Table of content
- 1. Introduction
- 1.1. In general
- 1.2. What is personal data?
- 2. Contact information
- 3. What personal data is processed and how is this data used?
- 3.1. What personal data are processed and for what purposes?
- 3.1.1. Usage data
- 3.1.2. Account data
- 3.1.3. Profile data
- 3.1.4. Publication data
- 3.1.5. Business member data
- 3.1.6. Communication data (as well as direct marketing data)
- 3.1.7. Correspondence data
- 3.2. The processor
- 4. Providing your personal data to third parties
- 5. International transfer (outside the EEA) of your personal data
- 6. Storage and deletion of your personal data
- 7. Security of your personal data
- 8. Amendments
- 9. Your rights
- 9.1. The right of access
- 9.2. The right to rectification
- 9.3. The right to erasure (‘right to be forgotten’)
- 9.4. The right to restriction the processing
- 9.5. The right to object
- 9.6. The right to data portability
- 9.7. The right to lodge a complaint with a supervisory authority
- 9.8. The right to withdraw your consent
- 10. Update of your personal data
1.1. In general
Fietsersbond vzw (hereinafter "We" or "Our" or "Us") understands that your privacy is important to you and that you are concerned about how your personal data is used. We respect and value the privacy of everyone who visits our website https://www.biketowork.be and uses our Application (App) Bike to Work. When you use our website and/or App, We will only collect and use personal data in the manner described here and, in a manner, consistent with our obligations and rights under applicable privacy laws.
This Privacy Statement applies when We act as a controller of the personal data from our website and App. In other words: We are controller because we determine the purpose and means by which the personal data is processed.
Transparency in the processing of personal data is a crucial part of the General Data Protection Regulation ("GDPR"). The starting point of this Privacy Statement is that your personal data will be processed in accordance with the relevant laws and regulations. It also takes into account principles such as fair and careful processing.
Please read this Privacy Statement carefully and make sure you understand it.
1.2. What is personal data?
Personal data is defined in the GDPR as “any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly". Personal data is, in simpler terms, all information that makes it possible to identify you. Personal data refers to information, such as your name and contact details, but also to information, such as identification numbers, electronic location data and other online identification factors.
2. Contact information
Our website and App are offered and managed by Fietsersbond vzw. We are registered in Belgium under registration number 0455.348.880 and our registered office is located at Oude Graanmarkt 63 - 1000 Brussels.
You can contact us:
- (a) by post, to Oude Graanmarkt 63 - 1000 Brussels;
- (b) via the contact form on our website;
- (c) by telephone, on 02 502 68 51 or
- (d) by e-mail, using email@example.com.
3. What personal data is processed and how is this data used?
3.1.What personal data are processed and for what purposes?
In this paragraph, We will set out the following issues:
- (a) the categories of personal data that We may process;
- (b) in the case of personal data that We have not obtained directly from you, the source and specific categories of that data;
- (c) the purposes for which We may process personal data; and
- (d) the legal bases for the processing.
We may process any of your personal data stated in this Privacy Statement as necessary to establish, exercise or defend legal claims, whether in judicial proceedings or in administrative or extra-judicial proceedings. The legal basis for this processing is our legitimate interests, namely the protection and exercise of our legal rights, your legal rights and the legal rights of others.
In addition, We may process your personal data when necessary to comply with a legal obligation to which We are subject, or to protect your vital interests or the vital interests of another natural person.
3.1.1. Usage data
We may process data about your use of our website and App ("usage data"). Usage data for our website may include your IP address, browser type and version, operating system, reference source, duration of your visit, page views and website navigation paths, as well as information on the timing, frequency and pattern of your use of the service.
Usage data for our App may include your IP address, geographic location, browser type and version, operating system, reference source, duration of your visit, page views and website navigation paths, as well as information on the timing, frequency and pattern of your use of the service.
The source of the usage data is our analytical tracking system. This usage data may be processed for the purpose of analyzing the use of the website and App. The legal basis for this processing is consent (for IP address and geographic location) and/or our legitimate interests (for the other personal data), namely, to monitor and improve our website and App. We do this by using cookies.
See in this respect our Cookie Statement.
3.1.2. Account data
We may process your account data ("account data"). The account data for our website and the App may include your name, surname, gender, date of birth, personal email address, professional email address (optional), employee number (optional), home address, work address, language preference, how you got to know Bike to Work, your transport choices, your bike ambition, your bike type, your employer (optional), your department (optional), Fietsersbond union membership (optional). You provide Us with this information by creating an account on the website or App. The account data can be processed to manage our website and App, to ensure the security of our website and App, to maintain backups of our databases and to communicate with you. The legal basis for this processing is your consent and our legitimate interests, namely the proper administration of our website, App and our association.
