Protection of personal data

Freedelity – Privacy Protection Policy


Type of data collected

Freedelity records personal data (the “Data”) that you agree to disclose in the context of your voluntary registration for the Freedelity Loyalty and Database Management Programme (the “Freedelity Programme”) set up by Freedelity partner sellers (“Partners”).

These personal data are as follows:
  1. The data visible on your electronic identity card (“eID Card”) excluding the National Register identification number) and those stored on the chip of your eID card (address): surname, first name, place and date of birth, sex, identity card number;
  2. Your email address and/or your mobile phone number if you have agreed to provide them to the relevant Partner(s);
  3. The login and password sent to you at the time and then your registration;
  4. The history of your purchasing transactions and communications with the Partner(s);

How is your personal information collected?

This Data is collected by the Partners by reading the eID Card either via eID readers, or via autonomous terminals or kiosks, or via any other interface(s) installed at the Partners’ premises, or via the Freedelity platform and its applications.

For persons who do not have a Belgian eID Card or do not wish to use it for the purposes envisaged by Freedelity and its Partners, the data defined above will be entered manually on the screen of a terminal, either by yourself or by the delegate (cashier) on the basis of the information you have voluntarily provided.

How is the information collected used?

The Data are automatically saved and updated in Freedelity’s file (hereinafter the “File”) and in the file specific to each Partner.

This data is necessary for the creation of a unique identifier and the creation of a personalized account (hereinafter “Freedelity Account”) and which is accessible on the Freedelity platform (hereinafter “Freedelity Platform”) which will allow:
  1. Identification at each subsequent use (purchase), by inserting your eID card in a card reader or by communicating to the Partners (or competent employees) your surname and first name in the event that you choose the manual registration;
  2. The implementation of the Freedelity programme by the partner;
  3. Secure access to the Freedelity platform by either (1) sending by email a password and an automatically generated login in the event that you have agreed to communicate your email address to the Partner, or (2) sending an email at your request on the Freedelity Platform via the insertion of your eID Card in your personal eID reader. This allows direct access to your Data and, if necessary, the Data use verification by the Partner;
  4. The immediate exercise of all your legal rights as defined in particular in the “Your Rights” section;
  5. Consultation of the status of points and/or benefits of the Loyalty Programme that you will have accumulated with each Partner: in the Loyalty Programme.

How is this data stored?

The data is stored on secure servers in Belgium. Adequate security measures have been put in place in accordance with the provisions of the relevant European Regulation.

Purpose of processing and Freedelity entities

The Data processing carried out by Freedelity has the following objectives:
  1. Creating a unique and reliable file of your Data;
  2. Creating a unique file for each Partner so that they can use Freedelity’s services for the benefit of their clients;
  3. To improve the quality of the information contained in the files: by participating in the Freedelity Programme set up by the Partner, you can update the regular Data (for example after a move) of your personal data contained in the File as well as in the files of the Freedelity Partners with which you are registered.
  4. To allow the exercise of control over the way your Data is used by each Partner;
  5. To allow the permanent consultation of the accumulated benefits status with each Partner via the Freedelity Platform;
  6. To allow the use of the Freedelity software to duly authorised subcontractors;

Data controller

Freedelity S.A. shall be responsible for the processing operations referred to in Article 5. Other processing operations are carried out by Freedelity subcontractors and/or third-party partners who assume their responsibilities.

Freedelity is located rue du Panier Vert 70, 1400 Nivelles, and duly registered under number BCE0818399886. Freedelity can be reached by telephone at 02/880.98.36 and by email at the following address privacy@freedelity.be.

For any questions about the processing of your Data by Freedelity and/or third party partners and subcontractors, you can contact our Data Privacy Officer at the following email address dpo@freedelity.be or by phone at the number above.

Freedelity Partners

Freedelity makes available certain software and tools developed by or for it that enable contractual relationships to be established with sellers called Partners. The Partners’ objective is to offer their customers business benefits that result from the services contractually selected by the Partner with Freedelity.

