Mobile Locker:

Datenschutzbestimmungen

Privacy policy - website

Thank you for visiting our website!

The protection of your privacy and personal data is of utmost importance to us. We aim to protect your privacy and aim to ensure that you can safely entrust us with your personal data. As such, we undertake to handle your personal data securely and discreetly. Furthermore, we take appropriate security measures to avoid loss, alteration, access by unauthorised persons and/ or any other unlawful processing of your personal data.

This privacy policy covers the processing of personal data by us via our website https://www.mobilelocker.eu.

We aim to be transparent regarding how we process your personal data and what we do with your personal data. We provide you with more detail on those processes in this privacy policy.

Who are we?

Mobile Locker with registered office at Nijverheidsstraat 94,2160 Wommelgem (Belgium) and registered with the Belgian Crossroads Bank of Enterprises under company number 0643.621.922 (RLE Antwerp, section Antwerp)(hereinafter, "Mobile Locker", "we" or "us").

You can contact us via the following contact details:

E-mail: info@mobilelocker.eu
Telephone number: +32 3 284 93 03

We aim to process your personal data in accordance with the applicable legal provisions regarding privacy and the protection of personal data, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter the "GDPR") and the applicable national implementing legislation.

Some definitions

As far as this privacy policy is concerned, the term "personal data" refers to: all iformation about an identified or identifiable natural person (the “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular through an identifier, such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural orsocial identity of that natural person. In other words, all the information which can be used to identify a person. These elements include, for instance, your surname, first name, date of birth, telephone number and email address, aswell as your IP address.

The term "processing"is very broad and covers, among other things, collecting, recording, organising, storing, updating, modifying, retrieving, consulting, using, disseminating, combining, archiving and deleting data.

Entity responsible for the processing of your personal data (the "data controller").

Mobile Locker is responsible for the processing of your personal data.

We are what the GDPR refers to as the “data controller” of your personal data. In concrete terms, this means that Mobile Locker, possibly together with other entities, determines the purpose and means for the processing of your personal data.

What categories of personal data do we process, why, on what legal basis and for how long?

In the table below you can read:

‍Column 1: what categories of personal data we process (the “Categories of personal data”);‍
Column 2: why we process your personal data(the “Purposes”); ‍
Column 3: on what legal grounds the processing is based (the “Legal basis”); and‍
Column 4: for how long we process your personal data (the “Retention period”).

All processing activities involving your personal data takes place for one or more specific purposes.

In addition, we only process your personal data when we can rely on a valid legal basis. The applicable legal basis, which you can find in the column ‘Legal basis’, means the following:

'Consent': you have given consent for the processing of personal data for one or more specific purposes;
‘Agreement’: the processing is necessary for the performance of a contract to which you are a party, or to take steps at your request for the conclusion of acontract;
'Legitimate interest': the processing is necessary to protect our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data

Personal Data Processing Table

Categories of personal data	Purposes	Legal basis	Retention period
Device information (Electronical) identification data	To allow you to access our website	Consent to cookies other than essential Our legitimate interest in profiling ourself with a well-functioning website and your interest to be able to use it in a smooth manner	Until the end of your visit to our website or until the relevant cookie is deleted
Personal identification information Contact information Company details in case you are representing/working for a company Choice of language Bank account details Username and password	To allow you to create a customer account via our website	Agreement	For the entire duration of your customer relationship with us
Personal identification information Contact information Contents of your message Attached files (optional: Images, behavioural information, sensitive information; ...)	To give you the opportunity to contact us easily with any practical, technical or organizational questions and to respond to them correctly and in a timely manner	Einwilligung	For the duration of the processing of your question or message and up to 10 years thereafter if the specific case at hand justifies such retention period
Personal identification information Contact information Contents of your message	To allow you to contact us to start a partnership	Einwilligung	For the duration of the processing of your question or message and our subsequent cooperation
Personal identification information Contact information Professional information such as your resume as included in your application e-mail	To process your application when you contact us per email through the "Jobs" section of our website	Agreement Consent with regards to optional information	For the duration of application process
Personal identification information Contact information The contents of your request and related information Front of the ID card and signature	To manage your request to exercise your rights	Legal obligation (article 12, 2. GDPR)	10 years for request (in the event of a judicial procedure: until termination of judicial procedure)
Personal identification information Contact information Any other information relating to you that may be necessary to defend and protect our rights	To defend and protect our rights	Legitimate interest (legal defence)	Applicable statute of limitations (see "Retention of your personal data")

