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01. General
02. Legal basis for the processing of your data
03. How is your data collected?
04. What data do we collect and use?
05. Why and how is this information used?
06. Who has access to your data?
07. Direct marketing
08. How long do we keep your data?
09. How do we secure your data?
10. Where do we store your data?
11. How can you contact us and exercise your rights?
12. Updates to this policy
Freedelity is a provider of IT services and solutions supporting the collection, update, and management of certain data (hereinafter "Data").
Freedelity's clients (hereinafter "Clients") are mainly consumer brands and companies seeking to develop a relationship with their consumers and offer them personalized services while meeting all regulatory requirements for data processing.
Each Freedelity Client is responsible for the processing of your personal Data. For some processing, Freedelity may serve as data controller and, for others, as a subcontractor of the Client. These distinctions are described below.
Your data and its protection are extremely important to Freedelity.
This privacy policy aims to explain how your Data is collected, used, stored, protected, and made accessible to our Clients.
Through the www.myfreedelity.com portal and the MyFreedelity application, you can access your Data at any time and manage its content and how it is used (consent management).
Freedelity processes your Data based on the consent you provided when you registered with Freedelity, in accordance with the terms described below.
You can view your Data at any time and modify your consent through a personalized secure access portal and the MyFreedelity application.
Your registration with Freedelity and your access and use of the portal and the MyFreedelity application imply a contractual commitment between Freedelity and you regarding the use of the portal and the MyFreedelity application, the terms of use of the portal and application, and this privacy policy.
There is a legitimate interest in informing consumers of aspects related to the use of the platform (website and mobile app) provided by Freedelity.
Your Data is collected:
Freedelity saves the Data that you consent to provide as part of your voluntary registration with Freedelity's data management program ("Freedelity File") provided by Freedelity to help its Clients collect and manage your Data and offer you personalized benefits and services.
You have access to other information on the portal and MyFreedelity mobile app, such as sales receipts, your purchase history, and communications. Freedelity does not process this information for its own purposes, but for the purposes of its Clients. For more information about this data, its processing, and its purpose, see the privacy policies of the relevant Clients.
The Data is used to:
By registering with Freedelity, you consent to your Data being updated (ex. after a move) in the Freedelity Client file, including those with whom you have registered. The Client list is viewable on the portal and MyFreedelity mobile app.
All such parties must comply with applicable data protection regulations and contractual provisions regarding a high security level.
Some public bodies are entitled to view or request some of your data. We must cooperate in such situations.
You Data will not be sold to third parties seeking email addresses for direct marketing purposes.
However, your data may be used to improve the accuracy and quality of consumer files belonging to other companies, including companies specialized in database management, as mentioned above. The Freedelity file containing your Data may serve as a source for validating, linking, or updating Data about you. The prerequisite for this use of your Data is that you are already registered in this other company's file. For this type of processing, the Freedelity file containing your Data may be transmitted to them periodically, subject to GDPR-compliant contractual guarantees.
These database managers are currently:
In principle, your Data will be kept for a maximum of 8 years from the date of your last activity.
The following are considered activity:
Some of your data may be kept longer, however, if required by our Clients or by legal obligations. More information can be found in the privacy policies of our Clients.
We make every effort to protect your Data. Your Data is stored on secure computers. When we work with other parties, we require the same level of security from them.
Despite all efforts made by Freedelity, we can never fully guarantee the security and protection of your data.
Data is stored on secure servers located in the European Union or in places with a sufficient and appropriate level of data protection, in accordance with the European Union or legislation.
Adequate security measures, verified by qualified independent organizations, have been implemented in accordance with the provisions of the applicable EU Regulation and best practices.
If you wish to exercise your rights regarding the use of your Data, you may do so at any time by accessing your personal account on the portal or MyFreedelity mobile app.
If you have not requested access to the portal or MyFreedelity application, you may email privacy@myfreedelity.com with your proof of ID attached to your request. You may also reach us by postal mail, with your proof of ID attached to your request, at Freedelity SA, Rue du Bosquet 8, bte 6, 1400 Nivelles, Belgium.
We are continually updating our services and solutions so that we can continue to provide you with the best possible support and service. For this reason, we regularly update this Privacy Policy so that it complies with how we process your Data. Although we make every effort to call your attention to changes, we recommend reviewing the Privacy Policy on a regular basis. It is therefore also your responsibility to keep yourself updated on changes.
This Privacy Policy was last amended on April 02, 2020.