DATA CONTROLLERS AND CONTACT DETAILS
1. SOURCES OF PERSONAL DATA
This Notice applies to Personal Data that We collect from or about you, through the
methods described below (see Section 2), from the following sources:
Nawhal's websites. Consumer-oriented websites operated by or for Nawhal's,
including sites that We operate under our own domains/URLs and mini-sites that We
operate on third party social networks such as Facebook ("Websites").
Nawhal's Mobile Sites/Applications. Consumer-facing mobile sites or applications
operated by or for Nawhal's, such as smartphone apps.
E-mail, SMS and other electronic messages. Electronic communications between
you and Nawhal's.
Nawhal's Consumer Services. Calls to our customer services.
OAline registration forms. Printed and other registration forms that we collect
through postal mail, in-store demos, contests and other promotions, events, etc.
Interactions with our advertisements. (For example, if you interact with one of our
advertisements on a third-party site, we may receive information about that
interaction.)
Data from other sources. Third party social networks (such as Facebook, Google, ...)
or market research (if your answers are not provided anonymously), third parties,
Nawhal's promotional partners, public sources and data that we receive when we take
control of another company.
2. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT
IT
Depending on how you interact with Nawhal's (online, o.line), We collect di.erent
types of information about you, as described below
Personal details. This includes any information you provide to Us that may enable Us
to contact you, such as your name, postal address, email address, social networking
details or telephone number.
Account login information. Any information required to give you access to your
specific profile/account. For example, your username/email address, alias, password
in encrypted format and/or your security question and answer.
Demographic information and interests. Any information that describes
demographic or behavioural characteristics. For example, your date of birth, age or
age range, gender, geographical location (e.g. postcode), product preferences,
hobbies and interests, household information or lifestyle.
Technical information about your computer/mobile device. Any information about
your computer or other technological device that you use to access one of our
websites or mobile applications, such as Internet Protocol (IP), the address used to
connect your computer or other device to the Internet, your type of operating system,
and the type and version of your web browser. If you access a Nawhal's website or
application via a mobile device, the information collected will also include, if
permitted, the unique identifier linked to your mobile device, the advertising identifier,
geolocation and other similar data linked to the mobile device.
Communication/website usage information. When you browse and interact with
our websites or newsletters, We use automatic data collection technologies to collect
certain information about your actions. This includes information such as links you
click, the pages or content you view and the length of time you view them, and other
similar information and statistics about your interactions, such as reaction times to
content, download errors and the length of visits to certain pages. This information is
recorded using automated technologies such as cookies (browser cookies, flash
cookies) and web beacons, and is also collected through third-party tracking. You
have the right to object to the use of such technologies. For more information, see
Section 3.
Market research and consumer feedback. This includes information that you
voluntarily share with Us about your experience using our products and services.
Consumer Generated Content. This is any content that you may create and then
share with Us on third party social networks or by uploading it to one of our websites
or apps, including the use of third-party social network apps such as Facebook. For
example, photos, videos, personal stories or other similar media or content. If
permitted, We collect and publish consumer-generated content in connection with
various activities such as contests and other promotions, website community
features, consumer engagement, and use of third-party social networks.
Third Party Social Network Information. This is any information that you share
publicly on a third-party social network or any information that is part of your profile
on a third-party social network (such as Facebook) that you allow the third-party social
network to share with Us. For example, your basic account information (name, email
address, gender, birthday, current city, profile picture, username, list of friends, etc.)
and any other information or activity that you allow the third-party social network to
share. We receive your third-party social network profile information (or a portion of it)
each time you download or interact with a Nawhal's web application on a third-party
social network such as Facebook, each time you use a social networking feature that
is integrated into a Nawhal's site (such as Facebook Store), or each time you interact
with Us through a third-party social network. To learn more about how your
information from a third-party social network is obtained by Nawhal's, or to opt out of
the sharing of such information, please visit the relevant third-party social network's
website.
