Privacy Policy

PRIVACY POLICY OF THE MEDIAHUIS GROUP

Version 2.0 modified on 1 October 2019

INTRODUCTION

Below you will find the privacy policy of the Mediahuis Group (hereinafter “Mediahuis” or “we”). This policy concerns the processing of personal data relating to natural persons, i.e. personal data on all websites, through all (mobile) apps and all services of the different entities within the Mediahuis Group. A list of the different Mediahuis Entities can be found here.

This policy is not applicable to the processing of personal data relating to legal persons.

This privacy policy does not affect, and should be read together with, the other applicable policies and agreements of the Entities of the Mediahuis:

This policy is divided into four parts:

  • Definitions
  • The different controllers within the Mediahuis Group
  • General information regarding the processing of personal data by all entities within the Mediahuis Group
  • Specific information regarding the processing of personal data by each entity within het Mediahuis Group

1. DEFINITIONS

Within this policy, it is necessary to use a number of technical terms. That is why we provide a brief overview of the definitions and frequently used terms in this section.

Recommended Content: suggestions for articles, advertisements, job offers and other information that a Mediahuis Entity attunes to the interests of a User (on the basis of Clicking Behaviour with his consent) or of a Registered User (on the basis of Clicking Behaviour with his consent, and of Registered Data).

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

Service: access to news, promotions, functionalities for a better User experience, (mobile) apps, recommended content or products that a Mediahuis Entity sells, provides or makes available on or through a Mediahuis Domain. Click here for an overview of the Services per Mediahuis Domain.

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

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

Targeted Advertisements: commercial information that is addressed to a User or Registered User, is tailored to his Click Behaviour, provided that he has given his consent.

Registered Data: personal data that a Registered User himself provides to a Mediahuis Entity. This information may vary by Mediahuis Domain, but usually includes: first name, surname, e-mail address, street, house number, postal code, city, gender, date of birth and/or desired newsletters. If you want to, you can also enter your phone and/or mobile number.

Click Behaviour: the interests of a User or Registered User who, with his/her consent, are derived from the use of a Service or from visiting or interacting with third party websites. Clicking behavior mainly includes:

(i) session data, i.e. operating system, device type, browser type, etc. This is necessary to provide you with a good User experience.
(ii) pages visited where we classify you according to areas of interest. We do this by adding keywords to certain sections or articles so that we can show you Recommended Content and Targeted Advertisements (e.g. sports, lifestyle, car enthusiast).

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

Mediahuis Group: the whole of Mediahuis Entities.

Mediahuis Entity: the legal person within the Mediahuis Group who offers/supplies a Service – the different Mediahuis Entities are to be found in this overview.

2. THE DIFFERENT CONTROLLERS WITHIN THE MEDIAHUIS GROUP

Each entity acts as a controller of your personal data if they sell, provide or make available their respective Service to you.

Click here for an overview of the different Mediahuis Entities per Service or Mediahuis Domain.

3.GENERAL INFORMATION REGARDING THE PROCESSING OF PERSONAL DATA BY ALL MEDIAHUIS ENTITIES

3.1 What are the purposes and legal basis for the processing of your personal data?

Each Mediahuis Entity processes personal data for specific purposes. The Mediahuis Entity always acts on the basis of a processing ground as is required by law. This is a legal basis which allows  the use of personal data. Examples of processing grounds are: consent, execution of an agreement, legal obligation and legitimate interest.

The purposes and legal basis for the processing of your personal data differ depending upon 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 Mediahuis Entity.

3.2 How does a Mediahuis Entity receive your personal data?

Each Mediahuis Entity processes your personal data in the first place because you pass them on yourself in the context of the provision of a Service.

