Privacy Policy

This privacy policy (hereinafter referred to as the "Policy") sets out the terms under which the company Cycle Home - Komut srl—with its registered office at Rue Vanderkindere 395, 1180 Uccle; Tel: +32 (0)2 725 63 92; E-mail: hello@komut.be; VAT BE 0771.412.591 (hereinafter referred to as "Lecomte," "we," or "our")—protects the personal data it may collect and use, particularly in accordance with our General Terms and Conditions of Sale and our cookie policy. The person responsible for data protection at Komut is Alexandre le Grelle (Rue Vanderkindere 395, 1180 Uccle, Belgium; +32 (0)2 725 63 92; support@komut.be).

Komut collects and processes personal data of Buyers and beneficiaries of buyers in Stores and on the Webshop as well as, more generally, of any prospect, candidate or visitor present on the Webshop (hereinafter collectively referred to as the « Data Subjects », « you », « your »).

Terms used with a capital letter should be understood according to the definitions in the general terms and conditions of sale, the law of 30 July 2018 relating to the protection of natural persons with regard to the processing of personal data and Article 4 of Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the « GDPR ») or according to the definitions established within this Policy and the other contractual documents of Komut.

By using our website and webshop, using the products and services offered by Lecomte, or participating in our promotions, you expressly agree to the way Komut collects and processes personal data.


1. What are the principles applicable to the processing of personal data?

Komut collects or uses your Personal Data as a « data controller », for the needs of its activity in Stores and on the Webshop, and defines on this occasion the purposes and means of processing your Personal Data.

Komut is responsible for the Personal Data that you share with us, and is committed to processing it in accordance with the requirements of applicable law, including the GDPR. This notably involves:

• Obtaining and processing your Personal Data lawfully and fairly;
• Obtaining your Personal Data for specific, explicit and legitimate purposes, and consequently not processing it in a manner incompatible with those purposes;
• Processing only the Personal Data that is adequate, relevant and limited to what is necessary in relation to the purposes for which it was obtained and is processed;
• Ensuring that your Personal Data is accurate, complete and, if necessary, kept up to date; and
• Storing your Personal Data only for a period not exceeding that which is necessary in relation to the purposes for which it was obtained and is processed, and in accordance with applicable laws on limitation periods.


2. What personal data do we collect, how and for what purposes?

Komut lists its processing of your Personal Data in the table below, where it specifies (i) the activities or situations in which it collects and/or processes your Personal Data (column 1), (ii) the categories of Personal Data (column 2), (iii) the purposes and the use made of it (column 3) and (iv) the legal basis establishing the reasons why we carry out these uses (column 4).

This Policy may be updated at any time. Any update will be communicated to you at the time you make a transaction with us, when you log into your customer account, or by email. The new version of the Policy comes into effect immediately and it cancels and replaces the previous version as of its "last updated" date.

3. Information and consent simultaneous with or prior to collection

Komut collects Personal Data from each Data Subject in various ways. Depending on the specific activities involved, you may receive a notice regarding the processing of your Personal Data, or a message directing you to such information.

1. Direct collection: we may receive your Personal Data when you create a customer account or place special orders/request services in stores, through various features of the online shop—specifically via your inquiries, orders, and service requests—and through cookies placed by Lecomte on your device.

2. Indirect collection: sometimes, we may receive your Personal Data from third parties—specifically from partners and service providers involved in supplying the products and services offered on the Komut Webshop—or via cookies placed by these third parties on your device.

When we collect Personal Data via forms (including electronic ones), we will indicate mandatory fields with an asterisk. Failure to complete these fields may prevent you from accessing a service.

Where required by law, we will endeavor to obtain your consent prior to processing your Personal Data, and you may withdraw your consent to such processing at any time—either by contacting us at support@komut.be, by changing your selection in the "My Account" section of the Webshop, by specifying your request via the Webshop's contact form, or in accordance with the conditions set out in Articles 8 and 9 of this Policy.

4. When do we disclose your personal data?

Some of your Personal Data may be accessible to other people.

Within Lecomte, staff members may have access to your Personal Data to the extent necessary to provide you with the products and services you have requested, to ensure the technical maintenance, protection, and security of the Webshop, or with your prior consent (particularly for promotional messages and newsletters).

