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PRIVACY POLICY

1. WHO WE ARE

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“We”, “us” or “our” means Knauf Energy Solutions with its registered office at Kortenberglaan 120, 1000 Brussel and with company number 0721.470.954. We act as controller for the personal data we gather through your use of our website, https://www.knaufenergy.com (“Website”).

This privacy policy is solely intended to provide you with information in relation to the processing of personal data through your use of the Website. For our privacy practices in relation to our services, we refer you to the agreement as may be concluded between us.

Your privacy is important to us, so we’ve developed this privacy policy that sets out how we collect, disclose, transfer and use (“process”) the personal data that you share with us, and which rights you have. Please take a moment to read through this policy.

If you have any questions, concerns or complaints regarding this privacy policy or our processing of your personal data or you wish to submit a request to exercise your rights as set out in article 4, you can contact us:
Via-mail: privacy@knaufenergy.com, to the attention of our DPO;
By post: to Knauf Energy Solution, attn. DPO, Kortenberglaan 120, 1000 Brussel.

This privacy policy was revised last on 5/12/2022


2. PERSONAL DATA COLLECTION AND USE


Personal data or information means data that can be used to identify or contact a specific person. Any time you contact Knauf Energy Solutions or a Knauf Energy Solutions affiliate about Smart Retrofit solutions, you may be asked for your personal data. Knauf Energy Solutions and its affiliates may share and use these personal data under the Smart Retrofits Privacy Policy. They may also aggregate them with other data to deliver or improve Smart Retrofit products, services, content, and advertising. You are not obliged to provide the personal data we request; however, if you opt to refuse, we will often be unable to provide you with Smart Retrofit products or services or answer your potential questions. A selection of the types of personal data that Knauf Energy Solutions might collect for Smart Retrofits and our potential use thereof has been listed below.

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3. TYPES OF PERSONAL DATA THAT WE COLLECT

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When you participate in a Smart Retrofit measurement of your home, use our Smart Retrofit home sensor network, contact us about Smart Retrofits, or when we create a Knauf Energy Solutions’ Smart Retrofit ID for you, we may collect a range of data, including your name, postal address, phone number, email address, and contact preferences. We may also collect continuous sensor data from various areas of your home, e.g., CO2, temperature, humidity, electricity, gas, heat meter, boiler flow rate, and return temperature readings.

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4. HOW WE USE YOUR PERSONAL DATA

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The personal data we collect allow us to update you about the latest Knauf Energy Solutions’ Smart Retrofit product and service announcements and any upcoming events. If you prefer not to be included on our mailing list, we can always be notified to unsubscribe. Personal data are also used to help create, develop, use, supply, and improve Smart Retrofit products, services, content, and advertising, as well as to prevent loss and for anti-fraud purposes. Smart Retrofit solutions identify the best improvement measures for a home, arrange for their on-site delivery and implementation, and then verify whether the measures have delivered the required return on investment. These solutions can also be part of an asset management solution, boosting efficiency to an even higher degree after a Smart Retrofit, e.g. through smart thermostat use. We may use your personal data, including your date of birth, to verify user identity, help identify users, and identify the right Smart Retrofit services. For example, date of birth can be used to confirm the age of Knauf Energy Solutions Smart Retrofit ID account holders. We may also periodically use your personal data to send you important announcements, e.g. notices about Smart Retrofit products, services, and events or changes to our general terms and conditions and policies. Because this information is essential to your communications with Knauf Energy Solutions, you cannot opt out of these notifications. We may use personal data for internal purposes, e.g. for audits, data analytics, and research to improve Knauf Energy Solutions’ Smart Retrofit products, services, and customer communications. If you participate in a Smart Retrofit contest or similar campaign, we may use the information you provide to administer these programmes.

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In terms of our Website we collect personal data for the purpose and according to the legal ground as listed hereunder:

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A. CONTACT DATA

Name; E-mail; Any personal data you choose to put in the ‘subject’ box and ‘message’ box or that you share with us in an e-mail*. 

We use your contact data in order to reply to your query, via e-mail or telephone. 

Legitimate interest: We have a need to be able to contact you in order to respond to your query. 

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B. PERSONAL DATA REGARDING YOUR ACTIVITIES ON OUR WEBSITE

IP address; device ID and type; referral source; browser type; operating system; geographical location; length of visit; page views; information about the timing, frequency and pattern of your service use. This information may be aggregated and used to help us provide more useful information regarding the use of our Website. In the event the usage data is completely anonymized (and can therefore not be traced back to you as an individual), this will not be considered personal data. (Note: In so far this personal data is collected via cookies, our cookie policy also applies) 

We process your personal data for the purpose of supporting the Website and enhancing your user experience, which includes ensuring the security, availability, performance, capacity and health of the Website. 

Legitimate interest: We have a need to be able to support the Website.

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C. LEGAL OBLIGATION

We may also use your personal data to fulfil our obligations as set out by the applicable law. 
Contact data and usage data, in so far relevant.