3.1.3. Profile data
We may process your information contained in your personal profile on our website ("profile data"). The profile data may include your name, surname, gender, date of birth, personal e-mail address, professional e-mail address (optional), employee number (optional), home address, work address, language preference for communication, how you got to know Bike to Work, your transport choices, your bike ambition, your bike type, your employer (optional), your department (optional), cyclist union member number (optional), your bike routes and geographic locations. The profile data can be processed for the purpose of enabling and controlling your use of our website and application. The legal basis for this processing is consent, our legitimate interests, namely the proper administration of our website, App and our association.
3.1.4. Publication data
If you enter a competition, We may process information about your score on our website and/or App ("publication data"). We will only mention your team name, company and any department, name, surname and relevant employer. The ranking can be consulted on the website. The publication data may be processed to enable this publication and to manage our website and App. The legal basis for this processing is consent or our legitimate interests, namely the proper management of our website and our association.
3.1.5. Business member data
We may process information relating to our customer relationships, including business member data (personal data for the employer's account). ("data of business members") The data of business members may include employer's name, sector code, VAT liability, website, telephone number, employer's address, number of employees, e-mail address and information in the communication between Us and you. The source of the business member data is you. The data of the business member may be processed to manage our relationships with business members, to communicate with business members, to track this communication and to promote our relevant products and services to business members. The legal basis for this processing is consent and our legitimate interests, namely the proper management of our business member relationships.
3.1.6. Communication data (as well as direct marketing data)
We may process information that you provide to Us in order to subscribe to our Bike to Work e-mail messages and/or newsletters ("Communication data"). The communication data may be processed to send you the relevant notifications, newsletters or relevant notifications through the App. In addition, you may receive e-mail messages from the Fietsersbond that are relevant to you (i.e. messages relating to Bike to Work related issues, such as messages relating to bike commuting).
The legal basis for this processing is consent.
3.1.7. Correspondence data
We may process information contained in or relating to any communication you send us. In addition, We may process your personal data to contact you regarding your account.
("Correspondence data"). Correspondence data may include the content of the communication and the metadata associated with the communication. Our website will generate the metadata related to the communications made using the contact forms on the website. Correspondence data may be processed for the purposes of communication with you and record keeping. The legal basis for this processing is our legitimate interests, namely the proper management of our website and our business and communication with users.
A processor is a natural or legal person who processes personal data at the request of or on behalf of Us. We may sometimes enter into a contract with this party to supply certain products and/or services. In other words: We use processors, because this is necessary for the service. In this case, We will enter into a written agreement with the processor whereby the security of your personal data is guaranteed by the processor. The processor always acts according to our instructions.
We call upon the following categories of processors:
- Companies that We have engaged for marketing purposes;
- Companies that We have engaged for ICT technical support, storage and hosting purposes;
- Companies that We have engaged for administrative purposes (e.g. CRM system);
4. Providing your personal data to third parties
We may provide certain personal data to your employer if your account is linked to a company. In this situation, your employer acts as another controller of the personal data. Your employer has access to information about your trajectory performance. This is necessary so that you can obtain certain benefits, such as an allowance for journeys made by bike. The employer's privacy statement applies to the use of your personal data.
It is possible that in the future your personal data may be provided to third parties that are not mentioned in this Privacy Statement. In that case We will amend this privacy statement as such and keep you informed of the changes in accordance with section 8. The legal basis for this processing is consent.
We may disclose your personal data when this is necessary to comply with a legal obligation to which We are subject, or to protect your vital interests or the vital interests of another natural person.
5. International transfer (outside the EEA) of your personal data
We will only store or transfer your personal data within the European Economic Area (the "EEA"). The EEA consists of all EU Member States plus Norway, Iceland and Liechtenstein. This means that your personal data will be fully protected under the GDPR or according to equivalent legal standards.
6. Storage and deletion of your personal data
We store your personal data as follows:
From the date on which you last logged on to our website and/or App, your personal data will be stored for a further 3 years. After this period, your personal data will be deleted.
Without prejudice to the above, We may retain your personal data when this is necessary to comply with a legal obligation to which We are subject, or to protect your vital interests or the vital interests of other natural persons.
