INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA
In the context of your use of the Start 2 Run app (in all countries except for The Netherlands), Hardlopen met Evy app (in The Netherlands) and the related websites owned by ENERGY NV, you will provide us with some personal details.
WHO PROCESSES YOUR DATA?
Your personal data will be processed by ENERGY NV, a company incorporated under Belgian law, with registered office at Schoebroekstraat 8, 3583 Beringen, registered at the Belgian Crossroads Bank for Enterprises under nr 0872.287.544, and with email address firstname.lastname@example.org, as data controller.
WHICH DATA DO WE PROCESS?
The details you enter:
- Your general personal details such as name, first name, date of birth, gender, chosen communication language,…;
- Your login and password when you create an account;
- Contact information such as e-mail, address,…;
- General physical characteristics such as weight,…;
2. Data generated by using the App:
- Health data or (calculated) data that can be related to physical condition such as heart rate at rest, maximum heart rate, BMI, …
- Activity data including distance, duration, speed, GPS location data and this as data throughout the time of your activity.
3. If you log in with Facebook, your Facebook ID and email address.
4. Information about your use of the website and the app (login details, time, browser used, device model, IP address, etc.) .
5. If you make purchases, the data related to these purchases.
PURPOSE OF THE PROCESSING OF YOUR PERSONAL DATA
We process your data to make the use of the App and/or website possible.
We also process your data to send you information that may be of interest to you.
More specifically, we use your data to:
|To allow you to use the app and the website, among other things to give you the opportunity to take part in the Start 2 Run program and to events, competitions, challenges, prize draws and to collect the prizes that you can win.||This is necessary for the use of the app and the website (article 6.1.b) GDPR)|
|To send you our newsletter if you have requested to receive this newsletter.||Your consent: you have registered for this in our app (institutions) (Article 6.1.a) GDPR).|
|To personalize your use of the website and the app;||This is necessary for the use of the app and the website (article 6.1.b) GDPR)|
|To communicate with you (for e.g. via push notifications in the Start 2 Run / Hardlopen met Evy app) about the evolution of your participation in the Start 2 Run program and about the program in general; this may include: communication about challenges and joint participation in events, as well as communication about other activities, workshops, etc. as part of the program (participation to some activities may be subject to specific conditions, including conditions regarding the way your personal data will be processed in the context of these activities: we advise you to read these conditions carefully).||This is necessary for the management of the program to which you participate (artikel 6.1.b) GDPR) and may also be necessary for our legitimate interests (article 6.1.f) GDPR) and more specifically to communicate about the program and participation in the program via the Start 2 Run website en to publicize the existence of the program within its organisation and to the outside world.|
|To use your pictures, audiovisual material and testimonies etc in the framework of the program and on the Start 2 Run / Hardlopen met Evy website, and for internal and external communication of Energy;||This is necessary for the management of the program to which you participate, and for the use of the app and the website (article 6.1.b) GDPR).|
|To manage our infrastructure and business policies, and comply with internal policies and procedures, including those regarding control, finance and accounting, billing and debt collection, IT systems, data and website hosting, business continuity, and management of archives, documents and prints; For example, when purchasing lessons packages, your data will be processed to make the purchase and delivery possible.||This is necessary for the use of the app and the website (article 6.1.b) GDPR) and may also be necessary for our legitimate interests (article 6.1.f) GDPR) and more specifically to (i) manage our infrastructures and (ii) monitor compliance with our internal policies as well as the security of our network.|
|To communicate with you regarding the activities of the program and to communicate with you if you send us messages and handling complaints and requests for access or correction of data;||This may be necessary for the management of the use of the website and the app (article 6.1.b) GDPR) but also for compliance with legal obligations (article 6.1.c) GDPR). This is also necessary for our legitimate interests: improving our services benefits everyone: both us and you (Article 6.1.f) GDPR).|
|To conduct market research and analysis, such as satisfaction surveys;||This is necessary for our legitimate interests: to know our services better and to improve them (Article 6.1.f) GDPR).|
|To comply with applicable laws and regulatory obligations (including regulations that are not those of the country where you live), such as laws relating to anti-money laundering and anti-terrorism; to comply with legal proceedings; to respond to requests from governments (including governments of countries other than the country where you live);||This may be necessary to comply with legal obligations (Article 6.1.c) GDPR).|
|To establish or defend our rights; to protect our activities or those of companies belonging to the same group or partners; to protect our (or your) rights, privacy, security or property, and / or those of the companies belonging to the same group; and to use the available remedies or limit our damage;||This may be necessary to comply with legal obligations (article 6.1.c) GDPR) or be necessary for our legitimate interests (article 6.1.f) GDPR) and more specifically to defend our rights in case of complaints or disputes with you or with third parties.|
|To provide you with important information regarding changes to our policies, terms and conditions, the website, mobile applications and other administrative information.||This may be necessary for the use of the website and the app (article 6.1.b) GDPR) but also for compliance with legal obligations (article 6.1.c) GDPR).|
SHARING OF PERSONAL DATA WITH THIRD PARTIES
ENERGY may, with your consent, transfer your personal data to the following addressees: other companies of the Golazo group. The Website and some components of ENERGY’s mobile applications are used to maintain contact and enable interaction between users.
