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FABORY PRIVACY SUMMARY

At Fabory Group and our subsidiary and affiliated companies and sites (collectively, “we”, “us”, or “our”), we are committed to protecting your personal data and respecting your privacy rights. We, as the data controller, are responsible for protecting your personal information. This privacy policy (“Privacy Policy”) explains what personal data is collected and how it is processed. Further details about the categories of personal data we collect, the purposes for which we use that data, the legal bases we rely on, and the applicable retention periods can be found in Annexes 1 and 2 to this Privacy Policy.

This Privacy Policy and other documents referenced in it apply to all personal data collected through our Service and any other related services, sales, marketing or events. In those cases, our affiliates and subsidiaries act as controllers of your personal data. This Privacy Policy applies to our websites and brands, namely www.fabory.com and any other website, mobile application, or other online service (“Service”) that links to this Privacy Policy.

Before accessing or using our Service, please ensure that you have read and understood our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.

Personal data is any information relating to an identified or identifiable natural person. It includes information such as email addresses, phone numbers, mailing addresses, payment card information, account numbers, and government-issued identification numbers. These are just examples and there are many other types of information that would be considered personal data.

QUESTIONS ABOUT OUR PRIVACY POLICY?

We hope you take some time to read through this Privacy Policy carefully. If you have any questions or concerns about our collection or use of your information, please contact us at data.protection@fabory.com.

Click on the links below to jump to each section:

1. WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE USE IT?

2. THIRD-PARTY DATA COLLECTION AND INTEREST-BASED ADVERTISING

3. YOUR CHOICES AND CONTROL OVER YOUR INFORMATION

4. HOW WE STORE AND PROTECT YOUR INFORMATION

5. DISCLOSURE OF YOUR INFORMATION

6. PROCESSORS AND INTERNATIONAL DATA TRANSFERS

7. YOUR RIGHTS IN RESPECT OF YOUR INFORMATION

8. LINKS TO OTHER WEB SITES AND SERVICES

9. HOW TO CONTACT US

10. CHANGES TO OUR PRIVACY POLICY

1. WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE USE IT?

We collect personal data directly from you (for example when you submit information while using our Service), automatically through your use of the Service, and from third‑party providers. The legal bases for these processing activities are described below and in the annexes to this Privacy Policy.

Please note, the laws that apply to the processing of personal data (including regulations, guidelines, government issued rules, and court opinions interpreting laws) (“data protection laws”) may require us to describe our processing using certain terms or in a specific way. Although we have tried to use terms consistent with data protection laws, we aren’t always able to use terms that may be used in your jurisdiction.

I. INFORMATION YOU DISCLOSE TO US

The personal data that we collect depends on the context of your interactions with us and the Service, the choices you make and the features you use, including for the following purposes:

  • to register an account and logon process. We use personal data you provide to create an account with us. Processing is necessary in order to enter into a contract with you or for the performance of the contract we have with you. Without providing your personal data, you cannot create an account with us;
  • to provide the Service. We process your personal data to enable you to use our services, including purchasing products through our website and using our applications on your mobile device. Processing is necessary in order to enter into a contract with you or for the performance of the contract we have with you. Without this information, we cannot provide the requested services;
  • to send administrative information to you. We may use your personal data to send you information about products or services you have purchased or information about changes to our terms, conditions, and policies. Processing is necessary for the performance of the contract with you or in order to fulfil our legal obligations;
  • to fulfil and manage your orders for products. We may use your personal data to fulfil and manage your orders and payments, and to address any issues with services provided through the website and/or applications, All payment data is stored by our third-party payment providers. You should review its privacy policies and contact the payment provider directly to respond to your questions. Processing is necessary for the performance of the contract with you;
  • to post reviews. We post testimonials on the website that may contain personal data, including first name, job title and testimonial which you submitted. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal;
  • to conduct surveys. We may process the personal data you provide when you choose to participate in surveys or feedback requests. We use this information to evaluate and improve our products and customer experience. Processing is based on our legitimate interest in improving the Service. You may withdraw your consent at any time;
  • recording phone calls. We may also record phone calls between our employees and individuals contacting us. The primary purposes of these recordings are to train our staff, to improve the quality of our services, and to ensure that our customer interactions are handled in a consistent and professional manner. The legal basis for the recording of calls is our legitimate interest and this lies in enhancing employee training, monitoring service quality, and ensuring that we can continuously improve the customer experience. These interests are balanced against your rights and freedoms. Recordings are retained only briefly and are anonymised without undue delay. Once anonymised, the data is no longer considered personal data and may be further used for training and service improvement, also with the use of AI. Opt-out / consent for phone recordings:
    • Inbound calls: callers are informed at the start of the conversation that the call may be recorded. They have the option to object (opt-out) immediately.
    • Outbound calls: when we initiate a call, the customer is informed afterwards that the conversation may have been recorded and is provided with an opportunity to object (opt-out).
    • Countries requiring consent: in some jurisdictions, such as Belgium and Germany, we will only record calls if the individual has actively given consent (opt-in). In such cases, consent may be withdrawn at any time by contacting us at data.protection@fabory.com. Withdrawal of consent will take effect up to the point when the data has been anonymised. 