A Mediahuis Entity further receives personal data from other sources:

  • Each Mediahuis Entity that processes your personal data, may also receive your personal data from another Mediahuis Entity,
  • Public sources, such as official government publications (e.g. Belgian Official Gazette, KBO),
  • Bisnode Belgium NV within the framework of the purchase of business contact details and of the unique identification, validation and linking of your personal data,
  • Advertisers,
  • Social media (see section 3.8 for more information thereon),
  • Partners with whom a Mediahuis Entity collaborates to divide you into target groups for Targeted Advertisements based on your Registered Data and your Click Behaviour on a Mediahuis Domain and on the websites of these partners. We only do this on the basis of 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 carried out by a Mediahuis Entity.

You can always contact him with questions or complaints in connection with any processing of personal data by a Mediahuis Entity. To contact the DPO, click here.

3.4 Who receives your personal data?

Each Mediahuis Entity may transfer your personal data to:

  • subcontractors who work on its behalf and its account (processors),
  • its employees in the context of the exercise of their function,
  • another Mediahuis Entity,
  • persons that are interested in an advertisement that you placed (e.g. vroom.be, zimmo.be, jobat.be),
  • advertising partners and advertisers for displaying Targeted Advertisements, if you have consented to this,
  • social media through which you log on to or interact with our Services,

Bisnode Belgium NV within the framework of the unique identification, validation and linking of personal data (see below),

  • commercial partners of a Mediahuis Entity, if you have consented thereto,
  • third parties in the context of discussions, investigations, evaluations, negotiations and executive measures in connection with a cooperation or corporate transaction (acquisition, merger, sale of shares or assets, joint venture, etc.) and with the professional advisors of the parties concerned (lawyers, consultants, etc.),
  • judicial, police or administrative authorities if required by the law or circumstances,
  • Partners with whom a Mediahuis Entity collaborates to divide you into target groups for Targeted Advertisements based on your Registered Data and your Click Behaviour on a Mediahuis Domain and on the websites of these partners. We only do this on the basis of your permission.

Mediahuis ensures that these recipients only have access to personal data that are relevant, adequate and necessary for the processing.

For certain processing, there are specific recipients of your personal data, those are each time listed below in Part 4 – Specific information about the processing of personal data by each Mediahuis Entity.

In order to improve the quality of databases of other companies, Mediahuis provides a limited set of personal data about you to an external party, namely Bisnode Belgium NV, Researchdreef 65, 1070 Brussels. Bisnode uses the personal data it receives from Mediahuis to validate, uniquely identify, link, correct and/or enrich information about you that is already stored in the files of other companies. Bisnode does not transfer the personal data it receives from Mediahuis to these other companies. Your data will only be used to validate, uniquely identify, link, correct and/or enrich data about you that are 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 the Mediahuis Group transfer your personal data to countries outside the European Economic Area?

The European Economic Area (EEA) includes all countries of the European Union and Norway, Liechtenstein and Iceland. The European legislation requires additional safeguards if a Mediahuis Entity transfers personal data to other countries situated outside the EEA. The European legislator imposes appropriate safeguards to controllers to assure that such countries maintain the same level of protection with regard to your personal data.

A Mediahuis Entity shall transfer your personal data to recipients outside the European Economic Area for certain processing. In such a case, the Mediahuis Entity shall warrant that the transfer is covered by the appropriate safeguards, including an adequacy decision of the European Commission, the Model Clauses of the European Commission or the EU-US privacy shield.

You may always consult the data protection officer (DPO) to have access to the appropriate safeguards provided by the Mediahuis Entity.

