May 2018

About this Privacy Policy

We know how important it is for you to understand how we use your data. This Privacy Policy sets out how and why we collect, store, process and share and most of all protect your personal data. We will always be transparent with you about what we do with your personal data.

In other words, we want you to feel that your personal data is safe with us, is used for only what is intended for, and that we continue to build our trustworthy relationship under and beyond the GDPR.

This Policy also tells you what your rights are in relation to the personal data you give to us. If you have any questions about this Privacy Policy or your rights under it, please contact our Data Protection Officer via e-mail

Our company name is ROCME bvba (registered under BE0627.620.088) and our registered address is Oude Baan 163 - Brasschaat - Belgium. ROCME is the “data controller” of any personal data it may collect, process and hold about you, unless we inform you otherwise.

1. What personal data do we collect?

The personal data we collect from you directly can include your first name, name, email address, company, title, mobile/landline telephone number, date of birth, address, your purchasing activity, your credit/debit card or other payment information, and any information you give us when you contact our customer service team or are in contact with one of ROCME’s employees, when you engage with our social media platform (for example by tagging us in a post on Instagram) or when you sign up for lead retrieval device reservations or any other product in our online webshop.

If you are using a mobile device and shopping with us online or browsing our website, we may collect your IP address or other device identifier, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other portable device information.

We may, where we have a lawful basis for doing so, also collect personal data about you from third parties who provide us with additional publicly available information about you.

2. When do we collect your personal data?

  • When you purchase products and services from us online or over the phone
  • When you access our website or use any of our mobile apps. Our website also uses cookies; to find out more about the use of cookies and how you can manage them, please read our Cookie Policy
  • When you register for our newsletter or request for a quote
  • When you have been in contact with one of our sales representatives or account managers during presentations, trade shows, exhibitions, conferences or roadshows
  • When you contact us or we contact you to take part in surveys
  • When you contact our customer service team, live at tradeshows and events, online or over the phone
  • When you engage with us on social media (by mentioning/tagging us or by contacting us directly)

3. How much data do we collect from you and for what purpose?

The personal data we ask and collect from you will be limited to what we strictly need from you in order to fulfil our obligation and commitment to you. This can be full service and order fulfilment, customer support and complaints, or simply keeping you up-to-date with our products and services.

We collect and store your personal data only for and limited to the purpose for which we need them for. By no means we will use your data for other purposes than we collected them for.

4. How do we use your personal data and what are our legal justifications for doing so?

To make our products and services available to you

We use your personal data to provide you with information, products and services that you request or purchase from us (i.e. to complete certain tasks, processes or orders on our website or within our apps, take payment online (where applicable) and deliver your products or services), and to communicate with you regarding those products and services that you purchased from us and respond to your questions and comments.

We may also use your personal data to measure how satisfied our customers are and provide customer service (including troubleshooting in connection with purchases or your requests for services or when you ask us questions on social media).

We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data when you make an order for products and services. Alternatively, in some cases, we rely on our legitimate interests as a business (for example, to measure customer satisfaction and troubleshoot customer issues). Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

When we need explicit consent from you, in order for you to freely opt-in into our services and offering, we will ask it from you in a clear and transparent manner, and ask it for very specific purposes only, which will be communicated to you in all transparency. You can withdraw this consent at any time.

For administrative and internal business purposes

We may use your personal data for our internal business purposes, such as administrative fulfillment or orders, administrative fulfillment of invoices, project management and internal reporting. We may also use your data to monitor the use of our website and ensure that our website is presented in the most effective and relevant manner for you and your device and setting default options for you.

It is in our legitimate interests as a business to use your personal data in this way. For example, we want to ensure our website is customer friendly and works properly and that our products and services are efficient and of high quality. We also want to make it easy for you to interact with us. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

For security and legal reasons

We use your personal data to:

  • ensure the personal and financial information you provide us is accurate;
  • conduct fraud checks or prevent other illegal activity;
  • protect our rights or property (or those of others); and
  • fulfil our legal and compliance-related obligations

In some cases we will use your personal data because it's necessary for us to comply with a legal obligation (such as if we receive a legitimate request from a law enforcement agency). In other cases (such as the detection of fraud) we will rely on our legitimate interests as a business to use your personal data in this way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

In relation to your ROCME customer relationship

We use your personal data to personalise your experience with ROCME to:

  • provide you with marketing information via SMS, post and email if you have given us your consent to this;
  • process your registration details, account activity and purchase history to analyse how you shop and what you shop for. This may include information on products you have viewed, historical transactions and products you have added to your online basket. This allows us to provide a browsing experience which is relevant to you;
  • carry out limited automated decision making (segmentation) based on the information you have given us when we segment our ROCME customer database to determine which offers that you may be interested in

We rely on your consent to send direct SMS, postal and email marketing messages to you based on the consent we acquired from you when you signed up, as amended by you from time to time.

