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PRIVACY NOTICE
1. INTRO
At Proximus we are committed to protecting the privacy of our customers and
users. We recognize that the personal data you entrust to us is valuable and
important to you, and we take our responsibility to safeguard your data very
seriously.
In this privacy notice, we will provide you with detailed information about the
personal data we collect about you, what happens with your personal data if you
use our services and apps and/or visit our different websites, for what purposes
your personal data are used, and with whom your personal data are shared. You
can also find out how you can control our use of your personal data. We will
also explain your rights regarding your personal data, and how you can exercise
these rights. To make the notice more readable, we have divided the different
topics into chapters, which are easy to consult using the selection menu.
In addition to complying with relevant data protection laws and regulations, we
are committed to upholding the highest ethical and moral standards in our
handling of personal data. We believe that privacy is a fundamental human right,
and that it is our duty to protect and respect your personal information.
2. Who are we?
The personal data we collect and use are stored in the files held by Proximus
PLC under Belgian Public Law (Boulevard du Roi Albert II 27, 1030 Brussels).
3. Who is in scope of this Privacy Notice?
With this privacy notice, we want to inform any natural person (not legal
persons nor companies) whose personal data we process in the context of the
provision about how we process their personal data.
Hence, this privacy notice aims at informing the following categories of
individuals, it being noted that the notice will be more relevant for certain
categories of individuals than for others:
* Our customers, both residential and professional, and persons who have
created a MyProximus account;
* Our ex-customers;
* Potential future customers (i.e. prospects);
* The customers of any subsidiary of the Proximus Group;
* The individuals using our services and products (e.g. family members of our
customers, employees of our professional customers who use our services);
* The individuals using the service or product of another Belgian or foreign
telecom operator that is currently using our network;
* The contact persons and representatives of our professional customers (e.g.
employees of our professional customers);
* The contact persons of our residential customers and users of our products
(e.g. relatives, guardians, judicial representatives that can legally
represent these individuals);
* The contact persons of other third parties such as suppliers and partners
that supply goods or services to us, indirect sales channels and
subcontractors;
* Visitors of our offices, premises or shops;
* Visitors of our websites and users of our mobile applications;
* Participants in competitions, campaigns, surveys, webinars, events, etc.
As a Proximus customer, it may happen that you allow family members, friends,
visitors and employees to use our products and services. An example is giving
them access to your Wi-Fi. This will mean that we process some of their data,
and this processing is therefore subject to this privacy notice. We have no
relationship with them, and therefore cannot notify them of this. We count on
you, as a customer, to take your responsibility and inform them about this.
4. What personal data do we collect and how long do we keep it?
This section provides an explanation of the categories of personal data that are
processed by us and the data elements that fall under each of the categories of
personal data. You can find more detailed information on what categories of
personal data are used for the different purposes in sections 6 and 7 of this
Privacy Notice.
4.1. Collected data (information you provide to us)
If you want to use our services and products, we need to collect some of your
personal information. The personal data collected may vary depending on the
situation in which they are collected. For example, we might collect your first
and last name, address, login, email address, phone number, mobile phone number,
date of birth, language or details of your identity document, which generally
allow us to uniquely identify you. Depending on the reason why we are in
contact, we might need additional information from you, such as specific
preferences and requirements related to the service in question.
We may collect your personal information in a variety of ways. When visiting us
in one of the Proximus points of sale or when browsing to the Proximus webshop,
we can collect personal data from you via the electronic reading of your
identity document or via the itsme app. Personal data can also be collected
verbally in the Proximus points of sale, by phone via customer service, in
writing via order forms, e-mail or text message, digitally via e-forms or when
you chat with our chatbot or via our website, via MyProximus Web and MyProximus
in the Proximus+ App and other Proximus apps or when you use social media to
contact us.
From the moment you become a Proximus customer, each subsequent customer contact
(e.g. when you place an order, participate in a survey, test or competition,
call our customer service, register for a newsletter,…) comes with the
collection and processing of personal data. Depending on the situation, Proximus
will collect the following categories of personal data from you:
* Identification and contact information: Information allowing us to uniquely
identify you and to contact you (first and last name, shipping/postal
address, e-mail address, (mobile) telephone number, VAT number, pseudonym
used online, easy switch ID, official identifier other than the national
registry number,…);
* National registry number: The national registry number of a customer;
* Profession information: Information relating to your profession and your
employer or the company you represent;
* Personal characteristics: Information relating to specific characteristics
and/or attributes (age, sex, birth date, place of birth, nationality,
language,…);
* Family and household composition: Data revealing a customer’s family and/or
household composition (number of children, marital status, number of
housemates, dependant persons, name of partner,…);
* IT and telecom product and service subscription information: Information
relating to the products or services that a person has subscribed to
(customer install base, list of IT and telecom services to which a person has
subscribed to, list of IT and telecom products that a person bought,…);
* Financial data: Information relating to a customer’s financial ‘credentials’
(bank account number, credit card information,…);
* Customer interactions: Any records of customer’s interaction with Proximus
(website visits, shop visits, orders, content of shopping basket, servicing
tickets…);
* Survey specific information: Information based on the questions asked in
surveys (brand image questions, customer needs questions, consumer behaviour
questions,…).
4.2. Obtained data (information we obtain from third parties)
We use personal data that is obtained from third parties, such as partners who
provide us with identification and contact data of prospects. You can find more
detailed information on how these data are used in sections 6 and 7 of this
Privacy Notice.
* Identification and contact information: Information allowing us to uniquely
identify you and to contact you (first and last name, shipping/postal
address, e-mail address, (mobile) telephone number, VAT number, pseudonym
used online, easy switch ID, official state-issued identifier other than the
national registry number,…);
* Personal characteristics: Information relating to specific characteristics
and/or attributes (age, sex, birth date, place of birth, nationality,
language,…).
* Product and service usage information: Information concerning an end-user’s
usage of the products and services.
4.3. Observed or generated data (information we obtain through your use of our
products and services)
We collect information when you use our products and services (fixed and mobile
services, TV, ...) and websites or when you visit our premises.
* Recordings of interactions with customer service : The audio recording or
text record of a customer’s interaction with customer service (recording of
customer service call, timestamp and duration of the conversation, a
speech-to-text transcription, a saved chat conversation with a customer
service agent,…);
* Image and video records: Images and videos of video surveillance cameras at
the Proximus premises that are used for security purposes;
* Internal identifiers: Records that are used by Proximus to uniquely identify
a customer or end-user (customer number, MyProximus credentials,…);
* Technical identifiers: Identifiers used in a technical context to relate a
specific item of a customer (service ID, mobile number, IMEI number, device
ID, ticket ID, case ID, quote ID, sales ID, IP address, box number,…);
* Product and service subscription information: Information on the products or
services that a customer subscribed to (customer install base, list of
services to which a customer has subscribed, list of products that a customer
bought …);
* Product and service usage information: Information concerning an end-user’s
usage of the products and services (mobile data usage, call minutes,
application usage, communication usage,...);
* Hardware information: Information on the devices used by a customer or
end-user (type, brand and firmware information of hardware (decoder, modem,
booster)) and of the devices that are connected to a Wi-Fi and/or mobile
network (brand, type and IMEI number of a mobile device,…);
* Billing information: Information related to billing (past payments,
outstanding amounts, invoice numbers,…);
* Personal data generated in the context of transmitting electronic
communications: Information collected through the use of the mobile or fixed
network by end users (call detail records (the originating phone number, the
number you are trying to reach), TV logs, IMEI number of an end-user’s
device, date, time duration and location of a communication or internet
connection,…)
* Network location data: Location data of an end-user’s device collected
through their use of the mobile network;
* Consumption habits: Information relating to a customer’s consumption habits
(purchasing history, tv-viewing behaviour, web browsing behaviour);
* TV viewing data: Data generated by a customer’s use of our Pickx (Proximus
TV) services.
4.4. Derived data (information we derive from collected, obtained and observed
or generated data)
In some cases, we use the collected, obtained and observed or generated data to
make certain conclusions.
* Segmentation information: Information that is used in order to divide persons
into different segments or groups (consumption habits, preferences, personal
interests, product and service subscription information, bad payer
information,…);
* Preference profile: A limited preference profile relating to the interests
and preferences of a customer or end-user based on their participation in the
Proximus reward program (Proximus For You) or their input in explicit
surveys. In case you provided your consent to the use of tv viewing data and
personal data generated in the context of electronic communications (certain
websites or applications that you visit or use) for direct marketing purposes
the preference profile can include this information as well;
* Leisure and personal interests: Information that provides an insight into the
leisure activities or personal interests of a customer or end-user
(membership to sports clubs, interest in fashion, subscription to an
automobile magazine,…).
4.5. How long do we keep personal data?
The retention periods of the personal data we process depends on the purpose,
you can find detailed information on the specific retention periods for the
different purposes in sections 6 and 7 of this Privacy Notice.
5. Personal data sharing with third parties
We share your personal data with different categories of subcontractors,
suppliers, partners, joint controllers, subsidiairies of the Proximus group,
governmental entities or other third parties. When you use our products and
services, we can share your personal data with third parties who collaborate
with Proximus for the provision of products and services. We share your personal
data with governmental entities when a legal obligation requires us to do so. In
some cases, the sharing of personal data is based on your consent, or where
adequate, our legitimate interest. In this section you can find an overview of
the different categories of third parties with whom Proximus shares personal
data.
5.1. Subcontractors, suppliers and partners
* Call centers for customer service and support purposes
* Partners or call centers who sell Proximus services in our name and on our
behalf
* IT service providers
* Network and telecommunications service providers
* Suppliers of mobile devices
* Market research partners
* Courier services
* Installation technicians
* Billing service providers
* Payment service providers such as your bank or building society and
collecting organisations
* TV service providers
* Recommendation engine providers
* Email service providers
* Marketing email providers
* Partners in the context of the loyalty program and competitions
* Debt-collection agencies and bailiffs
* Other telecom operators for the purpose of ensuring interconnection of
electronic communication services
* Third party service providers for the purpose of direct carrier billing
* Law firms
Proximus can enlist the services of subcontractors located outside the European
Economic Area. Proximus only works with subcontractors from countries that the
European Commission deems can guarantee a suitable level of protection, or with
subcontractors bound by the standard provisions approved by the European
Commission.
In addition, your personal data may be shared outside the European Economic Area
if this is required for the delivery of the service you wish to use, e.g. when
you call a number in a country outside the European Economic Area or visit a
website hosted by servers outside this area.
5.2. Joint controllers
We share your personal data with third parties who, together with Proximus,
determine the purposes and means of processing of your personal data. Your
personal data can be shared with the following third parties:
* Ads & Data for personalized targeted advertising (more detailed information
can be found in section “7.2.3.2. Targeted advertising on web and in mobile
applications (Ads&Data)”.
5.3. Subsidiaries of the Proximus Group
We can share personal data of customers with other companies of the Proximus
group in order to contact you by telephone with a view to informing you about
their products and services that may be of interest to you.
Your personal data will be used as part of the legitimate interest of Proximus
to allow other companies of the Group to process the data of Proximus customers
in order to offer them the products/services best adapted to their needs. You
can opt-out to the sharing of your personal data with other companies of the
Proximus group via MyProximus Web (click on your name or avatar in the top right
corner > My account > Alerts and Privacy) and/or MyProximus in the Proximus+ App
(click on the settings icon in the top right corner > Manage your account >
Alerts and privacy), by calling the Proximus customer service on 0800 55 800 or
by sending an email to privacy@proximus.com.
5.4. Governmental entities
We have a legal obligation to share your personal data with certain governmental
entities. The third parties with whom your personal data is shared in the
context of a legal obligation are listed below and you can find more detailed
information on data sharing in case of a legal obligation in section “6.3.3.
Comply with legal dispositions”. Your personal data is shared with the following
third parties in the context of a legal obligation:
* Judicial authorities
* Intelligence and security services
* Judicial police officer of the Belgian Institute for Postal Services and
Telecommunications
* Emergency services
* Judicial police officer of the Missing Persons Unit of the federal police
* Telecom Mediation Service
* (Deputy) Auditor of the FSMA
* Belgian Data Protection Authority
* Tax authorities
6. For what purposes (excluding marketing and sales purposes) do we use your
personal data?
In this section you can find more information about the purposes (excluding
marketing and sales purposes which can be found in section 7 of this Privacy
notice) for which we process personal data. The purposes are divided in
different categories. For each purpose there is a summary table containing the
most important information such as what categories of personal data, the legal
basis on which the processing is based, the retention period of the personal
data and where relevant the categories of third parties with whom the personal
data is shared or information about how to exercise specific data subject rights
in case it differs from the general ways to exercise data subjects rights that
are explained in section 11 of this privacy notice. The summary table is
followed by an explanation of the purpose.
6.1. General
6.1.1. Security purposes
6.1.1.1. Camera surveillance
Which categories of personal data will we use?
* Observed or generated data: Image and video records.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to protect our customers, visitors,
employees, contractors, and property.
How long will we process this data for this purpose?
The camera surveillance image and video records are stored for a period of one
month in accordance with the legally foreseen retention period unless the images
contain proof of a crime or damage or help to identify a victim, witness or a
suspect.
Who do we share this data with?
Camera surveillance images can be shared with judiciary and police forces based
on a legal obligation in case of legal requests.
How can you request access?
If you would like to request access to the camera surveillance images on which
you are captured please indicate the date, the location, and the time span
during which you have been captured on the camera surveillance images and submit
your request via privacy@proximus.com.
For more information on the various ways to exercise your rights, you can
consult section 11 below.
The premises of Proximus (including shops, buildings, sites…) are equipped with
surveillance cameras as indicated by the camera surveillance pictogram at the
entrance of the premises. The camera surveillance systems are used with the aim
of preventing, establishing, or detecting crimes against persons or goods in
accordance with the Belgian camera act. The camera surveillance images will not
be used for any other purpose.
6.1.1.2. Visitor management
Which categories of personal data will we use?
* Collected data: Identification and Contact information.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to guarantee security and safety in
our offices.
How long will we process this data for this purpose?
We will keep this data for a period of three years from the day of the visit.
With whom do we share this data?
Your data will be shared with the partner we rely upon for visitor management
purposes.
In case of a planned visit to one of the Proximus offices, your name, contact
and company details are collected and uploaded in a partner tool used for
visitor management and access to the offices and the parking. This tool will
furthermore generate a QR-code to enable your access to the Proximus offices on
the day of your visit.
Upon arrival in the lobby, you can check in via one of the check-in tablets,
where you are requested to scan the QR-code. This check-in will notify your host
of your arrival, print your visitor badge and generate the guest wi-fi
credentials. After your visit, you are requested to check out, again by scanning
the QR-code on one of the tablets. Your data is kept for a period of three years
from the day of the visit.
6.1.2. Recording of electronic communications for quality control purposes
Which categories of personal data will we use?
* Collected data: Identification and contact information.
* Observed or generated data: Recordings of interactions with customer service.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to control the quality of the
service of our call centres, as allowed by art. 10/1 of the Belgian Data
Protection Act.
How long will we process this data for this purpose?
The conversations will be stored for a period of 1 month after the electronic
communication has taken place.
With whom do we share this data?
This data is not shared with any third-parties. The recording can however take
place in name of Proximus by one of its external call centres.
How can I object?
If you have a specific reason (motivated request), you can object to our use of
your personal data for this purpose. Unless we have compelling grounds to
continue using it, we will stop using it. For more information on the various
ways to exercise your rights, you can consult section 11 below.
We are committed to offer you top-notch support and the ability to consult with
one of our agents to solve any problem you might encounter while using our
products and services. To achieve this level of quality of service however, we
need to properly train our agents and provide feedback on their crucial work.
These recordings concern calls, but also for example, the chat conversations you
might have with one of our agents.
These electronic communications are recorded and stored for one month. They are
consulted only in the context of spot-checks and complaints regarding a specific
call and are otherwise automatically deleted after a period of 1 month.
6.1.3. After-sales service, customer support and interactions with customer
service
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics, Financial data, Customer interactions, Copy of mandate or
deed.
* Observed and generated data: Internal identifiers, Technical identifiers,
Product and service subscription information, Products and service usage
information, Hardware information, Billing information, Personal data
generated in the context of transmitting electronic communications,
Consumption habits, Audio & Texting records.
What justifies this processing activity?
The necessity of the processing for the performance of the contract to which you
are a party (art. 6(1)(b) GDPR) as well as our legitimate interest (art. 6(1)(f)
GDPR) to address your questions and/or requests in the most efficient way.
How long will we process this data for this purpose?
As long as you remain an Proximus customer. The data processed in the context of
this purpose might be processed for a longer period in the context of other
purposes, such as e.g., for legal archiving purposes.
The interactions with the digital assistant is processed for maximum 3 months
after the closure of the conversation for documentation purposes to allow us to
access your interaction history for more efficient management of requests in
case of a recurring issue.
Regarding the retention period of recordings of electronic communications with
our call centers, see section ‘6.1.2. Recording of electronic communications for
quality control purposes’.
With whom do we share this data?
Depending on your request, your personal data will be shared with different
types of recipients providing support, maintenance, general IT, and
network-related services to Proximus.
Additionally, depending on the channel used to address your question or problem
to Proximus, some of your personal data might also be shared with the third
party acting on behalf of the customer (e.g., Telecommunciations Mediation
Service, Testaankoop / Testachats).
Proximus is committed to offer you the best customer experience both via the
various customer service channels (phone, chat, contact form or FAQs on the
Proximus website) that we put at your disposal and via indirect channels you may
reach out to in case of a question or issue (e.g., third party representing
you).