The table at Annex 1 sets out the categories of personal information we collect about you, how we use that information and the applicable retention period. The table also lists the legal basis which we rely on to process the personal information.

II. INFORMATION AUTOMATICALLY COLLECTED

We collect certain information automatically when you visit, use or navigate the Service, including for the following purposes:

  • to send you marketing and promotional communications. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”). We may use your personal data for our marketing purposes, depending on your marketing preferences. We will ask for your consent. You also have the right to withdraw your consent at any time;
  • to deliver targeted advertising to you. We typically collect this information through tracking technologies. We may use your personal data to develop and display content and advertising (and work with third parties who do so) tailored to your interests or location and to measure its effectiveness. We will ask your consent to use your personal data for this purpose. You also have the right to withdraw your consent at any time;
  • to develop our products or to improve our Service. We may use your personal data to further develop our existing products and services, or to develop new products and services. The processing is based on our legitimate interest;
  • to protect the Service, us, and others. We may use your personal data as part of our efforts to keep the website and applications safe and secure (for example, for fraud monitoring and prevention) and to protect others from harm or abuse. The processing of your personal data for this purpose is based on our legitimate interest.

Information we collect automatically about you may be combined with other personal information we collect directly. The table at Annex 2 sets out the categories of personal information we and our third parties collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.

2. THIRD-PARTY DATA COLLECTION AND INTEREST-BASED ADVERTISING

I. INTEREST BASED ADVERTISING AND DATA COLLECTED THROUGH THIRD PARTIES

Where you have provided your consent, we may use information collected through cookies and similar technologies to display advertisements tailored to your interests on our Service and on third‑party websites and platforms based on your browsing history. We permit third-party online advertising networks, social media companies and other third-party services to collect information about your use of our websites and mobile apps over time so that they may play or display ads on our Service, on other websites, apps or other services you may use, and on other devices you may use. For this purpose, third‑party advertising networks and social media platforms may collect information about your interactions with our websites and mobile applications over time, including through cookies and similar tracking technologies, in order to measure the effectiveness of advertising and to display relevant advertisements to you across different websites, applications and devices.

We may share a common account identifier (such as an email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services. Where permitted by data protection laws and subject to your consent, we and third-party advertising partners may use such information to support advertising‑related services, including reporting, attribution, analytics and market research. We do not permit our advertising partners to use this information for their own independent purposes.

II. SOCIAL MEDIA WIDGETS AND ADVERTISING

Our Service may include social media buttons or plugins, such as the Facebook Like button, Google Plus, LinkedIn, Snapchat, Instagram, Twitter or other widgets. When you interact with these features, the relevant social media provider may collect information about your interaction with our Service, including through the use of cookies or similar technologies. We display the interest-based advertisements to you through social media platforms.

These social media providers offer services that enables us to direct advertisements to users who have shown interest in our Service while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them. Please note that we do not control, and are not responsible for, other uses of your personal data by those social media companies. We recommend that you review their privacy policy to understand how they collect, use and share your personal data, and how you can set your privacy preferences on their sites and applications.

III. ANALYTICS AND USER EXPERIENCE INFORMATION

When using our Service, we use third-party analytics and user experience tools to monitor how our Service is used and to improve its functionality and usability. These tools collect information about interactions with the Service, including mouse clicks and movements, page scrolling and any text keyed into website forms. The information collected does not include passwords, payment details, or other sensitive personal data. We do not permit these third-party providers to use the information for their own independent purposes.

Please see our Cookie Policy which sets out the third-party service providers we work with to provide cross-device linking and advertising services and site analytics. We may also share information with others in an aggregated or otherwise anonymised form that does not reasonably identify you directly as an individual.

Specific information about how we use such technologies and how you can refuse or disable certain cookies is set out in our Cookie Policy. The use of cookies other than essential cookies, including for the purposes of targeted advertising, is performed on the basis of your consent.

See Your Choices and Control Over Your Information, below, to learn more about how you may control interest-based advertising, how we use social media widgets and user information.