Storage and deletion of your personal data
Your registered transport data will be stored anonymously (i.e. without any link to your personal data).
7. Security of your personal data
We will take appropriate technical and organizational measures to protect your personal data and to prevent the loss, unauthorized disclosure or alteration of your personal data.
You must ensure that your password cannot be guessed, whether by a person or a computer program. You are responsible for maintaining the confidentiality of the password you use to access our website/App and We will not ask you for your password (except when you log into our platform).
We may update this Statement from time to time by posting a new version on our website. This may be necessary, for example, if the law changes, or if We change things in a way that affects the protection of personal data. We encourage you to check this page from time to time to ensure that you are happy with any changes to this Privacy Statement. We will notify you of any significant changes to this Privacy Statement by e-mail.
9. Your rights
Some rights are complex and not all the details are included here. Please read the relevant provisions and guidelines of supervisory authorities for a full explanation of these rights.
Your most important rights under the GDPR are:
- A. the right of access;
- B. the right to rectification;
- C. the right to erase (‘right to be forgotten’);
- D. the right to restriction the processing;
- E. the right to object;
- F. the right to data portability;
- G. the right to lodge a complaint with a supervisory authority; and
- H. the right to withdraw your consent.
You can exercise your rights with regard to your personal data by means of a written notification to us. See chapter 2 for the contact details.
We will respond to your request within one month of receiving your request. Normally, We aim to provide a complete response within that time. However, in some cases, especially if your request is more complex, more time may be needed, up to a maximum of three months from the date We receive your request. You will be kept fully informed of progress.
9.1.The right of access
You have the right to confirm whether or not We process your personal data and, where We do so, to access the personal data, along with certain additional information. This additional information includes details of the purpose of the processing, the categories of personal data concerned and the recipients of the personal data. Provided that the rights and freedoms of others are not affected, We will provide you with a copy of your personal data. The first copy will be provided free of charge, but additional copies may be provided for a reasonable fee.
9.2. The right to rectification
You have the right to have inaccurate personal data about you corrected and, taking into account the purposes of the processing, to have incomplete personal data about you completed.
9.3. The right to erasure (‘right to be forgotten’)
In some cases, you have the right to have your personal data erased without undue delay. These circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw your consent to the processing based on consent; you object to the processing according to certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been processed unlawfully. However, there are exclusions from the right to erase data. The general exclusions include where processing is necessary: for the exercise of the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
9.4.The right to restriction the processing
In some cases, you have the right to restrict the processing of your personal data. These circumstances are: you contest the accuracy of the personal data; the processing is unlawful, but you oppose its erasure; We no longer need the personal data for our processing, but you need personal data for the establishment, exercise or defense of legal claims; and you have objected to the processing pending the verification of that objection. If processing on this basis is restricted,
We may continue to store your personal data. However, We will only process it by other means: with your consent; to establish, exercise or defend legal claims; to protect the rights of another natural or legal person; or for reasons of important public interest.
9.5.The right to object
You have the right to object to our processing of your personal data for reasons related to your specific situation, but only to the extent that the legal basis for the processing is that the processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party. If you make such an objection, We will no longer process the personal data unless We can demonstrate compelling legitimate grounds for processing which override your interests, rights and freedoms, or that the processing is intended to establish, exercise or defend legal claims.
In addition, you have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you object, We will stop processing your personal data for this purpose.
Furthermore, you have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes for reasons related to your specific situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
9.6.The right to data portability
Insofar as the legal basis for our processing of your personal data is based on:
- (a) consent; or
- (b) that the processing is necessary for the performance of a contract to which you are a party or for taking action at your request before you enter into a contract, and that such processing is carried out automatically, you have the right to receive your personal data from Us in a structured, commonly used and machine-readable format. However, this right does not apply where it would compromise the rights and freedoms of others.
9.7.The right to lodge a complaint with a supervisory authority
If you believe that our processing of your personal data violates data protection legislation (GDPR), you have the right to lodge a complaint with a data protection supervisory authority. In Belgium, the supervisory authority is the Data Protection Authority (DPA).
DPA contact details
Data protection authority
Drukpersstraat 35, 1000 Brussel
+32 (0)2 274 48 00
9.8.The right to withdraw your consent
Insofar as the legal basis for our processing of your personal data is consent, you have the right to withdraw this consent at any time. Revocation does not affect the lawfulness of the processing prior to revocation.
10. Update of your personal data
Please let Us know if the personal data We hold about you needs to be corrected or updated.
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