Contacting customer service in case of question or issue
Given the different questions you can address to our customer service and
depending on the channel used to get in touch with this service, we may process
different sets of personal data from you, and we may share your data with
different internal or external parties.
Below we describe the different steps that when you are in touch with the
customer service:
1. Smart routing in some of our customer service channels
For us to help our customers as quickly and efficiently as possible,
processes were set up to correctly identify you and to analyse your question
or issue. These processes were built into the following channels:
* By phone or by chat – Automated interactions with AI bot
When you contact our customer service via call or chat, you will first
meet a digital assistant that will offer to assist you. Proximus wants to
improve its interactions with its customers through different means,
aiming to reduce as much as possible the waiting time when you try to
reach our services.
When you reach out to our customer service, you will be put in contact
with an AI that will offer to assist you and will try to identify the
reason why you reach out to us to assist you in the most efficient way.
The AI will take different actions, depending on the following:
* If the AI can correctly identify the reason for your call/message, and
it is able to assist you without the intervention of an agent, then it
will offer you the information it believes you need or the solution you
might have requested.
* If the AI can correctly identify the reason for your call/message, and
it is not able to assist you without the intervention of an agent, then
it will put you directly in contact with the right agent that will
attempt to assist you with your request.
* If the AI is not able to correctly identify the reason for your
call/message, then it will put you directly in contact with an agent
that will attempt to assist you with your request.
Please note that you are always offered the possibility to be put in
contact with an agent.
Although the aim of the AI is to filter of the requests received by our
customer service and to put you in contact with the right agent, some
small decisions might be taken automatically (cancellation of an invoice
for instance). However, such actions could require additional
identification from you in order to prevent usurpation of your identity
before taking any actions that could impact you.
* By phone – Interactive Voice Response (‘IVR’)
Proximus relies on IVR for effective call routing. This technology uses
the personal data you provide (i.e., phone number or line number and
customer number) to verify your identity and to either route you
immediately to the best fit agent, depending on the type of question or
problem you selected in the selection menu, or to directly reply to your
question (in case an intervention by an agent is not required).
* Via the contact form on the Proximus website
You may also use a contact form to address Proximus with your question or
issue. Proximus may request certain personal data (i.e., phone number or
line number, customer number, email address and the personal data you
potentially provide to us in the free text field or in the attachment to
the contact form) to identify you and immediately direct your question or
issue to the appropriate agent.
* Via the FAQs on the Proximus website
The Proximus website contains a section with FAQs, which guide you through
some questions to determine the potential answer to your inquiry or
resolution of your issue. Each time you indicate that a proposed step in
the guided FAQ did not suffice as an answer to your question or did not
resolve your issue, further questions are asked, or other guidance is
given. At the end of a guided FAQ flow, you can indicate that you want to
get in touch with our customer service channels to help you. The
information on your questions and the steps taken in the guided FAQ flow
are captured and used to immediately direct your question to the
appropriate agent.
2. Identification and authentication by a customer service agent
Depending on the result of the checks in the smart routing of your chosen
communication channel and depending on the nature of your question or issue,
the agent may, through question and answer, process some additional personal
data (e.g., IBAN number, a mandate or a copy of your identity document). In
this way, the agent can verify that you are the customer account holder or
that you are mandated on behalf of the customer account holder to contact
Proximus.
3. Handling your question or issue
After the customer service agent has been able to identify you sufficiently,
he will proceed to handle your question or issue.
Depending on the reason why you contact Proximus, the customer service agent
will request or consult certain personal data related to you (e.g., the
technical identifier or information relating to the performance of the
product for which you are calling) and pass on certain information to other
teams offering assistance, maintenance or general IT- and network-related
services to Proximus.
4. Feedback to the third party (only applicable when you contact Proximus
through a third party acting on your behalf)
If your question or problem is submitted to Proximus via a third party, we
will also report back to this third party about the handling of the question
and/or the resolution of the issue. Personal data essential for the response
to the third party may thereby be shared with this third party.
Customer interactions initiated by Proximus
Next to the situations where you reach out to Proximus, Proximus might also
reach out to you (e.g., to schedule an appointment for installation of your
equipment and to remind you of an appointment you made). This requires the
processing of your personal data (i.e., name, mobile phone number, language
information relating to your appointment and your actions re. the appointment
communication).
6.2. When you’re becoming a customer
6.2.1. Contract commencement purposes
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics, Family and household composition, Financial data, Customer
interactions, National registry number.
* Observed or generated data: Internal identifiers, Technical identifiers.
What justifies this processing activity?
The necessity of the processing in order to take steps at the request of the
data subject prior to entering into a contract (art. 6(1)(b) GDPR) and the
necessity of the processing to comply with a legal obligation (art. 6(1)(c)
GDPR) namely the legal obligation of Proximus to carry out an identity check as
provided for under article 127, §3 of the Belgian Electronic Communications Act.
How long will we process this data for this purpose?
We will retain the personal data collected for this purpose for as long as you
remain an Proximus customer. The personal data processed in the context of the
provision of our services might be processed for a longer period of time in the
context of other purposes, such as e.g., for legal archiving purposes.
In case we need to identify you by reading or taking a copy of your (Belgian or
foreign) identity card or document, your identification document will no longer
be kept than necessary for the validation of it. After the validation process,
your identity document is deleted. The retrieved identification data can be
stored at a maximum up to 10 years after you have ceased to be a Proximus
customer.
With whom do we share this data?
For this purpose, your personal data may be processed by our indirect physical
sales channels, for example in case you purchase one of our products or services
via a non-Proximus branded shop. In addition, your personal data will be shared
with service providers acting on our behalf to provide services such as
processing the documentation used for the on-boarding of new customers. Lastly,
we may have to share your personal data with official authorities in the context
of our legal obligations.
When you become a Proximus customer and conclude a contract with us, we will
collect and process personal data about you. We will ask you for some personal
data, such as your name, address, telephone number, e-mail address, for the
management of our contractual relationship.
To comply with our legal obligations, we also read or take a copy of your
Belgian identity card, which includes your national registry number, or your
foreign identity document (such as your foreign identity card or passport).
Please refer to section “6.3.3. Comply with legal dispositions” for more
information about how we store personal data and share them with official
authorities in the context of our legal obligations. If you have more questions
about our online verification of your identity, please consult this page of our
website.
We also assign information to you, such as a customer number, login data, phone
number, box number or other technical identifiers linked to the services and
products we will provide you.
In case you move from another operator to Proximus and opt for “Easy Switch” to
facilitate the switch of operators, we will ask you to provide an Easy Switch ID
and your customer number and will take care of the cancellation and the
transfer. We will obtain the other necessary information to conclude the
contract with Proximus from your previous operator.
6.2.2. Assessment of new orders
Which categories of personal data will we use?
* Collected data: Identification and contact information, personal
characteristics, IT and telecom product and service subscription information,
customer interactions.
* Obtained data: Personal characteristics.
* Observed or generated data: Internal identifiers, product and service
subscription information, billing information.
* Derived data: Family and household composition, segmentation information.
What justifies this processing activity?
The necessity of the processing in order to take steps at the request of the
data subject prior to entering into a contract (art. 6(1)(b) GDPR) as well as
our legitimate interest (art. 6(1)(f) GDPR) in assessing new orders to mitigate
risks of non-payments and non-compliance with the contracts and to protect our
financial interests.
How long will we process this data for this purpose?
Information concerning the non-payments of a former customer is deleted when the
debt is time-barred (namely 5 years after the issue of the last unpaid invoice)
or when the former customer has settled all his/her debts with us. Information
linked to the other types of assessments performed (see detail below) is kept
until our competent services reevaluate whether the triggering factor of the
assessment is still relevant, which is done at regular intervals or at least
when a new order is triggered for manual review.
With whom do we share this data?
The information related to the outcome of the assessment of your new order may
be processed by our indirect physical sales channels, for example in case you
purchase one of our products or services via a non-Proximus branded shop.
We do not share any other personal data with third parties in the context of
this processing activity.
How can I object?
In the case where the processing of your personal data is based on our
legitimate interest, if you have a specific reason (motivated request), you can
object to our use of your personal data for this purpose. Unless we have
compelling grounds to continue using it, we will stop using it. For more
information on the various ways to exercise your rights, you can consult section
11 below.
We, like any business, must protect ourselves against the risk of
non-performance by new or existing customers of their obligations. The key
obligation of the customers is payment of their products and services. In this
context, we need to assess the risk of non-payment when dealing with new orders
from new or existing customers.
When you order a new product or service from us, we can assess the risk of
non-compliance with your payment obligation based on various factors such as
possible debts towards Proximus. Here are the typical steps involved in
assessing a new order.
When new or existing customers submit a new order, we will collect relevant
customer information from them and verify their identity, as explained in
section 6.2.1. “Contract commencement purposes” above. Based on this information
and other information available to us based on past activities of these
customers (such as history of non-payments), we will assess the new order. The
result of this assessment can be that the new order is validated without any
further review, that the new order is flagged for review (for example, when the
identification of the new customer has not been completed, when the order is
linked to a specific postal address which has been marked as presenting a high
risk of non-payment or non-compliance with the contract, when the customer has
been placed under guardianship by a competent judge or when we have otherwise
registered a flag on the customer profile to submit any order to a manual check
before validation), or that the new order is blocked (for example, when the
person concerned is a former customer and shows a history of fraudulent
activities or non-payments which lead to the termination of his/her services and
which have not been paid off since).
In case the order is flagged for review, it will go through a manual
case-by-case analysis by our competent services to detect factors whose
combination would indicate a risk of non-payment or non-compliance on the part
of the customer. Based on the results of the manual review of the order, we can
take the decision of validating, refusing, or submitting the order to specific
conditions (such as a prepayment) to mitigate the risk associated with the
order.
As far as our professional customers are concerned, we may acquire some data
from third parties and process such data in order to know the companies with
whom we might enter into business and ensure that these companies are
financially sound. Please refer to section 7.1.1.3. “Acquisition of data
relating to potential and existing professional customers” for more information
about how we collect and process such data.
6.2.3. Social tariff
Which categories of personal data will we use?
* Collected data: National registry number.
* Observed or generated data: Product and service subscription information,
Internal identifiers.
What justifies this processing activity?
This processing activity is necessary for compliance with a legal obligation of
Proximus (art. 6(1)(c) GDPR), namely the obligations foreseen in article 74 of
the Belgian Electronic Communications Act.
How long will we process this data for this purpose?
The national registry number will be processed for this purpose during
eligibility check, determining whether the consumer is eligible to benefit from
the social tariff. The other personal data will be processed as long as you
remain a Proximus customer benefiting from the social tariff.
With whom do we share this data?
The Federal Public Service Economy who is responsible for performing the check
to verify an applicant’s eligibility for the social tariff.
Article 74 of the Belgian Electronic Communications Act imposes an obligation on
Proximus as an operator to offer specific telecommunications services at a
reduced price for eligible consumers, which is known as the social tariff.
Consumers can request Proximus to benefit from the social tariff, upon which
Proximus needs to check their eligibility. The Federal Public Service Economy is
responsible for the check and provides a dedicated portal for operators to
submit consumers' national registry number for verification.
Once the national registry number is submitted to the portal, it will indicate
whether the applicant is eligible or not for the social tariff. If the check
results in a negative outcome, indicating the applicant's ineligibility, the
result of the check will be accompanied by a document containing a list of
contact points for any questions relating to the reason for refusal, which
Proximus will provide to the applicant. However, Proximus does not receive any
information regarding the specific reason for refusal by the Federal Public
Service Economy.
For consumers who have submitted a request to benefit from the previous social
tariff regime before 1/3/2024, the Federal Public Service Economy will notify
Proximus when they are no longer eligible for the social tariff. When this
occurs, Proximus is legally obliged to terminate the social tariff for these
consumers.
6.3. When you are a customer or user
6.3.1. Delivery of requested products and services
6.3.1.1. Provision of our products and services
Which categories of personal data will we use?
* Collected data: Identification and Contact Information.
* Observed or generated data: Product and service subscription information,
Personal data generated in the context of transmitting electronic
communications, Network location data, Technical identifiers, Product and
service usage information.
What justifies this processing activity?
This processing is necessary for the performance of the contract to which you
are a party (art. 6(1)(b) GDPR). Regarding personal data which would fall within
the scope of ePrivacy legislation, their processing is allowed under article
122, 123 and 125 of the Belgian Electronic Communications Act.
How long will we process this data for this purpose?
As long as you remain an Proximus customer. The data processed in the context of
this purpose might be processed for a longer period of time in the context of
other purposes, such as e.g., for legal archiving purposes.
With whom do we share this data?
Depending on the actual services you will use, your personal data will be shared
with different types of recipients providing support, maintenance, and general
IT and network-related services to Proximus.
Unsurprisingly, we will need to process your personal data to provide you with
the services you pay for, for the purpose of enabling their proper functioning:
* If you are using voice-to-voice or SMS services (be it mobile or fixed), we
will need to process data to make sure that a connection is established
between the proper caller and callee and that the telephony and SMS traffic
is properly routed across its network.
* In the context of the provision of internet access services, we will need to
process technical data on your usage that is needed to transport internet
traffic over our network and displaying the content you expect while
accessing the internet.
* Finally, if you use Pickx (Proximus TV) services, we will process technical
data about your usage. We require this data to be able to provide our Pickx
services to you, to deliver on-demand items (i.e., VOD), to schedule your
recordings and keep them available for you.
Important note: As a matter of principle, in the context of the provision of its
services, we do NOT access the content of your electronic communications. We
will process the metadata necessary to ensure the functioning of our services
and the correct transmission of an electronic communication (such as e.g., the
delivery of an SMS to the correct recipient), but our network will serve only as
a mere conduit for the content of the communications itself.
Access to the content of communications is rigorously regulated and is only
allowed under specific circumstances exhaustively enumerated under specific
articles of the Belgian Electronic Communications Act.
6.3.1.2. Interconnection with other telecom operators
Which categories of personal data will we use?
* Observed or generated data: Personal data generated in the context of
transmitting electronic communications.
What justifies this processing activity?
This processing is necessary for the performance of the contract to which you
are a party (art. 6(1)(b) GDPR). This processing of traffic data is allowed by
art. 122 of the Belgian Electronic Communications Act.
How long will we process this data for this purpose?
As long as it is necessary for the transmission of the communication. Traffic
data relating to interconnection will also be stored for billing purposes (see
section “6.3.2.1. Billing and accounting”).
With whom do we share this data?
We will need to both receive and share data with the other telecom operators
involved in that specific electronic communications, for the purpose of ensuring
interconnection of electronic communications services.
While it might not directly ring any bells, interconnection is a key activity
enabling your seamless day-to-day use of electronic communication services. In
simple terms, interconnection is what enables you – a Proximus customer – to
make use of your mobile data or to reach another person (be it by phone or SMS)
using the services of another operator, located on another electronic
communications network, in or outside Belgium.
All telecom operators have a legal obligation to enable access to their network
and to negotiate interconnection agreements with the operators of other
networks, based on the European Electronic Communications Code as well as the
Belgian Electronic Communications Act. These other operators might include
national operators (e.g., Telenet or Orange), operators in foreign countries
(e.g., Deutsche Telekom, Vodafone), and international carriers (e.g., BICS).
Without interconnection agreements and the necessary processing of personal data
these activities involve, global communication as we know it today would not be
possible.
In the context of interconnection services, your phone number and usage
information might be exchanged with other interconnection partners to ensure
routing of the communication as well as for billing purposes, reconciliation and
payment settlement purposes, dispute management purposes.
6.3.1.3. Planning and organization of network infrastructure
Which categories of personal data will we use?
* Observed or generated data: Personal data generated in the context of
transmitting electronic communications, Network location data.
What justifies this processing activity?
This processing is necessary for the performance of the contract to which you
are a party (art. 6(1)(b) GDPR). This processing of traffic data is allowed by
Article 125 §1. 2° of the Belgian Electronic Communications Act.
How long will we process this data for this purpose?
Signaling information will be stored for 14 days from the moment the signal has
been sent out.
Proximus stores aggregated data on end-user level for maximum three months.
Aggregated data on network level will be stored for maximum one year.
With whom do we share this data?
We may share the data with companies that assist us in the context of planning
and organization of the network infrastructure.
Planning and building stable, reliable, flexible, and efficient network
infrastructure is a fundamental requirement for operators like Proximus.
Effective planning and organization of telecom infrastructure are crucial for
Proximus to ensure seamless connectivity and service reliability to its
customers and end-users. By meticulously designing and managing the network and
by analysing current network capabilities and shortcomings, Proximus can provide
stable, high-speed internet and communication services, which not only enhances
user experience but also supports the growing demand for data and digital
services.
To achieve this purpose, Proximus collects and processes data generated in the
context of the transmission of electronic communications (e.g., in case of a
phone call this will be both the calling number and the called number) and the
network location data (i.e. the data of the device of the calling person and the
called person) to make sure that the signal (i.e. the phone call) contains the
required specificities in terms of quality, encoding and modulation to be
captured by and sent to the correct antenna and to be received by the device of
the called person.
Additionally, well-planned infrastructure allows for scalability and
adaptability, enabling Proximus to integrate new technologies and expand our
services efficiently. This is for example the case for the discontinuation of
the 3G network, which allows Proximus to free up space in the network to
consolidate and scale up the faster 4G and 5G networks, offering our customers
the most powerful, secure and energy-efficient mobile network. You can find more
information on this specific topic through this link.
While Proximus is committed to ensuring the optimal performance of our
telecommunication networks and services, we are therefore also analysing
information relating to the use of the telecommunication networks with the aim
of resolving and/or preventing network issues. For more information, see section
“6.3.6.3. Network Management”.