Minors

We do not intend to collect any personal data from persons younger than 16 years old.

Cookies

We also use cookies, primarily to permanently optimise our website for its users. For more specific information about the cookies we use, you can consult our cookie policy here .

Your privacy rights

To give you more control over the processing of your personal data, you have various rights at your disposal. These rights are laid down in the GDPR.

You have the following rights:

‍The right to access the personal data we process about you (article 15 GDPR):

You have the right to be informed by us at any time whether or not we are processing your personal data. If we are processing them, you have the right to access these personal data and to receive additional information about:

The purposes of the processing;
The categories of personal data concerned;
The recipients or categories of recipients (in particular, recipients in third countries);
The retention period or, if that is not possible, the criteria for determining that period;
The existence of your privacy rights;
The right to lodge a complaint with the supervisory authority;
The source of the personal data if we obtain personal data from a third party;
Whether we are using automated decision-making in respect of you.

If we cannot give you access to your personal data (e.g. due to legal obligations), we shall inform you as to why this is not possible.

You can also obtain a free copy, in an understandable format, of the processed personal data. Please note that we may charge a reasonable fee to cover our administrative costs for any additional copy you may request.

‍The right to request us to delete your personal data ('right to be forgotten')(article 17 GDPR):

In certain cases, you can request that we delete your personal data. Please also note that your right to be forgotten is not absolute. We are entitled to continue to store your personal data if this is necessary for, among other things, the execution of the agreement, compliance with a legal obligation, or the establishment, execution or substantiation of a legal claim. We shall inform you of this in more detail in our response to your request.

‍The right to rectification (article 16 GDPR):

If your personal data is incorrect, out of date or incomplete, you can ask us to correct these inaccuracies or incomplete information.

‍The right to data portability (article 20 GDPR):

Subject to certain conditions, you also have the right to have the personal data that you have provided to us for the performance of the agreement or for which you have given your consent, transferred by us to another controller. Insofar as technically possible, we shall provide your personal data directly to the new controller.

‍The right to restriction of processing (article 18 GDPR):

If any of the following elements apply, you may request us to restrict the processing of your personal data:

You dispute the accuracy of those personal data (in this case, its use shall be limited for a period that allows us to verify the accuracy of the personal data);
The processing of your personal data is unlawful;
We no longer need your personal data for its purposes, but you need them in establishing, exercising or substantiating a legal claim;
As long as no decision has been taken on exercising your right to object to the processing, you may request that the use of your personal data be restricted.

‍The right to object (article 21 GDPR):

You can object to the processing of your personal data on the basis of your particular situation, if we process your personal data on the basis of legitimate interests or on the basis of at ask of general interest. In this event, we shall cease the processing of your personal data, unless we can demonstrate compelling and legitimate grounds for processing which outweigh your own, or if the processing of the personal data is related to establishing, exercising or substantiating a legal claim.

‍The right not to be subject to automated decision-making (article 22 GDPR):

You have the right not to be subject to a decision made exclusively on the basis of automated data processing that significantly affects you or has legal consequences and that is made without substantial human involvement.

You cannot exercise this right infollowing three situations:

When automated decision-making is legally permitted (e.g. to prevent tax fraud);
When automated decision-making is based on your explicit consent; or
When automated decision-making is necessary for entering into, or performance of a contract (please note: we always endeavour to use less privacy-intrusive methods for entering into or performing the contract).

