October 23, 2020

Kup

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Privacy Policy

PREFACE
Below you will find the privacy policy of the Kup Group (hereinafter “Kup” or “we”). This policy concerns the processing of data in connection with natural persons, namely personal data, on all websites, via all (mobile) apps and via all services of the different entities within the Kup Group. You can find a list of the different Kup Entities here .

This policy does not apply to the processing of legal entity data.

This privacy policy is without prejudice and should be read in conjunction with other applicable Kup Entities guidelines and terms:

Cookie Policy
Subscription Terms
Terms of use
Telephone competition regulations
Ad hoc competition rules
This policy is divided into four parts:

Definitions
The various controllers within the Kup Group
General information about the processing of personal data by all Kup Entities
Specific information about the processing of personal data by each Kup Entity

  1. DEFINITIONS
    It is inevitable to use a number of technical terms within this policy. That is why we give a brief overview of frequently used terms in this section.

Recommended Content : suggestions for articles, advertisements, job offers and other information that a Kup Entity tailors to the interests of a User (based on Click Behavior with his permission) or of a Registered User (based on Click Behavior with his permission, and of Registered Data).

Cookies : Text or other files and similar technologies that store or consult information on your computer, tablet, smartphone or other equipment with which you visit a Kup Domain. More information can be found in our Cookie Policy.

Service: access to news, offers, functionalities for a better user experience, (mobile) apps, Recommended Content or products that a Kup Entity sells, supplies or makes available on or via a Kup Domain. For an overview of the Services per Kup Domain, see this overview .

User : you who visit a Kup Domain to enjoy a Service as a consumer, without creating an account. This can be done directly via a Kup Domain or after installing one of our apps.

Registered User : you who register your personal data by creating an account on a Kup Domain.

Targeted Ads : Commercial information directed to a User or Registered User, tailored to their Click Behavior, provided they have given their consent.

Registered Data : personal data that a Registered User himself provides to a Kup Entity. These data may differ per Kup Domain, but usually contain: first name, last name, e-mail address, street, house number, zip code, city, gender, date of birth, desired newsletters. If you wish, you can also provide your telephone and / or mobile number.

Click Behavior : the interests of a User or Registered User that, subject to his / her consent, are derived from the use of a Service or from visiting or interacting with third party websites. Click behavior mainly contains:
(i) session data, ie operating system, device type, browser type, etc. This is necessary to provide you with a good user experience.
(ii) pages visited where we divide you into areas of interest. We do this by adding keywords to certain sections or articles so that we can show you Recommended Content and Targeted Ads (e.g. sports, lifestyle, car enthusiast).

Kup Domain: a website or (mobile) application offered or operated by a Kup Entity.

Kup Groep: the entirety of the Kup Entities.

Kup Entity: the legal entity within the Kup Group that offers / supplies a Service – the various Kup Entities can be found in this overview .

  1. THE DIFFERENT PROCESSING RESPONSIBILITIES WITHIN THE Kup GROUP
    Each Kup Entity acts as the controller of your personal data if it sells, supplies or makes available to you its respective Service.

View here the overview of the different Kup Entities per Service or Kup Domain.

  1. GENERAL INFORMATION ON THE PROCESSING OF PERSONAL DATA BY ALL Kup ENTITIES
    3.1 What are the purposes and legal grounds for the processing of your personal data?

Each Kup Entity processes personal data for specific purposes. The Kup Entity always does this on the basis of a processing ground as required by law. This is a legal basis that allows you to use personal data. Examples of processing grounds are: consent, performance of an agreement, legal obligation and legitimate interest.

The purposes and legal grounds for the processing of your personal data differ depending on the Service. More information about the applicable purposes and legal grounds can be found in Part 4 – Specific information about the processing of personal data by each Kup Entity.

3.2 How does a Kup Entity receive your personal data?

Each Kup Entity primarily processes your personal data because you provide it yourself in the context of the provision of a Service.

Furthermore, a Kup Entity also receives personal data from other sources:

Each Kup Entity that has your personal data can also receive personal data about you from another Kup Entity,
Public sources, such as official government publications (eg Belgian Official Gazette, KBO),
Bisnode Belgium NV in the context of the purchase of business contact details and the unique identification, validation and linking of your personal data,
Advertisers,
Social media (see more information in point 3.8),
Partners with which a Kup Entity collaborates to classify you into target groups for Targeted Ads based on your Registered Data and your Click Behavior on a Kup Domain and on websites of these partners. We only do this based on your permission.
3.3 How can you contact the data protection officer (DPO)?

