Privacy Policy

1. GENERAL

1.1. This Privacy Statement applies to the processing of data by BUFFL BVBA, with registered office at Hombeeksesteenweg 376, 2800 Mechelen, registered in the Kruispuntbank der Ondernemingen under the number 0688.975.459 (hereinafter" BUFFL ").

1.2. BUFFL attaches great importance to the protection of your personal data and your privacy. Your personal data will be processed in accordance with the legislation in force and this Privacy Statement

1.3. The purpose of this Privacy Statement is to specify the categories of personal data that BUFFL collects in the context of its commercial activities. BUFFL collects personal data through its website, applications, services and all other means linked to information and communication technology. , including e-mails, organization of competitions, etc. (hereinafter referred to as “the Platform”) The Privacy Statement also describes the way in which personal data is processed and shared with third parties and defines the various measures that BUFFL has implemented to ensure security and confidentiality. of the personal data collected.

1.4. You will be given the opportunity to become acquainted with this Privacy Statement during as well as after the registration process on the Platform. The privacy statement can always be found under the" privacy policy "tab in the BUFFL application. when completing your profile or participating in surveys or journals), you agree to the terms of this Privacy Statement.

1.5. BUFFL is to be considered as the controller of the processing of personal data and will act in accordance with applicable privacy legislation including the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016).

1.6. If you have any questions regarding this Privacy Statement or feel that your interests are not or insufficiently represented, you can contact us via e-mail: operations@buffl.be

1.7. In a changing world in which technology is constantly evolving, we would like to point out that this Privacy Statement may be subject to change. We therefore invite you to regularly consult the latest online version in our application and we will website or application or via the other usual communication channels (for example by e-mail) about any modification of the Privacy Statement.

1.8. Please note that the Platform may contain hyperlinks to other digital platforms or internet sources through which personal data may be collected through cookies or other technological means. BUFFL is in no way liable for these websites and internet sources which it does not control.

BUFFL is also not liable for the collection, use and distribution of your data by these third parties. BUFFL advises you to study the Privacy Statement of these other websites and internet sources in order to understand how these third parties collect and use your personal data.

WHAT PERSONAL DATA PROCESSED BUFFL?

Your personal data is data that can be used to identify you directly (data such as your surname and first name can identify you immediately) or indirectly (data such as your zip code or telephone number can indirectly identify you).

In the event of interactions with you, we may collect various data according to the relevant service types:

your basic data such as your name, gender, date of birth, position and marital status;

your contact information such as your address, e-mail address, username on social media and telephone number;

Information that you share with us when filling out surveys or journals;

technical information such as the duration used per completed survey or journal, which surveys or journals you opened or completed and your IP address;

your location data that is collected using your IP address, GPS function, Wi-Fi access points or other sensors;

Information that you provide to BUFFL to allow us to send you a prize or to provide it in any form.

2.3. In certain circumstances we may also process special categories of data, in particular data relating to (a) health and well-being and (b) data relating to minors. We process this with particular attention.

Data on health and well-being

Taking into account the specific subject of the survey or journal, we also process health and well-being related information such as medical diagnoses, use of medicines and the like.

The processing of this data will only be done with your prior explicit consent and for the purposes for which you have given permission. Access to this data is limited to the persons who need it to perform their duties and the permitted objective. reach.

Data on minors

"Minors who have not yet reached the age of 13 may only register for a BUFFL account with the consent of a parent or legal guardian. The parent (s) or legal representative of the user under the age of 13 must submit it is in the interest of this user to read the Privacy and Cookie Statement and instead of exercising this user's rights, BUFFL will request the consent of a parent (s) or legal representative via e-mail. In the e-mail we will explain what information we collect, how we intend to use it and how the parent (s) or legal representative can give consent, If we do not receive consent from the parent or legal representative within a reasonable period representative, we will remove the parent's contact details and other personal information about the child that was collected to contact you. " },

Minors over the age of 13 may register for a BUFFL account without the consent of a parent or legal guardian. However, in that case we recommend that you involve the parents or legal guardian in reading and approving the Privacy and cookie statement.

