Personal Data may be collected in the following situations: 

• When You visit the Vorwerk Sites and use their features, certain Personal Data relating to You may be collected as a Visitor to the Vorwerk Sites in order to maintain and improve the Vorwerk Sites; 
• As part of managing our commercial relationship and in particular when placing an order, certain Personal Data relating to You may be collected as a Customer of Vorwerk; 
• As part of managing our relationship with prospects (contact, online forms or via Advisors, follow-up of commercial prospecting, etc.) certain Personal Data relating to You may be collected; 
• During visits to Vorwerk locations (head office, agencies, stores, etc.), certain Personal Data relating to You may also be collected. 
• When you wish to join Vorwerk and apply to become a Vorwerk employee or Advisor, certain Personal Data may be collected. 

In any case, Vorwerk only collects Personal Data that is strictly necessary for the purposes of its activities. Therefore, only relevant, adequate information is collected, limited to what is necessary in relation to the purposes for which it is processed. 

The Personal Data collected from You and processed by Vorwerk or its Subcontractors are for specific, explicit and legitimate purposes and are likely to vary depending on the context of the collection.

3.1. Vorwerk Website Management

Purpose: Security and improvement of navigation on Vorwerk sites

Data collected: Connection information, device used, preferences and security settings, browser, plug-ins used or even the operating system

Legal basis: Legitimate interest

Recipients or categories of Recipients: Web service provider, host

Purpose: Analysis of interactions and development of statistics on Vorwerk Sites

Data collected: Content, locations, pages consulted

Legal basis: Consent

Recipients or category of Recipients: Web service provider

Purpose: Creation of a user account on the Vorwerk Sites

Data collected: Identification data (surname, first name, date of birth) and contact details (email address, telephone number)

Legal basis: Consent

Recipients or category of Recipients: Your Advisor

3.2. Marketing, prospecting and demonstration

Purpose: Management of communication and prospecting operations, regardless of the means used (emails, letters, newsletters, telephone, text messages, etc.)

Data collected: Identification data (surname, first name) and contact details (email address, postal address, telephone number)

Legal basis: Consent

Recipients or categories of Recipients: Your Advisor

Important: During demonstrations of Vorwerk products, certain data relating to your health may be collected. 

If you request a demonstration of a food preparation appliance, you may inform the responsible Vorwerk Advisor of your food allergies or intolerances. This information is passed on to prevent dishes that you cannot eat from being prepared during the product demonstration. 

If you provide this information to the responsible Vorwerk Advisor, it will be stored by the Vorwerk Advisor in the section reserved for them on the platform we use for the management of product demonstrations and sales. Only those who strictly need access, including your Advisor and their branch manager, can view this information. 

Your consent forms the legal basis on which we rely to collect and process this type of Personal Data. In any case, data on food allergies and intolerances will be deleted shortly after the product demonstration. 

3.3. Management of job applications

Purpose: Management of job application requests

Data collected: Identification data (surname, first name, date of birth), contact details (email address, postal address, telephone number), curriculum vitae

Legal basis: Consent

Recipients or categories of Recipients: Vorwerk

Purpose: Building a CV Library

Data collected: Identification data (surname, first name, date of birth), contact details (email address, postal address, telephone number), curriculum vitae

Legal basis: Legitimate interest

Recipients or categories of Recipients: Vorwerk

3.4. Placing and managing order

Purpose: Placing and managing an order and delivery

Data collected: Identification data (surname, first name), contact details (email address, postal address, telephone number)

Legal basis: Contractual performance

Recipients or categories of Recipients: Your Advisor, our delivery service provider, our external logistics partners

Purpose: Request for financing

Data collected: Identification data (surname, first name), contact details (email address, postal address, telephone number) and financial data

Legal basis: Contractual performance

Recipients or categories of Recipients: Financing partner

Purpose: Remote payment by bank card

Data collected: Card number, expiration date, visual cryptogram

Legal basis: Contractual performance

Recipients or categories of Recipients: Remote payment service provider

Purpose: Follow-up of invoice payment via internal customer information form

Data collected: Identification data (surname, first name, date of birth), contact details (e-mail address, postal address, telephone number) and financial data

Legal basis: Legitimate interest

Recipients or categories of Recipients: Vorwerk

Purpose: Management of banking complaints

Data collected: Identification data (surname, first name), contact details (email address, postal address, telephone number), card number