3. YOUR CHOICES AND CONTROL OVER YOUR INFORMATION

You have several choices and controls over how your personal information is used, including:

  • Profile and data sharing settings: You may update your profile information, such as your username or address, and may change some of your data sharing preferences on your account page.
  • How to control your email preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. Once your request has been processed, you will no longer receive promotional emails from us. Service‑related communications, including transactional, technical or security‑related messages, are not subject to un-subscription, as they are necessary for the performance of the contract or to comply with legal obligations. You may not opt out of service-related communications.
  • Cookies, tracking and interest-based advertising preferences: We may use cookies and similar tracking technologies (like web beacons and pixels) to collect or store information. Specific information about how we use such technologies and how you can refuse or disable certain cookies is set out in our Cookie Policy. The use of cookies other than essential cookies, including for the purposes of targeted advertising, is performed on the basis of your consent.
  • Geolocation and in-branch location: You can control location tracking by adjusting your location services settings in the application on your mobile device or via the website. If you disable location services, certain features of the Service may not function as intended. When you access the Service from a computer or device, we may continue to approximate your location based on your IP address. This relates only to approximate location information and cannot be disabled through device settings.

4. HOW WE PROTECT AND STORE YOUR INFORMATION

Keeping your information safe: We have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we collect, receive, use, or store, including measures designed to protect data transferred to different countries for use or processing in accordance with this Privacy Policy. We will do our best to protect your personal data taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for your rights and freedoms posed by the processing. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations. You should however access the Service within a secure environment. If you believe your account has been compromised or you suspect any type of data breach, please contact us at data.protection@fabory.com.

We may de-identify (as also referred to as “anonymize”) and aggregate data for its business purposes, including but not limited to, to improve the products and features of the Service, to maintain the security and integrity of its systems, for analytics, and other legitimate business purposes. "De-identified Data" means information that cannot reasonably be used to infer information about, or otherwise be linked to a particular data subject. De-identified Data includes anonymized data and is no longer “personal data” under applicable data protection laws. Where we process De-identified Data, we commit to maintain and use the information in de-identified form and not attempt to reidentify the information, except where permitted by law. We may disclose De-identified Data to third parties who commit themselves to maintaining the De-identified Data in anonymized form and not attempt to re-identify the data for any business purpose.

Retention of your information: We will only keep your personal data for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as business records, tax, accounting or other legal requirements). In determining data retention periods, we take into consideration the applicable law, contractual obligations, and your expectations. When there is/are an indication(s) of potential legal claim(s) or liability, the retention period will be extended accordingly.

When we have no ongoing legitimate interest need to process your personal data, i.e. when we no longer have a legal basis in accordance with applicable law, we will either delete or anonymize it and we will make such determination based on applicable laws. When the processing of personal data is based on your consent, the data will be stored for as long as there is valid consent for the processing. See Annexes 1 and 2 for the retention period of the data that we collect.

5. DISCLOSURE OF YOUR INFORMATION

In order to offer our products and provide the Service, we work together with other parties. Some parties process personal data exclusively on our behalf, which is laid down in a data processing agreement. We only give these parties access to your personal data on the basis of our instructions. We will share your personal information with the following categories of recipients:

  • Our affiliates and companies in the same group of companies as us: Our affiliates and subsidiaries (i.e., any organization or brand we own or control) or Torqx Capital Partners B.V., our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies may use your personal information in the same way as we can under this Privacy Policy, insofar as this is necessary for the purposes described in this Privacy Policy and for which there is a basis;
  • Third parties at your request: You may choose to share your activities on the Service with your friends through email, text or on various social media networks;
  • Promotional partners: Third parties with whom we partner to provide contests and sweepstakes, or other promotional activities, which will usually be identified by name in the Official Rules of the contest or sweepstakes;
  • Select third parties: Third parties, so that they can provide you with information and marketing messages about products or services that may interest you. To opt-out of our sharing your personal information with such companies, see our Cookie Policy;
  • Service providers and advisors: Third-party vendors and other service providers that perform services for us, on our behalf, which may include identifying and serving targeted advertisements, providing mailing or email services, tax and accounting services, product fulfilment, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services;
  • Suppliers: Personal information may be shared with our product suppliers for logistical purposes and to improve distribution, for resolving warranty and related issues in the event of a recall or rebate of a product, and in connection with trade shows we host where the supplier is an exhibitor;
  • The public: When you provide feedback or post user content on our site. For example, if you post a product review on our website or a comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our website or on our social media pages;
  • Purchasers and third parties in connection with a business transaction: Personal information may be disclosed to third parties in connection with a Fabory-related transaction, such as a merger, sale of Fabory assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another Torqx entity or third party, or in the event of a bankruptcy or related or similar proceedings; and
  • Law enforcement, regulators and other parties for legal reasons: Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of our visitors, or others.

