Last updated: October 4, 2024

 

This Privacy Policy describes how MyComfort24 (the 'Site', 'we', 'us', or 'our') collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from mycomfort24.be (the 'Site') or otherwise communicate with us about the Site (collectively, the 'Services'). For the purposes of this Privacy Policy, 'you' and 'your' refer to you as the user of the Services, whether you are a customer, website visitor, or any other individual whose information we have collected under this Privacy Policy.

Please read this Privacy Policy carefully.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the updated Privacy Policy on the Site, revise the 'Last updated' date, and take any other steps required by applicable law.

How we collect and use your personal information

To provide the Services, we collect personal information about you from various sources, as detailed below. The information we collect and use depends on your interactions with us.

In addition to the specific uses outlined below, we may use the information we collect about you to communicate with you, provide or improve the Services, comply with any applicable legal obligations, enforce applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

What personal data we collect

The type of personal data we obtain about you depends on your interactions with our Site and your use of our Services. When we use the term 'personal data', we mean data that identifies you, relates to you, describes you, or can be associated with you. The following sections describe the categories and specific types of personal data we collect.

Information we collect directly from you

Information you provide directly to us through our Services may include:

• Contact information including your name, address, phone number, and email address.
• Order information including your name, billing address, shipping address, payment confirmation, email address, and phone number.
• Account information including your username, password, security questions, and other information used for account security.
• Shopping information including the items you view, add to your cart, save to your account, such as loyalty points, reviews, referrals, or gift cards, or purchases.
  • Loyalty points/product reviews/referrals/gift cards
• Customer support information including the information you wish to include in communications with us, for example, when you send a message through the Services.

Some features of the Services may require you to provide us directly with certain information about yourself. You may choose not to provide this information, but in that case, you may not be able to use or access these features.

Information we collect about your use

We may also automatically collect certain information about your interaction with the Services ('Usage Data'). For this purpose, we may use cookies, pixels, and similar technologies ("Cookies'). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address, and other information about your interaction with the Services.

Information we obtain from third parties

Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

• Companies that support our Site and Services, such as Shopify.
• Our payment processors, who collect payment data (e.g., bank account, credit card, or debit card information, billing address) to process your payment, fulfill your orders, and provide the products or services you requested, so that we can fulfill our contract with you.
• When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties with whom we work, may automatically collect certain information using online tracking technologies, such as pixels, web beacons, software development kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. Please also refer to the section below, Third-party websites and links.

How we use your personal information

• Provision of products and services. We use your personal data to provide you with the Services in accordance with our agreement with you, including processing your payments, fulfilling your orders, sending notifications regarding your account, purchases, returns, exchanges, or other transactions, creating, maintaining, and otherwise managing your account, arranging shipping, facilitating returns and exchanges, and other features and functionalities related to your account. We may also enhance your shopping experience by enabling Shopify to match your account with other Shopify services you might wish to use. In this case, Shopify processes your data as set out in its Privacy Policy and Consumer Privacy Policy.
• Marketing and advertising. We may use your personal data for marketing and promotional purposes, such as sending marketing, advertising, and promotional communications via email, SMS, or post, and to display advertisements for products or services. This may involve using your personal data to better tailor the Services and advertisements on our Site and other websites. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in selling our products, in accordance with Art. 6 (1) (f) GDPR.
• Security and fraud prevention. We use your personal data to detect, investigate, or take action on potential fraudulent, illegal, or malicious activities. If you choose to use the Services and register an account, you are responsible for keeping your account login credentials secure. We strongly advise you not to share your username, password, and other access details with anyone else. If you believe your account has been compromised, please contact us immediately. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in keeping our website secure for you and other customers, in accordance with Art. 6 (1) (f) GDPR.
• Communication and service improvement. We use your personal data to provide you with customer support and to improve our Services. This is in our legitimate interest to communicate with you, provide you with effective services, and maintain our business relationship with you, in accordance with Art. 6 (1) (f) GDPR.