Legal basis: Legal obligation

Recipients or categories of Recipients: Remote payment service provider

3.5. Post-contractual or pre-contractual relationship

Purpose: Collection of Customer reviews

Data collected: Identification data (surname, first name), contact details (email address, telephone number)

Legal basis: Legitimate interest

Recipients or categories of Recipients: Vorwerk

Purpose: After-sales customer service

Data collected: Identification data (surname, first name), contact details (email address, postal address, telephone number) and billing data

Legal basis: Contractual performance and legal obligation

Recipients or categories of Recipients: Vorwerk, our external repair service providers

Purpose: Quality improvement and training of customer service employees

Data collected: Identification data (surname, first name), contact details (email address, postal address, telephone number) and billing data

Legal basis: Legitimate interest

Recipients or categories of Recipients: Vorwerk, our external call center service providers

Purpose: Contact for demonstration of Vorwerk products in Benelux

Data collected: Identification data (surname, first name), contact details (e-mail address, postal address, telephone number) and data relating to food intolerances and allergies

Legal basis: Contractual performance

Recipients or categories of Recipients: Your Advisor

Exclusively for the purpose of quality improvement and training of our customer service, Vorwerk Benelux may record certain telephone calls with its customer service. If this is the case, you will always be informed by telephone in advance during the call. These recordings are not kept for longer than thirty (30) days for this purpose and are only accessible to authorised employees.

3.6. Combating fraud and non-payment

Purpose: Creating a database of Customers with payment arrears

Data collected: Identification data (surname, first name); contact details (postal address, email address, telephone number), payment methods

Legal basis: Legitimate interest

Recipients or categories of Recipients: Vorwerk

Purpose: Combating fraud and insolvency

Data collected: Identification data (surname, first name); contact details (postal address, email address, telephone number), payment methods

Legal basis: Legitimate interest

Recipients or categories of Recipients: Financing partner

In accordance with the regulations on Personal Data, Vorwerk stores Your Personal Data for the period that is strictly necessary to achieve the purposes of this privacy policy, unless You have given Vorwerk permission to store Your Personal Data for a longer period. 

The retention period may be based on the specific circumstances of the Processing, regulations that require information to be kept for a certain period, or statutory limitation periods relating to disputes. Where a limitation period is laid down by law, the retention period may not be shorter than that period. 

As Data Controller, Vorwerk undertakes to comply with the retention periods imposed by the applicable regulations. 

With regard to orders of Vorwerk products: Your Personal Data may not be retained longer than is strictly necessary for managing the commercial relationship. It may be retained for commercial prospecting purposes, for similar or non-similar products if you have given your consent for this, for a period of three (3) years from the end of the commercial relationship (i.e. the expiry of the contractual warranty on our products) or from the last contact with Vorwerk initiated by you. At the end of this period, Vorwerk may contact you again to ask whether you wish to continue receiving commercial offers. 

With regard to requests for contact and information, demonstrations, workshops, and the sending of newsletters and commercial offers: Vorwerk retains your Personal Data for up to three (3) years after the last contact with Vorwerk initiated by you. 

All accounting and tax-related information, including in particular purchase orders and invoices, may be retained for ten (10) years from the end of the financial year in which the sales contract was concluded, on the basis of Vorwerk’s legal obligations. 

Recordings of the Vorwerk Benelux telephone customer service are kept for a period of thirty (30) days from the date of the telephone contact with customer service. 

All data collected in the context of recruitment are kept for a period of two (2) years from the date of submission or from the last contact with you. 

At the end of the relevant statutory limitation period, the Personal Data will be destroyed or irrevocably anonymised so that you, as the Data Subject, are no longer identifiable in any way. 

For questions about the retention period of certain types of Personal Data that we process, you can contact the Data Protection Officer at the following address: dpo_be@vorwerk.com . 

Since your Personal Data is confidential, only persons and entities within the Vorwerk group authorised by Vorwerk may access it, where this is necessary in the context of our activities and in particular for managing your orders. 

As part of providing our services, we may transfer Personal Data to entities other than Vorwerk or to service providers who will act as Processors. In all cases, the sharing of your Personal Data is carried out in accordance with the applicable legislation and will be limited to what is strictly necessary to achieve the purposes set out in this privacy policy. 