A data protection officer (DPO) has been appointed for all processing operations by a Kup Entity.

You can always contact them with questions or complaints regarding any processing of personal data by a Kup Entity. To contact the DPO, click here.

3.4 Who receives your personal data?

Every Kup Entity can pass on your personal data to:

subcontractors who work on its behalf and on its behalf (processors),
its employees in the performance of their duties,
another Kup Entity,
persons who are interested in an advertisement you place (eg vroom.be, zimmo.be, jobat.be),
advertising partners and advertisers for showing Targeted Ads, if you have consented thereto,
social media through which you log in to or interact with our Services,
Bisnode Belgium NV in the context of the unique identification, validation and linking of personal data (see below),
commercial partners of a Kup Entity, if you have agreed to this,
third parties in the context of discussions, investigations, evaluations, negotiations and executive measures in connection with a cooperation or corporate law transaction (acquisition, merger, sale of shares or assets, joint venture, etc.) and to the relevant professional advisers of the parties involved (lawyers, consultants etc.),
judicial, police or administrative authorities if required by law or circumstances,
Partners with which a Kup Entity collaborates to classify you as target groups for Targeted Ads based on your Registered Data and your Click Behavior on a Kup Domain and on websites of these partners. We only do this based on your permission.
Kup ensures that these recipients only have access to personal data that are relevant, adequate and necessary for processing.

For some processing operations, there are specific recipients of your personal data, these are listed below in Part 4 – Specific information about the processing of personal data by each Kup Entity.

In order to improve the quality of data files of other companies, Kup provides a limited set of personal data about you to an external party, in particular Bisnode Belgium NV, Researchdreef 65, 1070 Brussels. Bisnode uses the personal data it receives from Kup to validate, uniquely identify and / or link information about you that is already stored in the files of other companies. Bisnode does not transfer the personal data that it receives from Kup to these other companies. Your data will only be used to validate, uniquely identify and / or link data about you that is already in the possession of other parties. For more information about the processing of personal data by Bisnode Belgium, see www.bisnodeenu.be .

3.5 Does a Kup Entity share your personal data with countries outside the European Economic Area?

The European Economic Area (EEA) includes the countries of the European Union and Norway, Liechtenstein and Iceland. European law requires additional safeguards when a Kup Entity transfers personal data to other countries located outside the EEA. To ensure that these countries have the same level of protection for your personal data, the European legislator imposes appropriate guarantees on data controllers.

For certain processing operations, a Kup Entity will pass on your personal data to recipients outside the European Economic Area. In such a case, the Kup Entity will ensure that the transfer is covered by appropriate safeguards, including an adequacy decision by the European Commission, the model provisions of the European Commission or EU-US privacy shield.

You can always consult the data protection officer (DPO) to view the appropriate safeguards provided by the Kup Entity.

3.6 What rights do you have as a data subject?

Under the conditions, restrictions and modalities provided by the applicable law, you can contact Kup to exercise the following rights:

You have the right to inspect your personal data. This allows you to check which personal data a Kup Entity processes.
You have the right to have your personal data corrected . This allows you to correct or supplement incorrect or incomplete personal data that a Kup Entity processes.
You have the right to erase your personal data. This allows you to permanently delete personal data that a Kup Entity processes. A Kup Entity is not always obliged to delete your personal data at your request – this right only applies in the cases and to the extent provided by law.
You have the right to restrict the processing of personal data relating to you. This allows you to freeze the use of your personal data by a Kup Entity, without deleting it. A Kup Entity is not always obliged to limit your personal data at your request – this right only applies in the cases and to the extent provided by law.
You have a right to object . This allows you to object to the further processing by a Kup Entity of your personal data. A Kup Entity is not always obliged to comply with your objection.
You have the right to withdraw your consent at any time when the processing of your personal data takes place on the basis of your consent.
You always have the right to object to the processing of your personal data for direct marketing purposes .
You have a right to data portability . This makes it possible to move, copy or forward personal data smoothly from one controller to another. This right can only be exercised if the processing is based on your consent or on an agreement with you.
For all processing operations included in this privacy policy, you can exercise all your rights by contacting the DPO. To contact the DPO, click here.

