In order to safeguard your privacy as much as possible, we adhere to the following core values:
Limited Collection: We take great care to limit the information we collect and use only that information which is necessary to sell our products and/or provide our services (as defined below).
Security: We take appropriate measures to secure your personal data and require the same from parties using your data on your behalf.
Right of Persons: We respect your rights under applicable privacy laws (including the right to access, correct or delete your personal data in accordance with such laws).
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
- PERSONAL DATA WE COLLECT AND USE
The personal information we collect about you when you purchase our Products or use our Services includes the following (collectively referred to as "Personal Information"):
Your contact details. Your name, postal address and other contact details, such as your telephone number and email address, and any other contact details you provide to us (including delivery address when you purchase our products online).
Your electronic identification data and other information we automatically collect when you use our online services. When you visit our website, use (open, click, read, cursor movements, etc.) our newsletter or are confronted with online marketing advertisements from Brouillon, we automatically collect data through your browser or device, using cookies and other technologies to track website visitors (including web analytics), such as your browsing habits, the products and services you like and the contents of your abandoned shopping cart.
Your online purchases. In order to complete your online purchases through the official Brouillon website or through other official Brouillon social media channels, we use your name, phone number, contact information and all relevant information about your purchases, such as the amount and date of your purchases, the product(s) you are purchasing, the device you are using to make your purchases, payment method, payment status, bank account information, promo codes, optional additional personal card or engraving information, delivery method and delivery address.
Your information when subscribing to our newsletter. To provide you with Brouillon's newsletter with inspirational and commercial content, we use your email address and additional information if you add it to your profile, such as name. Brouillon also sends personalized newsletters based on your personal preferences if you have provided them to us.
If you attend events or trade shows organized or attended by Brouillon, you may also be recorded when we take photo or video footage of such events or trade shows. If you call us with a question or complaint, your telephone conversations with us may be recorded.
Your Communication Data. Any data shared by you when you communicate with us via email, online, phone, social media or any other form, such as questions, requests or complaints.
Your data on lotteries, subscribing and winning, lead generation campaigns, competitions or trial promotions. Any data you share when you participate in a lottery, sales promotion campaign, contest or trial, or subscribe and win.
Your ratings, reviews and feedback. The opinions, experiences, preferences and interests and product or event reviews that you publish on our websites, share with us online or through social media.
2. PURPOSES OF USE OF PERSONAL DATA
The Personal Data we collect is used only for the following purposes:
For the performance of our contract with you: To carry out our obligations arising from contracts between you and us and to provide you with the products, services and information you request, including managing and dealing with your requests, queries or complaints. This also includes enabling you to purchase our products, responding to your requests for customer service, responding to your enquiries, providing essential information about our products and services that you request etc.
For our legitimate commercial interests: We use your Personal Data as described above (both on an aggregate and individual basis) for the purpose of advertising our products and services, contacting you via email, regular mail, social media or other channels for direct marketing or other commercial purposes. We also use your Personal Data to analyze and improve the quality of our products and services, such as providing customer service and after-sales, and to understand you as a customer (customer optimization). This allows us to find out what may interest you, to measure and understand the effectiveness of ads we serve to you and others, and to deliver relevant ads. In addition, based on your use of our services and products you have purchased, we may approach you with advertisements or other marketing materials that are customized to your personal preferences and experiences.
We may also use your personal data for our other legitimate commercial interests, such as to operate and expand our business operations; to develop and improve or customize our products and services; to generate aggregate statistics about the users of our products and services; to enable our business operations; to carry out Company policies and procedures; to enable us to conduct business transactions, such as a merger, sale, reorganization, transfer of Brouillon's assets or business, acquisition, bankruptcy or similar event; or for other legitimate business purposes permitted by applicable law.
Use of information based on your consent:
If you have not purchased a product from us, we will only send you direct marketing messages (such as newsletters, promotions, product news or service updates) by email, other electronic means, by telephone or by regular mail (such as leaflets), after obtaining your consent to do so.
Children under the age of 16 cannot legally give consent. Instead, consent from their parent or legal guardian must be provided.
You may withdraw your consent at any time (see Your Rights section below).
To comply with our legal obligations: Any Personal Data we collect may be used to comply with a legal obligation to which we are subject, such as regulatory, tax or investigative authorities.
3. SOCIAL MEDIA
If you participate in various social media forums such as Facebook, Twitter, Pinterest, Instagram, LinkedIn, etc., you should be familiar with and understand the tools of those sites so that you can make choices about how to share the personal data in your social media profile(s).
Depending on the choices you have made regarding your settings on various social media sites (and/or in combination with your settings on the Brouillon pages), certain personal data may be shared with Brouillon about your online activities and social media profiles (e.g. interests, marital status, gender, username, photo, comments and content you have posted/shared etc.).
4. SHARING OF YOUR PERSONAL DATA
We share your Personal Data with the following parties:
Third Party Suppliers. We occasionally contact third parties to help us provide our products and services to us, including:
- Business partners, suppliers (such as IT service providers) and subcontractors;
- Advertising and media companies that perform marketing and media activities for us;
- Providers of analysis services and search engines that help us to improve and optimise our website.
