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Privacy

Freedelity – Privacy Protection Policy


Nature of information collected

Freedelity saves the following personal data pertaining to you (“Data”) which you consent to communicate when you voluntarily sign up to the Freedelity loyalty scheme and database management (“Freedelity Scheme”) set up by Freedelity partner traders (“Partners”):
  1. data visible on your electronic identity card (“eID card”): first name, surname, place and date of birth, sex, identity card no. (excluding the National Register identification no.) and stored on your eID card chip (address);
  2. your e-mail address and/or GSM no., if you consented to providing them to the Partners concerned.

When Freedelity is the Partner’s sub-contractor (see below: “Purposes and Processing managers”), Freedelity will inter alia save the log of your purchase transactions and communications with Partner(s) in question on behalf of said Partner(s).

How is your personal data collected?

The Data is collected by reading it from the eID card either using eID readers, or using a terminal (kiosk, tablet, computer or other interface), installed on Partners’ sites; for people who have no Belgian eID card or who do not want to use one for the purposes anticipated by Freedelity and its Partners, the (same) Data will be entered into a terminal screen manually, yourself or by the cashier, based on the information which you provided.

How is the information collected used?

Data taken from the eID card will be saved automatically in the Freedelity database (and in the file unique to each Partner), necessary for creating a unique login (generated automatically) and a “Freedelity account” for:
  1. fast identification with each subsequent use (purchase) (by using your eID card or by communicating your first name and surname if logging in manually)
  2. enabling your participation in the Freedelity (Loyalty) Scheme (and subsequently authenticating your status as a participant) set up by the Partner(s) in question);
  3. and if you also provided the Partner with your e-mail address: when you first use it, an e-mail will be sent to you by Freedelity with a login and password so that you may access the “Freedelity Platform”, so that you may (by identifying yourself using either your eID card and a compatible reader, or the login and password which you received by e-mail) directly access all of your Data and see how it is being used by each Partner, and immediately exercise any right inherent to it (see the “Your rights” section) and/or consult the status of your Loyalty Scheme points accumulated with each Partner.

Purpose of processing and Processing managers

Freedelity

The exact purpose of saving and keeping your data up-to-date is:
  1. to create a unique, reliable database containing your Data and similar data on other dealers which wish to join the Freedelity Scheme set up by a Partner, so that its Partners may provide the other services described below (see: “Freedelity Partners”);
  2. by participating in the Freedelity Scheme set up by the Partner, to improve database quality, you consent to the Data being used for the purposes of updating (for example, after moving house) the Freedelity database (as with the Databases of the different Freedelity Partners with which you have signed up, a list of which may be found on our website);
  3. so that you may directly, completely and immediately check how your Data is being used by each Partner and/or so that you may consult, at any time, the status of your loyalty points accumulated with each Partner by accessing the Freedelity Platform (if you consented to providing your e-mail address and the Partner opted for the Freedelity Loyalty Scheme);

Freedelity SA (rue du Panier Vert 70, 1400 Nivelles) is responsible for the aforementioned processing; if you have any questions about how your Data is processed, please write to our Data Privacy Officer at the following e-mail address: dpo@freedelity.be.

Freedelity Partners

To enable its Partners to provide one or more of the following services to their clients (according to their Freedelity contract options, and the options which you chose when you signed up with the Partner(s) in question):
  1. issue the legal guarantee (2 years, linked to purchase) in digital form;
  2. communicate with you and notify you of the Partner’s direct marketing (based on saving the e-mail address and telephone number);
  3. by participating in the Freedelity Scheme set up by the Partner, you consent to Data being used for the purposes of updating (for example, after moving house) the databases of different Partners, to improve database quality;
  4. management of the loyalty scheme managed via the Freedelity platform (accessible based on the e-mail address provided), so that at any time, you may consult the status of your loyalty points and immediately and fully track how your Data is being used by the different Partners;
  5. direct marketing (to better meet your expectations and preferences determined based on your transactions log)
  6. and if you also consented to providing your e-mail address: direct electronic marketing (e-mail/GSM), sending a copy of the digital legal guarantee as evidence.

The Partner is the entity responsible for the aforementioned processing, in line with the current General Data Processing Regulation (“GDPR”) and its own Privacy Policy; Freedelity acts as a sub-contractor on the Partner’s behalf (except that Freedelity does not conduct any profiling either for its own benefit or that of the Partner and is limited to providing anonymous statistics so that the Partner mat conduct consumer profiling, for direct marketing purposes) according to the contractual options chosen by the Partner in question.

Legal basis

Data will be processed by Freedelity based on consent granted for processing different Data. Your consent may be withdrawn at any time, either for all processing, or one or more specific types of processing (including the aforementioned processing undertaken by its Partners as those solely liable for said processing). Freedelity also reserves the right to update your Data in Freedelity’s legitimate interests to improve the quality of the Freedelity database (and those of its Partners);

Recipients

Only competent staff of Freedelity, its Partners (access limited to their own database), and Freedelity sub-contractors (only for logistic management of Direct marketing campaigns exclusively on behalf of its Partners) will have access to your Data; Your Data will not be sent to third parties for direct marketing purposes. To improve the quality of other companies’ files, the Freedelity database containing your Data may, however, be used as a source for validating or linking personal data pertaining to you already found in said companies’ database (in line with the GDPR); your Data will not be sent to said companies. For this type of processing (exclusively seeking to validate and link data, your Data not sent to third parties), the Freedelity database containing your Data may also be sent to another database manager (in line with the GDPR).

Storage time

Your Data will be kept for a maximum of 10 years depending on the last thing you did (purchase) and completely deleted after 5 years’ inactivity, or 5 years after expiry of the 2-year legal guarantee, and for a period of 15 years (from the date it was last saved in the database concerned) only for the purposes of updating and validating the databases of Partners or other companies (see: “Recipients”).

Your rights

Opposition

If you wish to oppose use of your Data (in the cases stipulated in the GDPR), you may do so at any time with a single click, by accessing your personal space on the Freedelity Platform. If you do not have access to the Freedelity Platform (either because you have not provided your e-mail address, or because the Partner has not opted for this service for its clients):
  1. for updating your Data: please send an e-mail to Freedelity at the following address: privacy@freedelity.be ;
  2. for direct marketing and the legal guarantee (and other services provided by the Partners): please send an e-mail to the address indicated by the Partner (in its own Confidentiality Policy provided when you signed up and available at its checkouts);

Access, correction, deletion and limited processing

Under certain conditions, you may also access your Data, correct it if necessary, delete it, limit its processing, and seek portability to another processing manager. If you have any questions, please send an e-mail to privacy@freedelity.be, attaching to your question evidence of your identity.

Complaint

Finally, you may file a complaint with the authority competent in the matter in Belgium if you do not receive a reply to your question: https://www.dataprotectionauthority.be/.

Connection