4.1. With our partners and service providers

Third-party partners and service providers may access your Personal Data, acting (i) either as processors (within the meaning of the GDPR) to provide Lecomte services necessary for the purposes set out above (accounting management, store management, hosting, maintenance, marketing), or (ii) as data controllers to provide services complementary to those of Lecomte—duly identified and under their sole responsibility (payment services, installment payments, third-party cookies, including social media)—subject to the conditions set out in Articles 10 et seq. below.

4.2. With public authorities and bodies

In accordance with applicable law or with your express authorization, Komut may share your Personal Data with third parties—including public bodies, officers of the court, ministerial officers, or debt collection agencies—for the purposes of:

(i) Protéger les droits, les biens ou la sécurité des Personne Concernées, de Lecomte, de ses salariés ou d'autres personnes

(ii) Permettre l’évaluation des actifs de Lecomte dans l’hypothèse d’une fusion ou de la vente d'actifs de la société (dans ce cas, vos Données à Caractère Personnel seront divulguées à l'acquéreur potentiel, et l’acquéreur potentiel aura la charge de renouveler les informations et/ou le recueil de votre consentement, le cas échéant et selon le droit applicable) ; et

(iii) To comply with a legal obligation, a judicial or administrative order, or legal proceedings of any nature, or to implement enforcement measures required by competent authorities.


5. Where do we store your personal data?

Lecomte engages the services of Odoo SA and its subcontractors for the maintenance and hosting of its management system and website, including the Personal Data collected and processed. Odoo SA and its subcontractors host Personal Data primarily in Europe and, in exceptional cases, in the United States under the certification


Privacy Shield which allows data to be transferred from the European Union to the United States.

Lecomte operates within the European Union, and some of its service providers are located abroad. Consequently, we may need to transfer your Personal Data from a country within the European Economic Area ("EEA") to a country outside the EEA. When Lecomte transfers Personal Data outside the EEA, such transfer will always be carried out in a lawful and secure manner:

• Either by transferring Personal Data to countries where the level of personal data protection is deemed adequate by an adequacy decision of the European Commission
• Either by transferring Personal Data to a recipient in the United States that is certified under the Privacy Shield, such a mechanism being deemed to ensure an adequate level of protection for your Personal Data pursuant to an adequacy decision by the European Commission;
• Either by signing the Standard Contractual Clauses (signed by Komut and its service providers) that have been approved by the European Commission as providing an adequate level of protection for your Personal Data

Either by transferring Personal Data to service providers that have implemented Binding Corporate Rules in accordance with Article 47 of the GDPR.

6. How long do we keep your personal data?

We will retain your Personal Data only for the period necessary to fulfill the purposes for which it was collected (typically, the duration of the contract when you purchase a product or use a service, which may extend for the duration of the provision of said service and/or until actual receipt of the ordered product and the expiration of the applicable withdrawal period).

• When you contact us with a request for information, we retain your Personal Data for the time necessary to process your request (unless it leads to an order from you, in which case the retention period is extended as indicated above);
• When you create a customer account in our stores and/or on our webshop, we retain your personal data for a period of three years following a period of inactivity (absence of active contact from you);
• When you have agreed to receive promotional messages, we retain your Personal Data until you unsubscribe or following a period of inactivity (absence of active contact on your part) set at three years;
• When cookies are placed on your computer, we retain them for as long as necessary to fulfill their purpose and for a period defined in accordance with local regulations and recommendations; and
• When you contact us to apply for a job opening or submit a speculative application, we retain your Personal Data until the position is filled or for a period not exceeding two years.

In all these situations, however, we may be required to archive your Personal Data for a longer period, particularly in compliance with specific legal or regulatory provisions and/or to adhere to applicable limitation periods.

In the event that we retain your data for longer periods for other reasons, we will inform you of those reasons and the applicable retention period at the time your Personal Data is collected.


7. How is your personal data protected?

We are committed to keeping your Personal Data secure and to taking all reasonable precautions to this end. We implement all organizational and technical measures required under this Policy and applicable law to protect your Personal Data against unauthorized access, alteration, disclosure, loss, or destruction, including through SSL (Secure Socket Layer) data encryption. We contractually require the same commitments from the service providers who process your Personal Data.

