👨‍🏭Privacy policy

Privacy statement Cirklo

General

Cirklo is a gift card system that focuses on cities and municipalities. This digital solution allows citizens to purchase gift vouchers from their own city/municipality at the counter or in the webshop and to spend them in a network of local entrepreneurs, demarcated by the city or municipality. With Cirklo, Fairville gives the local economy a boost.

The Cirklo webshop is offered by Fairville NV, with registered office at Steenweg Deinze 154, 9810 Nazareth BE 0756.963.452, [email protected]

General Data Protection Regulation

In all cases, we will comply with applicable laws and regulations, including the General Data Protection Regulation of 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter "GDPR").

When you buy something from our webshop, we collect the personal information you give us, such as your name, address and email address. Fairville NV is therefore responsible for the processing of personal data. The processing of personal data includes any operation that may be carried out on this data, such as collection, recording, use or storage. In other words, Fairville NV always bears the final responsibility to you as a citizen.

Fairville NV will subsequently implement and apply internal technical and organizational policy measures to ensure that the processing meets the requirements of the GDPR and that your rights are always guaranteed. Such measures may include, among other things, minimising the processing of personal data, pseudonymising personal data as soon as possible, transparency regarding the functions and processing of personal data, enabling you to exercise control over the processing of information, etc.

Fairville NV can call on processors, such as service providers in software, IT, lawyers, etc.

What personal data is processed?

By default, personal data includes any information about you as an identified or identifiable individual. These are collected for the buyer during the purchase process in the webshop and for the merchant during the registration process in the application.

All data that Fairville NV collects can be combined with each other to better tailor our services and offers to your personal needs.

The following personal data are processed on behalf of the buyer who purchases a gift voucher on the webshop:

  • Name;

  • Email address;

  • Address;

  • Town;

  • Country/Region;

  • Zip code;

  • Data obtained through cookies, in accordance with our Cookie Policy;

  • Data related to your personal purchasing habits.

The following personal data are processed on behalf of the trader (natural person) who registers on the application:

  • Name;

  • Email address;

  • VAT number;

In accordance with the GDPR, we do not process sensitive data such as data about your racial or ethnic origin, political opinions or sexual preferences, among others.

What do we process your personal data for?

Fairville NV can process personal data for the following specific purposes:

  • The management of your customer file;

  • To get in touch with you;

  • Carrying out payment transactions;

  • The continuous improvement of our services, channels and processes;

  • The development of studies, models and statistics;

  • Preventing money laundering, fraud and terrorist financing;

  • Compliance with various legal provisions and tax obligations;

  • Answering well-founded questions from the judicial or supervisory authority to access the data;

  • Direct marketing.

However, only the data that is strictly necessary to achieve the purpose intended by the customer will be processed.

What is the legal basis for the processing of your personal data?

We only process your personal data in one of the following cases:

  • When we asked you for permission to do so and you gave it to us. You can withdraw this consent at any time. This withdrawal is only valid for the period after the withdrawal and therefore does not affect the lawfulness of the processing carried out up to the time of the withdrawal;

  • When we perform a contract or pre-contractual measure;

  • We are required by law or regulation;

  • On the basis of a "legitimate interest", in which we make a very thorough balance between the interest of the customer and your interest, including the protection of your privacy.

Legitimate interests include, for example:

  • The prevention of fraud and abuse;

  • The management of disputes;

  • The evaluation of the total customer relationship;

  • Offering products or services that are most closely possible to your needs and desires;

  • Improving processes and apps;

  • Direct marketing, such as:

    • Informing our customers about new products or services;

    • To create a profile of our customers;

    • To make personalized offers for our customers' birthdays;

    • Acquire new customers, subscribers, or members.

To whom can we transfer your personal data?

The personal data will not be exchanged, sold or communicated to other organisations in any way, unless:

  • You were informed of this and gave your explicit consent;

  • This is required for our services;

  • We are subject to a legal obligation;

  • There is a legitimate interest for the third party concerned.

If we use a company outside the European Economic Area in this context, we will only do so if we obtain guarantees of the same adequate level of protection with regard to your personal data as within Europe.

We may also use anonymous, aggregated data for commercial purposes or for internal and external reporting. After all, this data can never be traced back to a specific individual.

What are your rights when processing your personal data?

Your rights

You always have the right to access the personal data collected about you, and to exercise that right easily and at reasonable intervals, so that you can find out about the processing and check its lawfulness. This right must not, of course, affect the rights or freedoms of others, including business secrets or intellectual property, and in particular the copyright protecting the software.

You also have the right to withdraw your consent at any time. A withdrawal should be free of charge and without adverse consequences for you as a person. It must be possible to revoke it as easily as it was granted. All data processing based on this consent will of course be stopped. If there is no other legal basis for processing this data, the data will be deleted.

If your personal data is processed for the purpose of direct marketing, you have the right to object to this processing at any time free of charge. In this case, we will immediately stop processing personal data for direct marketing purposes.

You also have the right to have your personal data corrected. If your personal data is incorrect, incomplete or irrelevant, you can have it changed or supplemented. In certain cases, you also have the right to request a restriction of the processing of your data for a particular service and the right to object to the use of your data on the basis of legitimate interest.

You have the right to transfer personal data. Under certain conditions, you may have certain data that you have provided to us transferred to another controller or to yourself.

Finally, you have the right to have your personal data erased ("right to be forgotten") and not to have it further processed when the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, when you have withdrawn your consent or object to the processing of your personal data, or when the processing of your personal data is otherwise inconsistent with this Privacy Statement.

How can you exercise your rights?

The user can send an e-mail to [email protected] and send his/her request to: Fairville NV, Steenweg Deinze 154, 9810 Nazareth, Belgium.

If you do not agree with the position of Fairville NV, you have the right to lodge a complaint with the Belgian Data Protection Authority (privacycommission.be).

DPO contact details

You can contact our Data Protection Officer ("DPO") by writing to him at the following address: Fairville, for the attention of the DPO – Steenweg Deinze 154 – 9810 Nazareth or by sending an email to [email protected]

How long will your personal data be kept?

Your personal data will be stored for as long as necessary for the aforementioned purposes.

What if there are any changes to this privacy statement?

It goes without saying that the processing of personal data may evolve over time as a result of changed legislation, technical progress, etc. Fairville NV therefore reserves the right to amend this privacy policy in the future if necessary. When this happens, it will notify its users appropriately through the existing application.

Date of last modification : 25/11/2024

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