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Social Media Policy

Version: November 2021

This Social Media Policy applies to the processing of personal data on the social media channels of e-Bo Enterprises NV and its affiliated companies (hereinafter referred to as “we” or “us” or “e-BO Group”). e-Bo Enterprises NV acts as Data Controller on its respective social media channels.

e-Bo Group assures you the confidential processing of your personal data in accordance with the General Data Protection Regulation, in short ‘AVG’ or ‘GDPR’. If you come into contact with e-BO Group in a other context, also our general Privacy policy and Cookie policy apply.

Questions about applicable law and this policy can be directed to our Data Protection Officer (“DPO”) at privacy@ebo-enterprises.com.

We process your personal data when you visit us on social media channels. With our various social media channels we want to offer you a wide range of multimedia services and exchange ideas with you on topics that are important to you. In addition to the respective social network provider, we also collect and process personal user data on our social media channels. With this notice we let you know what data we collect from you in connection with our social media channels, how we use it and how you can object to the processing of your data. For the respective processing purposes and data categories, please refer to the individual social media channels listed in more detail below.

The data processing serves the following purposes:

• Communicate with our social media channel Visitors
• Handling requests from visitors via our social media channel
• Obtain statistical information about the reach of our social media channels
• Conducting customer surveys, marketing campaigns, market analyses, competitions or similar promotions or events
• Resolve disputes and lawsuits, exercise or defend legal claims or lawsuits

The processing of your personal data is necessary to achieve these goals.

Unless expressly provided otherwise, the legal basis for the processing is our legitimate interest (GDPR Art. 6 Para. 1 f). Our legitimate interests include the ability to respond to your messages or inquiries and to analyze the reach and use of our social media channels to create appropriate design and ongoing optimization. Insofar as you wish to enter into a contractual relationship with us with your request, the legal basis for such processing is GDPR Art. 6.1 b).

If we intend to process your personal data for a purpose other than that stated above, we will inform you of this prior to such processing.

1. Facebook

The E-BO Group Facebook Fanpages (“Fanpage(s)”) are operated by Facebook Ltd., 4 Grand Canal Square, Grand Canal Harbour, D2 Dublin, Ireland (“Facebook”). When you visit our Fanpages, Facebook processes your personal data in accordance with their privacy policy which can be found here.

We process the following personal data:

• Your Facebook username and comments posted on our Fanpage(s) and messages you send us through our Fanpage(s)
• Your activity on our Fanpage(s) through the Facebook Insights service, e.g. visits to our site, range of contributions, visits and average duration of video views, information about the countries and cities where our visitors come from and statistics about the gender relations of our visitors
• Other information necessary to complete requests from our Visitors or to unambiguously identify our Visitors in our systems

Joint controllership with Facebook

We use the statistical information (the visits to our site, the range of contributions, visits and average duration of video views, information about the countries and cities our visitors come from and statistics about the gender ratios of our visitors) related to the use of the Fanpage(s) that Facebook makes available in anonymised form via the Facebook service “Insights”. Conclusions about individual users and access to individual user profiles by E-BO Group are not possible.

More information about Facebook Insights can be found here.

On this basis, E-BO Group NV and Facebook are regarded as “joint controllers” within the meaning of the GDPR and have therefore entered into a so-called joint controller agreement to comply with the requirements of the GDPR. This joint controller agreement is available here. Here you will find all information relevant to you as a data subject, in particular with regard to the exercise of your rights under data protection law.

In addition to the processing of personal data stated in this privacy statement, E-BO Group has no influence on the processing of personal data by Facebook in connection with your use of the Fanpages.

2. Instagram

The E-BO Group Instagram pages are operated by Facebook Ltd., 4 Grand Canal Square, Grand Canal Harbour, D2 Dublin, Ireland, the service provider for Instagram. When you visit the E-BO Group Instagram pages, Instagram will process your personal data in accordance with their privacy policy which can be found here.

We use the statistical information (visits to our site, contribution offerings, information on the countries and cities our Visitors come from and statistics on the gender ratios of our Visitors) regarding the use of our Instagram pages that Instagram makes available through the Instagram service "Insights" in an anonymised form. Conclusions about individual users and access to individual user profiles by E-BO Group are not possible.

We process the following personal data:

• Your Facebook username and comments posted on our Fanpage(s) and messages you send us through our Fanpage(s)
• Your activity on our Fanpage(s) through the Facebook Insights service, e.g. visits to our site, range of contributions, visits and average duration of video views, information about the countries and cities where our visitors come from and statistics about the gender relations of our visitors
• Other information necessary to complete requests from our Visitors or to unambiguously identify our Visitors in our systems

On this basis, E-BO Group and Instagram are considered "joint controllers" within the meaning of the AVG and have therefore entered into a so-called joint controller agreement to comply with the requirements of the AVG. This joint controller agreement is available here, with Instagram being part of Facebook. Here you will find all information relevant to you as a data subject, in particular regarding the exercise of your rights under data protection legislation.

3. Twitter

If you visit E-BO Group on Twitter, the operator of Twitter (Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) collects and processes personal data to the extent described in their privacy policy. Their privacy policy is here be seen.