5.1 Relevant categories of persons and/or entities 

The Personal Data concerning you that is collected by Vorwerk may be intended for the following categories of persons and/or entities: 

• For Vorwerk staff who are authorised to process Personal Data; 
• For other entities of the Vorwerk Group (in particular Vorwerk International Strecker & Co, Verenastrasse 39, 8832 Wollerau, Switzerland) and their authorised staff. During the sales processes of Vorwerk products, you have the option to subscribe to other services provided by Vorwerk entities, such as the Thermomix recipe platform (Cookidoo®) and the Thermomix® app, both offered by Vorwerk International Strecker & Co. 

Please note that in this case specific data protection notices may be communicated to you. You can consult the privacy policy of the Thermomix® recipe platform (Cookidoo®) and the Thermomix® application on the Vorwerk Sites. 

• For Vorwerk Processors, such as: 

o Website hosting providers; 

o Communication service providers; 

o Marketing service providers for the organisation of competitions, satisfaction surveys, commercial campaigns and loyalty programmes, or for sending messages and newsletters; 

o Service providers who create links to a form to be contacted by a Consultant or to a page on the Vorwerk Sites; 

o Targeted advertising and paid referral service providers; 

o Service providers appointed by Vorwerk for the performance of sales contracts with you, involved in the provision of services that are ancillary to the performance of these contracts, such as delivery service providers, remote payment on the Vorwerk Sites; 

o Financial institutions for the management of consumer loans for the purchase of Vorwerk products and payment institutions; 

o Service providers responsible for assessing information relating to payment incidents, credit or the initiation of legal proceedings for the purposes of combating fraud and non‑payment; 

o Service providers responsible for collecting opinions from our Customers after a purchase; 

o Software service providers, repair service providers, logistics partners; 

o Debt collection agencies, fraud prevention organisations, etc. 

• For Advisors affiliated with Vorwerk. 

All persons or entities that have access to your Personal Data are bound by a duty of confidentiality and security. Vorwerk has carefully selected these Processors and constantly ensures that they comply with Vorwerk’s instructions. These companies are contractually not authorized to use Your Personal Data for purposes other than those set out in this privacy policy. 

5.2 Processing of Your Personal Data by Vorwerk Advisors 

In the context of product purchases, a Vorwerk Advisor will act as a Processor on our behalf and will collect and process Your Personal Data. 

Vorwerk Advisors may collect Your identification data (first name and last name) and Your contact details (email address, postal address, telephone number) as well as purchase data (Your product interests) so that we can process Your contact or purchase requests. 

Your data will be collected by Your Advisor in the context of sales made at home, and will be transferred to Your Advisor during sales made on the e-shop. If you indicate that you do not yet have an Advisor at the time of purchasing Thermomix devices from Vorwerk, an Advisor will be assigned to You after the purchase. This Advisor will contact You to schedule a demonstration of your purchased product in connection with your right to a demo following the purchase of certain Thermomix products. This right to a demo arises from the purchase of certain Thermomix products under the conditions set out in Vorwerk’s general terms and conditions. The Customer has the right at all times to refuse the demo. 

The processing of your contact details for organizing this demonstration is based on the performance of the contract concluded with you and the resulting right to a demo as an additional optional service (Article 6.1(b) GDPR). In this context, Your Advisor acts as a processor on behalf of Vorwerk, on the basis of a data processing agreement in accordance with Article 28 GDPR, and acts solely in accordance with Vorwerk’s instructions. 

5.3 Transfer of Personal Data to the authorities 

Certain Personal Data may also be transferred to legally authorized authorities in order to comply with the legal, regulatory, or contractual obligations to which Vorwerk is subject. 

The Recipients of Personal Data as mentioned above may be located outside the European Economic Area. Information thus transferred to third countries may be subject to legitimate access requests from local authorities on the basis of the applicable laws in those countries. 

Vorwerk makes every effort to select partners that provide guarantees in terms of security and confidentiality and to enter into contractual relationships that are in line with regulations, in particular those at the European level. 

Unless the country to which the Personal Data are transferred has been qualified by the European Commission as a country offering an adequate level of protection for Personal Data, Vorwerk requires these Recipients to comply with the data protection measures laid down in the applicable regulations. This can, for example, be achieved by concluding an agreement for cross‑border data flows that is drawn up in accordance with the standard contractual clauses from Controller to Processor issued by the European Commission and currently in force, and by implementing additional technical and organizational measures to ensure the protection of these data. 