In other cases (for example, measuring the effectiveness of our marketing), we will rely on our legitimate interests as a business to communicate with you in an engaging and efficient way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

5. Who do we share your personal data with?

We will never sell any of your personal data to a third party.

However, in order for us to provide our services to you, we share your personal data with our trusted third party service providers or our group companies, as detailed below. Whenever we share your personal data, we put safeguards in place which require these organisations to keep your data safe and to ensure that they do not use your personal data for their own marketing purposes.

Third party service providers

To fulfil orders for products and services

We work with a number of trusted service providers who carry out services on our behalf. When you purchase products and services from us, the services provided by these organisations includes delivery and pick-up of goods, build-up and break-down of on-site equipment, on-site technical support, on-site equipment rental, online registration platforms, technology integration and processing payments. It is in our legitimate interests as a business to work with these service providers since we may not have the capabilities to provide these services ourselves. In each case, we will ensure that the service provider is only allowed to use your personal data in order to provide the services to us and for no other purpose.

To prevent crime and comply with laws

We share your financial information including your credit, debit card or other payment information with third parties to ensure that your payment is safe and that your details are not being used fraudulently. This data sharing enables us to conduct fraud analysis which ensures that genuine and accurate payment details are provided to us for any purchase. We may share your personal data with credit agencies if you are requesting credit.

There may be other scenarios where we are subject to a legal obligation to share or disclose your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime or fulfil a legal requirement.

Other professional services

We may need to disclose your personal data to our insurers where we believe that it is required under our contractual relationship with our insurance provider to do so.

We work with carefully selected third parties, such as customer database hosting providers and marketing agencies who assist us in providing you with a positive customer experience.

ROCME associated companies

We may share the personal data we collect with other organisations associated with ROCME where those other companies share various operations and business processes with us. We will do this in order to fulfil our contractual obligations to you, or because it is in our legitimate interests to do so.

Transfer of your personal data outside the EEA

We may need to transfer your personal data outside of the European Economic Area (EEA) for example the USA, in the following circumstances:

  • where you have requested a service which is fulfilled by one of our trusted third parties or associated companies which sit outside of the EEA; or
  • where we work with a supplier which processes some of its personal data outside of the EEA.

These countries may not have the same data protection laws as the UK and the EEA and so your personal data may not be subject to the same protections. However, in such cases, we will make sure that any transfer of your personal data to countries outside the EEA is subject to appropriate safeguards as if it were being processed inside the EEA and under the guiding principles set out in this privacy policy.

6. Your rights

You have a number of rights relating to your personal information and what happens to it. You are entitled to:

  • have your data processed in a fair, lawful and transparent way;
  • be informed about how your personal data is being used, an example being this privacy policy;
  • access personal data we hold about you;
  • require us to correct any mistakes in your personal data;
  • require us to delete personal data concerning you in certain situations where there is no good reason for us to continue to process it;
  • request that we transfer your personal data to you or another service provider in a simple, structured format;
  • object at any time to processing of your personal data for direct marketing purposes;
  • object to automated decision making which produces legal effects concerning you or similarly significantly affects you;
  • object in certain other situations to our continued processing of your personal data; and
  • otherwise restrict or temporarily stop our processing of your personal data in certain circumstances

You can read more about your rights, including the circumstances in which they apply, in the Guidance from the Belgian Data Protection Authority

You also have the right to complain about our use of personal data to a local Data Protection Authority of your residence, nationality or where your rights have been infringed. In Belgium, you can do these by contacting the Belgian Data Protection Authority via their website

7. Changing your preferences

If you no longer wish to be contacted by us about our products or services, or for other marketing purposes, you can amend your preferences or unsubscribe by contacting us or simply follow the unsubscribe link provided in emails you receive from us.

We want to ensure that all the information we have about our customers is factually correct and up to date. If you find that the personal data we have about you is inaccurate or needs updating (for instance, you may have changed your name or address) then please contact us so that we can correct it.

If you have created a profile on the ROCME website, you can change the details stored about you by logging into your account.

8. Security and retention of your personal data

Security of your personal data

We take the security of your personal data very seriously. We have implemented various strategies, controls, policies and measures to keep your data secure and keep these measures under close review. We protect your data by using encryption techniques and we use other safeguards such as firewalls and password protection. This means that your data is protected and only accessible by co-workers who need it to carry out their job responsibilities. We also ensure that there are strict physical controls in our buildings which restricts access to your personal data to keep it safe.

Retention of your personal data

In broad terms, we will only retain your personal data for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of the data and the reason that we have the data in the first place.

We have procedures in place regarding our retention periods which we keep under review taking into account our reasons for processing your personal data and the legal basis for doing so.

9. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make significant changes we will let you know but please regularly check this policy on our website to ensure you are aware of the most updated version.


This Privacy Policy was last updated on May 24