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D. LEGITIMATE INTEREST

We have a need to defend our interests
We process your personal data to enforce or exercise any rights that are available to us based on the applicable law, such as use for the establishment, exercise or defense of legal claims. 
Contact data and usage data, in so far relevant. 

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5. COLLECTION AND USE OF NON-PERSONAL DATA

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We also collect data in a form that cannot be directly traced to a specific person. Non-personal data may be collected, used, transmitted, and disclosed for any purpose. Here are a few examples of nonpersonal data we could collect and how they might be used. Data collected could include, e.g. occupation, language, postal code, area code, unique device identifier, referring URL, location, and the time zone in which the Knauf Energy Solutions product is used. These help better our understanding of customer behaviour and improve Smart Retrofit products, services, content, and advertising. We may collect data about customer activity on our Smart Retrofit website and related to other Smart Retrofit products and services. These data may be aggregated and used to help provide more useful information to customers and target key elements of the Smart Retrofit website, products, and services. Aggregate data are considered non-personal data for the purposes of this Privacy Policy. We may collect and store details about your use of Smart Retrofit services, including search behaviour. This information may be used to enhance the relevance of our service performance. We may collect data on your Knauf Energy Solutions’ Smart Retrofit device and application use to optimise these solutions. In cases where non-personal data are aggregated with personal data, the aggregate data will be treated as personal data for as long as they remain in an aggregate state.

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6. COOKIES AND OTHER TRACKING TECHNOLOGIES

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Knauf Energy Solutions’ Smart Retrofit websites, online services, interactive applications, email correspondence, and advertising may use cookies and other tracking technologies, e.g., pixel tags and web beacons. These tracking technologies may help us better understand user behaviour, let us know which areas of our Smart Retrofit websites people have visited, and facilitate and measure advertising and search engine optimisation (SEO) effectiveness. We treat data collected by cookies and other tracking technologies as non-personal data. However, to the extent that local law considers Internet Protocol (IP) addresses or similar identifiers as personal data, those identifiers will also be treated as personal data. Likewise, to the extent that non-personal data have been aggregated with personal data, aggregate data will be treated as personal data for the purposes of this Privacy Policy. Knauf Energy Solutions and our partners may also use cookies and other tracking technologies to store personal data when you use the Smart Retrofit website, online services, and applications. To this end, we aim to personalise your Knauf Energy Solutions’ Smart Retrofit solutions experience and make it more convenient. For instance, we can properly welcome you the next time you visit the Smart Retrofit website if we know your first name. Knowing your country and language may facilitate providing you with a customised, more beneficial experience. If you would like to disable cookies, please consult your browser provider for instructions on how to do so. Please note that disabling cookies may also inhibit access to certain Knauf Energy Solutions’ Smart Retrofit website features. We are, just as most internet services are, entitled to automatically collect certain data to store in log files. These data may include Internet Protocol (IP) addresses, browser type and language, internet service provider (ISP), operating system, date/time stamp, click stream data, and redirecting to and exiting websites and applications. These data may be used to analyse and understand trends, manage the Smart Retrofit website, learn more about user behaviour on the site, improve the Smart Retrofit product, services, and content, and collect demographic data about our user base as a whole. Knauf Energy Solutions may also use these data for its marketing and advertising services.

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7. THIRD-PARTY DISCLOSURE

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Knauf Energy Solutions occasionally provides strategic partners that collaborate with Knauf Energy Solutions to provide Smart Retrofit products, services, and content or that assist Knauf Energy Solutions with selling Smart Retrofit to customers with access to certain personal data. Service providers Knauf Energy Solutions shares personal data with companies that provide Smart Retrofit services, e.g., data processing, processing customer orders, product delivery, management and improvement of customer data, providing customer service, gauging your interest in Smart Retrofit products and services, and conducting customer research and satisfaction surveys. These companies are obliged to protect your data and may be located anywhere that Knauf Energy Solutions operate.

In order to provide you with our Website, we work with an IT-service provider for the hosting of the Website.

In order to respond to your query, we may have to provide your contact data and query to third parties, such as partners, subcontractors or clients.

We may also disclose your personal data in the event such disclosure is required or necessary in order to fulfil a legal obligation. We may also disclose personal data in order to protect your vital interests or the vital interest of another natural person.

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8. PERSONAL DATA PROTECTION

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Knauf Energy Solutions takes the security of your personal data very seriously. Concerning Smart Retrofit solutions, Knauf Energy Solutions uses authentication, authorization, and encryption technologies to safeguard your personal data.

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9. PERSONAL DATA INTEGRITY AND STORAGE

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Knauf Energy Solutions makes it easy to keep your personal data accurate, complete, and up to date. 

Your personal data will be retained for as long as is necessary to complete the purpose for which they were collected, which includes a reasonable follow-up period.

The foregoing will, however, not prevent us from retaining any personal data if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.

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10. PERSONAL DATA ACCESS

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We grant you access to any Smart Retrofits-related personal data that we store for any purpose whatsoever; this includes requests to rectify inaccurate data or delete data should Knauf Energy Solutions not be required to retain them by law or for legitimate business purposes. We may refuse to process requests if they are tedious or pedantic, jeopardise the privacy of others, are highly impractical, or where not otherwise required by local law. Contact us by phone on your country’s Knauf Energy Solutions Support number for any access, rectification, or deletion requests.