Cookies

Like many other websites, we use cookies on our Site. Specific information about the cookies we use in connection with supporting our store with Shopify can be found at https://www.shopify.com/legal/cookies. We use Cookies to support and improve our Site and Services (including to remember your actions and preferences), to perform analytics, and to gain better insights into user interaction with the Services (in our legitimate interest to manage, improve, and optimize the Services). We may also allow third parties and service providers to use cookies on our Site to better tailor the services, products, and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can set your browser settings to delete or reject cookies. Please note that deleting or blocking cookies may negatively affect your user experience and may cause some Services, including certain features and general functionality, to not work correctly or to no longer be available. Furthermore, blocking Cookies may not fully prevent the way we share information with third parties, such as our advertising partners.

How we disclose personal data

In certain circumstances, we may disclose your personal data to third parties for contract performance, legitimate purposes, and other reasons covered by this Privacy Policy. Such circumstances may include:

• With vendors or other third parties who perform services on our behalf (e.g., IT administration, payment processing, data analysis, customer support, cloud storage, fulfillment, and shipping).
• With business and marketing partners to provide services and display advertisements to you. Our business and marketing partners will use your data in accordance with their own privacy statements.
• When you instruct, request, or otherwise authorize us to transfer certain data to third parties, for example, to deliver products to you or through your use of social media widgets or login integrations, with your consent.
• With our affiliates or otherwise within our group of companies, in our legitimate interests to run a successful business.
• In connection with a business transaction, such as a merger or bankruptcy, to comply with applicable legal obligations (including responding to subpoenas, search warrants, and similar requests), to enforce applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

We disclose the following categories of personal data and sensitive personal data about users for the purposes set out above in "How we collect and use your personal information" and "How we disclose personal data":

Category	Categories of Recipients
Identifiers such as basic contact information and certain order and account information Commercial information such as information about orders, shopping, and customer support Internet or other similar network activity, such as usage data Geolocation data such as locations determined by an IP address or other technical measures	Vendors and third parties who provide services on our behalf (such as internet providers, payment processors, fulfillment partners, customer support partners, and data analytics providers) Business and marketing partners Affiliates

We do not use or disclose sensitive personal data without your consent or for the purpose of inferring characteristics about you.

With your consent, we share personal data as follows to carry out advertising and marketing activities.

Third-party websites and links.

Our Site may contain links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated with or controlled by us, it is important that you read their privacy and security policies and other terms. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of the information on these sites. Information you provide in public or semi-public areas, including information you share on third-party social networks, may also be visible to other users of the Services and/or users of these third-party platforms, without restriction as to its use by us or by a third party. The inclusion of such links on our Site does not in itself imply an endorsement of the content on such platforms or of their owners or operators, except as stated in the Services.

Children's data

The Services are not intended for use by children, and we do not knowingly collect personal data about children. If you are the parent or guardian of a child who has provided us with personal data, you may contact us using the contact information below to request its deletion.

As of the effective date of this Privacy Policy, we do not have actual knowledge that we 'share' or 'sell' (as these terms are defined in applicable law) personal data of individuals under 16 years of age.

Security and retention of your data

Please note that no security measure is perfect or impenetrable, and we cannot guarantee 'perfect security'. In addition, data you send to us may not be secure during transmission. We advise you not to use unsecured channels to communicate sensitive or confidential information to us.

How long we retain your personal data depends on various factors, such as whether we need the data to maintain your account, to provide the Services, to comply with legal obligations, to resolve disputes, or to comply with other applicable contracts and policies.

Your rights

Depending on where you live, you may have some or all of the rights listed below regarding your personal data. However, these rights are not absolute and may only apply in certain circumstances, and in some cases, we may refuse your request, to the extent permitted by law.

