PRIVACY POLICY

INTRODUCTION

First of all, thank you for your interest in TADAAM. In order to use our Services, we will have to request certain information from you that is required for starting up and maintaining the service, for example your name, address, but also the necessary payment details, etc. During your use of our Services, we also receive additional information from you regarding your use. We think it is very important that you have a good idea of everything that happens with your data and that does not happen. We have tried to bring this information together in a clear and transparent manner in the privacy policy below. If you have any further questions or concerns after reading the following, please do not hesitate to contact us. You will find our contact details at the bottom of this policy.

Who are we?

TADAAM is an innovation project within Telenet. In that sense, Telenet bv (with its registered office at Liersesteenweg 4, 2800 Mechelen, and registered with the CBE under number 473.416.418) is the person ultimately responsible for processing your personal data.

From the perspective of setting up an innovation project, TADAAM has various systems in which your data is stored and processed. The Services offered by TADAAM also differ significantly from the Services offered by Telenet. That is why we have opted for a more tailored privacy policy for TADAAM.

What information do we collect?

A. The data that we collect directly from you
In the first instance it is about the data that we receive directly from you when requesting, starting up and using the Service.
This is, for example, the data that we request to register you as a customer with TADAAM.
By this we mean, for example, your e-mail address, your name, your address, but also, for example, your payment details. Regarding the registration of your payment details, we refer you to the special section below.B. The data resulting from the use of the Service
In addition, we also have data resulting from the use of the Service, this includes more technical data, traffic data or location data.

  • This includes, for example, the registration of the product / Service itself to which you are registered; • The technical data of the hardware that you use such as the model or service number;
  • We also collect information about your use of our Services (internet, TV, online services). Hereby we receive information both about the Services themselves but also about how you use them. For example, we can know how long you have watched a certain program. This allows us to gain an insight into our Services themselves and any adjustments that we need to make.
  • The location and traffic data such as the IP address or the mast to which you are connected during your actual use, your login and passwords, etc.

C. The information we obtain from third parties
To improve our services it is possible that we purchase data from specialized third party companies such as Bisnode. With the socio-demographic data or consumer information that we obtain from such companies, we can get started to adjust, improve, etc. our Services.

Why should I create an account?

As a TADAAM customer you have the option to create a TADAAM account. This is not mandatory but creating an account does have some advantages:
  • You can easily log in to all our Services;
  • You have access to a My TADAAM where you can easily manage or change your settings if necessary
    If you use one account, we also group and assign the ways in which you use our Services (via PC, app, etc.). This way we get a clear picture of how you use our Services and what you expect from them, which can only benefit the service. An account is personal and cannot be shared with other. By granting access to your account to other people, your personal details will also be accessible to others.

What information is it about and what do we use your information for?

We collect this data for a number of obvious reasons.

A. Because they are necessary for the implementation of our agreement
We collect this data because it is necessary for starting, executing or terminating our agreement, for example:

  • To start the Service, we need information such as name, address and telephone number;
  • To be able to carry out the invoicing, we need your payment details.

B. Because we have a legitimate interest
It is our intention to always offer you the best service, for which your personal data can also provide us with useful information. In that case we speak of a legitimate interest on the basis of which we can keep track of your personal data. Some examples are:

  • We may need to contact you regarding the Service you purchase, for example, to inform you about usage options, or in case you have ended the Services to inform you about new promotions, products or improvements;
  • Because the insight into your data allows us to maintain or improve the network, etc;
  • Our services are based on a personalized use of our Services. On the basis of your personal data, data we derive from your use of our Services, but also any additional data (for example, socio-demographic data that, among other things, relates to you as a customer and / or your family, as well as statistical data on neighborhood or level and consumer information) we try to tailor our Services to your preferences and interests. We are thinking here of a personalized proposal for a specific film or TV show by combining your personal data and your viewing behavior, or we can also send you personalized advertising based on your personal data, etc.

C. Because we are legally obliged to do this

In many cases, we are also required by law to store certain personal data and / or to communicate this to government agencies.
For example, we are required to maintain your internet data for 12 months in order to be able to transfer them to the competent authorities as part of a police or judicial investigation. Or there are still a series of general tax and accounting obligations on the basis of which you must keep records.

D. Based on the express permission we have received from you
Subject to your consent, we also wish to use your data to keep you informed of advertising related to non-similar products and Services from TADAAM, our legal successors or other members of the group.

Who do we share your information with?

A. Data transfer

  • With our legal successors and other members of the group.

    As mentioned above, TADAAM is an innovation project within Telenet BV. It is therefore possible that your personal data will be passed on to Telenet BV or other members of the Telenet group (Liberty Global BV, Telenet Group bv, Telenet Retail bvba and Telenet Group Holding NV). In those cases, however, your data can only be used for the same purposes as those stated in the TADAAM privacy policy.

  • With external partners that we appoint in the context of our services to you
    In certain cases we rely on external partners in the context of our services. If we pass on your data to third parties, then this transfer can only take place for the same purposes for which Tadaam processes your data itself and the transfer is also limited to the data that these parties need to perform their duties in our assignment. We ensure that they, just like us, manage your data securely, respectfully and with due diligence and we provide adequate contractual guarantees for this. For instance:
  • For the delivery of the hardware we can call on external courier or parcel service;
  • To provide the necessary customer service, we can also call on external call centers, etc. To ensure that these partners can give our customers the best possible support to our TADAAM customers, it goes without saying that we must also provide them with insight into your data.
  • We use an external system, Stripe, to process the monthly payment. Consequently, Stripe must have the necessary information to be able to set up and settle the payment.