3.7 Do you wish to file a complaint with the supervisory authority?

You have the right to file a complaint with the supervisory authority:

If you use or visit a Service through your social media account (e.g. log in via your facebook account) or interact on our social media channels or via buttons or other techniques, the Kup Entity can extract data that is shared publicly via the social networking site such as public profile information, list of friends, your use of social networking sites, and your email address.

The use of or interaction with social media is subject to the rules of the social media channel – no Kup Entity has any influence over this. Consult the terms of use and the privacy policy of the relevant social media network to understand how the network handles your personal data.

  1. SPECIFIC INFORMATION ON THE PROCESSING OF PERSONAL DATA BY EACH Kup ENTITY
    Below you can find out what the different processing operations are within each Kup Entity. Each of the processing below takes place at each Kup Entity, unless indicated otherwise.

For more general information about this processing (who is the controller, what are the contact details of the data protection officer and supervisory authority, who are the recipients of your personal data, what are your rights, Kup shares your personal data with countries outside the EEA, etc.) , see Part 3 – General information about the processing of personal data by the different Kup Entities .

4.1 You contact us for a question, request for information or complaint

When you contact a Kup Entity for a question, request for information or complaint, that Kup Entity processes your personal data on the basis of its legitimate interest in answering or helping you.

Each Kup Entity keeps your personal data for a maximum of 10 years after your question, request for information or answering your complaint has been completed.

4.2 You participate in market research or surveys

When you participate in a survey or market research, the Kup Entity concerned processes your personal data based on your permission. You always have the right to withdraw your consent.

Every Kup Entity that conducts market research or surveys keeps your personal data for a maximum of 3 years after the end of the research / survey.

4.3 You are a contact person of a business customer for one of the Services (B2B)

When a Kup Entity provides a Service to a business customer (B2B), it processes your personal data in the context of its customer management on the basis of the need to take pre-contractual measures (order intake, follow-up prospects, etc.), to complete the agreement. (account creation, management, delivery, billing, collection, etc.) and based on its legitimate interest (invitation to participate in survey or market research, direct marketing, etc.).

Each Kup Entity that processes your personal data in the context of its customer management, keeps your personal data for a maximum of 10 years after the end of the customer relationship.

4.4 You are a customer-consumer for one of the Services (B2C)

When a Kup Entity provides you with a Service, it processes your personal data

In the context of its customer management based on the need to take pre-contractual measures (order intake, follow-up of shopping cart abandonment, etc.) and / or the need to execute the agreement (creation and management account, provision of a Service, invoicing , recovery, etc.)
For sending invitations to participate in surveys or market research as well as for direct marketing based on its legitimate interest.
If you use a Service, the concerned Kup Entity will also collect and use your Click Behavior under the following conditions and modalities for:

Analysis and improvement of
the Service that you purchase based on the legitimate interest of Kup. This allows us to improve the digital news experience on Kup domains for all users.
the different Services across Kup Entities, whether or not via the same device, based on your permission. This allows us to better map the combined use of Services.
Recommended Content : If you consent to this through your privacy preferences in your account, we may recommend articles or other content that are more relevant to your interests and that you have not yet read. For this, the Kup Entity involved draws up a profile so that it knows your preferences.
Targeted Ads : If you give permission, online advertisers can show ads that are tailored to your interests using cookies and similar technologies. More information can be found in the Cookies policy.
Every Kup Entity that processes your personal data in the context of pre-contractual measures and / or customer management, keeps your personal data for a maximum of 10 years after the end of the customer relationship. The use of Click Behavior is subject to a maximum period of 3 years after receipt.

You can enjoy our Services as soon as you visit a Kup Domain or after installing one of our apps (User). If you choose to create an account with a Kup Domain, you will become a Registered User and our Services are more extensive than these for Users. If you are a subscriber, you can also read the “plus” articles marked with (+) on the newspaper sites.

What Kup entity that offers service through which Kup Domain, you can find here .

