Privacy

Privacy Policy

02/01/2020

1. Who we are

"We", "us" or "our" means Routty NV, with its registered office at Veldkant 31, B-2550 Kontich, Belgium and with company number 0719.282.219.
We act as controller for the personal data we gather through your use of the Routty platform.

This Privacy Policy is solely intended to provide you with information in relation to the processing of personal data through your use of the Routty platform. For our privacy practices in relation to our services, we refer you to the agreement as may be concluded between us.

Your privacy is important to us, so we've developed this Privacy Policy that sets out how we collect, disclose, transfer and use ("process") the personal data that you share with us, and which rights you have. Please take a moment to read through this policy.

If you have any questions, concerns or complaints regarding this Privacy Policy or our processing of your personal data, or you wish to submit a request to exercise your rights as set out in article 4, you can contact us:

1. Via-mail: privacy@routty.be to the attention of our Data Protection Officer;

2. By post: to Routty NV, Veldkant 31, B-2550 Kontich, Belgium

2. How we use and collect your personal data

Personal data is defined as any information relating to an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.), that can be used to directly or indirectly identify a natural person.

The personal data we collect, is collected and used for the purposes as listed hereunder:

1. We process your personal data for the purpose of providing access to the Routty platform and in further extend, to enhance your user experience, which includes ensuring the security, availability, performance, capacity and health of the Routty platform.

2. We process your personal data to enforce or exercise any rights that are available to us based on the applicable law, such as use for the establishment, exercise or defense of legal claims.

3. We may also use your personal data to fulfil our obligations as set out by the applicable law.

The following categories of personal data can be distinguished:

1. Profile data: If an account is created on the Routty platform, we collect the following personal data: name, e-mail address. This is information that is provided directly by you.

2. Usage data: We collect personal data regarding your activities on the Routty platform: IP address, device ID and type, referral source, language settings, browser type, operating system, geographical location, length of visit, page views, or information about the timing, frequency and pattern of your service use. This information may be aggregated and used to help us provide more useful information regarding the use of the Routty platform. In the event the usage data is completely anonymized (and can therefore not be traced back to you as an individual), this will not be considered personal data for the purpose of this Privacy Policy. This is personal data that is automatically collected through your use of the Routty platform.

The legal basis for the processing of your personal data is providing Routty in a platform-as-a-service model with user and role-based access restrictions.

Your personal data will solely be used for the purposes as set out in this article.

3. Retention of your data and deletion

Your personal information will not be kept for longer than is necessary for a specific purpose. However, considering it is not possible for us to specify a period in advance, the period of retention will be determined as follows:

1. Disabled user accounts, that include profile data, are retained for a period of 12 months.

2. Usage data is retained for a period of 12 months.

In the event you withdraw your consent or you object to our use of your personal data, and such objection is successful, we will remove your personal data from our databases. Please note that we will retain the personal data necessary to ensure your preferences are respected in the future.

The foregoing will, however, not prevent us from retaining any personal data if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.

4. Your rights

This article lists your principal rights under data protection law. We have tried to summarize them for you in a clear and legible way.

To exercise any of your rights, please send us a written request in accordance with article 1 of this Privacy Policy. We will respond to your request without undue delay, but in any event within one month of the receipt of the request. In the event of an extension of the term to respond or in the event we do not take action on your request, we will notify you.

4.1. The right to access

You have the right to confirmation as to whether or not we process your personal data and, in the event we do so, you have the right to access such personal data, together with certain additional information that you also find listed in this Privacy Policy.

You have the right to receive from us a copy of your personal data we have in our possession, provided that this does not adversely affect the rights and freedoms of others. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies.

4.2. The right to rectification

If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed.

4.3. The right to erasure (right to be forgotten)

In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include:

1. The personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed;

2. You withdraw your consent, and no other lawful ground exists;

3. The processing is for direct marketing purposes;

4. The personal data have been unlawfully processed; or,

5. Erasure is necessary for compliance with EU law or Belgian law.

There are certain exclusions to the right to erasure. Those exclusions include where processing is necessary,

1. for exercising the right of freedom of expression and information;

2. for compliance with a legal obligation; or,

3. for the establishment, exercise or defense of legal claims.

4.4. The right to restrict processing

You have the right to restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes), if:

1. You contest the accuracy of the personal data (and only for as long as it takes to verify that accuracy);

2. The processing is unlawful and you request restriction (as opposed to exercising the right to erasure);

3. We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; or,

4. You have objected to processing, pending the verification of that objection.

In addition to our right to store your personal data, we may still otherwise process it but only:

1. with your consent;

2. for the establishment, exercise or defense of legal claims;

3. for the protection of the rights of another natural or legal person; or,

4. for reasons of important public interest.

We will inform you before we lift the restriction of processing.

4.5. The right to data portability

To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, 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 adversely affect the rights and freedoms of others.

You also have the right to have your personal data transferred directly to another company, if this is technically possible, and/or to store your personal data for further personal use on a private device.

4.6. The right to object to processing

You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:

1. The performance of a task carried out in the public interest or in the exercise of any official authority vested in us;

2. The purposes of the legitimate interests pursued by us or by a third party.

If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

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 make such an objection, we will cease to process your personal data for this purpose.

4.7. The right to complain to a supervisory authority

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In Belgium, you can submit a complaint to the Authority for the protection of personal data (Privacy Commission), Drukpersstraat 35, 1000 Brussel (commission@privacycommission.be), www.privacycommissie.be/contact.html.

5. Providing your personal data to others

In order to provide you with our website, we work with service providers to process and store your personal information. We use the following categories of service providers:

1. Azure Infrastructure service provider

We may also disclose your personal data in the event such disclosure is required or necessary in order to fulfil a legal obligation. We may also disclose personal data in order to protect your vital interests or the vital interest of another natural person.

6. International transfers

We will not transfer your personal data outside of the European Economic Area

We will ensure that any transfer of personal data to countries outside of the European Economic Area will take place pursuant to the appropriate safeguards.

7. Amendments to the Privacy Policy

From time to time, we have the right to modify this Privacy Policy. You will always be able to consult the most recent version of the Privacy Policy in the Routty Portal, and you will be notified of any changes.