Terms and Conditions
We understand that your trust in us, PolyREC and Recovinyl (service providers), is our most important asset.

If you have any questions regarding these Terms and Conditions, please contact us on info@polyrec.eu or info@recovinyl.com

By accepting our Terms and Conditions, you agree with the statements below.

Usage of RecoTrace

  1. Use of RecoTrace is free of charge and without any obligations.
  2. You understand that PolyREC, Recovinyl and individual PolyREC member organisations cannot guarantee flawless performance of RecoTrace. Disruptions of the service, errors and malfunctions might occur but will be addressed immediately. If you experience an issue, please alert PolyREC or Recovinyl team at info@polyrec.eu or info@recovinyl.com.
  3. You submit your recycling and/or converting data to RecoTrace on a voluntary basis and to the best of your abilities, at least once a year (preferably twice).
  4. You accept to submit your data on time, before the communicated deadline.
  5. You are familiar with and understand the CPA definitions of recycling, converting, waste and by-product. You commit to register data compliant with these definitions (consult the CPA documents).
  6. PolyREC, Recovinyl and PolyREC member organisations cannot be held responsible for the errors/issues in RecoTrace caused by an inadequate use or abuse of the system.
  7. PolyREC, Recovinyl and PolyREC member organisations cannot be held responsible for the loss of registered data in case of malfunctioning of the software. However, will do everything necessary to restore any lost data.
  8. Data you provide through RecoTrace, although stored by PolyREC and Recovinyl, remains your property. You can request an export and deletion of your data at any point in time.
  9. PolyREC, Recovinyl and PolyREC member organisations are not responsible for the correctness of the data you provide.

Security of your data

RecoTrace is built following all the standard practices (ISO 27032) to ensure security of your data.

  1. You understand that you are responsible for the security of your RecoTrace account and are expected to follow general best practices to keep your RecoTrace account and your data secure (creating strong password, never sharing your password with anyone, not leaving your laptop open in public, etc.)
  2. PolyREC, Recovinyl and PolyREC member organisations cannot be held responsible for misuse of your data by third parties if data has been accessed through your account. For example, if you have shared your password with a third person and he/she disclosed your data.
  3. If you suspect that security of your account has been jeopardised, it is your responsibility to change your password and to inform PolyREC or Recovinyl about the incident.
  4. To fulfil our role of the Data Collector to the CPA (the CPA documents) and assist you in case of problems, it is essential for some of us to have access to individual companies’ data. Only the following people have access to the individual data provided by the companies:
    1. RecoTrace administrator from Recovinyl
    2. RecoTrace administrators from PolyREC (one person per member organisation)
    3. IT consultants and developers contracted by PolyREC and/or Recovinyl
    4. Recovinyl auditors and Recovinyl Regional Representatives (have access only to PVC data, upon certain conditions and always with a permission from you).
  5. Everyone listed above (13 a – d) has signed an NDA, does not work for a recycler or a converter and has received a training on competition law compliance.
  6. Individual companies’ data will never be disclosed.
    Your data will not be shared with third parties (e.g., sector associations), unless you explicitly give your permission to do so (for example, by ticking a box ‘I agree to share my data with the following sector associations’ on RecoTrace).

Use of your data (for reporting purposes)

Data submitted to RecoTrace will be used for the reporting to the CPA and for the reporting on the individual pledges of PolyREC member organisation and Recovinyl.
Only aggregated data will be used for the reporting purposes. Data will be aggregated by (waste) sector, country of origin and polymer.
Even when reporting aggregated data, compliance with the European Competition Law will always be assessed before sharing aggregated data with the CPA and public.

Use of your personal data: Privacy Policy

Our privacy policy is applicable to:

      • PolyREC website www.polyrec.eu
      • Recovinyl website www.recovinyl.com
      • RecoTrace website www.polyrec.org
      • all interactions between PolyREC and RecoTrace users, prospects and business partners
      • when visiting the building/office of PolyREC.
    1. PolyREC and Recovinyl acts in accordance with (i) the Belgian Privacy Law of 8 December 1992 on privacy protection in relation to the processing of personal data and/or (ii) the EU Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC and (iii) all (future) Belgian laws regarding the implementation of this Regulation.
    2. Visiting the Website, appealing on the services of PolyREC or Recovinyl, subscribing for the newsletter, any communication with PolyREC, creation of an account on RecoTrace, subscription to a seminar/webinar/event and downloading files implies your explicit approval (through disclosure of your personal information or opt-in) of the Privacy Statement and consequently how we collect, use and process your personal data.
    3. Types of personal data we might collect and process:
        • Name and Surname
        • E-mail address
        • Telephone number (landline and/or mobile phone)
        • Company data
        • Payment and billing information
        • Your function and position
        • Images and pictures
        • Gender
        • Nationality
    4. PolyREC also automatically collects anonymous information regarding your use of the Website. As such, PolyREC shall, for example, automatically log which sections of the Website and Platform you visit, which web browser you use, which website you visited when you obtained access to the Website. We cannot identify you through these data, but it allows PolyREC to draw up statistics regarding the use of the Website.
    5. This personal data is collected in the context of:
        • Visiting the Website
        • Collaboration with PolyREC or Recovinyl
        • Incoming and outgoing correspondence with PolyREC or Recovinyl
        • Invoicing
        • Registering for events, webinars, seminars.
        • Visiting PolyREC or Recovinyl offices
        • Through recording of webinars after prior personal consent
        • Subscription to the newsletter (whether through the Website or otherwise)
        • Appealing on the services of PolyREC or Recovinyl, whether through the Website and/or whether or not via the Website a mobile device
        • Whilst drafting reports of meetings
    6. PolyREC and Recovinyl might use your personal data for the following purposes:
        • Execution of the agreement with PolyREC and/or Recovinyl (incl. follow-up thereof)
        • Responding to questions (received through the contact forms or otherwise)
        • Sending newsletters
        • Creating statistics
        • Drawing up a quote
        • Follow-up after a meeting
        • Creation of an account (free or paying) and the confirmation thereof
        • Providing support/assistance (e.g. in case of problems)
        • Send targeted marketing and advertising, updates and promotional offers based on your communication preferences and – where applicable – upon explicit consent
        • Conducting customer satisfaction studies, surveys and other market research
        • Confirmation of the subscription of a webinar/seminar/event/etc.
        • Issuing invoices and the collection thereof
        • Legally required publications (Moniteur Belge, etc.)
    7. PolyREC and Recovinyl shall not disclose your personal data to third parties, unless it is necessary in the context of performing the agreement and optimisation thereof (including but not limited to PolyREC and Recovinyl). In this respect, your personal data may be disclosed to payment providers, software providers, cloud partner, transport partners, external consultants and service providers, legal entities.
    8. If it is necessary that PolyREC or Recovinyl discloses your personal data to third parties, the third party concerned is required to use your personal data in accordance with the provisions of this Privacy Statement.
    9. PolyREC and Recovinyl might disclose your personal data in the following cases:
        • To the competent authorities if PolyREC or Recovinyl is obliged to do so under the law or under legal or future legal proceedings and to safeguard and defend our rights
        • If PolyREC or Recovinyl, or most of its assets, are taken over by a third party, in which case your personal data is one of the transferred assets.
        • The contact details of RecoTrace users to other RecoTrace users after prior consent
        • To the participants of events after prior consent
    10. In all other cases, PolyREC and Recovinyl will not sell, hire out or pass on your personal data to third parties, except when it has obtained your permission to this end and has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your personal data.
    11. Any transfer of personal data outside the European Economic Area (EEA) to a recipient whose domicile or registered office is in a country which does not fall under the adequacy decision enacted by the European Commission, shall be governed by the provisions of a data transfer agreement, which shall contain (i) the standard contractual clauses, as referred to in the ‘European Commission decision of 5 February 2010 (Decision 2010/87/EC)’, or (ii) any other mechanism pursuant to privacy legislation, or any other regulations pertaining to the processing of personal data.
    12. Storage of personal data and your privacy rights
      1. Unless a longer storage period is required or justified (i) by law or (ii) through compliance with another legal obligation, PolyREC and Recovinyl shall only store your personal data for the period necessary to achieve and fulfil the purpose in question, as specified in the Privacy Statement under ‘Use of personal data’.
      2. You have the following rights when it comes to your personal data:
        1. Right to access your personal data
        2. Right to rectification, completion or update of your personal data
        3. Right to delete your personal data (‘right to be forgotten’). PolyREC and Recovinyl wishes to point out that in this context certain services will no longer be accessible and/or can no longer be provided if you delete resp. request deletion of certain required personal data.
        4. Right to limit the processing of your personal data
        5. Right to transferability of your personal data
        6. Right to object to/oppose the processing of your personal data

If you wish to invoke your privacy rights, please contact info@polyrec.eu, info@recovinyl.com.


If you have questions and/or remarks about the way PolyREC or Recovinyl collects, uses and/or processes your submitted and your personal data, please contact us: info@polyrec.com

In case you are not satisfied with the way PolyREC or Recovinyl handled your questions and/or remarks or have any complaints about the way PolyREC collects, uses and and/or processes your personal data, note that you have the right to lodge a complaint with the Privacy Commission.