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Privacy

Freedelity – Privacy Protection Policy

01. General information
02. Legal basis for processing your personal data
03. How is your personal data collected?
04. What personal data do we collect and use?
05. Why and how is this information used?
06. Who has access to your personal information?
07. For how long do we keep your personal data?
08. How do we secure your personal data?
09. Where do we keep your data?
10. How can you contact us to exercise your rights?
11. Updating this policy

01. General information

Freedelity is a provider of computing solutions and services to support collecting of certain personal data referred to hereinafter as (“Data”), its updating and its management. Freedelity Customers hereinafter (“Customers”) are mainly mass market brands involved with developing a personalised relationship and services with their customer consumers, while complying with the various regulatory requirements in regard to processing of personal data.

Freedelity and its Customers are jointly responsible for processing your personal data.

Freedelity places great importance on your personal data and its protection.

The purpose of this privacy protection policy is to explain to you how your Data is collected, used, kept, protected and made accessible.

Through the www.myfreedelity.com portal and the MyFreedelity app, you can access your Data at any time and manage it both in regard to its content and its use (consent management).

02. Legal basis for processing your personal data

Data processed by Freedelity is done on the basis of the consent that you gave it when you registered in the Freedelity file in accordance with the procedures described below.

Via personal and secured access to the MyFreedelity portal and app, you may at any time update, consult your data and modify all the consents.

Your registration in the Freedelity file and access and use of the portal as well as the MyFreedelity app furthermore suppose a contractual commitment between Freedelity and you relating to the use of the MyFreedelity portal and app, the portal’s and the app’s conditions of use and this privacy policy.

How is your personal information collected?

03. Your personal Data is collected
  1. by the Customers by filling in a form, an order on an eCommerce site, reading an eID card, through eID readers, through a terminal installed at the Customers or any other type of terminal. For people who do not have a Belgian eID Card or do not wish to use it, this data may be entered manually on the screen of a terminal, either by yourself or by the cashier on the basis of the information you will have provided.
  2. or by Freedelity through its platform or its MyFreedelity app or any other means that Freedelity will have set up.

Freedelity records the Data that you consent to communicate when you voluntarily sign up for the Freedelity database management programme (“Freedelity File”) set up by Freedelity to help its Customers in collection and management of your Data and to offer you personalised benefits and services.

04. What personal data do we collect and use?
  1. name, first name(s), date and place of birth, sex, identity card no., nationality and address details, commune where identity card was issued, validity date of identity card, history of address details
  2. your email address and/or GSM no. and their history
  3. language preference
  4. your login and password sent to you at the time of your registration
  5. creation date of your profile, information relating to sending the confirmation email for registration in the FREEDELITY file, date of last visit on the MyFreedelity portal and app.

You have access to other information on the MyFreedelity portal and app, for example, receipt details or purchase and communication histories... FREEDELITY does not process this data on its own account, but on account of its Customers. Further information on this data, its processing and the purposes of this can be obtained in the privacy policies of the Customers’ concerned.

05. Why and how is this information used?

The Data is used to:
  1. create a unique identifier and a “Freedelity Account”,
  2. fill in your data by processing your address details.
  3. transfer the data to Customers with whom you are registered,
  4. identify you quickly with each use (purchase) by inserting your eID card in a reader or by providing your first name and surname if logging in manually,
  5. create a reliable file of all the personal Data of registered consumers,
  6. help our Customers to maintain quality and keep your personal Data up to date,
  7. enable you to directly, completely and immediately check how your Data is being used by each Customer and/or so that you may view your benefits with our Customers, by accessing the MyFreedelity portal and app, at any time.
  8. notify you (in particular by mail and text message) of information relating to the MyFreedelity portal and app, new functionalities and technical developments,
  9. inform you by email about integration of new Freedelity Customers.

By registering in the Freedelity file, you consent to your Data being updated (for example after moving house) in the Freedelity Customers’ file, for those with whom you have registered. The list of Freedelity Customers to whom you have consented your Data can be consulted on the portal.