You must maintain the security and confidentiality of your Webshop login details (username, password) to prevent unauthorized use or misappropriation of your account (identity theft).

8. Your rights

You have a number of rights regarding your Personal Data, namely:

• A right of access and information: you have the right to be informed about the processing to which your Personal Data is subject, and in particular (i) to know whether or not your Personal Data is being processed, and if so, (ii) to access such Personal Data and obtain a copy thereof.
• A right to rectification: you have the right to have your incorrect Personal Data rectified or to complete incomplete Personal Data, including by providing a supplementary statement.
• A right to erasure ("right to be forgotten"): in certain cases, you have the right to have your Personal Data erased. However, this is not an absolute right, and Lecomte may rely on a legal basis or have a legitimate reason to retain your Personal Data.
• A right to restriction of processing: in certain cases, you have the right to restrict the processing of your Personal Data.
• A right to data portability: you have the right to receive the Personal Data you have provided to Lecomte in a structured, commonly used, and machine-readable format, and you have the right to transfer such Personal Data to another controller without hindrance from Lecomte. This right applies only (i) where the processing of your Personal Data is based on your consent or on a contract and (ii) where such processing is automated.
• Right to object to processing: You have the right to object to the processing of your Personal Data at any time. However, when you exercise your right to object to processing based on Lecomte’s legitimate interest, Lecomte may invoke compelling legitimate grounds to continue the processing to which you object.
• A right to withdraw your consent to processing based on consent at any time: you may withdraw your consent to the processing of your Personal Data where such processing is based on your consent. Withdrawing your consent does not affect the lawfulness of processing carried out based on that consent prior to its withdrawal.
• The right to lodge a complaint with the supervisory authority: you have the right to file a complaint with your supervisory authority for the protection of personal data.
• A right to provide instructions regarding the use of your data after your death: you have the right to provide instructions to Komut regarding the use of your Personal Data after your death.
• A right to obtain a copy of the standard contractual clauses signed by Lecomte when your Personal Data is transferred outside the EEA.

For further information regarding your rights and how to exercise them, please consult Article 9 ("Contact") of this Policy. Please note that we may require you to prove your identity and fully substantiate the information contained in your request before processing it.


9. Contact

For any questions or concerns regarding our processing and use of your Personal Data, or if you wish to exercise any of the rights mentioned above, please contact us using the following details:

• By phone at +32 2 201 92 97, Monday to Friday from 9:30 a.m. to 5:30 p.m.
• Par e-mail à support@komut.be (réponse en trois jours ouvrable)
• Via the live chat on our webshop, Monday to Friday from 9:30 a.m. to 5:30 p.m.

You may also exercise your rights by submitting your request via the contact form on the Lecomte website.

10. Stores & Webshop

Komut provides third parties only with the Personal Data necessary for Lecomte’s services and requires that they do not use your Personal Data for other purposes, except in the cases mentioned below. These third parties act solely on Lecomte’s instructions when acting as processors within the meaning of the GDPR: they are legally required to comply with applicable personal data protection laws and are contractually bound to ensure the same level of security and confidentiality for your Personal Data as Lecomte provides to you.

More specifically, Lecomte informs you that your postal address, email address, and telephone number are transferred to our delivery service providers for the purpose of carrying out services—specifically to implement delivery preferences, provide delivery notifications or tracking, and conduct satisfaction surveys. Some of these providers, acting as processors within the meaning of the GDPR, may transfer this Personal Data outside the EEA (see Article 5).

Komut provides you with additional information regarding certain third-party service providers that (i) collect and process your feedback concerning the Webshop and Komut, including for warranty or pre-litigation purposes, (ii) collect and process your payment information, and (iii) share your Personal Data on social media—particularly where such third parties are required to obtain consent or are acting as data controllers in the performance of their services.

This information is not exhaustive, and Komut invites each Data Subject to consult the privacy policies of its partners and third-party service providers who collect and/or process their Personal Data—whether via the Webshop or otherwise, and whether in conjunction with Komut or under their sole responsibility.

10.1. Management system subcontractors

These third-party service providers process data for which Odoo acts as the data controller or data processor, on behalf of Odoo.

10.2. Data controllers and third-party processors

These third-party service providers process data for which Lecomte is the data controller—acting as data processors on Lecomte’s behalf—or they receive such data as data controllers, for the specific purpose of performing the services for which they were engaged.