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11. LOCATION-BASED SERVICES

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To provide Knauf Energy Solutions product-related location-based services, Knauf Energy Solutions and its partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your computer or Knauf Energy Solutions’ Smart Retrofit devices. Where available, location-based services may use GPS, Bluetooth, and your IP address, along with crowdsourced Wi-Fi hotspots, mobile phone mast locations, and other technologies to locate the approximate location of devices. Unless you consent, these location data will be anonymously collected in a form that does not personally identify you and will be used by Knauf Energy Solutions and its partners and licensees to provide location-based products and services.

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12. YOUR RIGHTS

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This article lists your principal rights under data protection law. We have tried to summarize them for you in a clear and legible way.

To exercise any of your rights, please send us a written request in accordance with article 1 of this privacy policy. We will respond to your request without undue delay, but in any event within one month of the receipt of the request. In the event of an extension of the term to respond or in the event we do not take action on your request, we will notify you. You have the right to:

  • request access and receive confirmation as to whether or not we process your personal data and, in the event we do so, you have the right to access such personal data, together with certain additional information that you also find listed in this privacy policy. You can request a copy of your personal data. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies;

  • rectification or completion of your personal data if the personal data we hold about you is inaccurate or incomplete;

  • request erasure of your personal data when:

  • if the legal ground for the processing is consent, you withdraw your consent, and no other lawful ground exists;

    the processing is for direct marketing purposes;

    the personal data have been unlawfully processed; or,

    erasure is necessary for compliance with EU law or Belgian law.​

    the personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed.

There are certain exclusions to the right to erasure. Those exclusions include where processing is necessary.

  • object to processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:

  • the purposes of the legitimate interests pursued by us or by a third party.

    the performance of a task carried out in the public interest or in the exercise of any official authority vested in us.

​​​If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. 

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

  • to complain to a supervisory authority If you consider that our processing of your personal information infringes data protection laws. In Belgium, you can submit a complaint to the Authority for the protection of personal data, Drukpersstraat 35, 1000 Brussel (contact@apd-gba.be), https://www.gegevensbeschermingsautoriteit.be

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13. AMENDMENTS TO THE PRIVACY POLICY

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We have the right to modify this privacy policy from time to time. You will always be able to consult the most recent version of the privacy policy on the Website and/or by any other means such a printed version of the most recent version of the privacy policy.

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14. THIRD-PARTY SITES AND SERVICES

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Knauf Energy Solutions’ Smart Retrofit websites, products, applications, content, and services may contain links to third-party websites, products, and services. Our products, services, or content may also use or offer third-party products, services, or content. Data collected by third parties, which may include things like location or contact data, are governed by their own privacy practices. We encourage you to inquire about these third-party privacy practices.

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15. INTERNATIONAL USERS

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Any data you provide may be transmitted to or be opened by entities worldwide, as stipulated in this Privacy Policy. Personal data related to Knauf Energy Solutions’ Smart Retrofit products and services concerning residents of Switzerland or a European Economic Area Member State are controlled by Knauf Energy Solutions SPRL and processed by Clayton MacKenzie Ltd on its behalf. Knauf Energy Solutions uses approved model contract clauses for the international transfer of personal data collected in the European Economic Area and Switzerland.

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16. OUR COMPANY-WIDE COMMITMENT TO YOUR PRIVACY

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To guarantee the security of your Smart Retrofits-related personal data, we inform Knauf Energy Solutions employees about our privacy and security guidelines and strictly enforce privacy protection.

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17. INTERNATIONAL USERS

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Knauf Energy Solutions may be obliged by law, a legal process, litigation, and/or requests by public and government authorities in or outside your country of residence to disclose your personal data. We may also disclose information about you should we determine it appropriate and necessary for reasons of national security, law enforcement, or other issues of public interest. We may also disclose your personal data should we decide that such disclosure be reasonably required to enforce our general terms and conditions or protect our users or operations. Furthermore, we may transfer some or all the personal data collected to a relevant third party in the event of a reorganisation, merger, or sale.

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18. PRIVACY-RELATED QUESTIONS

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If you have any questions or concerns about the Knauf Energy Solutions Privacy Policy or data processing, or if you wish to file a complaint about a possible violation of local privacy laws, please contact us. We are always available by phone on your country’s Knauf Energy Solutions Support number. Any such communications will be investigated, and a response will be provided as soon as possible, where appropriate. If unsatisfied with the response, you may refer your complaint to the relevant regulator in your jurisdiction. If requested, we will attempt to provide you with information on the relevant channels through which to file a complaint and that may have a bearing on your circumstances. Knauf Energy Solutions may periodically update its Smart Retrofit Privacy Policy.

Substantial amendments to the policy will be announced on the Knauf Energy Solutions’ Smart Retrofit website at the time of the amended Privacy Policy’s posting.

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