‍The right to withdraw your consent (article 7 GDPR):

If your personal data are processed on the basis of your consent, you may withdraw this consent at any time upon simple request.

‍The right to lodge a complaint with the supervisory authority (article 77, 1. GDPR)

You can file a complaint with the data protection supervisory authority. A list of the supervisory authorities within the European Union can be accessed via the following hyperlink: https://www.edpb.europa.eu/about-edpb/about-edpb/members_nl.

In Belgium, the competent supervisory authority is the Data Protection Authority, with the following contact details:

Website: https://www.dataprotectionauthority.be

Contact details:

Data Protection Authority
Drukpersstraat 35, 1000 Brussels, Belgium

+32 (0)2 274 48 00 +32 (0)2 274 48 35 contact@apd-gba.be

‍Exercising your rights

To exercise these rights, you can contact us by using the contact details set out in Section – ‘Contact us’.

In order to verify your identity when you wish to exercise these rights, we may ask you to send us a copy of the front side of your identity card. The national security number and the image on your electronic identity card shall not be retained by us. We strongly advise you to “blackline” the national security number and the image before transmitting a copy of your electronic identity card to us.

You can exercise the above mentioned rights free of charge, unless your request is manifestly unfounded or excessive (for instance due to its repetitive nature). In such cases, we shall be entitled to charge you a reasonable fee or to refuse to respond to your request.

Retention of your personal data

We shall only retain your personal data for as long as necessary to achieve the intended purpose. You should take into account that numerous (legal) retention periods result in the fact that personal data (must) remain stored. Where there is no obligation to retain the data, it shall be routinely deleted once the purpose for which it was collected has been fulfilled.

In addition, we may store your personal data if you have given us your consent to do so or if we may require this data in the context of a legal claim. In the latter case, we need to use certain personal data as evidence. To this end, we store certain personal data, in accordance with the applicable statute of limitations, which may be up to thirty years; however, the usual statute of limitations in relation to personal claims is ten years.

Sources of your personal data

We process personal data that you spontaneously provide tous. If additional personal data are required, we will inform you whether or not you are obliged to communicate them and what the consequences are if you do not communicate them. Failure to communicate personal data may result in our inability to provide our services to you.

In particular, we identify the following categories of sources:

External partners and independent service providers.

Categories of recipients

Within our organisation, we ensure that your personal data is only accessible to those who need it to fulfil contractual and legal obligations.

We will only disclose your personal data to third parties in accordance with statutory provisions or if you have given your consent. In certain cases, our employees are supported by external service providers in performing their tasks.

Furthermore, we do not transfer personal data to third parties unless we are obliged to do so on the basis of legal provisions (e.g. transfer to government bodies such as supervisory or law enforcement authorities).

In particular, we identify the following categories of recipients:

Governmental or regulatory authorities when requested in the context of complying with a judgment or decree, legislation, regulation, standard or legal process;
External service providers that enable us to provide the website functionalities to you;
External (legal and financial) advisors and consultants.

‍Transfer to third countries outside of the European Economic Area (“EEA”)

We shall only transfer your personal data to processors or controllers in third countries to the extent we are legally entitled to do so.

Insofar as such transfers are necessary, we take the necessary measures to ensure that your personal data are highly protected and that all transfers of personal data outside the EEA take place lawfully.

Security of your personal data

The security of your personal data is an important concern for us. We take reasonable and adequate technical and organisational security measures to protect your personal data against accidental or intentional manipulation, loss, destruction or access by unauthorised persons.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protectyour personal data, we cannot guarantee the security of your personal data transmitted to us via the internet. Any transmission of personal data is at your own risk.

Questions orcomplaints?

We aim to securely protect your privacy and personal data. If you have any questions or complaints about the way in which we process your personal data, you can notify us thereof via our contact details as mentioned above in the section ‘Contact us’.

Amendments

In response to feedback, or to reflect changes in our processing activities, we may amend this privacy policy from time to time. We therefore invite you to always consult the latest version of this privacy policy on our website.