BUFFL advises parents or legal guardians to monitor the use that a minor user makes of the Platform and to make such users aware of the use that can be made of their personal data on the basis of the Privacy and cookie statement

WHY DO BUFFL PROCESS YOUR PERSONAL DATA?

3.1. Communication tool between innovative companies and users

BUFFL uses your personal data for the analysis of market and satisfaction surveys and marketing strategies. These surveys or journals give us a better insight into your views and opinions. We share the answers you have given when completing surveys with our customers This information may show trends and may be useful for our customers to improve their products and services, but the customer cannot provide this information back to you, so you will never be contacted by a from our clients.

Your consent is used as a ground for permissible lawful processing of your personal data.

3.2. Improving user experience and quality control of the BUFFL app

If you use our Platform, we process technical data to provide you with our website and the functionality of our apps and to enable our administrators to manage and improve the performance of our website and app. In our app, such as a photo or your location, BUFFL processes this data to provide you with the requested information or functionalities. In addition, the duration of the session is recorded to ensure the quality of the completed survey or journal.

The legitimate interest of BUFFL is used as a ground for permitting the processing of your personal data. The use of your personal data helps us to optimize our company and to minimize disruptions. We do time tracking because the registration of the duration of the session reduces the risk of misuse when completing the surveys or journals, so that we can guarantee our customers the quality of the data obtained.This goal can only be achieved by registering the duration required for one survey or journal.

3.3. E-marketing

When creating your user account, you can explicitly opt-in to receive communications from BUFFL and / or BUFFL partners (without transferring data to these partners). If you accept this, BUFFL will send you electronic newsletters ("Newsletters") that contain information of a commercial nature about new products and services, promotions and benefits, the possibility to take part in promotions / competitions, etc.

If you do not wish to receive our Newsletters, you can withdraw your consent at any time via the link that is directly integrated into the Newsletter.

3.4. Participation in promotions and competitions

Your personal data will be processed in the context of the follow-up and organization of promotions / competitions in which you would participate via our Platform.

Your consent is used as a ground for permissible lawful processing of your personal data.

3.5. Profiling

We determine general or specific user profiles - based on the information you provide to us (eg when completing your profile, participating in surveys or journals or based on the choice of certain prices in our application) - because of the following reasons:

To better meet your needs and expectations and to offer you the best services;

To determine whether you meet the criteria for a specific market research;

"For scientific or market research purposes, the correlation can be investigated between the answers given in a certain survey or journal on the one hand and the different characteristics - tags - that were collected on profiling on the other. uses your person's level and, moreover, anonymised, so the customer will never be able to get this information back to you or to contact you in any way. " },

We rely on your permission to proceed with profiling. It is also in our legitimate interest to proceed with this profiling within the framework of the scientific or market research that we offer to our customers.

We reassure you that this profiling is not intended to make automated decisions that have negative consequences for you.

4. YOUR RIGHTS

In accordance with legislation, you have access, correction, deletion and transferability of your data. In certain cases you also have the right to object to or limit their processing. These rights are free of charge and can be exercised at any time.

4.1. General rights

Access right: you have the right to access and receive a copy of the data that relates to you.

"Right of improvement: we take all reasonable measures to ensure that the information we have is up-to-date and to remove any information that is incorrect or no longer necessary for processing. We encourage you to open your account regularly (if applicable) and consult your data to ensure that it is up to date, and if you find that your data is incorrect or incomplete, you have the right to ask us to correct it, or you can delete all your data from your BUFFL change your account by clicking on the 'profile' button at the bottom of the app. " },

Right to delete (" right to be forgotten "): in certain circumstances (for example, when you withdraw your consent or when the processed data is no longer necessary for the purpose of processing) you have the right to ask us to change your data remove.

Right to limit the processing: you can request to limit the processing of your data, after which your data will no longer be processed (but will be retained).

Transferability right: you have the right to obtain that the data that you have provided to us is transferred to you in a structured format or transferred directly by BUFFL to another data controller.

Right of opposition: If the processing of your data is based on a legitimate interest, you have the right to object to this at any time. However, please note that in this case BUFFL has the right to present its legitimate reasons that justify further processing.