In providing their services, they will access, receive, maintain or otherwise process personal data on our behalf. Our contracts with these service providers do not permit the use of your personal data for their own (marketing) purposes. In accordance with applicable legal requirements, we take commercially reasonable steps to require third party suppliers to adequately protect your personal data and process it only in accordance with our instructions.
Business Transaction. In addition, Personal Data may be released as part of a merger, sale or transfer of Brouillon's business assets.
Third parties in case of a legal requirement. We may disclose your personal information if we believe disclosure is required by law.
With consent. We may also disclose information about you, including personal information, to another third party, where you have consented or requested that we do so, for example in the case of a promotional campaign with another sponsor.
5. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
In most cases, your personal data will be processed within the European Union. However, please note that Brouillon may transfer and process any personal data you provide to us to countries other than the country where you are resident. The laws of these countries may not provide the same level of protection for your personal data. Brouillon or third party suppliers we use will therefore ensure that all appropriate safeguards are taken and that all applicable laws and regulations are complied with in relation to such transfers, more specifically for personal data transferred to countries outside the European Economic Area. This means that we have entered into legally necessary contracts with recipients of your data, including standard contractual clauses as approved by the European Commission or other supervisory authorities where required.
You are entitled to receive a copy of all documentation showing the appropriate security measures taken by making a request to us.
We will take reasonable steps to ensure that your Personal Data is properly secured using appropriate technical, physical and organizational measures to protect it from unauthorized or unlawful use, modification, unauthorized access or disclosure, accidental or unlawful destruction and loss.
7. DATA RETENTION
We retain your Personal Data for as long as necessary to fulfill the purpose for which it was collected and used (e.g., for as long as it takes to provide you with customer service, answer questions, or resolve technical issues), unless a longer period is necessary for our legal obligations or to defend a legal claim.
8. YOUR RIGHTS
Subject to the conditions set out in applicable law, you have the following rights in relation to our processing of your Personal Data:
Right of access - You have the right to request confirmation if Brouillon is processing personal data about you, and if so, access to the personal data and additional information. Upon request, we can also provide you with a copy of the personal data being processed;
Right to rectification - You have the right to request that Brouillon correct, amend or supplement your Personal Data if we have incorrect or incomplete information about you. You may also correct, amend or supplement your Personal Data yourself by updating your profile. We also kindly request that you ensure that changes in personal circumstances (such as changes of address, bank account, etc.) are reported to Brouillon so that we can ensure that your personal data is up to date. Brouillon will take all reasonable steps to ensure that all Personal Data is accurate;
Right to withdraw consent - You have the right to withdraw your consent to receive marketing communications at any time by following the instructions in a marketing communication or by contacting us. If we use your Personal Data based on your consent for reasons other than marketing communications, you may withdraw your consent by contacting us;
Right to erasure - You have the right to request the erasure of any irrelevant Personal Data that we hold about you where (i) the data is no longer needed in connection with the purposes for which it was collected; (ii) you withdraw your consent and there is no other legal basis for processing; (iii) you object to the processing in the case of direct marketing purposes, or - in all other cases - there is no overriding legitimate reason for processing; (iv) we have processed your data unlawfully. If you have such a request and all requirements are met, we will ensure that Brouillon deletes the data that we are not legally obliged to retain;
Right to limit data use - You have the right to limit our use of your Personal Data where (i) you dispute the accuracy of the Personal Data; (ii) the use is unlawful but you do not want us to delete the data; (iii) we no longer need the Personal Data for the relevant purposes but you need it for the establishment, exercise or defense of legal claims; or (iv) where you object to data use on the basis of our legitimate interests pending verification that Brouillon does indeed have compelling interests to continue the relevant data use;
Right to Data Portability - to the extent that we use your Personal Data to perform a contract with you and that Personal Data is processed automatically, you have the right to receive all such Personal Data that you have provided to Brouillon in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller when technically possible;
Right to Object - to the extent that we depend on our legitimate interests to use your Personal Data, you have the right to object to such use and we must cease such processing unless we can demonstrate compelling legitimate grounds for the use which infringes your interests, rights and freedoms, or where we need to process the data for the establishment, exercise or defense of legal claims. You also have the right to object to profiling activities carried out by Brouillon;
For more information about your rights, or how to exercise them, please contact us using the contact form.
Enter all email addresses that you use and have used for all related Brouillon services, but not limited to newsletter sign-up and purchase details.
Upload a copy of your ID card/passport, from which you have blacked out all information that is not required to identify you, which is everything except your first name and last name. For clarity, please black out the following information:
- Citizen's service number (please note that on some identity cards/passports this number is given in 2 different places);
- Document number;
- Date of Birth;
- Issue date;
- Expiration Date.
Upon receipt of all information as set out above, we will respond to your request in accordance with applicable law.
9. POLICY CHANGES
10. CONTACT US