B. International processing of your personal data.
If personal data are processed outside of the European Union, for example in the case of Stripe, we ensure that this data enjoys an appropriate level of protection there, similar to the protection that they would enjoy in the European Union, through contractual or other measures.

C. Transfers in the context of reorganization, etc
Finally, we reserve the right to transfer data, including personal data, in connection with a reorganization, restructuring, merger, sale or other transfer of assets.

What do we do with anonymous data?

We use anonymous, aggregated data for commercial purposes and reporting both internally and externally. This data can never be returned to a specific natural person. A few examples: location reports (“how many people were at a certain moment in a certain place”), viewing figures for TV channels to determine, for example, the popularity of certain programs. TADAAM guarantees that all these parties that receive data from us can never be traced back to a natural person to be identified.

How do we protect your data?

We attach great importance to the security of your personal data. We therefore use various security technologies and procedures to adequately protect your personal data against unauthorized access, use or disclosure.

For example, we store personal data that you share with us on computer systems that have limited access and are housed in secure buildings. It is your responsibility to keep the password you use to protect your accounts and personal data confidential.

How long do we store your data?

We do not keep your personal data longer than necessary to achieve the purpose for which we collect it. Depending on the purpose, the retention period may therefore differ. For example, traffic data relating to connections is never kept for longer than 12 months and your TV viewing behavior for a maximum of 36 months.

Sometimes the period can also be longer, for example to meet our legal obligations (to meet our accounting and tax obligations, for example, we are obliged to keep your billing information up to 7 years) or because of the legal necessity to keep certain data (in particular your contract, invoices and correspondence relating to complaints in this regard) to be kept as evidence in pending disputes, up to a maximum of 10 years after the termination of your contract.

Certain data from former customers can be used for a period of 2 years after the termination of the contract to recognize the former customer and keep them informed of new products and promotions

What rights do I have and how do I exercise them?

A. What rights do I have?

  • The right of inspection You have the right to know at any time whether or not we are processing your personal data, and if we are processing it to view that data and receive additional information about elements such as the processing purposes; the categories of personal data concerned; etc.
    You also have the right to receive one free copy of the processed data, in understandable form.
  • The right for improvement of personal dataYou have the right to have incomplete, incorrect, inappropriate or outdated personal data rectified without delay.
  • The “right to forget”You have the right to have your personal data removed in the following cases, and without unreasonable delay, for example when your personal data is no longer needed for the purposes for which it was collected or otherwise processed by TADAAM.

    Keep in mind that we cannot always remove all requested personal data, for example when the processing thereof is necessary for the institution, exercise or substantiation of a legal claim.

  • The right to limit processingYou have the right to obtain the limitation of the processing of your personal data if one of the following elements applies:

    o You dispute the accuracy of that personal data: its use is limited during a period that allows TADAAM to check the accuracy of the data; oThe processing of your personal data is unlawful: instead of deleting your data, you request a restriction on its use;
    o TADAAM no longer needs your data for the original processing purposes, but you need it for the institution, exercise or substantiation of a legal claim: instead of deleting your data, its use is limited for the institution, exercise or substantiation of the legal claim; oas long as no decision has been made on the exercise of your right to object to the processing, you request to limit the use of your personal data.

  • The right to transfer of personal data (“data portability”)You have the right to “recover” your personal data, for example, to make it easier to change service providers. This is only possible for the personal data that you have provided to TADAAM, based on permission or after agreement.
  • The right to object to the processing of your personal dataYou have the right to object to the processing of your personal data based on your special situation if the processing is in the legitimate interest of TADAAM or in the public interest. TADAAM will cease processing your personal data, unless TADAAM can demonstrate compelling and legitimate grounds for processing that outweigh yours or when the processing of the personal data is related to the filing, exercise or substantiation of a legal claim (for example, filing of a request to a court).
  • Opt out for direct marketingYou always have the right to oppose the use of your personal data for direct marketing purposes without having to give a reason.

B. How should I exercise my rights?

To exercise your privacy rights, you must inform us of this by email at gdpr@tadaam.be/. To prevent any unauthorized disclosure of your personal data, we must verify your identity. In case of doubt or ambiguity, we will first ask you for additional information (preferably a copy of the front of your identity card).
You can exercise your privacy rights for free, unless your request is manifestly unfounded or excessive, in particular because of the repetitive nature. In such a case, we have – in accordance with privacy legislation – the right and the choice to (i) charge you a reasonable fee (taking into account the administrative costs of providing the requested information or communication and the costs that accompanied by taking the requested measures), or (ii) refusing to comply with your request.

What about changes to this policy?

This privacy policy may change from time to time, for example due to market evolutions and new processing activities. We therefore invite you to always consult the latest version of this policy on our website (www.tadaam.be/privacy). We will of course inform you in advance via our websites or other current communication channels of any substantive change and we will ask for your prior permission for our (new) processing activities when required by law.

Who can I contact for complaints?

Do you want to report a privacy incident or do you have complaints? Contact us at support@TADAAM.be and clearly state “privacy” in the title.

For complaints related to the processing of your personal data by TADAAM, you can contact the Data Protection Authority, Drukpersstraat 35, 1000 Brussels / +32 (0) 2 274 48 00 / contact@apd-gba.be / www.gegevensbeschermingsautoriteit.be