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.

Which categories of personal data do we process and for what purposes?
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 (the visits to our site, the range of contributions, information about the countries and cities where our Visitors come from and statistics about the gender ratios of our Visitors) related to the use of our Instagram pages that Instagram makes available sets via the Instagram service “Insights” in anonymized 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 Instagram username and comments on our Instagram pages and messages you send us through our Instagram pages
• Your activity on our Instagram pages through the Instagram Insights service, e.g. visits to our site, the range of contributions, 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 regarded as “joint controllers” within the meaning of the GDPR and they 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, where Instagram is part of Facebook. 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.

3. Twitter
When 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 can be found here.

We process the following personal data:

• Your Twitter username and comments posted on our Twitter pages and messages you send us through our Twitter pages
• Your activity on our Twitter pages via the twitter Analytics service, eg visits to our site, the range of contributions, information about the countries and cities 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 except your Twitter username if you send us a direct message.

Joint controllership with Twitter

We use the statistical information (the visits to our site, the range of contributions, information about the countries and cities where our Visitors come from and statistics about the gender ratios of our Visitors) related to the use of our Twitter pages that Twitter makes available establishes via the “Analytics” service in anonymized form. Conclusions about individual users and access to individual user profiles by us are not possible.

As a result, E-BO Group and Twitter are regarded as “joint controllers” within the meaning of the GDPR.

In addition to the processing of personal data stated in this privacy statement, we have no influence on the processing of personal data in connection with your use of our Twitter company 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 you can find here.

We process the following personal data:

• Your LinkedIn username and comments posted on our LinkedIn pages and messages you send us through our LinkedIn pages
• Other information necessary to complete requests from our Visitors or to unambiguously identify our Visitors in our systems

Joint controllership with LinkedIn

We use the statistical information (the visits to our site, the range of contributions, information about the countries and cities our Visitors come from, and statistics about our Visitors’ working relationships) related to the use of our LinkedIn company page that LinkedIn makes available states via the LinkedIn “Analytics” service in anonymized form. Conclusions about individual users and access to individual user profiles by E-BO Group are not possible.

As a result, E-BO Group and LinkedIn are regarded as “joint controllers” within the meaning of the GDPR and they 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 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 the 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 reach of contributions, the average length 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 E-BO Group YouTube channel that makes YouTube available in anonymized form through the “Analytics” service. Conclusions about individual users and access to individual user profiles by E-BO Group are not possible.

We process the following personal data:

• Your YouTube username and comments on our YouTube channel
• Your activity on our YouTube channel through the YouTube Analytics service, e.g. visits to our site, reach of contributions, average duration of video views, information about the countries and cities where our visitors come from and statistics on the gender ratios 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 except your YouTube username if you send us a direct message.

To whom are your personal data sent?

Within E-BO Group, only persons and bodies that need personal data to fulfill 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.

We point out that when processing data through our social media channels, your personal data may be processed outside the territory of the European Union. This can pose risks for users, because it can, for example, make it 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 by European Standard Module Clauses, we would like to point out that these providers are committed to complying with EU data protection standards.

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

How long do we keep your personal data?

If not expressly provided otherwise (e.g. in a specific consent form), we will delete your personal data as soon as it is no longer necessary for the purposes mentioned above, unless deletion or blocking would conflict with our legal obligations to provide and retain data ( such as data retention for periods provided for by commercial or tax law). Your messages sent through our social media channels will be deleted if your question has been answered and there are no other grounds to give or oblige us to keep the messages.

Exercise your rights?

Our Visitors can request information about the personal data that we store and process about them at E-BO Group, as indicated in our Privacy Policy. In addition, our Visitors may, under specific circumstances, demand correction or deletion of the personal data about him or her. 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, common and machine-readable format.

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

Right to object

If the processing is based on consent, our Visitors have the right to object at any time to the processing of personal data concerning them. If we process our visitors’ personal data to protect our legitimate interests, our visitors may object to the processing at any time for reasons arising from his or her particular situation. In the event of an objection, we will stop processing the personal data of the data subject concerned, unless we can provide compelling reasons overriding the interests, rights and freedoms of our Visitors or prove that the processing serves the establishment, exercise and defense of legal claims. claims or disputes. With regard to the processing of personal data through the “Insights” service offered by Facebook, Facebook has assumed primary responsibility. This concerns the processing of Insights data and the execution of rights of data subjects. Therefore, please contact Facebook directly about any obligations arising from the GDPR regarding the processing of Insights data. Although you can exercise your rights against us, we will forward any questions we receive about this to Facebook.With regard to the processing of personal data through the “Page Insights” service offered by LinkedIn, LinkedIn has assumed primary responsibility. It concerns the processing of “Page Insights” data and the implementation of the rights of data subjects. Therefore, please contact LinkedIn directly about any obligations arising from the GDPR regarding the processing of “Page Insights” data. Although you can exercise your rights against us, we will forward any questions we receive about this to LinkedIn.

Where can you submit a complaint?

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 concerning you is in violation of the GDPR.

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