6. PROCESSORS AND INTERNATIONAL DATA TRANSFERS

We will engage processors who adequately implement appropriate technical and organizational measures and who guarantee the protection of your rights. In order to ensure this, we enter into data processing agreements with our processors. This is required under the data protection laws. The data processing agreement regulates, among other things, data security, confidentiality and your rights.

If your personal data are transferred to ‘third countries’ – i.e., countries outside the European Economic Area (“EEA”) – we will only do so if the third country offers an adequate level of protection. In some countries outside the EEA – which as at the date of the last update of this Privacy Policy include Andorra, Argentina, Canada (commercial organizations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland , the United Kingdom under the GDPR and Directive (EU) 2016/680, the United States (commercial organizations participating in the EU-US Data Privacy Framework) and Uruguay (for more information and up to date list of the countries please, check here) – your personal data are sufficiently protected in accordance with European data protection laws and regulations. Where this is not the case, we provide appropriate safeguards to ensure adequate data protection, such as the most recent standard contractual clauses as approved by the European Commission and by additional safeguards, a copy of which can be obtained by sending an e-mail to data.protection@fabory.com. If no appropriate safeguards are in place, we will only transfer your personal data if a legal exception applies. An example of a legal exception is explicit consent.

7. YOUR RIGHTS IN RESPECT OF YOUR INFORMATION

The rights described in this section applies to all users. You have the following specific rights under applicable data protection laws in respect of your personal information that we hold:

  • Right of access. You have the right to access the personal data collected about you. You also may request to know the categories of personal data collected about you, the information or categories of information shared with third parties, or the specific third parties or categories of third parties to which the information was shared; or, some combination of similar information. However, there are certain exemptions, meaning that data subjects may not always receive all of the information we process;
  • Right to data portability. Under certain circumstances, you may request us to transfer your personal data, provided by you, to another controller. Also, you have the right to receive your personal data, which have been provided by you, in a structured, commonly used and machine-readable format and to transmit those data to another controller;
  • Right to rectification. Without prejudice to your right to review or change the information in your account to make sure it is accurate and up-to-date, you also have the right to request rectification of any other of your personal data, provided to us if you consider it to be inaccurate or incomplete. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete;
  • Right to erasure. You generally have a right to request your personal data or part of it to be erased (e.g., when your personal data are no longer necessary for the stated purposes in this Privacy Policy, the personal data have been unlawfully processed); however, we may not always erase your personal data because sometimes the processing is still necessary. For example, for complying with statutory obligations or for lodging, exercising or substantiating legal claims. Therefore, we will weigh your interest in having your personal data erased against the necessity of maintaining the personal data for our legitimate interests. Please be aware that if you request us to delete your personal data, you may also not be able to continue to use the Service; and
  • Right to restriction. Under certain circumstances, you may have the right to restrict a business’s ability to process personal data about you. For example, if the accuracy of your personal data is contested, the processing is unlawful or personal data is no longer needed for purposes of the processing. However, we can still use restricted data in certain circumstances (e.g., when your personal data is needed for legal claims or to protect another data subject’s rights);
  • Right to object. Under certain circumstances, you may object to the processing of your personal data by us or third parties engaged by us. We will consider several factors when assessing an objection to our processing in furtherance of our legitimate interests, including: our users’ reasonable expectations; the benefits and risks to you, us, other users, or third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. Your objection will be upheld, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. For example, you may object to the use of your personal data for direct marketing purposes.

To protect your privacy, we will take reasonable steps to verify your identity before responding to the request. Only you, or someone legally authorised to act on your behalf, can submit a verifiable request regarding your personal data. When you submit a request, we may ask you to confirm your name, email address or other information in our records to verify your identity. This is a security measure to ensure that personal data is not disclosed to persons who are not entitled to it.

We will respond to your request as soon as possible, and no later than one month after receipt. In doing so, we will also assess whether and to what extent we can or must comply with the request under the law. If an extension of up to two months is necessary, we will also notify you of this within one month of receiving the request. Submitting your request is free of charge, unless the request is evidently unfounded or excessive, in particular due to its repetitive nature. We also reserve the right to charge a reasonable fee if you request additional copies in connection with your access request. You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at: http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.htm.

8. LINKS TO OTHER WEB SITES AND SERVICES

The Service may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.

9. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the website, please contact the Data Protection Officer at Data.Protection@fabory.com.

10. CHANGES TO OUR PRIVACY POLICY

We may modify or update this Privacy Policy from time to time and you should review this page periodically. We will update the ‘last modified’ date at the bottom of this page when we post changes to this Privacy Policy. Where we have your email address, we will notify you of any material changes to this Privacy Policy. If you object to any changes, you may stop using our Service. Continuing to use our Service after we publish changes to this Privacy Policy means that you have read and understood the changes.

Effective date: 18 March, 2026.  

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