6.3.2. Customer management
6.3.2.1. Billing and accounting
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics, Financial data.
* Observed or generated data: Internal identifiers, Technical identifiers,
Product and service subscription information, Product and service usage
information, Billing information, Personal data generated in the context of
transmitting electronic communications.
What justifies this processing activity?
This processing is necessary for the performance of the contract to which you
are a party (art. 6(1)(b) GDPR) or our legitimate interest (art. 6(1)(f) GDPR)
to process personal data to accurately bill and invoice for the services we
provide to end-users of our professional customers. The processing of your
traffic data for this purpose is allowed by art. 122, §2 of the Belgian
Electronic Communications Act.
How long will we process this data for this purpose?
We will keep billing-related data for the duration of the contract with you and
for an additional 7 years thereafter to comply with our legal obligations
related to tax and accounting.
With whom do we share this data?
We will share your personal data with service providers acting on Proximus’
behalf to provide billing-related services such as the management of our legal
archive for documents such as invoices. In addition, some of your personal data
will be shared with the company that employs you or other business relations of
yours in case your employer pays all or part of your bill. If you choose to pay
your bills by means of direct debit, some of your personal data will be shared
with payment service providers such as your bank or building society and
collecting organisations so that your direct debit instruction is completed.
Billing is a part of the majority of services we offer to you. For this purpose,
we use data related to your contract and your consumption to calculate and
generate invoices, generally on a monthly basis. This also implies the
application of the appropriate taxes and credits.
We will also use your contact details to send you billing documents and ensure
that the invoice is appropriately delivered to our customers. Depending on your
preferences, your invoice will be sent to you:
* on paper via the post;
* online, via SMS or email; or
* on your MyProximus account, via the Proximus+ App and on myproximus.be.
If you choose to pay your bills by means of direct debit, you authorize your
bank to pay your Proximus bill automatically. This is done on the due date,
which is mentioned on your bill or payment statement.
In case you use the possibility to pay for products/services offered by third
parties via a statement in your Proximus invoice, we and this third party will
share billing-related personal data about you, as further explained in section
“6.3.2.3. Third-Party Services or Direct Carrier Billing”.
6.3.2.2. Collection process
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics, Financial data, Customer interactions.
* Observed or generated data: Internal identifiers, Product and service
subscription information, Billing information.
* Derived data: Segmentation information.
What justifies this processing activity?
This processing is necessary for the performance of the contract to which you
are a party (art. 6(1)(b) GDPR).
How long will we process this data for this purpose?
We will keep billing-related data for the duration of the contract with you and
for an additional 7 years thereafter to comply with our legal obligations
related to tax and accounting.
With whom do we share this data?
Debt-collection agencies and bailiffs.
In case a customer does not pay invoices or fees in a timely manner, we may be
obliged to take actions in order to collect the unpaid amounts.
In view of collecting unpaid invoices or fees from our customers, we may process
your personal data in order to take different types of actions, where
appropriate, such as:
* Classify the concerned person depending on the type of customer (e.g.
residential or business customer), the communications with the customer in
the context of collection (timing and means of communications like call or
SMS), the collection actions towards the customer (payment promise and
instalment plan) and the reason for the delay or absence of payment (e.g.
bankruptcy, passing) in order to define the appropriate collection steps;
* Inform the customer about the unpaid amount;
* Temporarily cut off the customer’s access to our services (telephone, TV and
internet);
* Flag the customer as a ‘bad payer’; or
* Make use of the services of a debt-collection agency or a bailiff.
6.3.2.3. Third-Party Services or Direct Carrier Billing
Which categories of personal data will we use?
* Collected data: Identification and contact information, Financial data.
* Obtained data: Product and service subscription information.
* Observed or generated data: Internal identifiers, Technical identifiers,
Product and service usage information, Billing information.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to offer direct carrier billing
payment services for third-party services to our partners and provide a safer
means of payment for our customers online.
How long will we process this data for this purpose?
For the purpose of offering direct carrier billing payment services, we will
keep your personal data for 2.5 years after their creation. This is without
prejudice of the retention period of billing-related data in order to comply
with our legal obligations related to tax and accounting.
With whom do we share this data?
Third-party service providers (usually online merchant who offer digital
content) from which you purchased services to be paid by means of direct carrier
billing.
How can I object?
Any subscription paid via direct carrier billing can be stopped by replying STOP
(in capitals) to the third-party service provider's mobile number or by
contacting the contact number of the third-party service provider. For more
information on alternative ways to exercise your rights, you can consult section
11 below.
We offer our customers the possibility to pay for products/services offered by
third parties (“third-party services”) via direct carrier billing. When you want
to buy a digital service for instance, the provider of the service will offer
you different means of payment. One of them is called “direct carrier billing”.
It means the amount of the third-party service will be mentioned in a statement
attached to your mobile telecom operator’s invoice.
If you wish to resort to this means of payment, we will share personal data
about you with the service provider. The provider will mainly transfer us
information about the third-party service purchased. If required, we will use
and transfer your phone number to allow your identification by the provider and
confirm whether the transaction can go through or not (e.g. if you decided on a
limited maximum amount lower than the price of the service, the transaction will
not go through).
For these categories of information, we are acting as a controller and are
transferring your personal data based on our legitimate interest to offer direct
carrier billing payment services for third-party services to our partner and
provide a safer means of payment for our customers online.
When the transaction is confirmed, the service will be mentioned in a statement
attached to your telecom invoice and the amount will be collected by us and
transferred to the third-party service provider. In this situation, the service
provider is controller of the data related to the purchase of the third-party
service and we are acting on the service provider’s behalf as its processor.
6.3.2.4. Verification services to 3rd Parties
Which categories of personal data will we use?
Proximus acting as a sub-processor:
* Obtained data: Identification and contact information (collected by Digital
Service Providers and shared with Proximus via Telesign).
Proximus acting as a controller:
* Collected data: Identification and contact information, Subscription
information.
What justifies this processing activity?
Proximus and Digital Service Providers both have legitimate interests (art.
6(1)(f) GDPR) that justify this processing activity. Proximus aims to generate
revenue and assist Digital Service Providers in combating fraud through
telecommunication services. Meanwhile, Digital Service Providers seek to prevent
fraud on their platforms and streamline the identification process for
individuals seeking registration.
How long will Proximus keep this data?
The match results and risk levels are deleted after 90 days.
Who do we share this data with?
The match results are shared with our subsidiary, Telesign, who is acting as
processor for the Digital Service Providers. No other data is shared by
Proximus.
How can I object?
If you have a specific reason (motivated request), you can object to our use of
your personal data for this purpose. Unless we have compelling grounds to
continue using it, we will stop using it. For more information on alternative
ways to exercise your rights, you can consult section 11 below.
We can process your personal data for the provision of verification services to
third parties (Digital Service Providers), including subsidiaries of the
Proximus Group, to allow them, in the context of preventing and combating fraud,
to check whether the data they possess corresponds with the data in our customer
database, but without disclosing your name or other customer data to the third
party. It allows them to evaluate the validity of data a unique customer
provides during the registration process and as such helps them to detect the
creation of fake accounts.
It is important to emphasise that in this process, we never share your name with
these Digital Service Providers – only the match results as well as a risk level
are communicated to Telesign.
6.3.2.5. Dispute management
Which categories of personal data will we use?
The categories of personal data we will use for dispute management purposes,
will depend on the nature of the dispute. In general, we will process the data
necessary to uniquely identify you (identification and contact information).
Depending on the nature of the dispute, other personal data might also be
processed (e.g., in case of a billing dispute, billing and payment information
will be processed.
What justifies this processing activity?
This processing is necessary for the performance of the contract to which you
are a party (art. 6(1)(b) GDPR) in case of a dispute related to you as a
customer or our legitimate interest (art. 6(1)(f) GDPR) to resolve disputes in
case of a dispute when you are not a Proximus customer.
How long will we process this data for this purpose?
Your personal data will be kept for ten years after the dispute has come to an
end for evidentiary purposes (e.g. if your name appears in a document that
serves as evidence in a dispute between you and us, this personal data will be
kept for ten years because the evidence document will be kept as long). In order
to manage potential future data protection related disputes, a trace of your
consent (e.g. consent collected for targeted advertising purposes) will be
stored for the duration of the consent + 5 years, which is the prescription
period for any actions before the Belgian Data Protection Authority.
With whom do we share this data?
The people with whom your personal data in the context of dispute management is
shared, will also depend on the nature of the dispute. Your personal data might
for example be shared with a law firm in case the dispute is taken to court.
In the context of a dispute, we will process some of your personal data. First,
we will process the personal data linked to your customer account, in order to
uniquely identify you and to contact you in the context of the dispute.
Depending on the nature of the dispute, we might also process other personal
data (e.g., billing information, payment information, information about your
products and services) and share your personal data with other partners (e.g.,
law firm, debt collection agency,…).
For more information about your data subject rights you can consult section 11
below.
6.3.2.6. Market research
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics, IT and telecom product and service subscription information,
Survey specific information.
* Obtained data: Identification and contact information.
* Observed or generated data: Product and service usage information, Product
and service subscription information, Billing information, Hardware
information.
* Derived data: Segmentation information.
What justifies this processing activity?
Sending out the invitations to participate to market surveys: our legitimate
interest (art. 6(1)(f) GDPR) to perform market research.
The processing in the context of the participation to market surveys: your
consent (art. 6(1)(a) GDPR) to participate to market surveys.
How long will we process this data for this purpose?
The contact and identification information used to send out invitations are
retained for a maximum of 5 years after the end of your contract with Proximus.
The personal data processed in the context of market research and surveys is
retained for a maximum of 3 years after the date of the survey.
Who do we share this data with?
We share and receive personal data in the context of market research with/from
different research partners.
Some of our research partners perform market surveys, orientated towards data
subjects in our customer and user database, on our behalf. These market surveys
are sent out through different communication channels (SMS, email and pop-ups on
the website and in Proximus applications) or are conducted through interviews
(face to face interviews, interviews via digital means or phone interviews);
Other research partners of ours are only involved in the recruitment of
participants that match the target profile for specific market surveys; and
Our research partners can also provide us with results of market surveys
oriented towards data subjects within their own database.
How can I object?
If you don’t want to receive invitations to participate to market research
surveys, you can opt-out for market research through the privacy preferences in
your ‘My Proximus’ environment via MyProximus Web (click on your name or avatar
in the top right corner > My account > Alerts and Privacy) and/or MyProximus in
the Proximus+ App (click on the settings icon in the top right corner > Manage
your account > Alerts and privacy) or submit a request through the webform or
via privacy@proximus.com .
For more information on alternative ways to exercise your rights, you can
consult section 11 below.
How can I withdraw my consent?
You can always withdraw your consent, at any time, by contacting
privacy@proximus.com.
For more information on alternative ways to exercise your rights, you can
consult section 11 below.
We do market research with the aim of testing and improving (new) products and
services, which consists of performing market surveys on the following concepts:
* Brand image and communication testing: before launching a large communication
campaign, we perform a pre-test of the campaign to ensure that the message is
well understood and clear, and that the campaign will generate impact. After
the media campaign went live, we test among a representative sample of the
target group if the communication campaign had impact (seen, know which
brand, liking, message take out…).
* Concept testing: before launching a new service or product, it is tested
among consumers to be sure it is relevant for them and there is a market
potential for us.
* Understanding of customer needs and behaviors: to better understand consumers
and the new trends, we perform market research to unveil their needs and how
they are behaving.
* Market penetration of products and services and benchmarks with regards to
the competition: measure the penetration of products and services and define
their clientship in order to have a good view on our position vs competitors.
* Satisfaction and loyalty: surveys to measure the satisfaction level of our
customers or of the customers of competitors with regards to different
products or services.
We sometimes also cooperate with research partners:
* Some of our research partners perform market surveys, orientated towards data
subjects in our customer and user database, on our behalf. These market
surveys are sent out through different communication channels (SMS, email and
pop-ups on the website and in Proximus applications) or are conducted through
interviews (face to face interviews, interviews via digital means or phone
interviews);
* Other research partners of ours are only involved in the recruitment of
participants that match the target profile for specific market surveys; and
* Our research partners can also provide us with results of market surveys
oriented towards data subjects within their own database.
6.3.2.7. Quality assurance, improvement, and development of (new) products and
services
Which categories of personal data will we use?
* Collected data: Identification and contact information, Customer
interactions, Survey specific information.
* Observed or generated data: Internal identifiers, Technical identifiers,
Product and service subscription information, Product and service usage
information, Hardware information, Personal data generated in the context of
transmitting electronic communications.
* Derived data: Segmentation information.
What justifies this processing activity?
The processing of personal data for quality assurance is necessary for the
performance of the contract to which you are a party (art. 6(1)(b) GDPR).
The processing of personal data for the improvement and development of (new)
products and services is based on our legitimate interest (art. 6(1)(f) GDPR) to
provide high quality and innovative products and services that meet the evolving
needs of our customers.
How long will we keep this data?
Aggregated personal data is processed for a maximum of 3 years. However, there
are shorter retention periods for personal data that is not aggregated, as well
as for personal data used for diagnostic purposes.
Who do we share this data with?
We may share your personal data with network and telecommunications service
providers and suppliers of the hardware devices we provide to customers to
enable our customers to use our products and services.
How can I object?
If you have a specific reason (motivated request), you can object to our use of
your personal data for the processing activity which is based on our legitimate
interest. Unless we have compelling grounds to continue using it, we will stop
using it. For more information on the various ways to exercise your rights, you
can consult section 11 below.
We are committed to ensuring high-quality performance and innovation of our
products and services. To achieve this, we continuously monitor and evaluate
their performance, investing in improvements and the development of new
offerings. This involves collecting and analysing data on usage and customer
feedback to ensure the quality of our products and services, enhance them and
improve customer satisfaction.
An important aspect to achieve this goal is monitoring the performance of the
different hardware and software components that are used in the provisioning of
our products and services. We use advanced diagnostic tools and analytics to
track the functionality and efficiency of these components which involves
collecting data on various performance metrics. By analysing this data, we can
identify any deviations from expected performance levels, identify issues and
resolve them as well as pinpoint and anticipate potential issues before they
impact our customers. For example, if we notice, based on customer complaints
and technician interventions, that there are recurring issues in the Wi-Fi setup
at multiple customers due to specific hardware or software components, we can
analyse these issues at a macro level. This allows us to proactively take
actions to improve the performance of the Wi-Fi or prevent these issues from
occurring with other customers. By maintaining rigorous monitoring and analysis
of both hardware and software performance, we can ensure that our products and
services meet high standards of quality and reliability.
Collecting customer feedback is another crucial part of our commitment to ensure
high-quality performance of our products and services and their continuous
improvement and innovation. We actively seek input from our customers. This
feedback helps us understand customer needs and preferences, identify areas for
improvement, and gauge overall satisfaction with our products and services. By
incorporating customer insights into our development process, we can tailor our
offerings to better meet their expectations and address any issues promptly.
Additionally, customer feedback guides our decisions on developing new products
and services, ensuring that we stay responsive to market demands and continue to
provide value to our customers. You can find more information about how customer
feedback is collected in section “6.3.2.6. Market research”.
By integrating the monitoring of hardware and software performance with the
active collection of customer feedback, we not only enhance the quality and
reliability of our products and services but also significantly improve the
overall customer experience. Furthermore, we continuously evaluate our processes
based on customer feedback and the analysis of the customer journey to ensure
they are seamless and responsive to our customers’ needs. These efforts ensure
that we remain responsive to our customers’ needs, proactively address potential
issues, and continuously innovate to meet and exceed their expectations.
6.3.3. Comply with legal dispositions
6.3.3.1. Legal obligation to store and to share traffic data and other location
data other than traffic data (art. 121/8, 122, art. 123 and art. 127/1, para. 2
Belgian Electronic Communications Act)
Which categories of personal data will we use?
* Observed or generated data: Personal data in the context of electronic
telecommunications.
What justifies this processing activity?
This processing activity is necessary for compliance with a legal obligation of
Proximus (art. 6(1)(c) GDPR), namely the obligations foreseen in art. 121/8,
122, art. 123 and art. 127/1, para. 2 of the Belgian Electronic Communications
Act.
How long will we process this data for this purpose?
The Belgian Electronic Communications Acts foresees in different retention
periods, depending on the types of data that are stored:
* Identifiers of both the source and the destination of the communication,
exact date and time of the beginning and the end of the communication and
location of the terminal equipment of the communicating parties at the
beginning and at the end of the communication and other location data: 4
months from the date of the communication and – in case of specifically
identified fraud or specifically identified malicious use of the network –
for as long as needed to analyse and mitigate this fraud or malicious use.
* Phone number at the source of the incoming communication, IP address,
timestamp and gate used for sending the incoming communication and exact date
and time of beginning and end of the communication: 12 months from the date
of the communication and – in case of specific malicious use of the network –
for the period needed to process this malicious use of the network.
With whom do we share this data?
* Internally, your traffic data and other location data can only be processed
by Proximus collaborators in charge of managing telecommunications traffic,
combating fraud or malicious use of the network, complying with legal
obligations or by members of the Coordination Cell (each service has only
access to the strict necessary).
* The following official authorities might be informed of (parts of) your
traffic data and other location data in the context of their respective
competences: (1) Belgian Institute for Postal Services and Telecommunications
(“BIPT”), (2) Telecom Mediation Service, (3) Belgian Competition Authority,
(4) Judicial authorities or the Council of State.