Payment and financial information. Any information that We need to fulfil an order,
or that you use to make a purchase, such as your credit or debit card details
(cardholder name, card number, expiry date, etc.) or other forms of payment (if
available). In any event, We or our payment service provider(s) manage payment and
financial information in accordance with applicable laws, regulations and security
standards, such as the Payment Card Industry Security Standard PCI DSS.
What do we use your Personal Information
for?
Our reasons Our legitimate
interests
Consumer services. We use your Personal
Information to serve our customers, including
responding to your requests. This requires the use
of certain personal contact details and information
relating to the reason for your request (e.g. order
status, technical problem, question/complaint
about a product, general question, etc.).
• Compliance with
contractual
obligations
• Legal obligations
• Our legitimate
interests
• Improving and
developing new
products and services
• Improving e.iciency
Competitions, marketing and other promotions.
With your consent (if required), We use your
Personal Information to provide you with
information about goods or services (e.g. marketing
communications, campaigns or promotions). We
do this by using e-mail, advertisements, SMS,
telephone calls and postal mailings to the extent
permitted by applicable law. Some of our
campaigns and promotions take place on third
party websites and/or social networks. This use of
your Personal Data is voluntary, which means that
you may object to the processing of your Personal
Data for these purposes. For more information on
how to change your preferences regarding
marketing communications, please see Sections 9
and 10 below. For more information about our
competitions and other promotions, please refer to
the o.icial rules or information accompanying each
competition/promotion.
• With your consent
(if required)
• Compliance with
contractual
obligations
• Our legitimate
interests
• Define the products
and services likely to
be of interest to you
and introduce them to
you.
• Identify the types of
customers for new
products or services.
Third-party social networks. We use your Personal
Data when you interact with third party social
network features such as "like" functions in order to
provide you with advertisements and to interact
with you on third party social networks. To find out
more about how these features work, what profile
data We obtain about you and how you can object
to this processing of your Personal Data, please see
the privacy notices of the relevant third-party social
networks.
• With your consent
(if required)
• Our legitimate
interests
• Define the products
and services likely to
interest you and
present them to you.
• Determine the types
of consumer for new
products or services.
Customisation (oAline and online). With your
consent (if required), We use your Personal Data (i)
to analyse your preferences and habits, (ii) to
anticipate your needs based on our analysis of your
profile, (iii) to improve and personalise your
experience on our websites and applications, (iv) to
ensure that the content of our websites and
applications is optimised for you and your
computer or device, (v) to provide you with targeted
• With your consent
(if required)
• Our legitimate
interests
• Define the products
and services likely to
interest you and
present them to you.
• Determine the types
of consumers for new
products or services.
advertising and content and (vi) to allow you to
participate in interactive features, when you choose
to do so. For example, We may store your
username/email address or alias so that you can
log in quickly next time or so that you can easily find
items that you have placed in your shopping cart.
Based on this type of information and with your
consent (if required), We also show you specific
Nawhal's content or promotions that correspond to
your interests. The use of your Personal Data is
voluntary, which means that you can object to the
processing of your Personal Data for this purpose.
See Section 8 below for more information on how to
object to such processing.
Order fulfilment. We use your Personal
Information to process and ship your orders, to
notify you of the status of your orders, correct
addresses and to verify your identity and other
activities relating to fraud detection. This involves
the use of certain Personal Data and payment
information.
• Compliance with
contractual
obligations
• With your consent
(if required)
• Legal obligations
• Our legitimate
interests
• Improving and
developing new
products and services
• Improving e.iciency
• Protecting our assets
and people
Other general purposes (e.g. internal survey or
market research, statistics, security). In
accordance with applicable laws, We use your
Personal Information for other general business
purposes such as conducting internal or market
research, or evaluating the e.ectiveness of
advertising campaigns. We reserve the right, if you
have Club membership accounts, to merge these
accounts into a single account. We also use your
Personal Information to ensure our security.