Vorwerk remains vigilant with regard to the activities of the European Commission and will apply any 

new measure required by a future decision on the level of protection of Personal Data. 

You may request a copy of these clauses from the Data Protection Officer at the following address: dpo_be@vorwerk.com 

As part of some of its commercial prospecting campaigns, with Customers for similar products or those who have given their consent for this, Vorwerk may use the services of a Processor in order to better target people who are likely to be interested in this advertising. This Processor (Google Analytics, Google Ads) carries out profiling of the data of Vorwerk Customers and prospects, based on purchase‑intent predictions and your browsing behavior on the website. More information about the use and retention periods of marketing Cookies can be found in our Cookie Policy (https://benelux.thermomix.com/en/cookie-policy). 

To minimize the operations carried out on Your data and to protect them better, the data that Vorwerk passes on to its Processor are pseudonymized, so that they are non‑identifiable for the Processor that receives and uses them on behalf of Vorwerk. 

This Processing is intended to better target the audience of Vorwerk’s marketing campaigns and thus to limit the number of commercial requests that You are likely to receive. 

Where applicable, a data protection impact assessment to ensure the respect of Your fundamental rights and freedoms has been carried out by Vorwerk in relation to this Processing. 

As a Data Subject in relation to the Processing of Personal Data, You have several rights. These, however, are not absolute and are subject to certain conditions, in accordance with the regulations on Personal Data. 

8.1 Right to information 

Vorwerk undertakes to inform you about the collection and use of your Personal Data and therefore ensures that concise, transparent and accessible information is provided about the conditions and methods of the collection and Processing of Personal Data. 

 8.2 Right of access 

You have the right to access Personal Data relating to you, free of charge and at any time, so that you can obtain information about the existence of the Processing, the methods thereof, the categories of Personal Data that are processed, the Recipients of the Personal Data, the period during which your Personal Data is stored, and the rights you can exercise in accordance with the GDPR.

You also have the right to obtain a copy of your Personal Data as stored by Vorwerk. 

8.3 Right to rectification 

You may request Vorwerk to rectify your Personal Data, especially when it is no longer up to date or is incomplete. 

8.4 Right to object 

You have the right at any time, on grounds relating to your particular situation, to object to the Processing of Personal Data relating to you. 

The right to object is limited by Vorwerk’s legitimate interest in the Processing of Personal Data and other legal requirements. 

You have the right not to be subject to a decision based solely on automated Processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. 

In addition, you always have the right to object to the use of Personal Data for direct marketing purposes, in which case you do not have to provide any reasons. 

8.5 Right to erasure of Personal Data (or “right to be forgotten”) 

As a Data Subject, you have the right to have your Personal Data erased by Vorwerk if one of the following conditions applies: 

• When the data is not or is no longer necessary for the purposes for which it was collected or otherwise processed; 
• When you withdraw the consent on which the Processing is based and there is no other legal ground for the Processing; 
• When you believe that the Processing of your data is unlawful; 
• When the data must be erased on the basis of a legal obligation laid down by Union law or the law of the Member State to which Vorwerk is subject; 
• When you have objected to the Processing of data and Vorwerk has no legitimate or compelling reason to refuse the request. 

8.6 Right to restriction of the Processing of Personal Data relating to you 

As a Data Subject, you have the right to obtain restriction of processing from Vorwerk if one of the following conditions applies: 

• When the accuracy of the data is contested, and for a period enabling Vorwerk to verify the accuracy of the data; 
• When the Processing is unlawful and you oppose the erasure of your data and instead request the restriction of the Processing; 
• When the data are no longer necessary for the purposes for which they were collected, but you need them for the establishment, exercise or defence of legal claims; 
• When you object to Processing based on Vorwerk’s legitimate interest, during the verification of whether Vorwerk’s legitimate grounds override yours. 

8.7 Right to data portability 

You may obtain from Vorwerk the Personal Data you have previously provided to it in a structured, commonly used and machine-readable format. 

You may also transfer this data to another Controller or request that the Personal Data be directly transferred by Vorwerk to another Controller, where technically feasible. 

