Personal data protection policy

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1. General

Freedelity is a provider of IT solutions and services to support the collection, updating and management of certain personal data (hereinafter "Data").

Among other things, Freedelity enables its customers to centralize and update your data by creating a reference file.

Freedelity's customers (hereinafter referred to as "Customers") are mainly :
Retail chains (https://www.myfreedelity.com/repertoire-des-commerces) and other companies wishing to authenticate you (KYC) and get to know you better (market research) in order to develop a relationship and personalized services with their consumers (you), while meeting the various regulatory requirements in terms of Data protection and processing, and with whom you have registered for a loyalty program, a dematerialization of the warranty, or any other customer relations program (for example, a club)

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2. What data do we collect and use?

Depending on the context and the treatments to which you have subscribed, Freedelity processes the following data:
[list][item]Identification data: surname, first name, date and place of birth (hashed, no direct identification possible), gender, language, unique identifier, token, identity card number (until 31/07/2026. Number is hashed, no direct identification possible)

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4. Recipients of your data

Your Data are accessible by the competent Freedelity staff.

It is also processed by :

1. Our technical subcontractors (hosting, maintenance, emailing, security, etc.)
2. Our partner retailers (as part of the shared maintenance of your data)
[/item][/item][/item][/item][/item][/item][/item][/item][Freedelity customers for additional services (KYC, market research, connection tools)[/item]
3. Competent authorities, if required by law. Certain public authorities have the right to consult or request part of your Data. We must cooperate in such cases

All such parties must comply with the regulations applicable to the protection of personal data, and in particular the rights you have as a data subject, and must respect the contractual provisions aimed at ensuring a high level of security.

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5. Where do we store your data?

The 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 opinion of the European Commission or legislation, so that the level of protection of individuals guaranteed by the General Data Protection Regulation is not compromised.

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6. Your rights

You have the following rights regarding the processing of your Data:

Right of access

You have the right to obtain confirmation that your Data is being processed by Freedelity, to ask us about the Data we hold about you and to obtain a copy of your Data.

Right of rectification

You have the right to rectify inaccurate Data and to complete incomplete Data.

Right to object

You have the right to object to any use of your Data, where processing is based on our legitimate interests.

Right to restrict processing

You may ask us to restrict the processing of your Data, in accordance with applicable data protection legislation.

Right to be forgotten or deleted

You have the right to ask us to delete your Data, if you find yourself in the conditions provided for by the applicable Data protection legislation, unless we are legally obliged to retain some of it.

Right to withdraw your consent

You have the right to withdraw, at any time, your consent to the processing carried out on the basis thereof, and this at any time, without justification and without this calling into question the lawfulness of the processing carried out when your consent was active.

Right to Data portability

You may request that your Data be recovered in a machine-readable format or that your Data be transferred to another data controller of your choice. For intellectual property reasons, the file containing your Data will be unstructured (flat file).

Complaints concerning Freedelity's processing of your Data may be addressed to the Data Protection Authority, rue de la Presse 35, 1000 Brussels / +32 (0)2 274 48 00 / contact@apd-gba.be.

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7. How can you contact us and assert your rights?

You can exercise your rights :
[list]

Via MyFreedelity (https://www.myfreedelity.com) If you do not have access to the MyFreedelity portal or application: you can send an email to privacy@myfreedelity.com, enclosing proof of your identity with your request.

Directly in store: you can exercise your rights by contacting the in-store cashier at the store concerned

By phone: +32 2 880 98 36

By email: privacy@myfreedelity.com

You can also send us a letter, enclosing proof of your identity, to Freedelity SA, Rue Altiero Spinelli 7, 1401 Nivelles. Please always state clearly the right you wish to exercise

[We would like to draw your attention to the fact that Freedelity also acts as a subcontractor for some of its customers. As a result, you may see, through the MyFreedelity portal or application, certain Data that are not processed by Freedelity as the data controller, but rather as a subcontractor (for example, sales receipts, purchase history analyses, etc.). In the event of requests to exercise any of your rights in relation to your Data, Freedelity may respond to such requests, in accordance with the provisions of the processing agreement entered into between Freedelity and its Customers, acting as data controllers, as well as the General Data Protection Regulation. Freedelity may also pass on your request to the Customer and will cooperate to the best of its ability to satisfy your request.

Similarly, when you use the MyFreedelity portal or application to exercise control over the processing of your Data by Customers, Freedelity automatically passes the instruction on to the Customer. It is the Customer's responsibility to act on this instruction on its own systems (by deleting your Data from its own systems, for example), in accordance with its own personal data processing policy. Freedelity acts only as an intermediary in this respect.

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8. Security

Your Data is stored on secure computer servers in accordance with state-of-the-art standards. When we collaborate with other parties, such as our subcontractors, we require the same level of security from them.

Adequate security measures, verified by competent and independent bodies, have been put in place in accordance with the provisions of the relevant European Regulation and in compliance with best practice, to prevent any destruction, loss, alteration, unauthorized disclosure or unauthorized access to your personal data.

Despite all the efforts made by Freedelity, we can never fully guarantee the security and protection of your Data.

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9. Shelf life

Your data is kept in the Reference File for a maximum of 3 years after your last interaction with one of the stores participating in the data maintenance pool (in-store purchase, loyalty program registration or data update).

Data processed in the MyFreedelity application or portal are kept for 3 years after the last active use of MyFreedelity.

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10. Contact and complaints

1. Freedelity SA - Rue Altiero Spinelli 7, 1401 Nivelles, Belgium - info@freedelity.be
2. Data Protection Officer: privacy@myfreedelity.com
3. Data Protection Authority : Rue de la Presse 35, 1000 Bruxelles - contact@apd-gba.be

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11. Cookies

We use cookies and trackers on our website, on the MyFreedelity portal, on the MyFreedelity application and to provide you with any other services set up by Freedelity.

You can manage your cookie preferences or withdraw your consent at any time by [url=JavaScript:reShowCookies()

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12. Updating this policy

We are constantly developing our solutions and services so that we can continue to offer you the best possible support and service. For this reason, we will regularly adapt this Privacy Policy to reflect the way in which we process your Data. Although we make every effort to draw your attention to these changes, we ask you to consult the Privacy Policy regularly. It is therefore also your responsibility to keep abreast of any changes.

This Privacy Policy was last amended on December 31, 2025.