• Compliance with
contractual
obligations
• With your consent
(if required)
• Legal obligations
• Our legitimate
interests
• Improving and
developing new
products and services
• Improving e.iciency
• Protecting our assets
and people
Legal reasons or merger/acquisition. In the event
that Nawhal's or its assets are acquired by or
merged with another company, including as a result
of bankruptcy, we will share your Personal
Information with our legal successors. We will also
disclose your Personal Information to third parties
(i) if required to do so by applicable law, (ii) in
response to legal process, (iii) in response to a
request from a law enforcement agency of
competent jurisdiction, (iv) to protect our rights,
privacy, safety or property, or those of the general
public, or (v) to enforce the terms and conditions of
any contract or our website.
• Legal obligations
• Our legitimate
interests
• Compliance with legal
obligations
• Protecting our assets
and sta.
Calls to Consumer Services. Communications with a Consumer Service will be
recorded or listened to, in accordance with the laws in force, for local operational reasons
(e.g. for quality or training purposes). Payment card details are not recorded. You will be
informed that your call is being recorded at the beginning of the call.
Sensitive personal information. We only process sensitive data for marketing purposes
if you have given your explicit consent. If we process personal data for other purposes, we
will do so on the following legal grounds: (i) detection and prevention of criminal activity
(including fraud prevention); and (ii) compliance with applicable legislation (e.g. to
comply with diversity reporting).
3. CHILDREN'S PERSONAL DATA
We will not knowingly collect personal data from children under the age of 13. However,
if we become aware that such personal data has been collected unintentionally, we will
delete it immediately. Nawhal's may, however, obtain personal data from children under
the age of 13 directly from the parent or legal guardian with that person's explicit consent.
4. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
Cookies/similar technologies. Please read our Cookies Notice to find out how to
manage your cookie settings and for details of the cookies We use and the purposes for
which We use them.
Log Files. We collect information in the form of log files that record your activities on the
Websites and gather statistics about your browsing habits. These entries are generated
automatically and help Us to correct errors, improve performance and ensure the security
of our websites.
Web beacons. Web beacons (also known as "web spies") are small segments of code
that provide a graphical image on a web page or in an e-mail for the purpose of transferring
data back to Us. The information collected via web beacons is for example the IP address
as well as data on how you reacted to an e-mail campaign (e.g. at what time the e-mail
was opened, which links in the e-mail you clicked on, etc.). We will use web beacons on
our websites or include them in e-mails that We send to you. We use web beacon
information for a variety of purposes, including site tra.ic reporting, unique visitor counts,
advertising, auditing, and email reporting and customisation.
5. USES MADE OF YOUR PERSONAL DATA
The following paragraphs describe the di.erent purposes for which We collect and use
your Personal Information and the di.erent types of Personal Information that is collected
for each purpose. Please note that not all of the uses below will be relevant to every
individual.
6. DISCLOSURE OF YOUR PERSONAL DATA
In addition to the Nawhal's entities or ad hoc local partners (in charge of Nawhal's
operations) listed in the Data Controllers and Contact Details section (see Section 11),
We share your Personal Data with the following types of third-party organizations:
Service providers. These are external companies that We use to help Us carry out Our
business (e.g. order fulfilment, payment processing, fraud detection and identity
verification, website operation, companies carrying out market research, support
services, promotions, website development, data analysis, CES, etc.). Service providers
and their sta. are only authorised to access and use your Personal Data on Our behalf
and in order to carry out the specific tasks that We have asked them to carry out, on the
basis of Our instructions. They are required to maintain the confidentiality and security of
your Personal Information. If required by applicable law, you may obtain a list of suppliers
who process your Personal Data.
Credit bureaus/debt collection agencies. Credit bureaus and debt collection agencies
are external companies that we use to help us check your creditworthiness (particularly
for orders with invoices) or to collect unpaid invoices, to the extent permitted by
applicable law.
Third party companies using your Personal Information for their own marketing
purposes. Except in situations where you have given your consent, we do not license or
sell your Personal Information to third party companies for their own marketing purposes.