• Right to access/know: You may have the right to request access to the personal data we hold about you, including details on how we use and share your data.
• Right to delete: You may have the right to request that we delete the personal data we hold about you.
• Right to correction: You may have the right to request that we correct inaccurate personal data we hold about you.
• Right to data portability: Under certain circumstances and with certain exceptions, you may have the right to receive a copy of the personal data we hold about you and to request that we transfer it to a third party.
• Right to opt-out of sale, sharing, or targeted advertising: You may have the right to request that we do not 'sell' or 'share' your personal data, or to opt-out of the processing of your personal data for purposes considered 'targeted advertising', as defined in applicable privacy laws. Please note that if you visit our Site with the Global Privacy Control opt-out preference signal enabled, we will, depending on your location, automatically treat this as a request to opt-out of the 'sale' or 'sharing' of information for the device and browser you are using to visit the Site.
• Restriction of processing: You may have the right to ask us to stop or restrict the processing of personal data.
• Withdrawal of consent: Where we rely on your consent to process your personal data, you may have the right to withdraw this consent.
• Appeal: You may have the right to appeal our decision if we refuse to process your request. You can do this by responding directly to our refusal.
• Manage communication preferences: We may send you promotional emails, and you can opt-out of receiving them at any time by using the unsubscribe option included in the emails we send you. If you unsubscribe, we may still send you non-promotional emails, such as emails about your account or orders you have placed.

You can exercise any of these rights where indicated on our Site or by contacting us using the contact information below.

We will not discriminate against you for exercising any of these rights. We may need to collect information about you to verify your identity, such as your email address or account details, before responding substantively to the request. In accordance with applicable law, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before we accept such a request from an authorized agent, we require the authorized agent to provide proof of this authorization to act on your behalf, and we may ask you to verify your identity directly with us. We will respond to your request in a timely manner, as required by applicable law.

Complaints

If you have any complaints about how we process your personal data, you can contact us using the contact information below. If you are not satisfied with our response to your complaint, you have the right, depending on your location, to appeal our decision by contacting us using the contact information below, or to lodge your complaint with your local data protection authority. For the EEA, you can find a list of the responsible supervisory data protection authorities here .

International Users

Please note that we may transfer, store, and process your personal data outside the country in which you reside. Your personal data will also be processed by personnel and external service providers and partners in these countries.

If we transfer your personal data outside Europe, we rely on recognized transfer mechanisms such as the European Commission's standard contractual clauses, or equivalent contracts issued by the relevant competent authority of the United Kingdom, where relevant, unless the data is transferred to a country that has been deemed to provide an adequate level of protection.

Contact

If you have any questions about our privacy practices or this privacy policy, or if you wish to exercise any of the rights available to you, please call or email us at gdpr@mycomfort24.be or contact us at Jean Jacminstraat 176, Halle, 1500, BE.

Under applicable data protection laws and unless explicitly stated otherwise, we are the data controller for your personal data.

 

 

Below you will find Intimates BV's previous privacy policy.

Guarantee regarding lawful and secure processing of personal data

 

At MyComfort24, we attach great importance to protecting your privacy. Therefore, we want to inform you as much as possible, respect, and give you control over what happens to personal data. We want to manage and use them safely and respectfully, like a good parent. This allows us to serve you better and provide the best possible experience. We start from the principle that everyone should have control over their personal data, and that everyone has the right not to share some of this with us. We commit ourselves never to pass on your data to third parties.

Below you will find information about what personal data we collect, why, and for how long. You will also learn how you can control this. Feel free to take the time to read our Cookie Policy and our General Terms and Conditions. This privacy policy applies to the websites www.mycomfort24.be, www.mycomfort24.nl and the internal operations of MyComfort24. It includes information about the personal data MyComfort24 collects and how MyComfort24 uses and processes this data.

MyComfort24 has taken sufficient technical and organizational measures to guarantee secure processing of your personal data. These measures correspond to the nature of the personal data and are proportionate to the severity of the potential risk. The risk of accidental or unauthorized destruction, loss, alteration, or access to and any other illegal processing of the data has been minimized. Unfortunately, not every risk can be completely avoided. If illegal access is obtained to MyComfort24's IT systems, we will immediately take all possible measures to minimize damage to and/or theft of the data, and we will always inform the data subjects in a timely manner.

 

Who is protected by this Privacy Policy?

persons who have requested a quote, applicants, our staff, our suppliers and our customers. This privacy policy also applies when you come into contact with MyComfort24's services in the context of prospecting, or when you visit our office.