4.5 You use Jobat as a job seeker

If you use Jobat as a job seeker, House of Recruitment Solutions BV processes your personal data for job placement (matching your profile as a job seeker with vacancies from employers) on the basis of:

the execution of the agreement with you (CV upload, sharing of value fit, etc.),
your permission (registration job event, sending job-related e-mails, displaying relevant vacancies on Jobat and the job vacancy partners domains of Jobat),
its legitimate interest (possibility for employers to comment on CVs),
the law (decree of 10 December 2010 on private employment services).
You always have the right to withdraw your consent.

In addition to the recipients mentioned in Part 3 – General information about the processing of personal data by the different Kup Entities , Kup NV shares your personal data with employers who purchase a Jobat service, but only to the extent that you allow this.

Kup keeps your personal data for a maximum of 10 years after inactivity or closing your Jobat account.

4.6 You participate in a competition or promotional action

When you participate in a competition or a promotional action of a Kup Entity, this entity processes your personal data for the management of the competition / promotion and the indication of the winner based on the agreement with you. The processing of your personal data is necessary to ensure that the competition or action runs smoothly and to contact the winners to hand over the prize.

Participation in a competition or promotional action may also be subject to competition rules or promotional conditions.

Each Kup Entity that processes your personal data for the management of the competition / promotion and the designation of the winner, keeps your personal data for a maximum of 10 years after the end of the competition or promotion.

4.7 You receive commercial information about Services from a Kup Entity

When you receive commercial information about Services from a Kup Entity, that entity processes your personal data for direct marketing purposes based on:

your consent, if the commercial information is based on Click Behavior or
its legitimate interest (if you have a relationship with that Kup Entity, eg you are a customer or partner, you participate in a competition or promotional action or you purchase a Service).
You always have the right to withdraw your consent.

You have the right to object at any time to the further receipt of commercial information about Services of a Kup Entity. You can exercise this right by changing the settings of your account or by contacting the Kup Entity from whom you receive this information, see here an overview of all Kup Entities .

Every Kup Entity that processes your personal data for direct marketing purposes, keeps this data for a maximum of 10 years after the end of the relationship with Kup.

4.8 You will receive information about products or services from partners of a Kup Entity

When you receive commercial information about products or services from a partner of a Kup Entity, that entity processes your personal data for direct marketing purposes based on your consent. You always have the right to withdraw your consent.

You have the right to object at any time to the further receipt of information about products and services from the partners of Kup. You can exercise this right by changing the settings of your account or by contacting the relevant Kup Entity, see here the overview of the Kup Entities .

Each Kup Entity that processes your personal data for direct marketing purposes keeps this data for a maximum of 3 years after the last receipt of commercial information from Kup partners.

4.9 You are visiting a Kup Entity

If you are a visitor to a Kup Entity, each Kup Entity processes your personal data in the context of visitor management on the basis of its legitimate interests (eg guided tour for schools, meeting with Kup contact person, inspection archive, etc.).

Each Kup Entity keeps your personal data up to 1 year after your last visit.

4.10 You are a supplier of a Kup Entity

If you supply products or services to a Kup Entity, that Kup Entity will process your personal data in the context of its supplier management on the basis of the need to perform the agreement with you.

Kup keeps your personal data for a maximum of 10 years after the last delivery.

4.11 You are applying for a job at a Kup Entity

If you apply for a job at one of the Kup Entities, that Kup Entity will process your personal data for:

The management and evaluation of the job applications in the context of the pre-contractual relationship,
Maintaining the recruitment reserve based on its legitimate interest.
Each Kup Entity keeps your personal data for a maximum of 5 years after the application procedure has ended.

4.12 In any case

If a Kup Entity processes your personal data for one of the aforementioned purposes, that entity also processes your personal data for:

detecting, preventing and combating fraud and abuse based on its legitimate interest. Less fraud and abuse benefits the Kup Entity, its customers and its suppliers. This includes, in certain cases, the use of Google’s reCAPTCHA service to prevent misuse by automated data entry. Google keeps the personal data necessary for this service, such as your IP address.
dispute management based on its legitimate interest, because Kup must be able to safeguard and defend its rights,
The conversations, investigations, evaluations, negotiations and executive measures in connection with a cooperation or corporate law transaction (takeover, merger, sale of shares or assets, joint venture, etc.) by a Kup Entity.

Each Kup Entity keeps your personal data for a maximum of 10 years after your personal data are inactive.