Information notice to customers employees

The present information notice for customers who are natural persons and customers' employees (the Information Notice) describes the conditions under which Mobile Locker NV, a limited liability company with registered address at Nijverheidsstraat 94, 2160 Wommelgem, Belgium and registered with the crossroads bank for enterprises under number 0643621922 (Mobile Locker or we), collects and processes personal data pertaining to the employees (the Data Subjects or you) of the entity who purchases, rents or reserves its products orservices (the Customer) and has therefore entered into an agreement (the Agreement) with it.

We may update the Information Notice from time to time. If we make material changes to this Information Notice, you will be notified accordingly.

Welche personenbezogenen Daten Mobile Locker ?

Mobile Locker processes the following personal data of the Data Subjects : name and first name, telephone number, email address, identity of the employer, unique identifiers, other personal data specifically provided by the data subject.

Zu welchen Zwecken werden die personenbezogenen Daten von Mobile Locker erhoben und verarbeitet?

Wir verarbeiten diese Daten für folgende Zwecke:

Management of the Agreement, delivery of our products and provision of our services,
Management of the Customer's account,
Billing and accounting purposes,
Customer relationship management, including the realization of surveys of satisfaction, the sending of follow-up emails, handling hotline calls, etc.,
Production of statistics,
Enhancing our products and services (through data analytics, conduct of surveys, monitoring of the services quality, training regarding the OMS platform, service rounds, etc.),
Promotion of our activities (sending of newsletters, magazines and brochures, organization of events, etc.). If you do not wish to receive marketing emails, follow the "unsubscribe" instructions included within each email communication,
Processing of access, installation planning,
Rectification, tickets and opposition requests, and other rights with respect to personal data, claims and litigation management.

The processing of the above personal data is necessary for the performance of the Agreement (with the Customer). With regards to the processing of Customer’s employees personal data, it is necessary for Mobile Locker’s legitimate interest to deliver its contractual obligations that this personal data is processed as it enables it to manage the claims and failures to comply that may arise from the performance of the Agreement and to enhance its products and services.

Insofar as the Customer is a natural person, the processing for the above mentioned purposes takes place on the legal basis of “performance of the Agreement” as meant under article 6.1.b) GDPR.

Insofar as the Customer is not a natural person, and the processing of its employee’s personal data for the above mentioned purposes takes place on the legal basis of “legitimate interest” as meant under article 6.1.f) GDPR.

The promotion of our activities is based on the legal basis of your “consent” as meant under article 6.1.a) GDPR.

Wer sind die Datenempfänger?

Ihre personenbezogenen Daten werden intern von ordnungsgemäß befugten Personen im Rahmen ihrer jeweiligen Zuständigkeiten verarbeitet.

Sie können auch an Mobile Locker und externe Dienstleister (wie IT-Dienstleister, die die Daten hosten, Webdesigner, Zahlungsdienstleister, Kommunikationsagenturen, Rechtsberater usw.) weitergegeben werden, jedoch nur im unbedingt erforderlichen Umfang und vorbehaltlich vertraglicher Garantien zur Gewährleistung der Sicherheit und Vertraulichkeit der Daten.

We transfer your Personal Data outside the European Economic Area to the following trusted parties:

Google LLC;
Microsoft Corp.;
Slack Technologies.

In doing so, Mobile Locker has verified that these parties comply with the relevant data protection requirements and provide an adequate level of protection for the processing of your personal data.

Wie Mobile Locker die Sicherheit Ihrer persönlichen Daten?

We processyour personal data as a data controller, in compliance with the applicable data protection legislation (i.e. EU General Data Protection Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (known as GDPR) and any implementing legislation, as well as any successor texts.

Wir verpflichten uns, technische und organisatorische Sicherheitsmaßnahmen zu ergreifen, um den Schutz Ihrer personenbezogenen Daten vor den mit der Nutzung von Informationssystemen verbundenen Risiken zu gewährleisten.

