Protection of personal data

Freedelity – Privacy Protection Policy


Type of data collected

Freedelity saves the following personal data pertaining to you (“Data”) which you consent to provide when you voluntarily sign up to the Freedelity loyalty and database management scheme (“Freedelity Scheme”) set up by Freedelity partner traders (“Partners”):
  1. Data visible on your electronic identity card (“eID card”): first name, surname, place and date of birth, sex, identity card no. (excluding the National Register identification no.) and stored on your eID card chip (address).
  2. Your e-mail address and/or mobile no., if you have consented to provide them to the Partner(s) concerned.
  3. The login and password sent to you at the time of your registration
  4. The history of your purchasing transactions and communication with the Partner(s) in question.


How is your personal information collected?

The Data is collected by Partners, by reading it from the ID card either via eID readers, or using a terminal (kiosk, tablet, computer or other interface) installed on Partners’ sites; for people who have no Belgian eID card or who do not want to use one for the purposes envisaged by Freedelity and its Partners, the (same) Data will be entered into a terminal screen manually, yourself or by the cashier, based on the information which you provided.

How is the information collected used?

Data will be saved automatically in the Freedelity file (and in the file specific to each Partner), necessary for creating a unique login and a “Freedelity account” for:
  1. Fast identification with each subsequent use (purchase) by inserting your eID card in a reader or by providing your first name and surname if logging in manually.
  2. Enabling your participation in the Freedelity Scheme set up by the Partner(s) in question.
  3. Enabling you to access the Freedelity platform, either by sending a login and password (by an automatically generated email, if you have consented to providing your email address to the Partner in question, or by email following your request, through the Freedelity Platform), or by inserting your eID card in your reader, which enables direct access to all your Data and its use by each Partner (see “Freedelity Partners” section), and allows you to immediately exercise any related rights (see “Your Rights” section) and to view the statement of your Loyalty Programme points that you have accumulated with each Partner.


Purpose of processing and managing entities

Freedelity

The concrete purpose of Data processing carried out by Freedelity is as follows:
  1. To create a unique, reliable file containing all your Data and similar data relating to other consumers who wish to join the Freedelity Scheme set up by Partners, and a file for each Partner, to enable Freedelity Partners to offer certain benefits to their customers as described below (see: “Freedelity Partners”).
  2. Improving file quality: By participating in the Freedelity Scheme set up by a Partner, you consent to the Data being updated (for example, after moving house) in the Freedelity file and in the files of the different Freedelity Partners with which you have registered, (a list of which may be found on our website).
  3. Enabling you to directly, completely and immediately check how your Data is being used by each Partner and/or so that you may view the statement of your loyalty points accumulated with each Partner by accessing the Freedelity Platform (which is open to each consumer registered who has a Freedelity Account), at any time.

Freedelity SA (public limited company) (rue du Bosquet n°8, 1400 Nivelles) is responsible for the aforementioned processing; For any question relating to the processing of your Data, you can contact our Data Privacy Officer via the following email address: dpo@freedelity.be.

Freedelity Partners

The Partners’ aim is to offer one or more of the following benefits to their clients (according to their Freedelity contract options, and the options which you chose when you signed up with the Partners in question):
  1. Participation in the loyalty programme managed via the Freedelity Platform, enabling you to view the statement of the loyalty points you have accumulated with each Partner, and the Data and to exercise immediate and full control over their use by the Partner(s) in question, by accessing the Freedelity Platform.
  2. Improving file quality: By participating in the Freedelity Scheme set up by a Partner, you consent to the Data being updated (for example, after moving house) in the Freedelity file and in the files of the different Freedelity Partners with which you have registered.
  3. Issuing the (2-year) legal guarantee, relating to the purchase of products from the Partner in question, in digital format (and if you have consented to provide your email address for this purpose: a copy of said digital guarantee is sent by email).
  4. Communicating with you and informing you of the Partner's direct marketing actions via the Freedelity Platform by post and electronically (based on the registration of your e-mail address and your telephone number), if applicable according to your preferences identified from the history of transactions made via the Freedelity platform (using anonymised statistical reports provided by Freedelity to the Partner in question for this purpose).

For the aforementioned data processing activities, the Partner acts as the data controller, (in the meaning of the current General Data Protection Regulation - “GDPR”) and its own Privacy Policy; Freedelity acts as a data processor on the Partner’s behalf (“Data Processor”) within the framework of one of more aforementioned processing activities (except that Freedelity does not conduct any profiling either for its own benefit or that of the Partner and is limited to providing anonymous statistics so that the Partner may conduct consumer profiling, for direct marketing purposes, according to the contractual options chosen by the Partner in question);

Legal basis

The Data will be processed by Freedelity based on the consent granted, by separate Data processing, via access to the Freedelity Platform (based on the consent that you have granted first to (the) Partner(s) in question for processing activities that concern them (exclusively or as well)); Your consent may be withdrawn at any time, either for all processing activities, or for one or more specific processing activities (including the aforementioned processing activities carried out by Partners as the sole data controllers); Freedelity also reserves the right to update your Data in Freedelity's legitimate interest to improve the quality of Freedelity files and those of its Partners;

Recipients

Only competent staff of Freedelity and its Partners (as access is limited to their own file), and the Freedelity data processor (only used for sending text messages, and mailing by post, on behalf of the Partner) will have access to your Data; Your Data will not be sent to third parties for direct marketing purposes. To improve the quality of other companies’ files, the Freedelity file containing your Data may, however, be used as a source for validating or linking personal data pertaining to you already registered in the file of other said companies, without involving any transfer of your Data. For this type of processing activity (aiming exclusively to validate and link data, without your Data being send to third parties), the Freedelity file containing your Data is transferred periodically to database managers who have received authorisation from Freedelity to view it for the sole purpose of validating and grouping data that has already been saved in a third party file (with contractual guarantees pursuant to the GDPR). These managers concern: EDM Belgium (Heizel Esplanade Heysel PB 27, B-1020 Brussels – You can find more information about personal data processing by EDM Belgium on edmmedia.be/privacy-statement) and Bisnode Belgium SA (Allée de la Recherche 65, 1070 Brussels - You can find more information about personal data processing by Bisnode Belgium on www.bisnodeetvous.be).

Storage time

Your Data will be stored for a maximum period of 5 years following the last activity (purchase) and deleted completely after 5 years of inactivity, or 5 years after expiry of the 2-year legal guarantee, for a duration of 10 years to guarantee compliance with tax legislation and the provision of proof of GDPR compliance, and to guarantee the improvement of file quality: for a duration of 15 years (from the last record in the file concerned) for the update of Data and validation of data saved in other companies’ files (see section: “Recipients”).

Your rights

Opposition
If you wish to oppose the use of your Data (in the cases stipulated in the GDPR), you may do so at any time with a single click, by accessing your personal space on the Freedelity Platform. If you have not requested access to the Freedelity Platform:
  1. To update your Data: by sending an email to Freedelity at the following address: privacy@freedelity.be.
  2. For direct marketing and the legal guarantee (and other services provided by the Partners under their sole liability): please send an e-mail to the address indicated by the Partner (in its own Confidentiality Policy provided when you signed up and available at its checkouts).


Access, rectification, deletion and restricted processing
Under certain conditions (as described in the GDPR) you may also access your Data, correct it if necessary, delete it, limit its processing, and seek portability to another data controller by sending an email to privacy@freedelity.be, attaching proof of your identity.

Complaints
You can lodge a complaint with the relevant authority in Belgium if you do not receive an answer to your request, on the website www.autoriteprotectiondonnées.be.