* Your location data can be shared with the management centers of emergency
services offering on-site aid in case of an emergency communication.
* The following official authorities might request access to your traffic data
and other location data, under specific circumstances prescribed by law: (1)
Intelligence agencies and security services, (2) Authorities competent for
the prevention of serious threats to public security, (3) Authorities
responsible for safeguarding vital interests, (4) Authorities competent for
investigating security breaches, (5) Administrative or judicial authorities
competent for the prevention, investigation, detection or prosecution of an
infringement committed online or through an electronic communications network
or service, (6) Administrative or judicial authorities competent for the
prevention, investigation, detection or prosecution of a serious crime, (7)
Administrative authorities responsible for safeguarding an important economic
or financial interest of the EU or Belgium, (8) Administrative or judicial
authorities competent for the prevention, investigation, detection or
prosecution of a criminal offence, (9) the BIPT, (10) Authorities legally
authorised to re-use data for purposes of scientific or historical research
or for statistical purposes.
To comply with its legal obligation to take appropriate, proportionate,
preventive and curative measures to detect fraud and malicious use of its
network and services and to enable centres of emergence services offering on
site aid to treat an incoming emergency communication, Proximus stores traffic
data and other location data. Proximus has a legal obligation to store traffic
data and other location data in order to:
* detect fraud or malicious use of the network or the service and to both
identify the source and the identity of the perpetrator; and
* enable management centres of emergency services offering on site aid to treat
an incoming emergency communication.
The Belgian Electronic Communications Act imposes on Proximus not only (in most
cases) which personal data it must store and for how long, but also who within
the company may process the data and to which other official authorities the
data could be transmitted, when requested and under specific circumstances.
6.3.3.2. Processing of data based on art. 125 Belgian Electronic Communications
Act
Which categories of personal data will we use?
* Observed or generated data: Personal data in the context of electronic
telecommunications, Technical identifiers, Location data of an end-user’s
terminal equipment, Volume usage information.
What justifies this processing activity?
In the case Proximus processes your personal data to offer you a service aiming
at preventing the reception of unsolicited electronic communications, when this
processing is not justified by Proximus’ legal obligation or legitimate interest
to prevent fraud: your consent (art. 6(1)(a) GDPR).
Processing of your personal data in the context of a request of the BIPT on
demand of the the judicial police officer of the Missing Persons Unit of the
federal police: protection of a vital interest (art. 6(1)(d) GDPR).
In the context of the processing of personal data to enable the intervention of
aid- and emergency services: our legitimate interest (article 6(1)(f) GDPR).
Processing of personal data for the prevention of fraud committed by means of
messages using telephone numbers, such as SMS or MMS messages, as authorized by
article 125, para. 1, 7° of the Belgian Electronic Communications Act: our
legitimate interest (article 6(1)(f) GDPR).
Processing of personal data in the context of the collaboration obligation
towards authorities: our legitimate interest (article 6(1)(f) GDPR).
For what purposes will your personal data be processed?
* To enable intervention of aid and emergency services;
* When the BIPT processes this data in the context of its general supervision
and control mission or by order of the investigating judge, public prosecutor
or on request of the department head of the state intelligence and security
services, the judicial police officer of the Missing Persons Unit of the
federal police;
* When the Telecom Mediation Service processes this data in the context of his
legal investigative tasks;
* When officials authorised by the Minister of Economy in the context of their
legal investigative competences process this data;
* To offer end users services consisting of preventing the reception of
unsollicited electronic communications; and
* When operators process this data with the sole purpose of combating fraud
committed through messages using telephone numbers. This includes the
anti-smishing platform set up by Proximus in the scope of its Cyber Security
Program (see our specific privacy notice related to network fraud prevention
for further information about how we process personal data in the context of
our actions to combat fraudulent messages over mobile text messages
(SMS/MMS)).
With whom do we share this data?
* Internally, your data can only be processed by Proximus collaborators in
charge of managing telecommunications traffic, combating fraud or malicious
use of the network, complying with legal obligations or by members of the
Coordination Cell (each service has only access to the strict necessary). The
following official authorities might request access to your personal data in
the context of electronic telecommunications, under specific circumstances
prescribed by law: (1) the BIPT, (2) the Telecom Mediation Service or (3)
Officials authorized by the Minister of Economy, (4) Belgian Competition
Authority and (5) Judicial authorities of the Council of State. Within the
scope of their competence, they can be informed of relevant traffic and
billing data with a view to settling disputes, including interconnection and
billing disputes.
Article 124 of the Belgian Electronic Communications Act provides for the
principle of telecommunications secrecy. This means that, in principle, no one
may learn about any information related to the electronic communication (its
content, the identity of persons concerned, or information related to the
communication) without the consent of all persons, directly or indirectly,
concerned by the communication.
In some circumstances however, the principle of telecommunications secrecy can
be overruled, namely:
* in the specific circumstances as described in articles 122 and 123 of the
Belgian Electronic Communications Act (more detailed information can be found
in section “6.3.3.1. Legal obligation to store and to share traffic data and
other location data other than traffic data (art. 121/8, 122, art. 123 and
art. 127/1, §2 Belgian Electronic Communications Act)”);
* when allowed or imposed by means of law;
* to ensure the security and good functioning of the electronic communications
networks and services, and in particular to detect and analyse a potential or
actual attack on that security, including to identify the origin of that
attack (more detailed information can be found in section “6.3.6.2. Network
and information security”);
* when it concerns actions to monitor and verify the good functioning of the
network and to ensure the optimal performance of the electronic
communications service (more detailed information can be found in section
”6.3.6.3. Network management”);
* to enable the intervention of aid and emergency services;
* when it concerns actions to combat fraud committed through messages using
telephone numbers (e.g. smishing and spoofing) (see our specific privacy
notice related to network fraud prevention for further information about how
we process personal data in the context of our actions to combat fraudulent
messages over mobile text messages (SMS/MMS)); and
* when actions are taken by certain official authorities, as determined by law.
6.3.3.3. Legal obligation to store and to share personal data processed or
generated in the context of the offering of networks or services to end users
(art. 126 and art. 127/1, para. 3 Belgian Electronic Communications Act)
Which categories of personal data will we use?
* Collected data: Identification and contact information, National registry
number or official external identifier other than the national registry
number.
* Observed or generated data: Personal data in the context of electronic
telecommunications, Location data of an end-user’s terminal equipment,
Product and service subscription information, Technical identifiers.
What justifies this processing activity?
This processing activity is necessary for compliance with a legal obligation of
Proximus (art. 6(1)(c) GDPR), namely the obligations foreseen in art. 126 and
art. 127/1, para. 3 of the Belgian Electronic Communications Act.
How long will we process this data for this purpose?
* As a principle, we will store your personal data for this purpose as long as
the electronic communications service is used + 12 months after the end of
the service.
* Some personal data that is related to a specific session (e.g., IP address at
the source of the connection and identifiers of the terminal equipment of the
end user like IMEI, PEI and MAC) will only be stored during the session + 12
months after the end of the session.
With whom do we share this data?
The following official authorities might request access to your personal data,
under specific circumstances prescribed by law: (1) Intelligence agencies and
security services, (2) Authorities competent for the prevention of serious
threats to public security, (3) Authorities responsible for safeguarding vital
interests, (4) Authorities competent for investigating security breaches, (5)
Administrative or judicial authorities competent for the prevention,
investigation, detection or prosecution of an infringement committed online or
through an electronic communications network or service, (6) Administrative or
judicial authorities competent for the prevention, investigation, detection or
prosecution of a serious crime, (7) Administrative authorities responsible for
safeguarding an important economic or financial interest of the EU or Belgium or
(8) Administrative or judicial authorities competent for the prevention,
investigation, detection or prosecution of a criminal offence.
Proximus has a legal obligation to store certain data, defined by law, when this
data is processed or generated in the context of the provisioning of electronic
communication networks or electronic communication services. These data include
data identifying the end user of the network or service (e.g. first name and
last name, national registry number,…), data identifying the date, time and
location of the activation of the service (e.g. date and time of the activation
of the service, physical address of the point of sales where the service was
activated,…) as well as data identifying the subscription and the terminal
equipment (e.g. IMSI, IMEI, MAC,…).
Proximus stores this data for the period prescribed by law and during this
retention period, it is possible for some official authorities to request access
to (some of) this data, under the conditions prescribed by law.
6.3.3.4. Legal obligation to store and to share personal data for the purpose of
safeguarding national security, combating serious crime, preventing serious
threats to public security, and protecting the vital interests of a natural
person in certain geographical areas determined by law (art. 126/1 to art. 126/3
and art. 127/1, para. 4 Belgian Electronic Communications Act)
Which categories of personal data will we use?
* Collected data: Identification and contact information, National registry
number or official external identifier other than the national registry
number.
* Observed or generated data: Personal data in the context of electronic
telecommunications, Location data of an end-user’s terminal equipment,
Product and service subscription information, Technical identifiers.
It is important to note that the categories of personal data described above,
will only be stored for certain geographical areas determined by law:
* Judicial districts that meet established criteria regarding the number of
offences committed;
* Police districts that meet established criteria regarding the number of
offences committed and are part of a judicial district that, in turn, does
not meet established criteria regarding the number of offences committed;
* Zones with a threat level ‘3’;
* Areas particularly exposed to threats against national security or for the
commission of serious crime (e.g., harbors, railway stations, airports,
prisons, nuclear sites…);
* Zones where there is a potential serious threat to the vital interests of the
country or the essential needs of the population (e.g., highways, town halls,
the royal palace, hospitals, the National Bank of Belgium…); and
* Zones where there is a potentially serious threat to the interests of
international institutions established on the national territory (e.g.,
embassies, EU and EEA buildings, buildings of NATO and UN…).
What justifies this processing activity?
This processing activity is necessary for compliance with a legal obligation of
Proximus (art. 6(1)(c) GDPR), namely the obligations foreseen in art. 126/1 to
art. 126/3 and art. 127/1, para. 4 of the Belgian Electronic Communications Act.
How long will we process this data for this purpose?
* Most of the time, we will store your personal data for this purpose for a
period of 12 months from the date of the communication.
* Data relating to the date and time of connection of the terminal equipment
with the network due to the fact that this equipment is started up and data
relating to the date and time of disconnection of the terminal equipment with
the network due to the fact that this equipment is shut down, will be stored
for a period of 6 months after it has been generated.
* In specific cases determined by law, a different retention period applies
(from 6 months from the date of the communication to 9 months from the date
of the communication).
With whom do we share this data?
The following official authorities might request access to your personal data,
under specific circumstances prescribed by law: (1) Intelligence agencies and
security services, (2) Authorities competent for the prevention of serious
threats to public security, (3) Authorities responsible for safeguarding vital
interests or (4) Administrative or judicial authorities competent for the
prevention, investigation, detection or prosecution of a serious crime.
Certain data - either collected, processed, or generated in the context of the
telecommunications networks and services provided by Proximus - may be of great
importance in safeguarding national security, combating serious crime,
preventing serious threats to public security and protecting the vital interests
of natural persons.
Therefore, Proximus is legally obliged to store certain personal data allowing
for the identification of end users, of their terminal equipment and of the use
of the network or service by these end users and to make this data available to
certain official authorities for the abovementioned purposes.
The legal storage obligation, however, is subject to criteria determining
certain geographical areas.
6.3.3.5. Legal obligation to store and to share personal data for the purpose of
direct or indirect identification of subscribers of an electronic communications
payment service (art. 127 and art. 127/1, para. 3 Belgian Electronic
Communications Act)
Which categories of personal data will we use?
* Collected data: Identification and contact information, National registry
number, Official external identifier other than the national registry number,
Personal characteristics.
* Observed or generated data: Personal data in the context of electronic
telecommunications, Location data of an end-user’s terminal equipment,
Product and service subscription information, Technical identifiers,
Financial and billing information.
What justifies this processing activity?
This processing activity is necessary for compliance with a legal obligation of
Proximus (art. 6(1)(c) GDPR), namely the obligations foreseen in art. 127 and
art. 127/1, para. 3 of the Belgian Electronic Communications Act.
How long will we process this data for this purpose?
We will store your personal data from the date of the activation of the service
until 12 months after the termination of the service.
With whom do we share this data?
The following official authorities might request access to your personal data,
under specific circumstances prescribed by law: (1) Intelligence agencies and
security services, (2) Authorities competent for the prevention of serious
threats to public security, (3) Authorities responsible for safeguarding vital
interests, (4) Authorities competent for investigating security breaches, (5)
Administrative or judicial authorities competent for the prevention,
investigation, detection or prosecution of an infringement committed online or
through an electronic communications network or service, (6) Administrative or
judicial authorities competent for the prevention, investigation, detection or
prosecution of a serious crime, (7) Administrative authorities responsible for
safeguarding an important economic or financial interest of the EU or Belgium or
(8) Administrative or judicial authorities competent for the prevention,
investigation, detection or prosecution of a criminal offence.
Proximus has a legal obligation to store certain personal data allowing the
identification of the subscribers of an electronic communications payment
service, so that the official authorities that are entitled to request access to
certain data can identify the subscriber.
Proximus is legally obliged to store these data throughout the entire duration
of the activation of the service and for 12 months after the termination of the
service.
6.3.3.6. Location sharing trough AML with Belgian emergency centers
Which categories of personal data will we use?
* Collected data: Identification and Contact information.
* Observed data: Location data (collected through the use of the mobile network
by you).
What justifies this processing activity?
This processing activity is necessary to comply with a legal obligation (art.
6(1)(c) GDPR), namely the obligations foreseen in art. 107 of the Belgian
Electronic Communications Act.
How long will we process this data for this purpose?
We process and disclose this data to the emergency services as long as you have
a subscription with Proximus.
With whom do we share this data?
Your location data is shared with Belgian emergency centers (medical emergency
service, fire department, police station,…).
Proximus is required by law to disclose your identification and contact
information and location data to the emergency services when you place an
emergency call. During an emergency call, every phone supporting Advanced Mobile
Location (AML) can transmit the most accurate position possible to the emergency
centers. The location information is only sent to the emergency centers when you
call 112 or 101 (or the old number, 100, which is no longer promoted). The
transmission of location data complies with Belgian law and is only used for
efficiently locating an incident.
In addition to this location data, we also provide them with the following
information: your phone number, your name, first name (and, if available, the
initial or initials of your first name), or the name of the company, body or
firm, an indication of whether your number is used for fixed or mobile service
(nomadic use is also indicated if we have this information) and your
geographical coordinates. For fixed electronic services, these include the
street name, house number, box number, postcode and municipality where the
service is installed. For mobile services, they include the street name, house
number, box number, postcode and municipality where you are established.
6.3.3.7. Access of emergency services to the Central Number Database (CNDB)
Which categories of personal data will we use?
* Collected data: Identification and contact information.
* Observed or generated data: Product and service subscription information.
What justifies this processing activity?
This processing activity is necessary for compliance with a legal obligation of
Proximus (art. 6(1)(c) GDPR), namely the obligations foreseen in article 106/2
of the Belgian Electronic Communications Act.
How long will we process this data for this purpose?
Your personal data is processed by the Central Number Database as long as you
are a subscriber with Proximus. Upon termination of the subscription, the
Central Number Database permanently deletes the personal data, provided you do
not become a customer of another operator.
With whom do we share this data?
Your data will be shared with the emergency services as defined in article 107,
§1, a. of the Belgian Electronic Communications Act, namely the medical
emergency service, the fire fighter services, the police services and the civil
protection, via the Central Number Database.
To comply with its legal obligation, Proximus has a legal obligation to give
access to the Central Number Database, a database established together with
other Belgian operators providing public telephony services, to emergency
centers. The Central Number Database centralizes subscriber data of all
operators. The types of subscriber data centralized in the Central Number
Database is stipulated by law and entails i) the phone number, ii) the first
name and last name and the initials, if any, iii) the street, house number, box
number, postal code and city of installation of the product (in case of a fixed
product) or where the subscriber resides (in case of a mobile product), iv) the
type of phone product (i.e. mobile phone number or fixed line number) and v) the
name of the operator (article 106/2, §3 Belgian Electronic Communications Act).
Management centers of emergency services offering on-site aid in case of an
emergency communication are connected to the Central Number Database, so they
have immediate access to the subscriber data belonging to the caller in case of
an emergency call. Based on this information, the management center can quickly
identify and locate the caller. For more information about the sharing of
location data with Belgian emergence centers, see the section “6.3.3.6. Location
sharing through AML with Belgian emergency centers”.
6.3.4. Directory management
Which categories of personal data will we use?
* Collected data: Identification and contact information, profession
information.
What justifies this processing activity?
Your consent (art. 6(1)(a) GDPR) to appear in public telephone directories and
directory assistance services.
If you consent to this publication, Proximus might have to further share your
data, as it is necessary to comply with a legal obligation (art. 6(1)(c) GDPR),
namely the obligations foreseen in art. 45 of the Belgian Electronic
Communications Act.
How long will we process this data for this purpose?
We make your data available to the people who draw up and distribute the
telephone directory or offer a directory assistance service via the Central
Number Database as long as you have not changed your preferences in this regard
and/or withdrawn your consent for the inclusion of your business activity.
With whom do we share this data?
Any company which would draw up and distribute a telephone directory or offer a
directory assistance service. This sharing takes places via the Central Number
Database (CNDB).
How can I withdraw my consent?
You can always withdraw your consent, at any time, either by email to
gids@proximus.com or annuaire@proximus.com. You can also withdraw your consent
by using the webform on the Proximus website or by adjusting your privacy
settings in MyProximus Web or MyProximus in the Proximus+ App.
For more information on the various ways to exercise your rights, you can
consult section 11 below.