06. Who has access to your personal information?
  1. Freedelity’s authorised staff,
  2. the users authorised by the Customers under their own responsibility and whose access is limited to their own file,
  3. certain businesses specialised in database management for marketing purposes, data quality and market surveys,
  4. Freedelity’s subcontractors.

All these parties must comply with the regulations applicable concerning data protection and contractual provisions aimed at ensuring a high level of security.

Certain public authorities have the right to consult or request a part of your personal data. We have to cooperate in such cases.

Your Data will not be marketed to third parties for direct marketing purposes.

Your data may be used to improve the quality and accuracy of files for consumers in other businesses, in particular through businesses specialised in database management mentioned above. The Freedelity file including your Data may therefore be used as a source enabling personal data about you to be validated or linked. The condition prior to this use of your data being that you are already registered in the file of this other business. For this type of processing, the Freedelity file containing your Data may be sent to them periodically, and this through contractual guarantees in compliance with the GDPR. Currently these database managers are:
  1. EDM Belgium (Heizel Esplanade Heysel PB 27, B-1020 Brussels – You can find further information concerning processing of personal data by EDM Belgium on nttps://edmmedia.be/privacy-statement ),
  2. Bisnode Belgium SA (Allée de la Recherche 65, 1070 Brussels - You can find further information concerning processing of personal data by Bisnode Belgium on www.bisnodeetvous.be).

07. For how long do we keep your personal data?

In principle, your Data will be kept for a maximum period of 8 years following the date of the last activity by you.

An activity is considered as:
  1. a purchase from one of our Customers,
  2. reading your eID card’s data or updating your Data via a terminal or an app installed with one of our Customers,
  3. use of the MyFreedelity portal or app,
  4. opening an email sent through our platform.

However, some of your data may be kept for longer if our Customers or legal obligations impose this. Further information may be obtained in our Customers’ privacy charters.

08. How do we secure your personal data?

We do everything possible to protect your personal data. Your personal data is kept on secured computers. When we collaborate with other parties, we demand the same level of security from them.

Despite all efforts made, we can never totally guarantee the security and protection of your personal data.

09. Where do we store your data?

The data is safely stored on secure servers located in the European Union.

Appropriate security measures and which are verified by independent and competent bodies have been set up in accordance with the provisions of the applicable European Regulation in this regard and in compliance with good practices.

10. How can you contact us to exercise your rights?

If you wish to exercise your rights to use of your Data, you may do so at any time, by accessing your personal space on the MyFreedelity portal or app.

If you have not requested access to the MyFreedelity portal or app: you can send an email to privacy@freedelity.be, attaching proof of your identity to your request. You can also send us a letter by mail, attaching proof of your identity to your request, to the following address Freedelity SA, Rue du Bosquet 8, bte 6, 1400 Nivelles.

For direct marketing and other services provided by the Customers under their exclusive responsibility: please send an email to the address indicated by the Customer in its own Privacy Policy available when you registered and available at its checkouts.

You may also access your Data, correct it if necessary, delete it, limit its processing, and request portability to another data controller by sending an email to privacy@freedelity.be, attaching proof of your identity. You can also send us a letter by mail, attaching proof of your identity to your request, to the following address Freedelity SA, Rue du Bosquet 8, bte 6, 1400 Nivelles.

You can lodge a complaint with the relevant authority in Belgium if you do not receive an answer to your request within the legal deadline on the website www.autoriteprotectiondonnees.be.

11. Updating this policy

We are continually developing our solutions and services in order to be able to continue to provide you with the best support. This is why we will regularly modify this Privacy Protection Policy so that it complies with the way in which we process your personal data. Despite the fact that we do all we can to draw your attention to changes we would ask you to regularly look at the Privacy Protection Policy. It is also your responsibility to keep up to date with changes.

This Privacy Protection Policy was last changed on 30/09/2019.

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