3.6 Which rights do you have as data subject?

Subject to the terms, limitations and conditions provided for by the applicable law, you may always contact Mediahuis for the exercise of the following rights:

  • You have a right of access to your personal data. This allows you to verify which personal data a Mediahuis Entity processes.
  • You always have the right to have your personal data corrected. This allows you to rectify or correct, inaccurate or incorrect personal data a Mediahuis Entity processes.
  • You have the right to have your personal data erased. This allows you to permanently delete personal data which a Mediahuis Entity processes. A Mediahuis Entity is not always obliged to delete your personal data at your request – this right only applies in the situations and to the extent provided for by law.
  • You have the right to limit the processing of personal data related to you. This allows you to freeze the use of your personal data by a Mediahuis Entity, without deleting it. A Mediahuis Entity is not always obliged to limit your personal data at your request – this right only applies in the situations and to the extent provided for by law.
  • You have the right to object to a processing of your personal data. This allows you to object to the further processing operations by a Mediahuis Entity of your personal data. A Mediahuis Entity is not always obliged to uphold your objection.
  • You always have the right to withdraw your consent whenever 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 the right to data portability. This allows you to easily move, copy or transfer your personal data from one controller to another. This right may only be exercised whenever the processing takes place on the basis of an agreement with you.

For all processing operations mentioned in this privacy policy, you may exercise your rights by contacting the DPO. Click here to contact the DPO.

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

You are entitled to file a complaint by the supervising authority:

3.8 Interaction through social media

If you use one of the Services of a Mediahuis Entity or visit them through your account on social media (e.g. login through your facebook account) or interact on our social media channels or through buttons or other techniques, the Mediahuis Entity may seize personal data hereof which is publicly shared through the website of the social network such as information on the public profile, list of friends, your use of social network sites, and your e-mail address.

The use of or interaction with social media is subject to the social media channel’s own rules – no Mediahuis Entity has any influence on this. Consult the user terms and the privacy policy of the concerned social media network to understand how such networks deal with your personal data.

4. SPECIFIC INFORMATION REGARDING THE PROCESSING OF PERSONAL DATA BY EACH ENTITY OF THE MEDIAHUIS

Below you can verify the different processing operations within the Mediahuis Entitiy. Each of the following processing operations takes place at each Mediahuis Entity, unless otherwise indicated.

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

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

If you contact an Entity of the Mediahuis for a question, a request for information or a complaint, the Mediahuis Entity processes your personal data on the basis of its legitimate interest to answer or help you.

Each Mediahuis Entity will retain your personal data for a maximum of 10 years after your question, request for information or response to your complaint has been completed.

4.2 You take part in a market research or surveys

When you participate in a survey or market research, the Mediahuis Entity concerned processes your personal data on the basis of your consent. You are always entitled to withdraw your consent.

Each Mediahuis Entity that carries out market research or surveys keeps your personal data for a term of maximum 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 Mediahuis Entity provides a Service to a business customer (B2B), it processes your personal data as part of its customer management based on the need to take pre-contractual measures (recording of orders, follow-up of prospects, etc.), to execute the agreement (creation and management of the account, delivery, invoicing, collection, etc.) and based on its legitimate interest (invitation to participate in surveys or market research, direct marketing, etc.).

Each Mediahuis Entity which processes your personal data in the context of its client administration keeps your personal data for a term of maximum 10 years after the end of the client relation.

4.4 You are a User of one of the Services (B2C)

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

  • In the context of its client administration based on the need to take pre-contractual measures (recording of orders, follow-up of abandoned shopping cart, etc.) and/or the need to execute the agreement (creation and management of an account, provision of a Service, invoicing, collection, etc.)
  • For sending out invitations to participate in surveys or market research as well as for direct marketing on the basis of its justified interest.

If you use a Service, the Mediahuis Entity concerned will also collect and use your Clicking Behaviour under the following terms and conditions:

  • Analysis and improvement of:
  • the Service you purchase on the basis of the legitimate interest of Mediahuis. This allows us to improve the digital news experience on Mediahuis domains for all Users.
  • the various Services across Mediahuis Entities, whether or not via the same device, on the basis of your permission. This allows us to better map out the combined use of Services.
  • Recommended Content: if you give your consent via your privacy preferences in your account, we can recommend articles or other content that is more in line with your interests and that you have not yet read. To this end, the Mediahuis Entity concerned will draw up a profile so that it knows your preferences.
  • Targeted Advertisements: if you give your permission, online advertisers can display advertisements that are tailored to your interests using cookies and similar technologies. More information can be found in the Cookies policy.