By default, your contact information is not included in directory services or
telephone directory. If you wish to have your contact information published free
of charge in directory services or telephone directory, we invite you to modify
your preferences in MyProximus. You may also, if you are a natural person,
consent to the inclusion of your professional activity in telephone directories
or directory enquiry services in MyProximus.
If you have expressed the wish to have your contact information published in
directory services or telephone directory, we are required by law to make them
available to the people who draw up and distribute the telephone directory or
offer a directory assistance service via the Central Number Database.
In this case, we provide them with the following information: your phone number,
your name, first name (and, if available, the initial or initials of your first
name) or the name of the company, body or firm and your address. For fixed
electronic communications services, these include the street name, house number,
box number, postcode and municipality where the service is installed. For mobile
services, they include the street name, house number, box number, postcode and
municipality where you are established. If you are a natural person, and
provided we have your consent to do so, we may also disclose to them your
professional activity for inclusion in telephone directories or directory
enquiry services. You have the right to access and rectify your data at any time
via MyProximus.
Note that some directories are likely to offer reverse search features (other
than a search based on your name or location): search by phone number, by
keyword, by professional activity, etc. Please consult the providers of
directory and directory enquiry services for more information on this subject.
We make your data available to the people who draw up and distribute the
telephone directory or offer a directory assistance service via the Central
Number Database as long as you have not changed your preferences in this regard
and/or withdrawn your consent for the inclusion of your business activity. You
can change your preferences and/or withdraw your consent for the inclusion of
your professional activity in telephone directories or directory enquiry
services at any time via MyProximus Web (click on your name or avatar in the top
right corner > My account > Alerts and Privacy) and/or MyProximus in the
Proximus+ App (click on the settings icon in the top right corner > Manage your
account > Alerts and privacy).
6.3.5. Sale of anonymized reports (aka location analytics)
Which categories of personal data will we use?
* Observed or generated data: The network location data used for the analytics
reports have been aggregated, anonymized and extrapolated. No personal data
or data on individuals are used in the context of the analytics reports.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to anonymize the network location
data as foreseen by article 123 of the Act of 13 June 2005 on electronic
communications which allows for the processing of electronic communication data
(including location data) that have been anonymized.
How long will we process this data for this purpose?
As the network location data have been anonymized, they are out of scope of the
GDPR and the obligation to have a determined retention period does not apply.
With whom do we share this data?
The anonymized, aggregated, and extrapolated location analytics reports are part
of the analytics solutions and are shared with customers of the Proximus
MyAnalytics platform. We do not share individual location data.
How can I object?
You can object to the processing of network location data for the creation
anonymized analytics reports in the My Proximus environment where you have the
possibility to submit such a request. You can find this under my account/my
privacy/mobile data network. For more information on alternative ways to
exercise your rights, you can consult section 11 below.
The network location data is aggregated, anonymized and extrapolated to create
an analytics report. No individual personal data or personal preferences are
collected, shared or resold in any way.
We are active in the analytics market and offers solutions revolving around
anonymised location reports based on the network location data of devices on the
Proximus mobile network. Every activity of a mobile phone on the Proximus mobile
telecommunications network generates network location data. This location
information makes it possible to determine the antenna tower through which a
mobile phone is connected to the Proximus mobile network. When a phone is off or
in airplane mode, no network location information is received. Unlike e.g. GPS
data, this is not accurate location data and therefore it can never be deduced
where exactly a cell phone is located within the coverage area. For example, it
cannot be deduced from this data whether a particular person has been to a
particular restaurant, or shop, bakery, …. The network location data are
aggregated, anonymized, and extrapolated before creating the analytics reports.
The mobile location data are processed to create anonymous, aggregated reports
to report on visitor numbers, the origin of visitors and/or the flow of persons
in a certain area or during a certain period. In order to ensure the anonymity
of the analytics reports, a threshold of 30 persons is used. Consequently, an
analytics report can only be created if there are at least 30 persons in an
area.
Local authorities, event organisers or entrepreneurs are interested in such
reports in order to obtain information, for example, about the number of
visitors at a particular location.
6.3.6. Fraud prevention and network security
6.3.6.1. Detection and prevention of telecommunications fraud
Which categories of personal data will we use?
* Collected data: Identification and contact information, IT and telecom
product and service subscription information, Customer interactions.
* Observed or generated data: Internal identifiers, Technical identifiers,
Product and service usage information, Hardware information, Billing
information, Personal data in the context of electronic communications,
Network location data, Consumption habits.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to ensure the security and integrity
of our telecommunications network and services, to protect our reputation and
financial interests, as well as protecting our customers. Regarding personal
data which are traffic data, their processing for this purpose is allowed under
articles 122, §4, paragraph 2, and 125, §1, 7°, of the Belgian Electronic
Communications Act.
The necessity of the processing for the performance of the contract to which you
are a party (art. 6(1)(b) GDPR). Regarding personal data which are traffic data,
their processing for this purpose is allowed under article 125, §2, of the
Belgian Electronic Communications Act.
This processing of some of the traffic data used for this purpose is necessary
for compliance with a legal obligation of Proximus (art. 6(1)(c) GDPR), namely
the obligations to prevent fraudulent activities foreseen in articles 121/8 and
122, §4, paragraph 1, of the Belgian Electronic Communications Act.
How long will we process this data for this purpose?
We retain your personal data for as long as necessary to detect, investigate and
stop cases of telecommunications fraud, and to comply with our legal obligation
to retain certain traffic data, as explained in section 6.3.3.1. “Legal
obligations to store and to share traffic data and other location data other
than traffic data (art. 121/8, 122, art. 123 and art. 127/1, §2 Belgian
Electronic Communications Act)”.
With whom do we share this data?
For this purpose, your personal data will be processed by our internal
departments involved in fraud detection and prevention.
Besides, third-party service providers who support us in monitoring and
analyzing the network traffic may also process your personal data.
To investigate suspicious activities spanning across multiple networks or
countries, we may collaborate and share limited personal data with another
Belgian or foreign telecom operator.
If there's a confirmed case of smishing, we might share specific details related
to confirmed cases of smishing (such as detected malicious domains) to Centre
for Cyber Security Belgium (CCB).
Lastly, we may have to share your personal data with official authorities in the
context of our legal obligations. Please refer to section “6.3.3. Comply with
legal dispositions” for more information.
How can I object?
In the case where the processing of your personal data is based on our
legitimate interest, if you have a specific reason (motivated request), you can
object to our use of your personal data for this purpose. Unless we have
compelling grounds to continue using it, we will stop using it. For more
information on the various ways to exercise your rights, you can consult section
11 below.
As an electronic communications provider, ‘telecommunications fraud’ is a big
concern for us. This notion covers practices where fraudsters abuse our
telecommunications products and services to try to illicitly acquire money or
other advantage from us or from our customers.
To defend ourselves and our customers, we adopt a multidimensional approach to
detect and prevent telecommunications fraud.
To detect anomalies or unusual activities that may indicate fraud, we analyze
information generated in the context of the use of our telecommunications
products and services. This can be done by:
* setting up rules to detect known types of fraud (such as ‘PBX hacking’, where
fraudsters gain unauthorized access to a company’s ‘Private Branch Exchange’
system, allowing them to make long-distance or international calls billed to
the compromised company, or ‘International Revenue Share Fraud’ where
attackers artificially inflate traffic to international premium-rate numbers
causing significant financial losses);
* comparing the current usage of our products and services against historical
data to detect deviations (for example, if one of our customers suddenly
starts making an unusually high number of international calls, it could be a
sign of fraudulent activity);
* monitoring SIM cards activity, for example by detecting frequent changes of
SIM cards in a device which can indicate SIM swapping attacks; or
* monitoring technical identifiers (such as IP addresses or device identifiers)
to detect fraud at the level of the device or unauthorized access to customer
accounts.
When suspicious activities are detected, we need to take actions to protect us
and our customers. Depending on the type of alert, we may take an automated
response to temporarily suspend the affected product or service until our
internal departments in charge of fraud detection and prevention verify the
alert. In other cases, the suspicious activity will first be investigated by the
concerned department who will then define the necessary measures to stop it.
It is also possible that we alert our customers about suspicious activities on
their account so that they can take protective actions.
Likewise, we also define usage thresholds for activities like call duration,
number of SMS sent, or data usage, triggering alerts to our customer when the
threshold has been exceeded. This allows us to detect suspicious, unusual usage
and violations of our General Conditions and prevent you from getting an
unpleasant surprise when you see the amount of your next invoice.
We may also have to report fraudulent activities to competent authorities and
collaborate with them to investigate such cases. Please refer to section “6.3.3.
Comply with legal dispositions” for more information about how we store personal
data and share them with official authorities in the context of our legal
obligations.
Please refer to our specific privacy notice related to network fraud prevention
for further information about how we process personal data in the context of our
actions to combat fraudulent messages over mobile text messages (SMS/MMS).
6.3.6.2. Network and information security
Which categories of personal data will we use?
* Observed or generated data: Personal data generated in the context of
transmitting electronic communications.
What justifies this processing activity?
This processing is necessary for the performance of the contract (article
6(1)(b) GDPR). The processing of personal data in the context of this purpose
that extends beyond what is strictly necessary for the performance of the
contract is based on our legitimate interest (article 6(1)(f) GDPR) to manage
the risks relating to the security of our networks and services as foreseen by
article 107/2 §1 of the Belgian Electronic Communications Act. The processing of
traffic data for this purpose is allowed by Article 122 §4/1 of the Belgian
Electronic Communications Act.
How long will we process this data for this purpose?
The personal data processed in the context of network and information security
can be retained for a period of 12 months in accordance with article 122 §4/1 of
the Belgian Electronic Communications Act except in cases of a potential or
actual attack on the network where the personal data can be retained for as long
as necessary to handle the attack.
With whom do we share this data?
We may share the data with competent governmental authorities in accordance with
article 122 §4/1 of the Belgian Electronic Communications Act.
How can I object?
In the case where the processing of your personal data is based on our
legitimate interest, if you have a specific reason (motivated request), you can
object to our use of your personal data for this purpose. Unless we have
compelling grounds to continue using it, we will stop using it. For more
information on the various ways to exercise your rights, you can consult section
11 below.
Proximus is committed to guarantee the uninterrupted availability of our
services. An important aspect in this commitment is the safeguarding of our
networks through a range of different security measures against any potential
threats that could cause service disruptions. Furthermore, these security
measures also aim to protect the (personal) data of our customers that pass
through our networks, ensuring it remains secure against any threats. Under the
provisions of article 122 §4/1 of the Belgian Electronic Communications Act,
traffic data may be processed for the purpose and in particular to identify the
origin of an attack on the network.
6.3.6.3. Network management
Which categories of personal data will we use?
* Observed or generated data: Personal data generated in the context of
transmitting electronic communications, Network location data.
What justifies this processing activity?
This processing is necessary for the performance of the contract to which you
are a party (art. 6(1)(b) GDPR). This processing of traffic data is allowed by
Article 125 §1. 2° of the Belgian Electronic Communications Act.
How long will we process this data for this purpose?
The personal data processed in the context of this purpose will be retained for
as long as necessary for the transmission of the communication.
With whom do we share this data?
We may share the data with companies that assist us in the context of network
management and network provisioning.
Proximus is committed to ensuring the optimal performance of our
telecommunication networks and services. To this end, we analyse information
relating to the use of the telecommunication networks with the aim of resolving
and/or preventing network issues.
Through this analysis, we can identify when an outage occurs in our mobile
network, when our fixed network is overloaded or threatens to become congested,
or when the quality of certain connections is not optimal. By studying and
analyzing network usage, we can respond quickly to prevent these situations and
perform effective network management.
You can find more information on the management of fixed and mobile internet
traffic on our network through this link.
6.4. When you have ceased to be a customer or user
6.4.1. Archiving purposes
Which categories of personal data will we use?
* Collected data: Identification and contact information, Customer
Interactions, Financial data; Billing information.
* Observed or generated data: History of product and service subscription
information.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to defend our rights in case of
contractual liability claims.
How long will we process this data for this purpose?
10 years after the end of the contractual relationship with Proximus (as
foreseen in art. 2262bis of the Belgian Civil Code).
With whom do we share this data?
This data is not shared with any third-parties.
Sometimes a conflict might arise between us and, for example, one of our (ex-)
customers. While we strive to resolve most such disagreements before further
escalation, regrettably this cannot always be avoided. For this reason, we need
to keep an archive of different categories of personal data relating to your
contractual relationship in order to potentially defend our rights and interests
in case of legal steps being undertaken.
6.4.2. Contract termination purposes
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics, Family and household composition, Financial data, Customer
interactions.
* Observed or generated data: Internal identifiers, Technical identifiers,
Product and service subscription information, Hardware information, Billing
information.
What justifies this processing activity?
This processing is necessary for the performance of the contract to which you
are a party (art. 6(1)(b) GDPR).
How long will we process this data for this purpose?
We will process the personal data listed above for this purpose until all
outstanding amounts have been paid and the rented Proximus equipment has been
returned.
With whom do we share this data?
In case you decide to switch providers, we will share your personal data with
your new operator of choice.
When you decide to terminate your contract(s) with Proximus, we will process
your personal data to manage the termination process. This personal data,
collected when you became a Proximus customer and through your use of Proximus
products and services, includes your name, address, telephone number, email
address, customer number, the products, and services you wish to terminate, and
any other relevant identifiers linked to your services and products.
You have the option to either cancel your products and services partially,
entirely or to switch to another provider. If you choose to switch providers, we
will facilitate the transfer of your products and services using your easy
switch ID. This applies to fixed internet, landline, mobile subscriptions, and
prepaid cards. We will ask you to provide the necessary information, such as
your new operator’s details and any relevant identifiers, to ensure a smooth
transition. More information about the termination procedure can be found on our
website.
Once you have cancelled your subscription(s), you will receive a confirmation
along with all relevant information regarding the cancellation and related
practicalities. For example, if you have rented any devices from Proximus (such
as a TV box, b-box, internet box, mobile coverage extender, etc.), you will be
informed of the return procedure. If you have a contract for a joint offer
(mobile subscription with a mobile phone linked to your subscription) and your
contract is less than 24 months old, you will be billed for the residual value
of your mobile phone.
After terminating all your contracts with Proximus, we may still process your
personal data for other purposes. You can find more information about some of
these purposes in sections “6.3.3. Comply with legal dispositions”, “6.4.1.
Archiving purposes”, “7.3.1. Ex-customer consent acquisition campaigns”, and
“7.3.2. Ex-customer ‘win-back’ actions”.
7. For what marketing and sales purposes do we use your personal data?
In this section you can find more information about the marketing and sales
purposes for which we process personal data. The purposes are divided in
different categories. For each purpose there is a summary table containing the
most important information such as what categories of personal data, the legal
basis on which the processing is based, the retention period of the personal
data and where relevant the categories of third parties with whom the personal
data is shared or information about how to exercise specific data subject rights
in case it differs from the general ways to exercise data subjects rights that
are explained in section 11 of this privacy notice. The summary table is
followed by an explanation of the purpose.
7.1. When you’re not a customer yet
7.1.1. Collection of contact data
7.1.1.1. Direct collection of contact data via events, …
Which categories of personal data will we use?
* Collected data: Identification and contact information.
What justifies this processing activity?
Your consent (art. 6(1)(a) GDPR) to collect your data when you are attending an
event for a specific purpose (e.g. to manage your subscription to a certain
event, to participate to a contest or a game, to keep you informed on (a
specific) product(s) or service(s),…).
How long will we process this data for this purpose?
Your contact data will be stored and processed for this purpose for 3 years
after you have given your consent.
A proof of your consent will be stored for the duration of the consent (3 years)
+ 5 years, which is the prescription period for any actions before the Belgian
Data Protection Authority.
With whom do we share this data?
Depending on the purpose for which your contact details were collected, your
data may be shared with call centers working on our behalf (in the context of
telemarketing campaigns), subsidiaries of the Proximus Group or other partners.
How can I withdraw my consent?
You can always withdraw your consent, at any time, to the processing of your
contact details, collected via an event, by addressing your request to Proximus
DPO at the e-mail address privacy@proximus.com. For more information on the
various ways to exercise your rights, you can consult section 11 below.
We regularly organize events or attend to events to present and promote new or
existing products and services.
If we organize an event for which advance registration is required, certain
contact data will be requested from you at the time of registration. This
information will be used to contact you in the run-up to and possibly also after
the event. If you have agreed to this, the data can also be used to keep you
informed about certain products and services.
When you attend an event organized by us or where we are present, you may also
voluntarily leave your contact data, for example in order to be kept informed of
a product or service that interests you or similar products and services, or
because you are taking part in a contest.
The collection and further processing of your contact data will be based on your
consent.
Depending on the purpose for which your contact data is collected, the retention
period and any parties with whom your contact data is shared will also vary. You
will be informed of the specific retention period and the specific partners with
whom your personal data will be shared prior to the collection of your contact
data.
It is always possible to withdraw your consent for the processing of your
contact data. If there is a specific e-mail address to which your request can be
sent, you will be informed about this prior to the collection of your contact
data. In all other cases, you can send your request to privacy@proximus.com.
Please refer to section 11 below for more information about your right to
object.
7.1.1.2. Acquisition of prospect data relating to potential residential
customers
Which categories of personal data will we use?
* Obtained data: Identification and Contact information, Personal
characteristics, Segmentation information.
What justifies this processing activity?
Your consent (art. 6(1)(a) GDPR), acquired via the third parties involved in the
collection of your personal data.
How long will we process this data for this purpose?