Their identity will be disclosed at the time of requesting your consent.
Third party acquirers using Personal Information for legal reasons or as a result of a
merger/acquisition. We will disclose your Personal Information to third parties for legal
reasons or in the context of an acquisition or merger (see Section 5 for more details).
7. RETENTION OF YOUR PERSONAL DATA
We will take all reasonable steps to ensure that your personal data is only processed for
a minimum period of time. We do this using the following criteria:
(a) Nawhal's will make a copy of your personal data to identify you for as long as
i) we maintain a commercial relationship with you (for example if you have
subscribed to our newsletters and have not yet unsubscribed, as long as you have not
withdrawn your consent to use your personal data for marketing purposes)
ii) your personal data is necessary for any other purpose described in this
statement and we have a valid legal basis for doing so,
AND
b) the period prescribed for tax obligations or necessary to protect our rights plus one
additional year from the end of that period. This additional year is added if, just before the
end of the initial period, there is a claim that We still need the personal data. This period
will be used to determine a new date on which the data will be deleted, destroyed or
anonymised. It goes without saying that we may keep the data for as long as the
requirement makes it necessary.
8. DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA
We use various reasonable measures (described below) to ensure the confidentiality and
security of your Personal Data. Please note, however, that these protections do not apply
to information that you share in the public domain, for example on third-party social
networks.
Persons who may have access to your Personal Data. Your Personal Data will be
processed by our sta. or agents duly authorised to do so, on a "need to know" basis,
according to the specific purposes for which your Personal Data has been collected (e.g.
our sta. who deal with queries submitted to consumer services will have access to your
consumer file).
Measures taken in operating environments. We store your Personal Data in operating
environments that apply su.icient security measures to prevent unauthorised access.
We apply reasonable standards to protect your Personal Data. Unfortunately, the
transmission of information over the Internet is not completely secure and, although We
do everything in our power to protect your Personal Information, We cannot guarantee the
security of data during transmission via our websites/applications.
Measures we expect you to take. It is important that you too play your part in protecting
and securing your Personal Data. When you create an online account, be sure to choose
a password that cannot be easily guessed by others and never share your password with
anyone. You are responsible for keeping this password confidential and for any use made
of your account. If you are using a shared or public computer, never choose the
"remember my username/e-mail address or password" option and make sure you log out
of your account every time you leave the computer. We also recommend that you use the
privacy settings or controls that We o.er on our websites/applications.
Transfer of your Personal Data. The storage and processing of your Personal Data as
described above may require that your Personal Data is ultimately
transferred/transmitted (and/or stored) to a destination outside your country of residence
and We may also transfer your Personal Data to countries outside the European
Economic Area (EEA) (e.g. other Nawhal's entities or ad hoc local partners) including
countries which have di.erent data protection standards to those in the EEA, in which
case We (i) may transfer your Personal Data to a destination outside the EEA (e.g. other
Nawhal's entities or ad hoc local partners) We may also transfer your Personal Data to
countries outside the European Economic Area (EEA) (e.g. other Nawhal's entities or ad
hoc local partners) including countries which have di.erent data protection standards to
those in force in the EEA, in which case We will (i) have in place standard contractual
clauses approved by the European Commission to protect your Personal Data (and you
will have the right to request a copy of these clauses by contacting us as set out below)
and/or (ii) rely on your consent (where permitted by law).
9. ACCESS TO YOUR PERSONAL DATA
Access to your Personal Data. If required by law, you, your successors, representatives
and/or relatives have the right to access, review and request a physical or electronic copy
of the information held about you. You also have the right to request information about
the source of your Personal Data.
These rights may be exercised by emailing Us at infoconso@nawhals.com or by writing to
Our consumer service at the address of the data controller specified below and enclosing
a copy of your ID or equivalent information (if requested by Us and permitted by law). If
the information requested is provided by someone other than you, without providing proof
that the request is legitimately made on your behalf, the request will be rejected.
Please note that any identifying information provided to Us will only be processed in
accordance with and to the extent permitted by applicable law.
