Privacy policy

Article 1 - Who processes your data

Datarecuperatie BV, trading under the commercial name SmartRepair, is the controller for the processing of your personal data.

Registered office: Bargiestraat 15 bus B, 8900 Ieper
Workshop: Maalse Steenweg 137, 8310 Brugge
Enterprise number: 0436.125.559
Email for privacy matters: info@smartrepair.eu
Telephone: +32 50 95 03 03

We have not appointed a data protection officer. Questions about this policy or about your rights should be addressed to the email address above.

Article 2 - What data we process

Identification and contact data: name, address, email address, telephone number, and for business customers the company name and VAT number.

File data: the fault reported, the work carried out, the parts fitted, the status history and the correspondence about your file.

Device data: make, model, IMEI or serial number, and for refurbished devices the measured battery capacity and the number of charge cycles.

Payment data: the amount, the time, the payment method and the transaction reference. Your card or account number does not enter our systems; that runs directly through our payment service provider.

Shipping data: sender and destination address, weight and tracking number.

Evidence of acceptance: the text of the declarations you ticked when placing your order, with the time, the language, the IP address and browser details.

Photographs of your device, taken on receipt and after the work is done.

Technical data about your visit to https://smartrepair.eu, as described in article 10.

Article 3 - For what purposes and on what basis

Performance of the agreement: handling your order, the repair or sale, shipping, payment and follow-up. Without these data we cannot perform the agreement.

Legal obligation: retention of invoices and accounting records, and compliance with tax obligations.

Legitimate interest: demonstrating acceptance of our terms, evidence in the event of a dispute or a guarantee claim, the security of our systems, and preventing misuse. In doing so we have assessed that your interests and rights do not override ours.

Consent: placing non-essential cookies, and sending commercial messages where you opt in. You may withdraw consent at any time, without affecting processing carried out beforehand.

Article 4 - IMEI, serial number and device data

We process your device's IMEI or serial number in order to identify it, to order the correct part, to distinguish your device from others in the workshop, and to be able to link a guarantee claim to the device it concerns.

We do not use these data to track your location or your use of the device, and we do not share them with third parties beyond what is necessary to perform your order.

We do not read the data on your device, except where this is technically necessary to carry out the order, and then only to the extent required.

Article 5 - Photographs of your device

We photograph your device on receipt and after the work is done, in order to record its condition and to avoid disputes about damage.

When storing them we strip the metadata from the image, including any location data.

We photograph the device switched off or with a neutral screen, so that the screen contents are not captured. If personal information nevertheless appears, we delete that photograph at your request.

These photographs are kept with your file for the period set out in article 8 and are not used for other purposes.

Article 6 - Who we share data with

We do not sell your data and share them only where necessary.

Payment service provider: for processing your payment and any refunds.

Carriers: for shipping to and from the workshop. They receive your name, address and contact details.

Parts suppliers: only the model and, where needed, the serial number, never your contact details.

Our hosting provider and the service that sends our email, in their capacity as processors.

Our accountant, and where necessary a lawyer or a bailiff in the event of a dispute.

Public authorities, where a legal obligation requires us to do so.

With every processor we have an agreement stipulating that they use your data solely for our purposes and protect them appropriately.

Article 7 - Transfers outside the European Economic Area

We aim to process your data within the European Economic Area.

Where a transfer to a third country is nevertheless necessary, it takes place solely on the basis of an adequacy decision of the European Commission or of the standard contractual clauses, supplemented by whatever measures the specific case requires.

On request we will provide information about the safeguards applying to a particular transfer.

Article 8 - How long we keep data

File data, including device data and photographs: up to two years after the file is closed, so that a guarantee claim and any challenge to it remain possible.

Evidence of acceptance of the terms: ten years, being the period within which a claim under the agreement may be brought.

Invoices and accounting records: seven years, as required by law.

Data concerning an uncollected device, including the erasure log or destruction certificate: five years after the device has been processed.

Correspondence that is not part of a file: twelve months.

After these periods expire, the data are deleted or anonymised.

Article 9 - Your rights

You have the right of access to the data we process about you, and to a copy of them.

You may have inaccurate data corrected and incomplete data completed.

You may request erasure of your data, in so far as we do not need to keep them to perform the agreement, to meet a legal obligation, or as evidence in the event of a dispute.

You may have processing restricted and object to processing based on our legitimate interest.

You may receive the data you provided to us in a common format or have them transmitted.

You may withdraw consent at any time.

Address your request to info@smartrepair.eu. We reply within one month. If we cannot identify you with certainty, we will ask for further information; we keep that information no longer than needed to handle your request.

Article 10 - Cookies and measurement data

On https://smartrepair.eu we place cookies that are necessary for the site to work, such as remembering your session, your language choice and the contents of your order. No consent is required for these.

We place non-essential cookies only after you have agreed to them. You may change or withdraw your choice at any time through the cookie settings on the site.

In addition, our servers keep technical logs of the pages requested, including the IP address and the time. We use these logs for the security and proper functioning of the site, and not to profile individual visitors. They are deleted after twelve months.

Article 11 - Security

We take appropriate technical and organisational measures to protect your data. Traffic with our site is encrypted, access to files is limited to those who need it, and access to the systems runs through personal accounts.

Devices in the workshop are kept in a locked area.

If a breach nevertheless occurs that poses a risk to your rights, we report it to the supervisory authority and, where the risk is high, directly to you as well.

Article 12 - Right to complain

If you disagree with the way we process your data, please tell us first via info@smartrepair.eu. We will consider your complaint and reply to you.

You also have the right to lodge a complaint with the Gegevensbeschermingsautoriteit, https://www.gegevensbeschermingsautoriteit.be. If you live in another Member State, you may also turn to the supervisory authority of your place of residence.