You always have the right to object, at any time and free of charge, to the processing of your data in the context of direct marketing, and BUFFL cannot exclude any exception. This also includes the right to oppose profiling. to the extent that it is related to direct marketing.

If you wish to exercise one of the above rights, you must send a request to operations@buffl.be

4.2. Withdrawal of your consent

"If BUFFL's processing is based on your consent, you can revoke it at any time. This withdrawal will not jeopardize the legality of the processing of your data that occurred during the period prior to the withdrawal of your consent. " },

In the context of direct marketing, this means that you can unsubscribe at any time from the newsletters (" Newsletters ") and other commercial communication from BUFFL. You will then be put in" opt-out ". You can unsubscribe by click on the unsubscribe link at the bottom of each email or by sending an email to operations@buffl.be.

Please note that the exercise of your right of opposition to sending direct marketing only applies to the given e-mail address. If you receive commercial messages at multiple e-mail addresses, the deregistration procedure will be repeated as much as necessary must be via your BUFFL account (if applicable) or via the “Unsubscribe” link that is included in every email.

TO WHOM ARE YOUR PERSONAL INFORMATION TRANSMITTED?

BUFFL assists its customers in the analysis of market and satisfaction surveys and marketing strategies. The results of the surveys or journals are communicated to its customers. BUFFL always shares your information in an anonymous form with its customers. There will therefore be no personal data, ie information that identifies you or makes it identifiable to be shared, so no third party will be able to contact you directly BUFFL only transmits non-personal demographic data to its customers, which enables our customers to gain insight into the different target groups, for which purpose you belong, without disclosing any personal data.

In order to manage our company and help us to provide you with certain products and services, we rely on specialized partners who act as subcontractors and are contractually affiliated with us. They must then follow our instructions and respect the confidentiality of the data that they have received on behalf of BUFFL and may under no circumstances use it for a purpose other than the performance of the work on behalf of BUFFL.

BUFFL ensures that these subcontractors:

only have the information necessary to perform their duties and

commit to BUFFL to process this data in a safe and confidential manner on the one hand and, on the other hand, to use it only for the performance of their duties.

If BUFFL becomes involved in a merger, asset sale, financing, liquidation or bankruptcy, or if some or all of our business activities are sold to another company, we may share your information with that company before and after the transaction is being closed.

The personal data can be passed on by BUFFL to the judicial authorities, administrative authorities or other bodies, or to third parties if this is necessary and / or desirable in order to meet the legal and / or regulatory obligations or in the context of the aforementioned purposes.

HOW ARE YOUR PERSONAL DATA PROTECTED?

BUFFL has taken appropriate safeguards to ensure the confidentiality and security of your personal data. BUFFL has implemented appropriate technical and organizational measures to protect data against accidental or unlawful destruction or accidental loss, damage, alteration, disclosure or unauthorized access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing. Examples of such measures that BUFFL uses are IT security policy, staff training, secure servers and encryption of your sensitive personal data.

INTERNATIONAL TRANSFER OF DATA

BUFFL will not transfer personal data to countries that do not have legislation on the protection of personal data that is equivalent to that applicable within the European Economic Area.

HOW LONG DO WE KEEP YOUR DATA?

If your data is collected on the basis of your consent, we will only use it until you withdraw your consent. From the withdrawal of your consent, your data will be retained for the minimum duration necessary to take the technical measures necessary for the deletion or anonymization of your data.

When your data is used to provide you with our services, this data will be stored for a reasonable period of time limited to the achievement of the goal that was sought during its collection, including the minimum duration required to complete the technical take measures necessary for the deletion or anonymization of your data.

In all cases, your data will be stored during the legal limitation period or any other retention period that would be imposed by law.

9. SUBMITTING A COMPLAINT

If you believe that privacy laws have been violated, you have the right to submit a complaint about the processing of your data to the data security authority whose data are the following:

Commission for the protection of privacy

Drukpersstraat 35 1000 Brussels

Tel .: +32 2 274 48 00 Mail: commission@privacycommission.be

10. HOW DO WE USE COOKIES?

It does not matter whether you have a BUFFL account or if you are a regular visitor to the Platform, when you use the Platform, we place" cookies "on your computer. A" cookie "is a file that our server transfers to the hard disk of your computer, tablet or smartphone is sent with which your surfing device can be identified and with which certain personal data can be collected.

