Privacy charter of the Colruyt Group
(version of 1 January 2010)

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

This charter applies to all communications (by post or e-mail) of the Colruyt Group, of all its subsidiaries and of the different departments.

1. General information

1.1. This is how we collect personal details

Personal details means:
- Address information enabling us to send communications,
or an e-mail address in the case of electronic information.

- Other personal details such as information about work, interests, etc. (optional)

We only keep the information the customers give us for example by means of:

• A special form to apply for folders of Colruyt, Bio-Planet, DreamLand, OKay, etc.
• An action where we gather addresses (e.g. for an additional discount, for the Extra discount card, etc.).
• Our Internet site where customers can also enter their personal details, for example for a reservation in one of the Colruyt web shops.

All personal details are kept in our customers list. We send you a personal message to give you the opportunity to check, correct or change your information or to ask us not to use it anymore (see 4.4).

When we receive your e-mail address for the first time, we also send you a personal message confirming this.

You can deregister from the entire Colruyt Group. In that case we keep your name and address in an internal Robinson list (*) to avoid that your details end up in our customers list again.
* 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.

1.2. What do we do with your personal details?

As soon as your personal details are recorded in our customers list, you will regularly receive our information at your home. If you want to receive communications by e-mail as well, please send us your e-mail address. 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.
Your personal details can also be used sporadically to send you invitations to participate in general or specific market research, executed by the Colruyt Group or by external parties by order of the Colruyt Group.

1.3. You choose the information you give

To allow us to send you our communications, we need your address or your e-mail address. As regards the other information (about your work, your interests, etc.), you are free to choose whether you give it or not.

1.4. We do not let or sell information

We treat personal details as confidential information and never sell or let them to third parties outside the Colruyt Group.

1.5. 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 2 different kinds of cookies:

1. 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.
2. Cookies to enhance your surfing comfort, such as language choice and personal code. For example, you do not have to indicate the language you speak over and over again.

2. Information based on purchase details

2.1. This is how we collect your purchase details

We can record the purchase details printed on your receipt using customised means (Extra discount card, customised coupons, etc.).

2.2. What do we do with purchase details?

Apart from the general information we send you, we can add more specific advantages for the products you generally buy. If we address specific information to smaller groups of customers, we can avoid over-communication, we reduce our costs and we use even less paper. On the other hand, we can offer interested customers additional benefits we think they will appreciate considering the products they generally buy.

If we look into what customers buy, we can for example find all amateurs of wine. In this case and if they are interested, we can provide more specific information about wine, offer new benefits and grant additional discounts.

Your purchase details can also be used sporadically to invite you to participate in general or specific market research, executed by the Colruyt Group or by external parties by order of the Colruyt Group.

2.3. You choose whether or not you want these additional personal benefits

You choose whether or not you want to benefit from these additional offers. To send you these offers, we temporarily record your purchase details in our 'customers' interests list'. If you do not want this, you can deregister for such offers (see 4).

2.4. We do not sell or let purchase details

Just like personal details (cf. 1.4) we never sell or let purchase details to third parties. The Colruyt Group commits itself only to use this information for customised actions.

3. This is how we send our information

3.1. First we decide what group of customers we would like to reach.

• For our general information we might for example select all our customers in a specific region, or all the customers of one store, or all the customers whose e-mail address we know.
• For customised communications, with extra benefits from a supplier for instance, we can select all the customers who bought specific articles (e.g. wine, toys). If the customers give their authorisation, we can propose new products, offer special discounts, etc. if they are interested.

3.2. We manage our own databases

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 addresses.
We never sell or let our address lists to external address managers.

4. You decide what we can do with your information
4.1. Information about your personal details

When we record your personal details in our customers list, you receive a personal message to let you know. You have the opportunity to check, correct or change your information or ask us not to use it anymore (see 4.4) and we tell you what the Colruyt Group does with your details. We also send you this information when we record your e-mail address for the first time.

4.2. Information about your purchase details

When we keep your purchase details in our 'customers' interests list' using customised means, you also receive a message to let you know. You can then choose whether or not you allow us to record your purchase details to send you additional benefits based on these data.

4.3. Access to your information

Afterwards you can retrieve, correct or change the personal details we save in our customers list any time. Simply ask us in writing. We will immediately grant your request.

4.4. Deregister

You can deregister at several levels:

1. Communications based on purchase details
   If you no longer want to receive offers based on your purchase details, all you have to do is ask us in writing. We guarantee that you will no longer receive any targeted communications based on your purchase details.
2. Communications by e-mail
   With each e-mail you receive, you have the opportunity to deregister. You can deregister for e-mails of a specific web shop or for all the e-mails of the Colruyt Group. You will receive an e-mail confirming that you have deregistered.
   
3. 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 ask us in writing. We guarantee that your details are no longer used to send you personalised information of 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.

5. External check by Quality Control

• To be allowed to collect information about our customers, we made a preliminary declaration with the Commission for Safeguarding individual privacy in Belgium for the data collected in Belgium and with the National Commission for Safeguarding data in the Grand Duchy of Luxembourg for information collected there.
• Apart from all the measures we take to protect your privacy to the best of our ability, 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.