We process the following personal data:

• Your Facebook username and comments posted on our Fanpage(s) and messages you send us through our Fanpage(s)
• Your activity on our Fanpage(s) through the Facebook Insights service, e.g. visits to our site, range of contributions, visits and average duration of video views, information about the countries and cities where our visitors come from and statistics about the gender relations of our visitors
• Other information necessary to complete requests from our Visitors or to unambiguously identify our Visitors in our systems

Joint controllership met Twitter

We use the statistical information (visits to our site, contribution offerings, information on the countries and cities our Visitors come from and statistics on the gender proportions of our Visitors) regarding the use of our Twitter pages that Twitter makes available through the "Analytics" service in an anonymised form. Conclusions about individual users and access to individual user profiles by us are not possible.

This qualifies E-BO Group and Twitter as "joint controllers" within the meaning of the AVG.

In addition to the processing of personal data mentioned in this privacy statement, we have no control over the processing of personal data in connection with your use of our Twitter business page.

4. LinkedIn

The E-BO Group LinkedIn pages are operated by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ("LinkedIn"). When you visit the E-BO Group LinkedIn pages, LinkedIn processes your personal data in accordance with their privacy policy which can be found here.

We process the following personal data:

• Your Facebook username and comments posted on our Fanpage(s) and messages you send us through our Fanpage(s)
• Your activity on our Fanpage(s) through the Facebook Insights service, e.g. visits to our site, range of contributions, visits and average duration of video views, information about the countries and cities where our visitors come from and statistics about the gender relations of our visitors
• Other information necessary to complete requests from our Visitors or to unambiguously identify our Visitors in our systems

Joint controllership met LinkedIn

We use the statistical information (visits to our site, contribution offerings, information on the countries and cities our Visitors come from and statistics on our Visitors' working relationships) regarding the use of our LinkedIn company page that LinkedIn makes available through the LinkedIn "Analytics" service in an anonymised form. Conclusions about individual users and access to individual user profiles by E-BO Group are not possible.

This qualifies E-BO Group and LinkedIn as "joint controllers" within the meaning of the AVG and they have therefore entered into a so-called joint controller agreement to comply with the requirements of the AVG. This joint controller agreement is available here. Here you will find all information relevant to you as a data subject, in particular regarding the exercise of your rights under data protection legislation.

Apart from the processing of personal data mentioned in this privacy statement, E-BO Group has no control over the processing of personal data in connection with your use of our LinkedIn company page.

5. YouTube

If you visit E-BO Group on YouTube, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, as operator of YouTube, collects and processes personal data to the extent described in their privacy policy. Their privacy policy can be found here.

We use the statistical information (the visits to our site, the range of contributions, visits and average duration of video views, information about the countries and cities our visitors come from and statistics about the gender ratios of our visitors) related to the use of the Fanpage(s) that Facebook makes available in anonymised form via the Facebook service “Insights”. Conclusions about individual users and access to individual user profiles by E-BO Group are not possible.

We process the following personal data:

• Your Facebook username and comments posted on our Fanpage(s) and messages you send us through our Fanpage(s)
• Your activity on our Fanpage(s) through the Facebook Insights service, e.g. visits to our site, range of contributions, visits and average duration of video views, information about the countries and cities where our visitors come from and statistics about the gender relations of our visitors
• Other information necessary to complete requests from our Visitors or to unambiguously identify our Visitors in our systems

We do not store or process any of your personal data other than your YouTube username if you send us a direct message.

Within E-BO Group company, only persons and bodies that need personal data to fulfil the above purposes are granted access to such data.

Comments and messages you leave on our social media channels are handled by our staff on the social media platform itself.

Please note that when processing data through our social media channels, your personal data may be processed outside the territory of the European Union. This may entail risks for users, as, for example, it may become more difficult to enforce users' rights. For details, please refer to the privacy statement of the social media channels. With regard to US providers bound through European Standard Module Clauses, we would like to point out that these providers are committed to complying with EU data protection standards.

We may disclose personal data to supervisory authorities, courts or law firms to the extent necessary to ensure compliance with applicable laws or to exercise, assert or defend legal rights, where permitted by law.

If not explicitly provided otherwise (e.g. In a specific consent form), we will delete your personal data as soon as it is no longer needed for the purposes mentioned above, unless deletion or blocking would be contrary to our legal obligations to provide and retain data (such as retaining data for periods provided for by commercial or tax laws). Your messages sent through our social media channels will be deleted once your query has been answered and there are no other grounds to give us the right or obligation to retain said messages.

Our Visitors may request information about the personal data we store and process about him or her from E-BO Group, as indicated in our Privacy Policy. In addition, our Visitors may demand correction or deletion of personal data about him or her under specific circumstances. They may also have the right to restrict the processing of personal data, as well as the right to disclosure of the data they have provided in a structured, commonly used and machine-readable format.

To exercise your rights, please contact us at privacy@ebo-enterprises.com.

If the processing is based on consent, our visitors have the right to object to the processing of personal data relating to him or her at any time. If we process personal data of our visitors to protect our legitimate interests, our visitors may object to the processing at any time for reasons arising from his or her specific situation. In case of an objection, we will stop processing the personal data of the data subject concerned, unless we can provide compelling reasons that override the interests, rights and freedoms of our visitors or prove that the processing serves to establish, exercise and defend legal claims or disputes.

Any visitor has the right to lodge a complaint with the relevant data protection supervisory authority if you believe that the processing of personal data relating to you violates the AVG.

Data Protection Authority, Drukpersstraat 35, 1000 Brussels
e-mail: contact@apd-gba.be

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