We use different types of cookies:

strictly necessary cookies and functional cookies": for example, this identifies your country and language that you choose to use in order to make using our site as simple and pleasant as possible for you.

" performance cookies ": we collect visitor statistics from our site to make it even more user-friendly and to propose content that better meets your needs;

commercial cookies": this allows us to propose offers that are adapted to your interests. However, this "cookies" type will only be installed on your computer if you have specifically consented to this.

You may refuse the installation of" cookies "on your computer, but such refusal may result in reduced functionality, a delay and even prevent access to some of the Platform\'s services.

For more information about" cookies ", we invite you to read our specific" cookies "policy.

COOKIE STATEMENT BUFFL

GENERAL

1.1. BUFFL uses cookies to simplify, supplement and personalize your visits to the Platform. This section gives you a better understanding of how cookies work, why they are used and how cookies are managed. , can be refused or deleted.

What is a cookie?

A cookie is a small text file that most websites store on your computer or mobile device when you consult the Platform. The cookie allows the sites to record data related to your navigation to facilitate your visits and optimize your experience. This allows the sites to save your actions and preferences (user name, language and other display parameters) for a certain period of time so that you do not have to re-enter this information each time you consult these sites or navigate between pages. adjust the content of a site to your needs and interests.The cookie is placed by the server of a website in the browser of your computer or mobile device.The cookie contains a unique code that ensures that your browser is recognized during your visit the site ("session cookie ") or during repeated future visits ("permanent cookie "). Cookies may be placed by the server of the website you visit or by partners with whom this site works. The server of a website can only read the cookies it has placed itself and has no access to other information that is on your computer or mobile device. The cookies are stored on your computer or mobile device in the directory of your browser. The content of a cookie usually consists of the name of the server that placed the cookie, an expiration date and a unique numeric code.

WHAT COOKIES USE BUFFL AND WHY?

Two types of cookies can be used on the Platform -" session cookies "and" permanent cookies ". Session cookies are temporary cookies that remain on your device until you leave the Platform. Permanent cookies remain much longer or until you delete them manually (for how long) a cookie remains on your device depends on the "lifetime" of the cookie in question or your browser settings).

Cookie type

Description

Do these cookies collect my personal data or am I being identified by this?

Strictly necessary cookies

Thanks to these session cookies, it is possible to surf on the Platform, use the functionalities of our sites and gain access to the secure zones. If the use of these cookies is disabled, then certain parts of the Platform may not be accessible The strictly necessary cookies make it possible, for example, to fill in a form. It is also thanks to the authentication cookies that you can consult your personal account when you open a user session of the site via logins (on-site portal site and mobile site).

These cookies do not identify you as an individual.

If you do not accept these cookies, this may have an impact on the performance of the Platform.

Performance cookies

The performance cookies collect statistics on the surfing behavior of surfers with the aim of making the sites more user-friendly and adapting their content better to visitors. For example, the performance cookies count the number of one-time visits and the number of error messages that have appeared and the pages most frequently visited are detected.

These cookies do not identify you as an individual. All data is collected or aggregated anonymously.

Functional cookies

We use functional cookies to improve your visit, make your use of the site more pleasant and to offer you more relevant information. For example, we use cookies to personalize the user interface that remember your preferences such as your language choice, your country choice or a personalized travel book.

We also use

" Flash "cookies. Flash Player has its own cookie system to share local information. Flash cookies are different from traditional cookies because they are stored by the browser. These locally shared objects are stored on the machine without any time limit. They provide standard surfing habits (history of the sites visited ...).

The information collected by these cookies may contain identifiable personal information that you have provided, such as username or profile picture. We will always ensure all transparency regarding the information we collect about you, what we do with it and with whom we share it. share.

If you do not accept these cookies, this may have a possible impact on the performance and functionality of the website and may restrict access to certain content on the Platform.