Each Mediahuis Entity that processes your personal data within the framework of pre-contractual measures and/or client management, keeps your personal data up to a maximum of 10 years after the end of the client relationship. The use of Click Behaviour is subject to a maximum period of 3 years after receipt.

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

Here you can find out which Mediahuis Entity offers which Service via which Mediahuis Domain.

4.5 You use Jobat as a jobseeker

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

  • the executing of an agreement with you (CV upload, sharing value fit, etc.),
  • your approval (subscription job event, sending job related e-mails, displaying relevant vacancies on Jobat and on Jobat’s domain vacancy partners),
  • its legitimate interest (possibility for employers to provide comments to CV’s)
  • the law (decree of 10 December 2010 regarding private labour placement).

You are always entitled to withdraw your consent.

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

Mediahuis NV will keep your personal data for a maximum of 10 years after your Jobat account has been inactive or closed.

4.6 You participate in a competition or promotional action

If you participate in a competition or promotional action of a Mediahuis Entity, such entity processes your personal data for the management of the competition/action and the designation of the winner on the basis of the contract with you. The processing of your personal data is necessary to manage the competition or action and to contact the winners to hand over the price.

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

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

4.7 You receive commercial information about Services of a Mediahuis Entity

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

  • your consent, if the commercial information is based on Click Behaviour or
  • its legitimate interest (if you have a relationship with this Mediahuis Entity, e.g. you are a customer or a partner, or you participate in a competition or promotional action or you take a Service).

You have always the right to withdraw your consent.

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

Each Mediahuis Entity that processes your personal data for marketing purposes keeps the data for a term of maximum 10 years after the end of the relationship with Mediahuis.

4.8 You receive commercial information about products or services from partners of a Mediahuis Entity

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

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

Each Mediahuis Enitity that processes your personal data for direct marketing purposes, keeps the data for a term of maximum 3 years after the last receipt of commercial information from partners of Mediahuis.

4.9 You are visiting Mediahuis Entity

If you are a visitor of a Mediahuis Entity, each Mediahuis entity processes your personal data, in the context of visitor management based on its legitimate interests (e.g. guided tour for schools, a meeting with a Mediahuis business contact, inspection of the archive, etc.).

Each Mediahuis Entity keeps your personal data for a term of maximum 1 year after your last visit.

4.10 You are a supplier of a Mediahuis Entity

If you supply products or services to a Mediahuis Entity, this Mediahuis Entity processes your personal data in the context of supplier management based on the necessity to perform the agreement with you.

Mediahuis keeps your personal data for a term of maximum 10 years as of the last delivery.

4.11 You apply for a job at a Mediahuis Entity

If you apply for a job at one of the Mediahuis Entities, this Mediahuis Entity processes your personal data for:

  • The management and evaluation of the job applications in the context of a pre-contractual relationship,
  • Maintaining a recruitment reserve list based on its legitimate interest.

Each Mediahuis Entity keeps your personal data for a term of maximum 5 years after the application procedure has been completed.

4.12 In any case

If a Mediahuis Entity processes your personal data for one of the aforementioned purposes, that entity processes your personal data as well for:

  • The detection, prevention of and fight against fraud and abuse based on its legitimate interest. Less fraud and abuse benefits the Mediahuis 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 will keep track of the personal data required for this service, such as your IP address,
  • dispute management based on its legitimate interest, as Mediahuis must be able to safeguard and defend its rights,
  • the discussions, investigations, evaluations, negotiations and implementing measures in connection with a cooperation or corporate transaction (acquisition, merger, sale of shares or assets, joint venture, etc.) by a Mediahuis Entity.

Each Mediahuis Entity keeps your personal data for a term of maximum 10 years after your personal data became inactive.