In practice, these third parties deliver monthly databases which we use only in
the context of one campaign – we do not import this data into our own systems
for further reuse.
The telecommunications sector is competitive, and customers are more and more
open to changing operators to get a better deal. For that reason, we strive to
broaden our spectrum of new potential customers on a regular basis.
On top of our actions to collect data of potential customers via our own actions
and events, we also acquire some data for these purposes from third parties. In
practice, we call upon the services of a few such third parties:
* TheWaveNew window (formerly known as Gowie)
* EDMNew window (part of The Data Agency)
* FiberklaarNew window and UnifiberNew window (Proximus joint ventures
deploying fiber and organizing prospecting actions in this domain)
* bpostNew window
In practice, these third parties deliver monthly databases which are only used
in the context of one campaign – we do not import this data into our own systems
for further reuse.
How is this data collected? These third parties might have their own sources
(which are subject to the same stringent rules on consent collection) or
organize contests and events of their own, through which your consent might be
collected.
For more information on the actual marketing activities based on the data
acquired, among others, from third parties, see the section “7.1.2. Proximus-led
commercial prospection” below.
7.1.1.3. Acquisition of data relating to potential and existing professional
customers
Which categories of personal data will we use?
* Obtained data: Identification and contact information (e.g. list of company
directors, shareholders, authorized representatives and contact persons,
their first name, last name, business address, fixed and mobile phone number,
email address, website), Personal characteristics, Profession information.
What justifies this processing activity?
Personal data about professional customers and prospects acquired from third
parties may be processed by us for different purposes (see below). The lawful
bases for such processing are detailed in the relevant sections of this privacy
notice but can be summarized as follows:
* Our legitimate interest (art. 6(1)(f) GDPR) to ensure that we do business in
a safe way by better understanding the companies with which we are or may be
entering into business; and to promote our brand, as well as relevant
products and services, to existing customers.
* Your consent (art. 6(1)(a) GDPR), acquired by the third parties involved in
the collection of your personal data or directly by us.
How long will we process this data for this purpose?
The retention periods of the personal data acquired from third parties depends
on the purposes for which we process it (see below). The respective retention
periods are detailed in the relevant sections of this privacy notice.
How can I object?
You can always object (without motivation) to the use of your personal data for
direct marketing purposes, including profiling to the extent that it is related
to such direct marketing. If you have a specific reason (motivated request), you
can object to our use of your personal data for the other purposes described
below. Unless we have compelling grounds to continue using it, we will stop
using it. For more information on the various ways to exercise your rights, you
can consult section 11 below.
To strive in the telecommunications and IT industry, we must ensure that we
carry out business in a safe and efficient way. This is why we collect and
process data in order to know the companies we are in business with or might
enter into business with, ensure that these companies are financially sound, and
spread awareness around our products, services, offers and promotions by
contacting them directly.
If you are the director, shareholder, authorized representative or contact
person of an existing or potential professional customer of ours, we may process
personal data about you such as your name, business address, phone number, email
address, title and function, language, date of birth, etc.
If you represent a one-person company or exercise a liberal profession, we may
process company information such as financial information, segmentation
information, business information, product and service subscription information
which qualify as personal data and fall within the scope of the GDPR.
We acquire some of this data from third parties, including:
* Graydon/creditsafeNew window
* InoopaNew window
* Smart ProfileNew window
* Trends Business InformationNew window
* UnizoNew window
We acquire from these third parties and use the data about existing and
potential professional customers and their representatives for various purposes:
* Collect additional information about professional customers in order to match
it with the existing data in our database and ensure this data remains
accurate and up to date (e.g. that companies’ details and contact information
are up to date, that closed or merged legal entities are removed, etc.).
* Categorize companies in order to obtain insights about their financial
situation (e.g. their creditworthiness, solvability, liquidity, suggested
credit-limit) or about their potential interests in IT and Telco products.
* Screen companies financially to ensure that we do business with companies
which are financially solid and not likely to go bankrupt, have delays in
payments, etc.
* Manage credits and take informed decision about granting a credit and
defining the credit-limit in light of the financial situation of the company.
* Contact the company’s representative or contact person by e-mail or by phone
to promote our products, services, offers and promotions that may be of
interest to the company. The way we process personal data for direct
marketing towards existing customers is further detailed in section “7.2.2.
Promotion of our products and services” and towards prospect customers in
sections “7.1.2. Proximus-led commercial prospection” and “7.1.3. Commercial
prospection led by indirect sales partners”.
Depending on the circumstance, the third party may collect the information
directly from the concerned persons via surveys, events or phone calls. In
addition, these third parties have their own sources which include official
and/or public sources (such as the Crossroads Bank for Enterprises, Belgian
Gazette, Chamber of Commerce, National Social Security Office and the Belgian
National Bank) or private sources (such as the third party’s partners or
customers).
7.1.2. Proximus-led commercial prospection
Which categories of personal data will we use?
* Collected or obtained data: Identification and contact information.
What justifies this processing activity?
Your consent (art. 6(1)(a) GDPR) to be kept informed about Proximus’ offers and
promotions.
How long will we process this data for this purpose?
Your contact data will be stored and processed for this purpose for 3 years
after you have given your consent.
A proof of your consent will be stored for the duration of the consent (3 years)
+ 5 years, which is the prescription period for any actions before the Belgian
Data Protection Authority.
With whom do we share this data?
Proximus’ controlled call centers and companies involved in the printing and
distribution of promotional flyers, acting as processors (in the context of
these campaigns).
How can I withdraw my consent?
Changed your mind after giving your consent? Please use the unsubscribe link in
our e-mails, reply STOP if you receive a text message, or contact the Proximus
DPO at the e-mail address privacy@proximus.com if you no longer wish to be
called, contacted via digital channels, or receive postal mail from us. For more
information on alternative ways to exercise your rights, you can consult section
11 below.
Like any other commercial company, we have a vested interest in promoting our
products and services, brand, image, and promotions to potential customers who
clearly expressed an interest in receiving such communications. To achieve these
goals, we will process personal data of prospects who have given their consent
to spread awareness around these offers and promotions by contacting them
directly, be it by phone, postal mail or e-mail.
We might directly acquire your data and consent (e.g., via consent collection
campaigns during music festivals) or we might acquire these data via a
third-party (see section “7.1.1.2. Acquisition of prospect data relating to
potential residential customers” above).
We are committed to only contacting you at reasonable intervals. For example,
telemarketing campaigns which we control will only include a potential
residential customer in one campaign per semester, while a potential SME
customer might be included on a quarterly basis.
7.1.3. Commercial prospection led by indirect sales partners
On top of our own commercial prospection activities, we also call upon the
services of companies specialized in sales to their own audiences, via different
channels. These companies apply their own expertise and use their own databases
to make sales for multiple different customers across different sectors.
The following companies are authorized to sell our products and services, among
the products of their other customers:
* U-SmileNew window
* NEO GroupNew window
* OnlyooNew window
The following companies are also authorized to sell selling our products and
services (among the products of their other customers) specifically on their own
website on the internet:
* AstelNew window
* DPG MediaNew window
* E-contractNew window
* Mijn verhuisNew window
* Mobiel WerktNew window
* SmoovedNew window
* WikipowerNew window
A few important notes:
* These indirect sales partners act – for their prospecting activities – as
separate controllers.
* The sales representatives from these companies must respect a basic set of
rules set out in the “Proximus Indirect Sales Charter”, but are otherwise
acting in total freedom in the context of these prospecting activities – we
have no control over their sales campaigns, whom they target, …
* In any contact, these sales representatives must present themselves as
working for one of these indirect sales partners, and NOT for Proximus.
* These companies use their own databases, for the benefit of multiple
different clients – Proximus does not deliver any personal data to these
indirect sales partners.
* Have you been contacted by one of these indirect sales partners and want to
exercise your data subject rights? You can contact the specific partner
directly.
7.1.4. Proximus Newsletters
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics.
What justifies this processing activity?
Your consent (art. 6(1)(a) GDPR) to use your data for the newsletter when you
subscribe to the newsletter as a prospect.
How long will we process this data for this purpose?
Your data will be processed for 3 years as from the date of the consent.
With whom do we share this data?
Our marketing email providers.
How can I object?
If you want us to stop sending you newsletters, you can do so by using the
unsubscribe link in Proximus e-mails. For more information on alternative ways
to exercise your rights, you can consult section 11 below.
We have a strong interest in promoting our products, services, and promotions to
existing customers and prospects who subscribed to the newsletter. We therefore
process your identification and contact data to send out newsletter emails,
which contain more information on those products, services, and promotions.
Your personal data is shared with our marketing email providers. These mail
service providers take care of sending out the newsletters.
7.2. When you are a customer or user
7.2.1. Creation and enrichment of customer profile
7.2.1.1. Basic segmentation of our customers for direct marketing purposes
Which categories of personal data will we use?
* Collected (or obtained) data: Identification and contact information,
Personal characteristics, Family and household composition, Customer
interactions.
* Observed or generated data: Product and service subscription information.
* Derived data: Segmentation information, Leisure and personal interests.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to further promote our brand, as
well as relevant products and services, to existing customers.
How long will we process this data for this purpose?
For five years after the end of your contractual relationship with Proximus.
How can I object?
You can always object (without motivation) to the use of your personal data for
marketing profiling purposes, as well as restrict the channels via which you
wish to be contacted, via MyProximus Web and/or MyProximus in the Proximus+ App
and opting out from “Marketing offers and personalized content”. For more
information on alternative ways to exercise your rights, you can consult section
11 below.
When it comes to direct marketing practices, a company has generally two
choices. The first one is to “carpet bomb” its whole eligible customer base,
meaning to target everyone with the same marketing message. This is costly and
counterproductive for the company, given the limited relevance of such a single
common message for most of the target audience, but can also be frustrating for
the recipients who might feel spammed with entirely irrelevant offers and
promotions.
The second approach is to limit the target audience to the persons to whom your
message might actually appeal. This involves having an idea of what might appeal
to a specific customer. This in turn requires processing of personal data, such
as the products already owned by a customer or the area they live in, to only
address the customers to whom a specific offer or promotion might apply. This
approach allows to limit the target audience to the customers who are eligible
for - and might at least potentially be interested in - a specific offer or
promotion. Unsurprisingly, this is our preferred approach.
In practice, we use different types of personal data when preparing a target
audience for a specific marketing campaign.
On a more general level, each Proximus customer belongs in one specific market
segment. To illustrate this concept, imagine a person subscribing for a
family-oriented Flex pack, with multiple mobile phones for their family members.
Such a customer will belong to the ‘Residential (as opposed to professional) –
Family’ segment. A single customer can only fit in one unique market segment of
this type.
While that level of segmentation provides a first way of excluding some
customers to whom a specific campaign would be irrelevant, it is not sufficient
to achieve a satisfactory level of relevance for each campaign.
When preparing a campaign, we will thus also consider the information already
being processed on our customers. Do you already own a mobile phone subscription
with us? You will be excluded from any campaign promoting mobile subscriptions
to customers with only a TV or internet line. Have you recently acquired an
expensive phone in a joint offer with a Proximus subscription? You will be more
likely to be included in a campaign promoting phone insurance. This allows for
campaigns which are much more relevant than simply based on a customer’s
macrosegment.
Finally, the highest level of campaign personalisation involves the actual
preferences of the customers. The determination of preferences mostly happens
with your consent (see section “7.2.1.2. Consent-based segmentation of our
customers for direct marketing purposes”); however, it is possible that we build
a limited preference profile based on your participation in the Proximus reward
program (Proximus For You) or based on your input in explicit surveys.
What are those preferences? Based on the data sources mentioned above, we will
slowly build a good idea of your interests. These interests and preferences will
be represented in a score from 1 to 10 assigned to your customer profile for
different types of dimensions. Did you mention in a specific survey that you
attended multiple festivals in recent years? Your ‘music lover’ score might
increase. Did you participate in multiple gaming-related contests in the context
of the “Proximus For You” reward program? Similarly, your ‘gaming lover’ score
might also be impacted by this information.
Important note: The vast majority of this preference scoring takes place only
with your consent, as the main data used to derive your preferences is your
usage of our products and services, as well as the type of websites or
applications you use (see section “7.2.1.2 Consent-based segmentation of our
customers for direct marketing purposes”).
You can always object to the use of your personal data for marketing profiling
purposes, as well as restrict the channels via which you wish to be contacted,
via MyProximus Web (click on your name or avatar in the top right corner > My
account > Alerts and Privacy) and/or MyProximus in the Proximus+ App (click on
the settings icon in the top right corner > Manage your account > Alerts and
privacy) and opting out from “Marketing offers and personalized content”. For
more information on alternative ways to exercise your rights, you can consult
section 11 below.
7.2.1.2. Consent-based segmentation of our customers for direct marketing
purposes
Which categories of personal data will we use?
* Observed or generated data: Personal data generated in the context of
transmitting electronic communications, TV viewing data.
* Derived data: Leisure and personal interests, Preference profile.
What justifies this processing activity?
Your consent (art. 6(1)(a) GDPR) to the use of these types of data for the
further personalization of our offers and promotions.
How long will we process this data for this purpose?
For five years after the end of your contractual relationship with Proximus.
How can I withdraw my consent?
You can always withdraw your consent, at any time, to the use of your personal
data for marketing purposes, as well as restrict the channels via which you wish
to be contacted, via MyProximus Web and/or MyProximus in the Proximus+ App. For
more information on alternative ways to exercise your rights, you can consult
section 11 below.
With your consent, we can go a step further in the customization of our offers
and promotions, by enriching your preference profile. For more basic information
on how we prepare customer preference profiles for the purposes of building
target audiences for marketing campaigns, see section “7.2.1.1. Basic
segmentation of our customers for direct marketing purposes” above.
With your consent, we can adapt our offers and your preference profile on the
basis of:
* Certain websites or applications that you visit or use. We are able to
identify the names of these websites or applications based on an analysis of
your landline and/or mobile internet traffic as long as you have a Proximus
mobile subscription and/or a Proximus internet connection. This allows us to
more accurately identify your areas of interest, activities and buying
habits. This operation is based exclusively on a limited list of websites and
applications. Websites and applications of a sexual, religious or political
nature, for example, are excluded. The sole purpose of this operation is to
refine the products and services that we offer you. For example, if you
regularly visit the Jupiler Pro League website, this information can help us
refine our commercial proposals. You might therefore be more interested in
our sports package than in our series package. Under no circumstances do we
collect the details of the pages visited/applications used. For example, if
you are listening to music via Spotify, we will not be able to identify the
artist you are listening to.
* Data on the usage of your Proximus services (TV, mobile and landline
telephony, and/or internet). When you make a call, we generate data such as
the duration of your calls, the start and end time, the numbers called, the
date, etc. For example, if you make a large number of international calls,
this information can help us refine our commercial proposals. Accordingly, we
may offer you an "international call" option the next time the company
contacts you. We can also identify the types of programs you watch, record or
rent via our TV Proximus service (Pickx) to identify your areas of interest.
Similarly, we can identify the model of phone you use to connect to our
mobile network or the type of device connected to your modem (printer, game
console, mobile phone, etc.), as well as the status of your WiFi connection.
For example, if we detect that you have a game console, we can provide you
with a technical solution that enables you to improve your gaming experience.
Important note: If there are several users (family members, co-tenants, etc.)
sharing a single Proximus subscription (internet connection, TV, etc.), the data
on all these users will be combined. This will also be the case if you are the
holder of several mobile subscriptions, unless the end users have identified
themselves by creating a MyProximus account. When, as the customer, you give
your consent to these processing activities, you should therefore also inform
the other users of your choice.
You can always withdraw your consent to the use these personal data for
marketing profiling purposes via MyProximus Web (click on your name or avatar in
the top right corner > My account > Alerts and Privacy) and/or MyProximus in the
Proximus+ App (click on the settings icon in the top right corner > Manage your
account > Alerts and privacy) and opting out from one or more sources of data
under “Tailor-made Proximus offers”. For more information on alternative ways to
exercise your rights, you can consult section 11 below.
7.2.1.3. Consumption profiling for the calculation of the most advantageous
tariff plan
Which categories of personal data will we use?
* Observed or generated data: Billing information, Product and service
subscription information, Product and service usage information, Consumption
habits.
What justifies this processing activity?
This processing activity is necessary for compliance with a legal obligation of
Proximus (art. 6(1)(c) GDPR), namely the obligations foreseen in articles. 109
and 110/1 of the Belgian Electronic Communications Act.
How long will we process this data for this purpose?
This most advantageous tariff plan is calculated on the basis of your
consumption profile for the last year. Only data from the last calendar year is
relevant for this purpose.
Belgian telecommunications operators have an obligation to indicate, at least
once a year and on a durable medium, which tariff plan would be most
advantageous to the users based on their consumption profile. In addition, the
users may require the operator – at any time - to indicate which tariff plan is
the most advantageous for them. The operator must answer within two weeks at the
latest.
In order to be able to provide you this information within that short timeframe,
we need to continually establish your consumption profile for the last calendar
year.
Keep in mind that since this is necessary for Proximus’ compliance with a legal
obligation, there is no possibility to object to this processing activity!
7.2.1.4. Market insights analysis
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics, Family and household composition.
* Observed or generated data: Product and service subscription information,
Customer interactions.
* Derived data: Leisure and personal interests, Preference profile.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to extract current market insights,
based on the data already processed for other purposes, and to monetize these
insights without having impact on the privacy of the concerned data subjects.
How long will we process this data for this purpose?
Once the data is anonymised, the output will be stored indefinitely. The actual
personal data will be processed in line with the segmentation purposes.