10.3. Social networks

The Webshop includes several features allowing Data Subjects to share content from the Webshop and their browsing on social networks; you are invited to check under what conditions these third-party data controllers process your Personal Data.

1. Facebook (and Instagram) is a social network that allows its users to communicate with each other and interact online, particularly to exchange opinions or experiences, as well as to access commercial (about products, services, or companies) or non-commercial information. Facebook allows the creation of personalised profiles, the sharing of content, and the creation of a network through friend requests, among other things.

The Facebook group acquired Instagram in 2012; the company operates the eponymous social network, which enables users to communicate with one another and centers on the sharing of photos and videos by members—whether amateur or professional—through subscriptions to various accounts' posts. Lecomte’s online store includes a link to Lecomte’s professional Instagram account.

Facebook and Instagram are managed by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. The data controller for individuals residing outside the United States and Canada is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Whenever a page on the Lecomte webshop contains a Facebook component (such as a share button), the data subject's web browser is prompted by that component to download it from Facebook onto the data subject's device. During this process, Facebook is informed of which page of the site the data subject is visiting.

If the Data Subject is connected to Facebook or Instagram at the same time, Facebook associates the pages visited on the Webshop with the profile of the Data Subject as well as other browsing information or related to your device, for the entirety of their browsing on the Site, always through Facebook components. In the same way, if the Data Subject clicks on one of these components, such as a ‘Like’ button, or if they post a comment, Facebook associates these actions with the profile of the Data Subject and retains this information. Facebook shares and cross-references this information on other Facebook products (notably Whatsapp) and with third parties.

Facebook receives this information from the Facebook components whether the Data Subject has clicked on the Facebook components or not, as long as they are connected to Facebook and/or Instagram. If you wish to oppose this transfer of information to Facebook, you can do so by logging out of Facebook prior to any visit to the Webshop. You can also use the Facebook or Instagram settings to oppose certain processing, and unsubscribe from marketing communications. Other services allow you to remove automatic data transmissions to Facebook, notably via modules integrated into web browsers.

The Facebook privacy policy is accessible at https://www.facebook.com/about/privacy.

The Instagram privacy policy is accessible from the site https://help.instagram.com/, section ‘Privacy and Security’, option ‘Instagram Data Use Policy’.

2. Twitter is a social network that allows for the exchange of messages (or "tweets")—limited to between 140 and 280 characters—either privately between users or publicly and openly on the Internet; the platform is funded by advertising. The Lecomte webshop includes a link to Lecomte’s professional Twitter account, where the company showcases its teams' activities, the products it offers for sale, and the various sports and activities that can be practiced using those products.

Twitter is managed by the company Twitter Inc., registered in the Delaware registry under number C 3006676 and located at 1355 Market Street, Suite 900, San Francisco, CA 94103, United States. For individuals residing outside the United States, the data controller is the company Twitter International Company, 1 Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.

If the Data Subject visits Lecomte’s Twitter account—even without being logged in or having a Twitter account—Twitter collects Personal Data regarding your browsing activity on Twitter, your location, and your device, particularly for the purpose of improving and personalizing advertisements. This Personal Data is collected by Twitter even when visiting the Webshop, without the Data Subject actually visiting Twitter.

If the Data Subject has a Twitter account, Twitter also collects tweets and interactions (“Likes”) with tweets from Lecomte’s Twitter account, and this Personal Data is cross-referenced and linked to the Personal Data collected and processed on your profile.

You can object to the processing of your Personal Data by Twitter by logging out of your Twitter account before visiting the Webshop, adjusting your account settings on Twitter to limit processing, or through the browsing settings of internet browsers or other dedicated applications.

Twitter's privacy policy is available at: https://twitter.com/fr/privacy.

10.4. Processing carried out by Google

Lecomte uses several distinct Google services on the Site, namely (i) marketing analytics and customer relationship tools from the Google Ads suite and (ii) the YouTube video hosting and sharing platform. These services are managed and provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States, which acts as the data controller. Google LLC operates in Belgium through its subsidiary Google Belgium S.A., registered under number 0878 065 378 with the Crossroads Bank for Enterprises, with its registered office located at Chaussée d’Etterbeek 180, 1040 Brussels.

