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Privacy Policy

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


01. General

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).


02. Legal basis for the processing of your data

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.


03. How is your data collected?

Your Data is collected:

  • By Clients when you fill out a form, you place an order on an e-commerce site, or your eID is read by an eID reader, a Client terminal, or any other type of terminal. For individuals who do not have a Belgian eID card or do not wish to use it, the same Data can be entered manually on a terminal screen, by yourself or by the cashier, based on information you provide.
  • By Freedelity through its platform, the MyFreedelity application, or any other means Freedelity may set up.

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.


04. What data do we collect and use?

  • Last name, first name, place and date of birth, gender, ID card number, nationality, home address, ID card issuance location, ID card validity date, history of home addresses
  • Your email address and/or GSM number and history
  • Language preference
  • Your login and password sent to you when you registered
  • The date your profile was created, information about the Freedelity File registration confirmation email, and the date you last visited the portal and the MyFreedelity application

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.


05. Why and how is this information used?

The Data is used to:

  • Create a unique ID and a Freedelity Profile
  • Complete your Data with the processing of your home address
  • Transfer Data to Clients with whom you are registered
  • Identify you quickly with each use (purchase), by inserting your eID card into a reader or providing your first and last name in the case of a manual registration
  • Create a reliable record of all saved consumer Data
  • Help our Clients maintain the quality of your Data, keep it up to date, and offer direct marketing services, including services involving geolocation systems
  • Notify you, by email, of new Freedelity Clients that are added
  • Transfer and update Data for advertisers, as mentioned in the Consumer's mobile app
  • Communicate (mainly by email and SMS) information to you about the portal and MyFreedelity application, related to new features and technical developments made by Freedelity
  • Allow you to exercise full, immediate, and direct control over the use of your Data, by each Client, and/or view your Client benefits at any time, by accessing the portal and the MyFreedelity mobile app

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.


06. Who has access to your data?

  • Qualified Freedelity staffmembers
  • Users authorized by Freedelity Clients (their staff), under their own supervision, whose access is strictly limited to their own file
  • Some companies specialized in database management for marketing, data quality, and market research purposes
  • Freedelity subcontractors

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.


07. Direct marketing

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:

  • EDM Belgium (Heizel Esplanade Heysel PB 27, B-1020 Brussels, Belgium ? You can find more information about EDM Belgium's processing of your personal data at https://edmmedia.be/privacy-statement).
  • Bisnode Belgium SA (Allée de la Recherche 65, 1070 Brussels, Belgium ? You can find more information about Bisnode Belgium's processing of your personal data at https://www.bisnode.be/fr-be/donnees-personnelles/).

08. How long do we keep your data?

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:

  • A purchase from one of our Clients; a registration or Data update through them or through update interfaces they provide
  • Reading or updating your eID card data through a terminal or application installed by any of our Clients
  • Using the portal and/or the MyFreedelity mobile app
  • Opening an email sent through our platform

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.


09. How do we secure your data?

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.


10. Where do we store 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.


11. How can you contact us and exercise your rights?

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.


12. Updates to this policy

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.

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