As most companies, we have an interest to build our market intelligence by
analysing the data we store on our customers and extract statistical insights
into e.g., the geographical spread of customers with a specific product, the
proportion of customers with a specific preference profile in a certain age
range, …
How will we do this? It will of course depend on the exact scenario, but you can
imagine the following example: we would like to determine the proportion of
“football lovers” in a given municipality. In such a case, we would select
customers living in that specific municipality which, first of all, have any
sort of preference profile, and then count specifically how many of these
preference profiles reflect an interest in football. The final output of this
exercise would be a simple statistical report on the proportion of customers
with a football preference compared to the entire customer base for that
specific municipality.
These anonymous reports could then feed our general market intelligence, leading
to potentially more effective advertising and marketing campaigns, but could
also potentially be sold to other companies, without affecting the privacy of
our customers.
7.2.2. Promotion of our products and services
7.2.2.1. Promotion of our products and services via telephone and e-mail
campaigns
Which categories of personal data will we use?
* Collected data: Identification and contact information.
* Derived and inferred data: Product and service subscription information,
Leisure and personal interests, Preference profile.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to further promote our brand, as
well as relevant products and services, to existing customers.
How long will we process this data for this purpose?
For five years after the end of your contractual relationship with Proximus.
With whom do we share this data?
Call centres working on our behalf, acting as processors (in the context of
telemarketing campaigns).
How can I object?
If you want us to stop contacting you for marketing purposes, please use the
unsubscribe link in our e-mails, reply STOP if you receive a text message from
us, or contact the Proximus DPO at the e-mail address privacy@proximus.com if
you no longer wish to be called by us, be contacted via digital channels or
receive postal mail from us. You can also object to the use of your personal
data for marketing purposes, as well as restrict the channels via which you wish
to be contacted, via MyProximus Web and/or MyProximus in the Proximus+ App. For
more information on alternative ways to exercise your rights, you can consult
section 11 below.
Like any other commercial company, we have a vested interest in promoting our
products and services, brand, image, and potential offers to existing customers.
To achieve these goals, we will process customer’s personal data to spread
awareness around these offers and promotions by contacting them directly, be it
by phone or per e-mail.
In practice, these activities take place in two stages:
* First, a list of customers to be contacted in the context of a specific
campaign is prepared. Whether you are included in a campaign will depend on
the goal of the campaign (what product or service we are promoting) and your
preference profile, if there exists one (to determine whether you would be
interested in the product or service being promoted, or whether you qualify
for a specific action). In some cases, we might launch general campaigns
which will target all customers indiscriminately.
* Once the target list has been prepared and you have been included as a
potential target, we will process your identification and contact information
(relevant to the communication channel used for this specific campaign, e.g.,
your e-mail address for an e-mail campaign) to deliver the marketing message.
We are committed to only contacting you at reasonable intervals, with different
intervals per channel of communication.
It goes without saying that you – the customer – remain in absolute control of
your preferences when it comes to Proximus’ marketing outreach. You can always
object to the use of your personal data for marketing purposes, as well as
restrict the channels via which you wish to be contacted, via MyProximus Web
(click on your name or avatar in the top right corner > My account > Alerts and
Privacy) and/or MyProximus in the Proximus+ App (click on the settings icon in
the top right corner > Manage your account > Alerts and privacy) and opting out
from “Marketing offers and personalized content”. For more information on
alternative ways to exercise your rights, you can consult section 11 below.
7.2.2.2. Promotion of our products and services online (e.g. on social media)
Which categories of personal data will we use?
* Collected data: Personal characteristics.
* Derived and inferred data: Leisure and personal interests, Preference
profile.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to further promote our brand, as
well as relevant products and services, to existing customers.
How long will we process this data for this purpose?
Your personal data will be stored and processed for this purpose as long as you
are a Proximus customer, plus 5 years after the end of your contractual
relationship with Proximus.
With whom do we share this data?
We do not share your personal data with the social media platform but determine
a specific target audience and ask the platform to show a specific advertisement
to this target audience.
How can I object?
You can change your settings for advertising via MyProximus Web and/or
MyProximus in the Proximus+ App or via www.youronlinechoices.com New window, or
contact the Proximus DPO at the e-mail address privacy@proximus.com. For more
information on alternative ways to exercise your rights, you can consult section
11 below.
We can display advertisements about our products and services on social media
platforms.
If you have a Facebook, Instagram, Twitter, LinkedIn or Google account, we can
display advertisements on these social media platforms about products, services
and promotions that might interest you. To this end, we determine a specific
target audience by using a number of parameters such as age, gender, interests,
and share this target with the provider of a social media platform and ask the
provider to show a specific advertisement to this target audience. For example,
we may ask a social media platform to show a Proximus advertisement to men
between 20 and 25 years with an interest in football. It is important to note
that we do not share your personal data with the provider of the social media
platform.
If you don't want such online advertisement, you can always object to the use of
your personal data for marketing purposes or restrict the channels via which you
receive information about our products and services, via MyProximus Web (click
on your name or avatar in the top right corner > My account > Alerts and
Privacy) or MyProximus in the Proximus+ App (click on the settings icon in the
top right corner > Manage your account > Alerts and privacy). You can also
change your preference concerning such online advertising via the website
www.youronlinechoices.comNew window. For more information about your data
subject rights you can consult section 11 below.
If you visit our Facebook page, Facebook can collect personal data about you and
link it with other personal data Facebook has collected about you elsewhere.
Facebook can use this data to provide us anonymous statistics about the people
who visit our Facebook page. For more information and to exercise your privacy
rights concerning the data collected by Facebook, please consult Facebook's
privacy noticeNew window.
Lastly, we also use advertising cookies and trackers on our websites and mobile
applications to collect information about your browsing habits on our websites
and applications and show you ads on other websites for products and services
you may be interested in. Such processing is carried out based on your consent.
If you want more information about our use of advertising cookies and how to
adapt your preferences or withdraw your consent, please consult our cookie
policy.
7.2.2.3. Promotion of our products and services on Pickx (Proximus TV)
Which categories of personal data will we use?
* Collected data: Identification and Contact information, Personal
characteristics.
* Observed or generated data: Technical identifiers, Subscription information.
* Derived data: Consumption habits, Leisure and personal interests, Preference
profile.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to further promote our brand, as
well as relevant products and services, to existing customers.
How long will we process this data for this purpose?
Identification and contact information and personal characteristics will be
processed for as long as you are a Proximus customer.
Other data processed in the context of this purpose is stored for 2 years as of
the collection of the data.
With whom do we share this data?
Partners helping us to deliver Pickx services and ThinkAnalytics, the partner
who provides us with the recommendation engine in the context of movie or TV
program recommendations.
How can I object?
You can always object (without a motivation) to the use of your personal data
for this purpose yourself via the options menu on your TV screen or via
MyProximus Web or MyProximus in the Proximus+ App (see section 11 below). For
more information on alternative ways to exercise your rights, you can consult
section 11 below.
Like any other commercial company, we have a vested interest in promoting its
products and services, brand, image, and potential offers to existing customers.
To achieve these goals, we will process customer’s personal data to provide you
with personalized recommendations relating to Pickx services (including movie or
TV program recommendations) and other Proximus products and services.
It goes without saying that you – the customer – remain in absolute control of
your preferences when it comes to our marketing outreach. You can always object
(without a motivation) to the use of your personal data for this purpose
yourself via the options menu on your TV screen or via MyProximus Web (click on
your name or avatar in the top right corner > My account > Alerts and Privacy)
or MyProximus in the Proximus+ App (click on the settings icon in the top right
corner > Manage your account > Alerts and privacy) . For more information on
alternative ways to exercise your rights, you can consult section 11 below.
7.2.2.4. Proximus Newsletters
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to further promote the brand, as
well as relevant products, services and promotions, to existing customers.
How long will we process this data for this purpose?
Your data will be processed for as long as you are a Proximus customer + 5 years
after a person has ceased to be a Proximus customer.
With whom do we share this data?
Our marketing email providers.
How can I object?
If you want us to stop sending you newsletters, you can do so by using the
unsubscribe link in Proximus e-mails. You can always object (without a
motivation) to the processing of your personal data for the purpose of sending
out newsletters in MyProximus Web or MyProximus in the Proximus+ App where you
have the possibility to submit such a request. For more information on
alternative ways to exercise your rights, you can consult section 11 below.
We have a strong interest in promoting our products, services, and promotions to
existing customers and prospects who subscribed to the newsletter. We therefore
process your identification and contact data to send out newsletter emails,
which contain more information on those products, services, and promotions.
Your personal data is shared with our marketing email providers. These mail
service providers take care of sending out the newsletters.
7.2.2.5. Proximus For You – the Proximus Loyalty Program
Note: This processing activity is not applicable to customers of the Scarlet
brand.
Which categories of personal data will we use?
* Collected data: Identification and contact information.
* Derived data: Leisure and personal interests.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to organize a loyalty program
offering advantages and surprises to members.
How long will we process this data for this purpose?
The personal data processed in this context will be retained for a period of 2
years after your participation to a contest or deal.
With whom do we share this data?
The contact and identification information can be shared with partners that
collaborate with us in the context of the Proximus For You Program to provide
the deals, gifts and events to members.
How can I object?
You can always object (without a motivation) to receiving communications in the
context of the Proximus For You Loyalty program yourself in the privacy settings
via MyProximus Web (click on your name or avatar in the top right corner > My
account > Alerts and Privacy) and/or MyProximus in the Proximus+ App (click on
the settings icon in the top right corner > Manage your account > Alerts and
privacy). For more information on alternative ways to exercise your rights, you
can consult section 11 below.
Proximus For You is our loyalty program offering members numerous exclusive
advantages and surprises. The Proximus For You experiences give members the
chance to win unforgettable experiences through fun and original contests. The
Proximus For You deals grant members the opportunity to benefit from exceptional
discounts with our partners, to receive surprises and gifts and have access to
exclusive Proximus events. The surprises and gifts can be personalized based on
a member’s areas of interest through the list of contests, deals and events a
member showed interest in. These areas of interest are also used for the purpose
of consent-based profiling of Proximus customers for direct marketing purposes
in case you have provided your consent to this purpose. You can consult the
section on that purpose for more information on the processing of personal data
in the context of consent-based profiling of Proximus customers for direct
marketing purposes.
In the context of the Proximus For You loyalty program we can send members email
and SMS communications as well as push notifications.
7.2.3. Other uses of your customer profile
7.2.3.1. Personalised advertising on TV
Note: This processing activity is not applicable to customers of the Scarlet
brand.
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics, Customer interactions.
* Observed or generated data: Consumption habits.
* Derived data: Segmentation information.
What justifies this processing activity?
Your consent (art. 6(1)(a) GDPR) to collect personal data and use it for
personalized advertising on the Pickx service.
How long will we process this data for this purpose?
Identification and contact information and personal characteristics will be
processed for as long as you are a Proximus customer.
Data related to your consumption habits and segmentation information will be
stored for 1 year upon collection of the data.
Data related to your interactions as a customer with Proximus will be kept for 2
years upon the date of the interaction.
How can I withdraw my consent?
You can always withdraw your consent, at any time, by adjusting your privacy
settings in MyProximus Web or MyProximus in the Proximus+ App. For more
information on alternative ways to exercise your rights, you can consult section
11 below.
By obtaining your consent, we offer you the opportunity to benefit from
customized advertising on our TV services, here referred to as Pickx. These ads
mainly relate to products and services of third-party companies.
With your consent, we have the possibility to further customize the
advertisements on Pickx. This customization is done on the basis of different
data groups:
* Administrative data which you have provided to us (language, age, postal
code, Proximus services used, etc.).
* We collect information on the use you make of Pickx. These elements consist
of information on your use of the Pickx service via your decoder, the Pickx
application and its TV service on the Web. This information includes TV
programs, films and series that you watch, record or rent (sports, cooking,
news, children's programs, etc.) and the actions you perform from your remote
control.
* Please note that the analysis of all the programs consulted via the Pickx
platform never concerns sexual, religious, or political content.
* Data which we have purchased from external firms, such as statistical data on
the neighborhood in which you live, whether the homes have gardens, the type
of household you have, etc.
If there are several users (family members, co-tenants, etc.) sharing the same
Pickx subscription, the areas of interest identified will only apply to the
subscriber’s personal profile. This is because the technology is not capable of
detecting who is watching a specific type of program. For example, if a member
of your family regularly watches Jupiler Pro League matches, football will be
added as an area of interest to your profile.
When you give us your consent, you should therefore also inform the other users
of your choice.
And what if I change my mind? No problem. You can change your consent at any
time via the "privacy" settings of MyProximus Web (click on your name or avatar
in the top right corner > My account > Alerts and Privacy) and/or MyProximus in
the Proximus+ App (click on the settings icon in the top right corner > Manage
your account > Alerts and privacy) . For more information on alternative ways to
exercise your rights, you can consult section 11 below.
7.2.3.2. Targeted advertising on web and in mobile applications (Ads & Data)
Note: This processing activity is not applicable to customers of the Scarlet
brand.
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics, Customer interactions.
* Observed or generated data: Consumption habits.
* Derived data: Segmentation information.
What justifies this processing activity?
Your consent (art. 6(1)(a) GDPR) to collect personal data and transmit them to
Ads & Data to automatically display targeted ads on websites and applications in
the Ads & Data portfolio.
How long will we process this data for this purpose?
Your identification and contact information and personal characteristics will be
processed for as long as you are a Proximus customer.
Data related to your consumption habits and segmentation information will be
stored for 1 year upon collection of the data.
Data related to your interactions as a customer with Proximus will be kept for 2
years upon the date of the interaction.
With whom does we share this data?
Ads & Data, as a joint controller.
How can I withdraw my consent?
You can always withdraw your consent, at any time, in the following ways: i) by
adjusting your cookie settings so that we no longer collect data related to your
use of our websites and mobile applications through the Proximus website or the
Proximus app; or ii) by adjusting your privacy settings in MyProximus Web or
MyProximus in the Proximus+ App. For more information on alternative ways to
exercise your rights, you can consult section 11 below.
Proximus and Ads & Data (Harensesteenweg 226, 1800, Vilvoorde, Belgium, KBO:
0809.309.701) process your personal data as joint controllers for purposes of
targeted advertising on websites and applications in the Ads & Data portfolio.
Ads & Data, an organisation ensuring the collaboration between Belgian providers
of advertising space, builds up target groups for advertisements and show
personalised advertisements on digital media and television, together with
Proximus.
The categories of personal data that Proximus and Ads & Data collect and use,
subject to your consent, are:
* Personal data you have shared directly with us, such as name, e-mail address,
age, gender, postal code.
* Data collected during your visit to and use of our websites and mobile
applications such as unique identifiers (e.g. your IP address), the URL of
the pages visited, click behaviour with regard to viewed articles or
advertisements.
* Derived data: these are interests that we derive from data at its disposal
such as age, gender, postal code, Proximus products and services, ... and
possibly your viewing behaviour, characteristics based on statistical and
public data. Based on this information, we can for instance deduce that you
are a “cooking enthusiast”.
This collaboration means, among other things, that, subject to your consent, we
will collect these personal data and transmit them to Ads & Data in an encrypted
form. This encryption means that Ads & Data will not be able to identify you
directly. Ads & Data then uses this information to build your advertising
profile (e.g. sports fan, male, age group, ...). Ads & Data uses this to
automatically display, with the help of service providers, targeted ads on
websites and applications in the Ads & Data portfolio.
In concrete terms, this means that Proximus and Ads & Data process your personal
data for the following purposes and on the basis of the following legal grounds:
* To create personalized online advertising profiles, based on your consent;
* To select personalized advertisements, based on your consent;
* To measure the performance of advertisements, based on your consent.
For these purposes, we will communicate your personal data to Ads & Data in its
capacity as joint controller, who will process them into an advertising profile.
You may withdraw your consent for the aforementioned purposes at any time,
firstly by adjusting your cookie settings so that we no longer collect data
related to your use of our websites and mobile applications either through the
Proximus website or the Proximus app, and secondly by adjusting your privacy
settings in MyProximus Web or MyProximus in the Proximus+ App. It may also be
useful to check whether you have accepted advertising cookies from third parties
on other sites or applications on which you surf and on which Ads & Data
broadcasts targeted advertisements, a list of these partners can be found on the
Ads & Data websiteNew window.
Ads & Data will share your advertising profile with:
* Processors that process data on our behalf (e.g. IT companies);
* Advertisers who want to use Ads & Data’s services to display advertising on
our websites and applications.
Ads & Data also shares an identification number from your browser with platforms
that provide support services for selecting and displaying targeted
advertisements.
Some recipients may be located in countries outside the European Economic Area
(EEA). If your encrypted data is transferred to them, this will be covered by
appropriate safeguards, such as European Standard Contractual Clauses, to
continue to ensure an adequate level of protection.
Ads & Data will constantly update your personal data and keep it for a maximum
of 13 months.
As a data subject, you have several rights. These are explained in section 11
below. Both Proximus and Ads & Data allow you to exercise certain rights in
accordance with the legal requirements. The Proximus Data Protection Officer
acts as a central contact, among other things because Ads & Data has no data to
directly identify you (e.g. name or e-mail address) and will therefore not be
able to respond to your request.
You can always withdraw your consent, at any time, in the following ways: i) by
adjusting your cookie settings so that we no longer collect data related to your
use of our websites and mobile applications through the Proximus website or the
Proximus app; or ii) by adjusting your privacy settings in MyProximus Web (click
on your name or avatar in the top right corner > My account > Alerts and
Privacy) and/or MyProximus in the Proximus+ App (click on the settings icon in
the top right corner > Manage your account > Alerts and privacy).