Mobile Locker allgemein anerkannte Sicherheitsstandards, um Ihre persönlichen Daten zu schützen.

Ihre personenbezogenen Daten werden für die Dauer der geltenden Verjährungsfrist einer Rechtshandlung gespeichert. Nach Ablauf eines Jahres ab dem Datum der Beendigung des Vertrags werden Ihre personenbezogenen Daten auf einem separaten Datenträger archiviert und sind nur bei Bedarf für eine begrenzte Anzahl von Personen zugänglich, die speziell dazu befugt sind.

For more information on the retention period of your personal data, you can contact us at the contact details mentioned below or consult our Privacy Policy.

Was sind Ihre Rechte?

To give you more control over the processing of your personal data, you have various rights at your disposal. These rights are laid down in the GDPR.

You have the following rights:

The right to access the personal data we process about you (article 15GDPR):

The purposes of the processing;
The categories of personal data concerned;
The recipients or categories of recipients (in particular, recipients in third countries);
The retention period or, if that is not possible, the criteria for determining that period;
The existence of your privacy rights;
The right to lodge a complaint with the supervisory authority;
The source of the personal data if we obtain personal data from a third party;
Whether we are using automated decision-making in respect of you.

If we cannot give you access to your personal data (e.g. due to legal obligations), we shall inform you as to why this is not possible.

You can also obtain a free copy, in an understandable format, of the processed personal data in an understandable format. Please note that we may charge a reasonable fee to cover our administrative costs for any additional copy you may request.

‍The right to request us to delete your personal data ('right to be forgotten') (article 17 GDPR):

‍The right to rectification (article 16 GDPR):

If your personal data is incorrect, out of date or incomplete, you can ask us to correct these inaccuracies or incomplete information.

‍The right to data portability (article 20 GDPR):

‍The right to restriction of processing (article 18 GDPR):

If any of the following elements apply, you may request us to restrict the processing of your personal data:

You dispute the accuracy of those personal data (in this case, its use shall be limited for a period that allows us to verify the accuracy of the personal data);
The processing of your personal data is unlawful;
We no longer need your personal data for its purposes, but you need them in establishing, exercising or substantiating a legal claim;
As long as no decision has been taken on exercising your right to object to the processing, you may request that the use of your personal data be restricted.

‍The right to object (article 21 GDPR):

You can object to the processing of your personal data on the basis of your particular situation, if we process your personal data on the basis of legitimate interests or on the basis of a task of general interest. In this event, we shall cease the processing of your personal data, unless we can demonstrate compelling and legitimate grounds for processing which outweigh your own, or if the processing of the personal data is related to establishing, exercising or substantiating a legal claim.

‍The right not to be subject to automated decision-making (article 22 GDPR):

You cannot exercise this right in following three situations:

When automated decision-making is legally permitted (e.g. to prevent tax fraud);
When automated decision-making is based on your explicit consent; or
When automated decision-making is necessary for entering into, or performance of a contract (please note: we always endeavour to use less privacy-intrusive methods for entering into or performing the contract).

‍The right to withdraw your consent (article 7 GDPR):

If your personal data are processed on the basis of your consent, you may withdraw this consent at any time upon simple request.

‍The right to lodge a complaint with the supervisory authority (article 77, 1. GDPR)

In Belgium, the competent supervisory authority is the Data Protection Authority, with the following contact details:

Website: https://www.dataprotectionauthority.be

Contact details:

Data Protection Authority
Drukpersstraat 35, 1000 Brussels, Belgium

+32 (0)2 274 48 00 +32 (0)2 274 48 35 contact@apd-gba.be

‍Exercising your rights

To exercise these rights, you can contact us by using the contact details set out above.

In order toverify your identity when you wish to exercise these rights, we may ask you to send us a copy of the front side of your identity card. The national security number and the image on your electronic identity card shall not be retained by us. We strongly advise you to “blackline” the national security number and the image before transmitting a copy of your electronic identity card to us.