1. Google Ads is a range of professional services offered by Google for the purposes of analysing visits to the Webshop, advertising management, and customer relationship management. Komut uses, in particular, the services of Google Customer Reviews and Google Analytics. These services aim, respectively, to evaluate Komut and the Webshop through the collection and aggregation of reviews from internet users and Buyers, and to provide Komut with analyses and statistics on internet users who have visited the Webshop; Google may also process the Personal Data collected for maintenance and support purposes of these services, or in connection with other Google services.

Google Analytics: whenever the internet user or the Buyer performs an action on the Webshop, Google collects and processes—acting as a processor on behalf of Lecomte (the data controller)—the user’s connection identifiers (cookies, IP addresses, identifiers of the devices used, Buyer identifiers) as well as information associated with requests sent to Google Analytics servers (IP addresses, date and time of requests, requested URL, subject of the request, browser and operating system type and language, device cookie). The IP address may be used to determine the internet user’s geographic location.

Google Ads removes a portion of the IP address (after 9 months) and cookie-related information (after 18 months) associated with queries. Upon Lecomte’s request or following the termination of the contractual relationship, Google deletes all personal data from its systems—subject to any applicable legal archiving obligations—within a period of up to 180 days from the request. Where Google has made such a mechanism available, you may also use the Google Ads service’s data subject request tool, including to exercise your rights to object to processing or to request the erasure of your Personal Data.

When you have a Google account, you have the option to determine whether your name and photo should appear next to your reviews and recommendations when displayed publicly.

You can obtain more information at the addresses: https://privacy.google.com/businesses/adsservices/
https://policies.google.com/technologies/ads?hl=fr

2. Youtube is a video hosting and sharing platform that allows users to view and comment on content uploaded by its users, and is funded by the insertion of advertisements, more or less personalised according to your consultations and your user account (YouTube account or associated Google account).

Whenever a page on the Lecomte webshop contains a YouTube component (such as a share button), the data subject’s web browser is prompted by that component to download it from Google onto the data subject’s device. During this process, Google is informed of which webshop page the data subject is visiting, as well as the unique identifiers associated with the browser, application, or device used by the data subject.

YouTube's privacy policy is accessible at: https://policies.google.com/privacy

If the Data Subject is logged into their Google account on the various services offered by Google, Google collects and associates information related to the Site with the Personal Data of the Google account. If the Data Subject uses an Android device on which Google applications are installed, the device regularly exchanges information with Google servers. Google cross-references information related to the Data Subject's activity on each of the services provided by Google.

Google may host and process your Personal Data in the United States or in other countries outside the EEA and Switzerland (in Taiwan and Singapore). Google is certified under the Privacy Shield for the processing of Personal Data in the United States and complies with Article 28 of the GDPR for other international transfers of Personal Data.

You can configure the use of your Personal Data by Google across the various Google services. If you wish to object to the cross-referencing of information by Google, you can do so by logging out of the services you have logged into with your Google account before using the Webshop. Other services allow you to disable automatic data transmissions to the various Google services, notably via plugins integrated into web browsers.

11. Cookies

Cookies are small pieces of text sent by our servers to your computer or device when you access our services. They are stored in your browser and sent back to our servers later so that we can provide contextual content. Without cookies, using the web would be a much more frustrating experience. We use them to support your activities on our website, for example your session (so you don’t have to log in again) or your basket.

Cookies are also used to help us understand your preferences based on your previous or current activity on our website (the pages you have visited), your language and country, which allows us to provide you with enhanced services. We also use cookies to help us compile aggregated data on traffic and interaction on the site, so we can offer better experiences and better tools in the future.

We also use third-party services such as Google Analytics, which set and use their own cookies to identify visitors and provide their own contextual services.

Here is an overview of the cookies that may be stored on your device when you visit our website:

You can ask your computer to alert you every time a cookie is sent or you can choose to disable all cookies. Each browser is slightly different, so check your browser's help menu to learn the correct way to modify your cookies or consult the following links.

• Chrome : https://support.google.com/chrome/answer/95647?hl=en
• Edge : https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy
• Firefox : https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Safari : https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• Opera : https://help.opera.com/en/latest/web-preferences/#cookies

We currently do not support the Do Not Track feature, as there is no industry standard for compliance.