In some cases, your information will be shared with third parties who provide services to us, or do so on our behalf (IT providers, cloud providers, etc.). Furthermore, ENERGY NV will not provide your information to other third parties without your prior permission unless we have a legitimate interest or are obliged to provide this information based on a statutory provision or court ruling. In any case, we commit to ensuring the confidentiality of your information, in particular by entering into suitable contracts with third parties.
ENERGY NV participates in Facebook’s Custom Audience programme that allows us to tune our ads to your use of our services, and to show you ads that are tailored to your interests if you are registered with Facebook and are logged into your Facebook account. To achieve this, we will share your email address in a hashed format that allows Facebook to identify you if you are registered with Facebook. You can change your ad preferences in your Facebook settings if you do not wish to receive ads tailored to your interests on Facebook.
ENERGY NV makes use of the services of TradeTracker.com. Their role is to help advertisers and publishers understand which advertisements displayed by publishers have generated which sales, leads or other actions for advertisers. This allows the advertiser to pay a publisher only when the advertisement displayed (or any alternative required action) by the publisher refers an individual to the advertiser and that individual makes a purchase. TradeTracker uses data, including cookies, to achieve this understanding. This data relates to individuals but does not identify them by name. It is pseudonymous data and relates to a single referral by an individual from one website to another, and then a confirmation that a purchase was made. TradeTracker also maintains a database of references to individual’s devices, so that we can understand whether an advertisement viewed on one device, for example a phone, caused a purchase to be made by that individual on one of their other devices, for example a laptop. This database does not allow people to be identified by name, which is not possible for TradeTracker itself to achieve. TradeTracker does not build profiles which show individuals internet purchase history over a period of time. TradeTracker also does not target individuals with advertisements for products and services based on their perceived interests. Their role is simply to measure the effectiveness of specific online advertisements.
PROCESSORS AND TRANSFERS TO COUNTRIES OUTSIDE THE EUROPEAN UNION
For the processing of your personal data we sometimes use third parties (e.g. hosting companies to store your data, or companies to send e-mails on our behalf). In so far as your data are forwarded to countries outside the European Union that do not provide an adequate level of protection to your data, we have ensured that the companies to which your data are forwarded offer an adequate level of protection. More specifically, we have concluded “Standard Contractual Clauses” (SCC) with them, or these companies are certified under the “Privacy Shield” program with the United States of America. For more information about these measures send an e-mail to email@example.com .
ENERGY will retain the Personal Information as long as necessary to achieve the purposes set out above unless a longer retention period (i) is required to cover our liability, or (ii) required by law or permitted.
YOUR RIGHTS TO YOUR PERSONAL DATA
You have the right to access and correct your personal data as well as the right to oppose to their use for direct marketing purposes, free of charge. You also have the right in certain circumstances to oppose to the use of it or to request the deletion of your personal data and the right to request a limitation of processing as well as the right to request the transfer of your data, as provided for in articles 15 to 20 of the GDPR (General Data Processing Regulation); you have also the right to revoke your consent to the processing of personal data relating to your health at any time (in which case you will not be able to use the app any longer).
If you want to exercise your rights, or if you have questions or comments, send an email to firstname.lastname@example.org.
Please note that certain personal info is excluded from the right to access, correction, destroy or Please note that some Personal Data may be excluded of the rights of access, rectification, objection, destruction or disposal, in accordance with applicable law.
If you are not satisfied with our processing of personal data and if you believe that contacting us will not solve the problem, the law gives you the right om to file a complaint with the competent supervisory authority.
Date : 6/12/2019