(version of 16 May 2011)

Because we want to provide clear information about how we take care of your personal details in the Colruyt Group, we have drawn up this code of conduct. In this charter, you can read the details about how we protect your privacy, how you have a say in this any time, and which checks are performed to ensure the accurate compliance with this charter.

Application

1. Database management

All the personal details are managed by the N.V. Etn. Fr. Colruyt, Edingensesteenweg 196, 1500 Halle (Belgium). Within the Colruyt Group, only the people in charge of the customers list have access to the data.

We never sell or let our address lists to external address managers. We handle your details as confidential information.

To be allowed to collect information about our customers, we made a preliminary declaration with the Commission for Safeguarding Individual Privacy in Belgium. This applies to information we collect in Belgium. For information we collect in the Grand Duchy of Luxembourg we made a declaration with the National Commission for Safeguarding data in the Grand Duchy of Luxembourg.

2. Which data are processed ?

2.1. Information of private customers (B2C)

  a) Personal details

Personal details means:

• Contact information such as address, e-mail address, telephone, GSM or fax number
• Other personal details: information about your occupation, your interests, etc.

We collect this information by means of for example:

• A form to apply for folders (of Colruyt, Bio-Planet, DreamLand and OKay)
• An action where we gather addresses (e.g. an additional discount, for the Extra discount card, etc.)
• The Internet site on which personal details can be entered, e.g. for a reservation in one of the Colruyt web shops.

All personal details are kept in our customers list. We personally inform you about this. You always have the possibility to check, correct, change or delete your data (see 6).

  b) Purchase and click information

The information on your receipt can temporarily be recorded by customised means such as an 'Extra Discount' card, personal coupons, etc.

When you receive a mail from us, we can record your clicking data. This enables us to use your profile to inform you more effectively about benefits you may find interesting.

With this information, we can provide you with general information but we can also offer you more specific benefits based on your profile. If we address specific information to customers, we can avoid over-communication, we reduce our costs and we waste even less paper.  On the other hand, we can offer customers additional benefits we think they will appreciate considering the products they generally buy or click to.

Thus we can for example look for all wine buffs based on the specific customer profiles. In this case we can provide more specific information about wine, offer new benefits and grant additional discounts. 

2.2. Information of professional customers and prospects (B2B)

'Professional customers' are customers who purchase their goods at the businesses of the Colruyt Group for the purpose of their professional activity. 'Prospects' are possible customers or companies with which we can start a form of cooperation.

• Contacts (name, function)
• Associates, partners in the business, collaborators
• Other company details, such as vat number or company number
• Possible interests we can satisfy with our services and activities.

To actively canvass for new customers, we not only keep the information about your company that you provide us, but we also gather information by means of external channels, a/o address managers. Each time we record such information in our customers list, we keep you informed. You then have the possibility to check, correct, change or no longer use your information (see point 6).

3. Internet

When you visit our Internet site, we keep some settings in 'cookies’. These are small pieces of information that are placed on your hard disk when you surf to our website. Our website uses different kinds of cookies:

• Cookies to be able to start a 'conversation' between you and our site. They are needed to have our site operate correctly and they disappear at the end of your visit to our site.
• Cookies to enhance your surfing comfort, such as language choice and personal code.  For example, you do not have to confirm the language you speak over and over again.

Thanks to these cookies we can also record specific information about the user. This is about the language chosen, the pages visited and the duration of the visits.

4. The purpose of gathering your information

As soon as your information is recorded in our customers list, you will regularly receive our information at your home. We can also send you our information by e-mail if you like. We commit ourselves only to use your personal details to make a correct treatment of your contract possible and to send you information of the companies of the Colruyt Group.
This information can be folders of Colruyt, OKay and Bio-Planet in your region, e-mails of the different Colruyt departments on their special offers, specific information about your store, etc.

With the intention to develop a possible cooperation, we like to keep our professional customers informed of our specific services and actions for companies.

5. You decide what we can do with your information

To allow us to send you our communications, we need your address or your e-mail address. You decide whether you provide additional information about your occupation, your interests, etc.

As regards our professional customers and prospects, we gather information about companies by means of external channels (a/o address managers) as explained in 2.2. You can request to consult this information any time.

When we record your personal details in our customers list, you will receive a personal message to let you know. You always have the possibility to check, correct, change or delete your data (see 6). The Colruyt Group also informs you of the use of these data.

When we keep information about what you purchase or click on, you will be informed. You decide whether we can record your purchase or click data, and whether we can send you additional offers based on this information.

6. Deregister

You can deregister at several levels:

• Communication based on purchase and click data: it is enough to request this in writing. We guarantee that you will no longer receive any communication based on your purchase or click data.
• Communication by e-mail: you can deregister each time you receive an e-mail from us. You can deregister for the e-mails of specific web shops or for all the e-mails of the Colruyt Group. You will receive an e-mail confirming that you have deregistered.
• All communications: if you no longer want to receive any personalised information of the Colruyt Group, you can deregister for the group's communications. Simply make this request in writing or by e-mail. We guarantee that your data is no longer processed to send you personalised information from the Colruyt Group. To make sure that your address does not end up in our customers list again, we will record it in an internal Robinson list*.

*A Robinson list is a list of names and addresses of people who no longer wish to receive personalised marketing communications. The Colruyt Group has its own internal Robinson list of people who no longer want to receive information from the Colruyt Group.

7. External check by Quality Control

Apart from all the measures taken to protect your privacy, Quality Control checks and guarantees:

• That we comply with the standards of Legislation for Safeguarding Individual Privacy in each country.
• That we observe the commitments made in this charter.

For this purpose, Quality Control carries out statistically and scientifically reliable surprise and random checks.