Additional rights (e.g. modification, deletion of Personal Data). You, your successors,
representatives and/or relatives may (i) request the deletion, portability, correction or
revision of your Personal Data, (ii) object to the processing of your data (e.g. for direct
marketing purposes), (iii) restrict the use and disclosure of your Personal Data and (iV)
revoke consent to any of our data processing activities.
Please note that, in certain circumstances, We will not be able to delete your Personal
Data without also deleting your user account. We may be required to retain some of your
Personal Data after you have requested deletion in order to fulfil our legal or contractual
obligations. We may also be permitted by applicable law to retain some of your Personal
Information for our business purposes.
10.YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
We strive to provide you with choices based on the Personal Information you have
provided to Us. The mechanisms below give you the following control over your Personal
Information:
Cookies/similar technologies. You manage your consent via (i) our consent
management solution or (ii) your browser to refuse some or all cookies/similar
technologies, or to request to be notified when they are used. See Section 3 above.
Advertising, marketing and promotions. If you wish your Personal Information to be
used by Nawhal's to promote its products or services, you may indicate this by checking
the appropriate box(es) on the registration form or by responding to the question(s) posed
by our sales representatives, consumer service representatives or sales sta.. If you
decide that you no longer wish to receive such communications, you can then
unsubscribe so that you no longer receive marketing communications at any time. To do
so, simply follow the instructions provided at the bottom of each communication. If you
no longer wish to receive marketing communications sent by any means, including third-
party social networks, you may opt-out at any time by logging into the websites/apps or
third-party social networks and changing your user preferences in your account profile by
unchecking the relevant boxes or by calling our Consumer Services. Please note that even
if you opt-out of marketing communications, you will still receive administrative
communications from Us, such as confirmations of orders or other transactions,
notifications about account activity (e.g. account confirmations, password changes, etc.)
and other important non-marketing announcements.
Customisation (oAline and online). If required by law, and if you want your Personal
Information to be used by Nawhal's to provide you with a customisation
experience/targeted advertising and content, you can indicate this by ticking the relevant
box(es) on the registration form or by answering the question(s) asked by our sales
representatives, or sales sta.. If you no longer wish to benefit from this, you may opt-out
at any time by logging into third-party websites/apps or social networks and changing your
user preferences in your account profile by unchecking the relevant boxes.
Consumer interest-based advertising. We partner with ad networks and other
advertising service providers ("Ad Providers") that serve ads on behalf of Us and other non-
a.iliated businesses on the Internet. Some of these advertisements are tailored to your
interests based on information collected over time on Nawhal's or non-a.iliated
websites. Visit www.aboutads.info/choices to learn more about this type of advertising,
as well as how to opt out of interest-based advertising practices from companies that
participate in the Digital Advertising Alliance (DAA) self-regulatory programme. In
addition, you can object to this type of advertising in the mobile applications of
companies participating in the DAA's AppChoices app by downloading the app from the
iOS or Android app store. You can also stop the collection of precise location data from a
mobile device by going to your device's location settings.
11.CHANGES TO OUR NOTICE
If We change the way We process your Personal Data, We will update this Notice.We
reserve the right to make changes to our practices and to this Notice at any time. Please
check this Notice regularly for updates or changes.
12.DATA CONTROLLERS AND CONTACT INFORMATION
To ask questions or make comments about this Notice and our privacy practices, or to
make a complaint about our compliance with applicable privacy laws, please contact our
Data Protection O.icer:
Abdeslam El Andaloussi
Nawhal's Group Data Privacy O.icer
+32 (0) 2 880 95 95
infoconso@nawhals.com
We will accept and investigate any complaint about the way in which We manage
Personal Data (including a complaint that We have failed to respect your rights under
applicable privacy laws).
Data controller
Magic Food BV
Willem Elsshotstraat 15-1
1800 Vilvoorde Belgique
Business Number BE : 0841.028.404
In charge of All card payment operations linked to a website or application.