The scope of services also depends on the personal choices and options you choose when you register with Freedelity Partners. Thus, the following are proposed:
  1. Participation in the loyalty programme managed via the Freedelity Platform which allows you (the consumer) to permanently consult the status of your accumulated benefits with each Partner;
  2. Improvement of the quality of the information contained in the files;
  3. Digitalization of the control of the validity of the guarantee linked to the purchase of certain products from the Partner(s). If you have agreed to provide your email address, you may also receive a copy of the digital warranty by email;
  4. A direct marketing service which notably concerns actions proposed by the Partner(s) via the Freedelity Platform either by post or electronically on the basis of the registration of your email address and your telephone number;

For the data processing referred to above, the Partner acts as the data controller for the above-mentioned processing within the meaning of the General Data Protection Regulation in force and, where applicable, its own Privacy Policy.

Freedelity then acts as a subcontractor within the meaning of the GDPR on behalf of the Partner for one or several of the above processing operations. The respective responsibilities are then determined in accordance with the provisions of the GDPR.

Freedelity does not carry out any profiling on its own behalf.

Legal basis

The Data will be processed by Freedelity on the basis of the granted consent and/or the agreement with the Partner(s). You may withdraw your consent at any time.

Recipients

The Data will be accessible exclusively by competent personnel of Freedelity, its Partners, and Freedelity subcontractors, and within the contractual context defined by Freedelity.

In order to optimise the quality of files created by other companies, the Freedelity File may be used to validate and/or link personal data concerning you and already recorded in the files of said companies.

For processing aimed exclusively at validating and linking data, the Freedelity File is transferred to database managers who have received Freedelity’s authorisation to consult it for the exclusive purpose defined above and provided that they undertake to comply with the contractual commitments entered into and comply with the rules set in the GDPR and/or the provisions applicable under Belgian law.

At the date of revision of this document, these managers consist of:
  1. EDM Belgium, Heyzel Esplanade BP 27, 1020 Brussels (edmmedia.be/privacy-statement).
  2. BISNODE Belgium NV: Allée de la Recherche 65, 1070 Brussels (bisnode.be/personal-data).

The list of managers can be modified and added to. You have the right to request the names of managers at any time except in the event that disclosure is not reasonably justified.

You will find more information about the processing of personal data by Bisnode Belgium at https://www.bisnodeetvous.be.

Storage time

Your Data will be kept for a maximum period of 15 years starting from the last activity with the Partner(s).

Right of opposition

If you wish to object to the use of your Data in any of the cases provided for in the GDPR, you may do so via your personal Freedelity Platform space.

If you have not requested access to the Freedelity Platform, you can email us at privacy@freedelity.be by attaching proof of your identity to your application.

Access, rectification, deletion and restricted processing

If you wish to exercise your rights under the GDPR, you may do so at any time. Thus, you can:
  1. Access your Data;
  2. Correct and/or add to the Data;
  3. Delete the Data, unless data retention is necessary to ensure Freedelity’s fundamental rights or to guarantee its tax and legal obligations;
  4. Limiting Data Processing;
  5. Request portability of the Data to another controller unless it is not technically feasible.

You can send an email to privacy@freedelity.be attaching proof of your identity to your application. Freedelity reserves the right to refuse to respond to your request if you do not supply proof of identity.

The requested changes will be provided free of charge but may involve substantial changes in Partner access for which Freedelity cannot be held responsible.

Updating this document

Freedelity reserves the right to update this Privacy Policy at any time to ensure full compliance with legal requirements in effect at the time. Freedelity also reserves the right to update the privacy policy to ensure the eventual integration of new services and to ensure the quality of service requirements that consumers can reasonably expect.

Complaints

In the unlikely event that your request has not been answered after the expiry of the period provided for by the Regulations in force at the time, or if you consider that your rights have not been respected, you may contact the competent authority in Belgium: https://www.dataprotectionauthority.be. We remain at your disposal for any other questions.