Version: June 2021
The Choice Platform is operated and managed by Choice NV, a limited liability company incorporated under the laws of Belgium, registered at the Crossroads Bank for Enterprises under the number 0748.659.757 and with its registered office at Jachthoorn 5, 3210 Lubbeek, Belgium or by any of its affiliates (jointly "Choice", "we" or "us"). Choice collects data when you ("User" or "you") use thePlatform, register as a user and contact us. Amongst these data, we also collect personal data, namely any information relating to an identified or identifiable natural person ("Personal Data"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Choice understands the importance of privacy and strives to protect it. All your Personal Data collected by Choice shall therefore be processed in accordance with the applicable privacy legislations, including the European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "General Data protection Regulation" or "GDPR"), together with codes of practice, regulatory guidance and standard clauses and other related legislation resulting from the GDPR, as amended from time to time.
1. Data Controller
Jachthoorn 5, 3210 Lubbeek, Belgium
2. The purposes of the processing
We collect your Personal Data for the following purposes:
a. to allow you to access and use the Platform;
b. to set up your User account and your access to your account;
c. to display content from external platforms.
d. to communicate with you and provide you with the appropriate support;
We want to guarantee a safe and lawful processing of your Personal Data, and we assure you that your Personal Data will be processed in a straightforward and lawful way. This infers that yourPersonal Data will only be processed for the aforementioned explicitly purposes.
3. Types of Data collected
3.1.1 When you use the Platform, we collect the following categories of data:
a. identification data such as your user account data (if any);
b. technical data such as your IP address, your operating system, the devices on which you use the Platform;
c. behavioural data such as the manner in which you use the Platform or the type of content you watch.
3.1.2 When you register for a User account, we collect the following categories of data:
a. identification data such as your email ,address, your name and surname, your address, your telephone number, your preferred language;
b. technical data such as your IP address, your operating system, your devices you use the Platform on.
3.1.3 When you contact us, we collect the following categories of data:
a. identification data such as you user account (if any), your email address or phone number;
b. the timings of your correspondence with us;
c. the content of your correspondence with us.
3.1.4 When you register for our newsletter, we collect the following categories of data:
a. identification data such as you user account (if any), your email address or phone number.
4. Lawful basis of processing
We process your personal data in strict accordance with the applicable privacy legislation and on the basis of the following legal grounds:
a. Performance of the agreement: we need to process most of your Personal Data to deliver our services, to comply with our obligations, to communicate with you prior to entering into a Commercial UserAgreement with you. For example, we need your contact details to be able to create a user account.
b. Legitimate interest: we sometimes need to process your Personal Data to achieve a legitimate interest. For instance, we collect your behaviour data to improve our services and the Platform.
c. Consent: we may also process your data if we are given express consent, e.g. when you register for a newsletter or when you agree to the use of specific cookies.]
5. Retention and deletion
We will only process and store yourPersonal Data for as long as required by the lawful basis on which they have been collected. This means that:
a. Personal Data collected in order to performa contract between you and Choice will be retained until such contract has been fully performed;
b. Personal Data collected for the purposes ofChoice's legitimate interest will be retained as long as needed to fulfil such legitimate interest;
c. Personal Data collected based on the User's consent can be retained for as long as such consent is not withdrawn.
We may be obliged to retain your PersonalData for a longer period to comply with a legal obligation or with an order of an authority. In any event, Choice will not retain your data longer than 10 year.
6. Your rights as data subject
6.1.1 Right for information and access
You are always entitled to know whatPersonal Data we have on you, how, where and for how long they are processed. You therefore have the right to request information regarding the Personal Data that we hold and process in your respect and to access these Personal Data. We will then provide you with information and/or access to the Personal Data that is being processed and on the source of such Personal Data.
Please note that we may request you to provide us with additional information necessary to confirm your identity before accessing your request for information or access.
6.1.2 Right of rectification and right of erasure
You have the right to request us, free of charge, to rectify any inaccuracies in your Personal Data if such Personal Data would be incomplete or inaccurate.
You have the right to request us, free of charge, to erase all your Personal Data collected, stored and processed by us, without unreasonable delay.
6.1.3 Right to object to data processing
You may, at any time, withdraw the consent that you have given to Choice to the processing of your Personal Data.
We may solely use your Personal Data to contact you for direct marketing purposes if you have explicitly consented hereto. If you have consented hereto in the past, and you no longer want to receive such direct marketing through mail, you may at any time unsubscribe.
6.1.4 Right to restriction
You have the right to obtain from us the restriction of processing where: (i) you contest the accuracy of the PersonalData, (ii) the processing is unlawful and you request the restriction instead of deletion of the Personal Data, (iii) we no longer need the Personal Data but they are required for a legal claim, and (iv) you have objected to the deletion and there is a verification of whether legitimate grounds can override this request.
6.1.5 Right to Data PortabilityWithin the limits set forth in the GDPR, you may request the portability of your Personal Data, i.e. by obtaining that the Personal Data you have provided to Choice will be returned to you or transferred to someone else of your choice, in a structured, commonly used and machine-readable format.
6.1.6 Right to lodge a complaint with the competent authority
If you are not satisfied with the way we process your Personal Data, please let us know and we will investigate your concern using the above communication means. You also have the right to lodge a complaint with a supervisory authority. In Belgium, the supervisory authority is the Gegevensbeschermingsautoriteit / autorité de protection des données: https://www.dataprotectionauthority.be/citizen.
7. Discloser to third parties and transfer to third countries
7.1 Discloser to third parties
We may also share Personal Data with third-party cloud providers and service providers who help us to provide, commercialise and improve the Platform and our services. We do not authorise these third-party service providers to use or disclose your Personal Data except as strictly necessary to perform any services under our supervision or to comply with applicable legislation. We seek to provide any such third-party serviceprovider with only the Personal Data they need to perform their specific function.
7.2 Transfer to third countries
Depending on the circumstances, some recipients of your Personal Data may be located in non-EU countries. In such case, if this country is not recognised by the European Commission as offering an adequate level of data protection, we will put in place appropriate safeguards to protect your Personal Data in accordance with the GDPR, such as the Standard Contractual Clauses of the European Commission, if necessary with additional measures.
Version: June 2021