8.8 Right to withdraw consent 

You may withdraw your consent at any time when your Personal Data are processed on the basis of that consent. The withdrawal of your consent is only effective for the future and therefore cannot call into question the lawfulness of the Processing carried out before this withdrawal. 

8.9 Right to lodge a complaint with a supervisory authority 

If you believe that your rights have not been respected, you have the right to lodge a complaint with a supervisory authority, namely the Data Protection Authority (Gegevensbeschermingsautoriteit): 

Gegevensbeschermingsautoriteit 

Drukpersstraat 35, 1000 Brussel 

Telefoon: +32 (0)2 274 48 00 

Faxnummer: +32 (0)2 274 48 35 

Email: contact@apd-gba.be. 

This does not affect your right to bring an action before a civil court. If you have suffered damage as a result of the Processing of your Personal Data, you may claim compensation. 

8.10 Right to decide on the fate of data after death 

You have the right to arrange the fate of your data after your death by setting out general or specific guidelines by sending your written instructions to the email address of the Data Protection Officer: dpo_be@vorwerk.com. 

8.11 Right not to be subject to an automated decision 

In accordance with the regulations on Personal Data, you have several rights with regard to automated decision-making: 

• The right to obtain human intervention from the Controller: this means that you can request a review of an automated decision by one of our authorized employees; 
• The right to express your point of view on the automated decision; 
• The right to contest this automated decision. 
• Please note that exercising these rights will not necessarily result in the revocation of the decision taken through the automated process. 

Please also note that we have no influence over the processes used by credit rating agencies to issue the credit score that will be communicated to us. 

You can exercise your rights or lodge a complaint regarding the Processing of your Personal Data by contacting us at the following address: dpo_be@vorwerk.be or benelux@customercare.vorwerk.com ; or: Vorwerk – 1800 Vilvoorde, Mechelsesteenweg 586 C. 

Vorwerk may, if necessary, ask for a copy of an identity document. The level of checks carried out by Vorwerk when processing requests to exercise rights varies depending on the nature of the requests, the sensitivity of the information communicated, and the context in which the request is made. 

Vorwerk undertakes to respond to every request as quickly as possible, and in any case within one (1) month of receipt of the complete request. However, this period may be extended by two (2) months, taking into account the complexity and/or number of requests received. 

Vorwerk makes every effort to implement appropriate technical and organizational measures that are 

adapted to the sensitivity of the data collected in order to ensure confidentiality and to prevent destruction, loss, alteration, unauthorized access or disclosure to Third Parties and any other unauthorized or unlawful Processing of the Personal Data collected. 

When the disclosure of Personal Data to Third Parties is necessary and permitted, Vorwerk ensures that these Third Parties offer the same level of protection as that provided by Vorwerk and requests contractual guarantees so that, in particular, the Personal Data are processed solely for the purposes that You have previously accepted, with the required level of confidentiality and security. 

Under no circumstances can we be held liable for direct or indirect damage resulting from the improper or unlawful use of the Personal Data by Third Parties. 

Since all Personal Data are confidential, access to them is limited to authorized persons or service providers acting on behalf of Vorwerk who need this data in the context of their duties. All persons who have access to Your Personal Data are bound by a contractual confidentiality clause and may be subject to disciplinary measures and/or other sanctions if they do not comply with these obligations. 

In the event of a proven Personal Data breach that is likely to result in a high risk to the rights and freedoms of the Data Subjects, Vorwerk undertakes to report this breach to the competent supervisory authority and, where required by Personal Data regulations, to the Data Subjects (individually or generally, depending on the case). 

The Vorwerk websites may contain links, in particular hypertext links, and/or offers from partners that refer to a Third-Party website. 

Vorwerk has no control over the content of Third-Party websites or the practices of these Third Parties with regard to the protection of Personal Data that they may collect and disclaims all responsibility for such content and practices. It is Your responsibility to inform Yourself about the privacy policy of these Third Parties. 

You can always reach us using the following contact details: 

Vorwerk Benelux BV 

Company number: 1005.465.871. 

Address: Mechelsesteenweg 586 C 

1800 Vilvoorde, België 

Email: benelux@customercare.vorwerk.com 

Vorwerk has also appointed a data protection officer. For questions relating to Vorwerk’s 

obligations regarding the protection of your personal data, or for complaints, you can contact 

Vorwerk’s data protection officer at: dpo_be@vorwerk.com .