The law of 8 December 1992 ('Privacy Act'), the law of 13 June 2005 ('Electronic Communications Act'), the requirements in the regulation for the European Parliament and the European Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, and the associated implementing decrees regulate the protection of your personal data.
We commit to fulfilling our obligations and respecting your rights every time we process your data. If you want to delve deeper into this topic, please consult the website of the Commission for the Protection of Privacy.

 

What does data processing mean?

 

'Data processing' means any processing of personal data. The term 'processing' includes, among other things, the collection, recording, organizing, storage, updating, modification, retrieval, consultation, use, dissemination or otherwise making available, aggregation, combination, archiving, erasure or destruction of personal data.

Who processes personal data?

Data Controller

MyComfort24/Intimates BV, with registered office at Jean Jacminstraat 176, 1500 Halle, with company number BE1013.151.538 is responsible for the processing of personal data to which this privacy policy applies.

MyComfort24 is therefore the data controller and determines which personal data are collected, for what purpose they are collected and what means are used to collect them.

Processors

When MyComfort24 uses subcontractors to process data, this will always be done in accordance with the purposes covered by this privacy policy. In addition, MyComfort24 will always provide clear instructions on the processing and stipulate in a processing contract that the processing must be carried out in accordance with this privacy policy.

 

What personal data do we process?

Personal data is data related to an identifiable person. You may have provided this data yourself, for example by placing an order or filling out a form on the website. In addition, we may also assign data to you that we have received through our collaboration, including data we have received from third parties (e.g., a phone number).

All data we collect can be combined with each other. MyComfort24 commits to processing only data that is necessary for the purposes covered by this privacy policy.

With regard to our activity, the following types of personal data may be processed:

In the context of an online order:

identification data such as first name, last name, email address, mobile/telephone number and address details;

data related to your order and payment details;

your interests and product preferences.

In the context of an application:

• data about education, training, profession and position.

In the context of a B2B contact:

the identification and financial data of the company you work for;

your profession, function, and contact details.

How do we collect your personal data?

MyComfort24 may collect personal data when, or in the context of:

• visiting our website;
• placing an order;
• sending a contact form;
• subscribing to the newsletter (whether via the website or not);
• subscribing to personalized offers;
• sending an email message;
• submitting an application;
• exchanging business cards;
• carrying out a prospecting assignment;
• preparing and/or concluding a cooperation agreement.

What do we use your personal data for?

We process personal data for various purposes, always processing only the data necessary to achieve the intended purpose.

For example, we use personal data:

• when we have received consent;
• in the context of preparing an order;
• to deliver your order;
• to keep you informed about the status of the order;
• to comply with legal or regulatory provisions to which we are subject.

We also provide your data to third parties if this is necessary to fulfill your order, for example, to our distribution center and our delivery services.

When MyComfort24 has a legitimate interest, we always strive for a balance between that interest and respecting the privacy of the data subject.

With consent, where required, we collect personal data for the following specific purposes:

• the execution of an agreement with MyComfort24;
• providing support;
• sending targeted marketing and advertising, updates, and promotional offers based on your interest;
• sending invoices and collecting payments;
• optimizing the quality, content, and management of the website;
• statistical purposes;
• creating a quote;
• answering a specific question;
• conducting customer satisfaction surveys, questionnaires, and other market research.

When visiting the MyComfort24 website, data is collected for statistical purposes. It is used to optimize our website. This data includes: IP address, presumed location of visit, time and day of visit, and which pages were visited.

Personal data security

MyComfort24 commits to taking reasonable, physical, technological and organizational precautions to prevent unlawful access to your personal data and the loss, misuse or alteration of this data.

MyComfort24 will store all personal data it has collected in the Cloud (with data center(s) within and outside the EU, in compliance with applicable laws and regulations).

Despite MyComfort24's security policy, the controls it carries out and the actions it takes in this context, an infallible level of security cannot be guaranteed. No method of transmission or transfer via the internet and method of electronic storage is 100 percent secure. As a result, MyComfort24 cannot guarantee absolute security for this.

However, we do everything we can to protect your personal data and privacy, both within our network and at our office.

