Personal data protection policy

01. General information
02. Legal basis for processing your personal data
03. How is your personal information 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.

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

02. Legal basis for processing your personal data

Data processed by Freedelity is done on the basis of the consent that you gave 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 can update, consult your data and modify all the consents at any time.

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.

03. How is your personal information collected?

Your personal Data is collected

• by the Clients by filling in a form, an order on an eCommerce site, reading an eID card, through eID readers, through a terminal installed at the Clients 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.
• 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?

• surname, first name(s), place and date of birth, gender, identity card number, nationality and home address, municipality of issue of the identity card, date of validity of the identity card, history of home addresses
• your email address and/or mobile number and their history
• language preference
• your Login and password sent to you when you registered
• date of creation of your profile, information relating to the sending of the registration confirmation email in the Freedelity file, date of the last visit to the portal and the MyFreedelity app

On the portal and the MyFreedelity app, you have access to other information, for example details of sales receipts or purchase and communication histories . Freedelity does not process this data on its own behalf, but on behalf of its Client. Further information regarding this data, processing and the purposes thereof can be obtained in the privacy policies of the Clients concerned.

05. Why and how is this information used?

The Data is used to:

• create a unique identifier and a “Freedelity Account”,
• complete your data by processing your home address,
• transfer the data to Clients with whom you are registered,
• identify yourself quickly with every use (purchase) by inserting your eID card into a reader or by giving your first and last name if you register manually,
• create a reliable file of all Personal Data of registered consumers,
• help our Customers to maintain quality and keep your personal Data up to date,
• allow you to exercise direct, complete and immediate control over the use made of your Data, by each Customer, and/or consultation
• of our Clients’ benefits for you, through access to the portal and the MyFreedelity app, at any time,
• notify you (in particular by mail and SMS) of information relating to the MyFreedelity portal and app, new functionalities and technical developments,
• inform you by e-mail about the integration of new Freedelity Clients.

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?

• Freedelity’s authorised staff
• users authorised by the Clients under their own responsibility and whose access is limited to their own file,
• certain companies specialising in database management for marketing, data quality and market research purposes,
• Freedelity’s subcontractors,

All such parties must comply with applicable data protection regulations and contractual provisions to ensure 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 sold to third parties for direct marketing purposes.

Your data may be used to improve the quality and accuracy of other companies' consumer files, in particular through the database management companies referred to 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: EDM Belgium (Heizel Esplanade Heysel PB 27, B-1020 Brussels - You can find more information about EDM Belgium's processing of personal data at edmmedia.be/privacy-statement), Bisnode Belgium SA (Allée de la Recherche 65, 1070 Brussels - You can find more information about Bisnode Belgium's processing of personal data at 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 your last activity.

An activity is considered as:

• a purchase from one of our Clients,
• reading your eID card’s data or updating your Data via a terminal or an app installed with one of our Clients,
• the use of the portal or the MyFreedelity app,
• the opening of an email sent through our platform.

Some of your data may, however, be retained for a longer period of time if our Clients or legal obligations require it. More information can be found in our Clients’ 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 keep your data?

The data is 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 your Data, you may do so at any time by accessing your personal space on the portal or the MyFreedelity app.

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

With regard to direct marketing and other services provided by Clients under their exclusive responsibility: by sending an email to the address indicated by the Client in their own Privacy Policy available at registration and at their checkouts

You may also access your Data, obtain its rectification, if necessary, obtain its deletion, limit its processing, and request its portability to another data controller by sending an email to privacy@freedelity.be. make sure to attach some kind of proof of identity to your request. You can also send us a letter by post, with enclosed proof of your identity, to the following address Freedelity SA, Rue du Bosquet 8, bte 6, 1400 Nivelles

Finally, you can lodge a complaint with the competent authority in Belgium in the event of failure to respond within the legal time limit to such a request on the website www.dataprotectionauthority.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 being made.

This Privacy Protection Policy was last amended on 30/09/2019