Our employees are trained to handle confidential data correctly. We use specialized companies that are responsible for the security of our ICT network and Cloud services.

In addition, we use various technical measures to protect your personal data, such as firewalls, antivirus software, encryption and access controls.

Should a data breach occur with adverse consequences for your personal data, you will be notified in the circumstances provided for by law.

The number of employees at our office who have access to your personal data is limited and carefully selected. These employees are granted access to your personal data insofar as they need that information to properly perform their duties.

Our websites sometimes contain links to third-party sites (social media, organizers of events we sponsor) whose terms of use do not fall under the scope of this privacy policy. Please read their policy on the protection of your personal data carefully.

Storage of personal data

Unless a longer retention period is required or justified by law or by compliance with another legal obligation, MyComfort24 will only store your personal data for the period necessary to achieve and fulfill the purposes, as described in this privacy policy.

The retention period may therefore vary per purpose. To comply with our legal obligations, for example, we are obliged to keep your billing data for a maximum of 7 years. This archived data is, of course, only accessible to a limited extent.

After the expiry of the applicable retention period(s), personal data will be anonymized or deleted.

Data of former customers may be used for a period of 1 year after the purchase of their last product to keep them informed of new products and promotions from MyComfort24, unless the customer explicitly indicates that they do not agree to this.

Persons who have subscribed to the newsletter and/or personalized offers will be deleted annually if they have not opened the newsletter within the preceding 24 months at the end of the year, have unsubscribed, or if the email address has bounced (hard).

Data of applicants who were not selected will be deleted 6 months after the selection period.

Your privacy rights

You can always appeal to the following privacy rights:

• right of access to the personal data that MyComfort24 holds about you;
• right to rectification, completion or updating of your personal data;
• right to be forgotten, resulting in the erasure of your personal data;
• right to restriction of processing of your personal data;
• right to data portability of your personal data;
• right to object to the processing of your personal data.

If you wish to exercise your privacy rights, as defined above, please send an email to gdpr@MyComfort24.be. Please indicate, in the email subject, which type of privacy right (e.g., right of access) you wish to exercise.

If the email address used when creating the data subject's account is no longer in use, the request must be made in writing to the address:

MyComfort24, Bilkensveld 1A, 1500 Halle, Belgium

The request must always include the following information:

• A copy of the front of the data subject's identity card, so that the data subject can be identified.
• The original email address used when creating the data subject's account, so that the correct account can be identified.
• The email address where the data subject wishes to receive the information.
• The nature of the request.
• The type of privacy right you wish to exercise.

If you have an account, you can manage your data yourself at any time in the account overview. You do this by going to my account.
and logging into your own account.

MyComfort24 will respond to your request within one month of receiving it.

If you no longer wish to receive newsletters or information about our services, you can unsubscribe at any time by clicking on the 'unsubscribe' button, as provided at the bottom of every newsletter and/or personalized offer from MyComfort24.

Processing of data of persons outside the EEA

Any transfer of personal data outside the European Economic Area (EEA) to a recipient whose domicile or registered office is in a country not covered by an adequacy decision issued by the European Commission will be governed by the provisions of a data transfer agreement that will contain the standard contractual clauses, as stipulated in the 'European Commission Decision of 5 February 2010 (Decision 2010/87/EC)', or another mechanism under privacy legislation or other regulations regarding the processing of personal data.

Privacy Policy Update

MyComfort24 is entitled to update this privacy policy by placing a new version on the website. It is advisable to regularly consult the website and the page on which the privacy policy is displayed so that you are aware of any changes.

Complaints

If you have any complaints about the way MyComfort24 collects, uses and/or processes your personal data, you can always submit a complaint by email to gdpr@mycomfort24.be. We will take your complaint seriously. However, if you wish to file a further complaint, you can do so with the Privacy Commission.

Contact MyComfort24

If you have any questions about the privacy policy or about how MyComfort24 collects, uses or processes your personal data, please contact us:

• by e-mail: gdpr@mycomfort24.be.
• or by post: MyComfort24/Intimates BV, Jean Jacminstraat 176, 1500 Halle