7.2.3.3. Targeted advertising on web and in mobile applications
Note: This processing activity is not applicable to customers of the Scarlet
brand.
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics, Customer interactions.
* Obtained data: Data collected by third parties for which you gave your prior
consent, statistical and public data obtained from external sources (e.g.,
data on the neighbourhood where you live you have given your prior consent to
the partner, cadastral data of your home taken from the cadastral plan made
publicly available by the Federal Ministry of Finance).
* Observed or generated data: Consumption habits.
What justifies this processing activity?
Your consent (art. 6(1)(a) GDPR) to collect and use your data for the purposes
of targeted advertising on web.
How long will we process this data for this purpose?
Identification and contact information and personal characteristics will be
processed for as long as you are a Proximus customer.
Data related to your consumption habits will be stored for 1 year upon
collection of the data.
Data related to your interactions as a customer with Proximus will be kept for 2
years upon the date of the interaction.
Data collected by third parties is only processed by Proximus for the execution
of a specific campaign.
With whom do we share this data?
We share your personal data with our DPM (= data management platform) and with
other websites and mobile applications that host ad banners.
How can I withdraw my consent?
You can always withdraw your consent, at any time, in the following ways: i) by
adjusting your cookie settings so that we no longer collect data related to your
use of our websites and mobile applications through the Proximus website or the
Proximus app; or ii) by adjusting your privacy settings in MyProximus Web or
MyProximus in the Proximus+ App. For more information on alternative ways to
exercise your rights, you can consult section 11 below.
Proximus, acting as an advertising agency (not as a telecommunications
operator), has the possibility of presenting you with advertisements relating to
its products and services or to those of other advertisers, on Proximus websites
and applications or on third party owned websites and applications.
An advertising agency is tasked with buying and selling online media space for
advertisers, i.e. brands or companies wishing to promote their products and
services through a campaign on the internet or in a mobile application. In
effect, the Proximus advertising agency acts as an intermediary between
advertisers or other parties and those third-party website and application
owners who sell advertising space, for example in the form of static banners and
videos.
When you view websites and applications that show advertisements, by accepting
their advertising cookies you are already consenting to a certain amount of
advertising personalization based on your preferred language for instance. By
granting us your consent, we can present you with more targeted and relevant
advertising.
Web profile
We’ll be able to choose advertisements that best match your web profile which is
determined from the data that we hold about you.
For example, if we notice that you often watch football on television, we may
infer that football is one of your interests and as a result, football related
ads will more likely be shown.
The data we use to build your web profile are as follows:
* Administrative data that you have shared with us (language, age, postal code,
type of customer, etc);
* Information about Proximus products that you purchased and/or Proximus
services that you use(d);
* Information relating to billing;
* The types of programmes you watch (sports, news, cookery, children's
programmes, etc) when you have a subscription to Pickx;
* The types of competitions you participate in on Pickx and data collected
through our Proximus For You loyalty program;
* Data collected from the Family Life application if you happen to use this
Proximus service.
* Ads that you have already viewed if you have a Proximus TV subscription and
you already benefit from personalized ads on TV – this is used to create
consistency between the different media on which you view ads;
* Data that we have derived from the information above (e.g., if you have just
bought a state-of-the-art smartphone from Proximus, we may conclude that you
are a fan of new technology);
* Data we receive from our partners and for which you have given your prior
consent to the partner. Please find the list of our partners here;
* Statistical and public data that we have obtained from external sources such
as data on the neighbourhood where you live. Please find the list of our
external sources here;
* Cadastral data of your home taken from the cadastral plan made publicly
available by the Federal Ministry of Finance (e.g. used to determine whether
you have a garden);
* The following data collected through third-party advertising cookies will
also be added to your web profile:
* Ads you have already viewed on websites and applications;
* Your interactions with those websites and applications;
* Pages visited on those websites and in those applications. For example, if
you browse a website selling sporting goods or have clicked on an
advertisement that we have shown you in connection with sporting goods,
this will allow us to identify an interest and add it to your profile.
* Data related to advertising cookies which you have accepted (browsing,
language, location, etc).
Your web profile allows us to replace certain banner ads or video ads with ones
that are more relevant to you. You will not receive more advertising than you do
currently.
List of advertisers
We also have the possibility of sending you advertisements based on lists of
users selected by the advertisers. This list may be refined by us at the
advertiser's request using segmentation criteria proposed by us.
For example, an advertiser could ask us to refine a list of users to select only
those believed to have an interest in football (as determined by their web
profile above) and to exclude those who do not.
Making the link between your viewing of websites and applications on which we
run ads and data we have about you will only be made if you give us your consent
and:
* You have authenticated yourself at least once on one of the Proximus websites
or applications (Pickx, MyProximus, Proximus.be, etc).
* You have accepted advertising cookies from third parties on the Proximus
websites or applications (see the cookie management policy on our website).
* You have accepted advertising cookies from third parties on the website or
application which you are using and on which we feature advertising.
You can withdraw your consent at any time via the privacy settings of
MyProximus. If you wish to withdraw your consent, go to your MyProximus Web
(click on your name or avatar in the top right corner > My account > Alerts and
Privacy) or MyProximus in the Proximus+ App (click on the settings icon in the
top right corner > Manage your account > Alerts and privacy). For more
information on your data subject rights, you can consult section 11 below.
7.2.3.4. Targeted advertising through TV channels
Note: This processing activity is not applicable to customers of the Scarlet
brand.
Which categories of personal data will we use?
* Collected data: Identification and contact information, Personal
characteristics, Customer interactions.
* Observed or generated data: Consumption habits.
* Derived data: Segmentation information.
What justifies this processing activity?
Your consent (art. 6(1)(a) GDPR) to collect personal data and use it for
personalized advertising on the Pickx service, with the direct participation of
the sales houses of the TV channels and the advertising platforms broadcasting
targeted ads.
How long will we process this data for this purpose?
Identification and contact information and personal characteristics will be
processed for as long as you are a Proximus customer.
Data related to your consumption habits and segmentation information will be
stored for 1 year upon collection of the data.
Data related to your interactions as a customer with Proximus will be kept for 2
years upon the date of the interaction.
With whom do we share this data?
Your personal data is shared, after pseudonymisation, with DPG Media and
Ads&Data, who operate as joint controllers together with Proximus.
How can I withdraw my consent?
You can always withdraw your consent, at any time, by adjusting your privacy
settings in MyProximus Web or MyProximus in the Proximus+ App. For more
information on alternative ways to exercise your rights, you can consult section
11 below.
Note: Contrarily to the processing activity described in section 7.2.3.1
“Targeted advertising on TV”, pseudonymsed data will be shared with the other
joint controllers involved in this activity, as described in the text below.
This also allows for the personalization of unskippable advertising present on
some TV channels.
What is the purpose of this processing activity?
If you give your consent, you allow the advertising sales houses of our partner
broadcasters (www.proximus.be/tvregies) to select and distribute the
personalized ads you see on the Pickx service (on your decoder, Pickx app and
Pickx website) based on your customer profile and to measure their performance.
This means that you will see the same ads less often and also fewer ads that are
inconsistent with your needs and focus of interest.
The joint controllers of your personal data are Proximus, the sales houses of
the TV channels and the advertising platforms broadcasting the targeted ads. You
can find the list of the sales houses of the concerned partner channels and
advertising platforms here (www.proximus.be/tvregies).
As a data controller, we must comply with a number of obligations, such as
safeguarding your rights, reporting security breaches, etc. As data processing
co-controllers, we have established and assigned these obligations in an
agreement that clearly describes the roles and responsibilities of each of the
parties in carrying out the obligations imposed by the General Data Protection
Regulation.
Contrarily to the processing activity described in section 7.2.3.1 “Targeted
advertising on TV”, pseudonymsed data will be shared with the other joint
controllers involved in this activity.
How do the TV broadcasters adjust the TV ads on the Pickx service and how do
they measure their results?
Through their advertising platforms, the advertising sales houses of the
concerned TV channels decide which commercials are shown to which subscribers
based on their customer profile(s).
For this purpose, we share the following information with the advertising
platforms of the sales houses of the respective TV stations:
* an encrypted identification code,
* technical information regarding the type of software or device used,
* as well as your customer profile(s) (for example young family, often watching
cooking programs)
This allows the sales houses of the concerned TV stations to expose the
commercials to the best suited public based on the segment data and in
particular:
* to estimate in advance the broadcasting costs of the advertising spots
according to the chosen target audience, channel and broadcasting time slots
* to make a report on the results of the targeted TV ad campaign after
broadcasting
Subsequently, the sales house of the concerned TV channel communicates the
aggregated results of the advertising campaign to the advertiser to inform him
about the exposed audience and the volumes of ads seen.
This method also allows sales houses to limit the number of exposures to a
particular advertisement on customer level.
How is your customer profile made?
Your customer profile is based on:
* the type of programs you watch on our TV services (sports, news, cooking,
children's programs...)
* the ads you have already watched if you have a TV subscription and if you
already use the personalized advertising service. This ensures more
consistency between the media on which you view the ads.
* the types of contests you participate in on Pickx and the data collected by
our Enjoy! loyalty program
* data about the composition of your family, collected in the Proximus+ app, if
you use this application.
* administrative data you have communicated to us (language, age, postal code,
type of customer, etc.), Proximus products purchased, Proximus services used,
information about your billing, etc. and other data we have derived from this
information.
* user data that we receive from partners and for which you have given prior
consent to the partner. We have the possibility of showing advertisements
based on selected user lists and communicate the list of subscribers who have
viewed the advertising campaign. A list of our partners can be found here
* statistical and public data obtained by Proximus from external sources, such
as statistical data about the area where you live. A list of our external
sources can be found here
* cadastral data about your home, taken from the cadastral map published by the
Federal Government Service Finance. This map is used, for example, to
determine whether or not you have a garden.
What if you change your mind?
No problem. You can change your consent at any time via the privacy settings in
the MyProximus section of the Proximus+ app or on Pickx TV.
7.3. When you have ceased to be a customer or user
7.3.1. Ex-customer consent acquisition campaigns
Which categories of personal data will we use?
* Collected or obtained data: Identification and contact information.
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to promote our brand, as well as
relevant products and services, by inquiring whether an ex-customer would be
interested to get offers and promotions beyond the usual retention period.
How long will we process this data for this purpose?
As this is a further purpose to the initial purpose of direct marketing towards
ex-customers, the retention period will be identical; 5 years after the end of
your contractual relationship with Proximus.
With whom do we share this data?
Call centers working on our behalf, acting as processors (in the context of
these campaigns).
How can I withdraw my consent?
Please use the unsubscribe link in Proximus e-mails, reply STOP if you receive a
text message, or contact the Proximus DPO at the e-mail address
privacy@proximus.com if you no longer wish to be called, contacted via digital
channels, or receive postal mail from Proximus. You can also object to the use
of your personal data for marketing purposes, as well as restrict the channels
via which you wish to be contacted, via MyProximus Web and/or MyProximus in the
Proximus+ App. For more information on alternative ways to exercise your rights,
you can consult section 11 below.
As an ex-customer, you might be interested in being informed of the different
offers and promotions relating to our products beyond the standard retention
period of five years. For that reason, towards the end of the five-year
retention period for the purpose of direct marketing towards ex-customers,
during one of the standard marketing calls, one of our call center agents will
ask you whether you would be interested in getting further offers and
promotions, for another period of 3 years.
Not interested? Don’t feel pressured! You can always refuse, and our call center
agents are not in any way incentivized for the collection of such consents.
Changed your mind after giving your consent? Please use the unsubscribe link in
our e-mails, reply STOP if you receive a text message, or contact the Proximus
DPO at the e-mail address privacy@proximus.com if you no longer wish to be
called, contacted via digital channels, or receive postal mail from Proximus.
7.3.2. Ex-customer ‘win-back’ actions
Which categories of personal data will we use?
* Collected data: Identification and Contact information.
* Derived and inferred data: Leisure and personal interests (‘preference
profile’ – for more information, see sections below).
What justifies this processing activity?
Our legitimate interest (art. 6(1)(f) GDPR) to further promote our brand, as
well as relevant products and services, to existing customers.
How long will we process this data for this purpose?
We will process your data as an ex-customer for 5 years after the end of your
contractual relationship with Proximus.
With whom do we share this data?
Call centres working on our behalf, acting as processors (in the context of
telemarketing campaigns).
How can I object?
If you want us to stop contacting you for marketing purposes, please use the
unsubscribe link in our e-mails, reply STOP if you receive a text message from
us, or contact the Proximus DPO at the e-mail address privacy@proximus.com if
you no longer wish to be called by us, be contacted via digital channels or
receive postal mail from us. For more information on alternative ways to
exercise your rights, you can consult section 11 below.
Just as for our customers, we have a vested interest in promoting our products
and services, brand, image, and potential offers to ex-customers, in an attempt
to win them back. To achieve these goals, we will process ex-customers’ personal
data to spread awareness around these offers and promotions by contacting them
directly, be it by phone or per e-mail.
In practice, these activities take place in two stages:
* First, a list of ex-customers to be contacted in the context of a specific
campaign is prepared. Whether you are included in a campaign will depend on
the goal of the campaign (what product or service we are promoting) and your
preference profile, if there exists one (to determine whether you would be
interested in the product or service being promoted, or whether you qualify
for a specific action). In some cases, we might launch general campaigns
which will target all customers indiscriminately.
* Once the target list has been prepared and you have been included as a
potential target, we will process your identification and contact information
(relevant to the communication channel used for this specific campaign, e.g.,
your e-mail address for an e-mail campaign) to deliver the marketing message.
We are committed to only contacting you at reasonable intervals, with different
intervals per channel of communication.
It goes without saying that you remain in absolute control of your preferences
when it comes to Proximus’ marketing outreach. If you want us to stop contacting
you for marketing purposes, please use the unsubscribe link in our e-mails,
reply STOP if you receive a text message from us, or contact the Proximus DPO at
the e-mail address privacy@proximus.com if you no longer wish to be called by
us, be contacted via digital channels or receive postal mail from us.
8. How do we protect your personal data?
The databases containing your personal data are secured. Updates guarantee a
high level of protection.
We take technical and organizational measures to protect the databases in which
your data are stored against unauthorized access/use, theft or loss. Our
security measures are regularly evaluated and updated to ensure that we can
continue to provide a high protection level.
Here(PDF, 389 KB) you will find a general overview of the technical and
organizational measures taken by us.
9. Information about specific products and services
9.1. Services for professional customers in which Proximus is acting as a data
processor
Proximus acts as a data processor whenever it processes personal data on behalf
of the customer.
This is for instance the case for personal data that:
* the customer stores in Proximus' data centers or cloud (e.g. Private or
public cloud services, IT Security services, Contact center services,
Workplace services, Internet of Things platforms and many other cloud based
services);
* the customer enters in a tool made available by Proximus (e.g. Invoice
Insights, Mobile Device Management);
* the customer has entrusted to Proximus for configuring the service;
* are processed by Proximus for providing assistance to the customer.
Other data processors or "sub-processors"
When Proximus acts as a data processor for the personal data of the customer or
its end users, it can be assisted by sub-processors. Proximus remains liable to
the customer for the protection of the personal data of the customer's end
users. The Proximus subcontractor list covers the subcontractors for the
products and services provided to our professional customers for which Proximus
acts as a data processor. Proximus will keep the list up-to-date.
The list of subcontractors can be consulted here(PDF, 279 KB).
9.2. Personal data in MyProximus
The information relating to the processing of personal data in the context of
MyProximus can be found in the privacy notice for MyProximus.
9.3. Family life
Proximus requires that the user creates a MyProximus account prior to accessing
this service. The data collected during the creation of the account is necessary
in order to give access to the service. The "Family life" profile includes the
following mandatory pieces of information: the surname, first name and email
address. The user has the possibility of completing his profile by adding other
optional data (photos, videos, telephone number, gender, birthday, etc.).
The data that the user provides via the various shared tools of Family life will
only be used in the context of this provided service. Only members of the circle
can see the information and content that the User shares. In addition to the
shared information the user also has the possibility of creating private events
in the "Calendar" tool and private tasks in the "TO DO list" tool. These private
events will only be visible to the user and, if he/she wishes, by a limited
number of members of the circle that he/she explicitly selects.
The user also has the possibility of sharing his location data to other members
of the circle in real time or in specific locations. Users can limit the sharing
of theirposition either in time, or to specific places and/or to certain members
of the circle. To use features such as these, the uUser must enable location
services by turning on the “Location” function in the application before it can
use his location data. Location data is processed for the sole purpose of
providing the user with the requested location services, i.e. to allow other
members of the circle to locate him. Location data is not shared with third
parties. Location data is kept as long as the “Locate” function is enabled in
the application. The user can disable location services at any time by turning
off the “Locate” function in the application.
The username linked to a user is associated to every post he/she creates. A user
(administrator or otherwise) can delete any post (message, photo, event, task,
contact, ...) that he/she has posted. In the event that the posts are not
explicitly removed prior a user leaving a circle or terminating the service, the
username linked to the user will be removed from all posts they may have
created. The user retains the possibility of deleting posts prior to leaving a
circle or terminating the service.
Unless otherwise specified, user data is managed and processed as long as the
user account remains active. In the event that the user decides to terminate
this service, notably in the event of account termination, his "Family life"
user profile will be removed from the date of deactivation. The removal of the
"Family life" user profile is independent of his/her MyProximus account, which
shall remain active, as it allows access to other services.
9.4. Data processing when you use Pickx (TV) through your decoder, the Pickx app
or through the Pickx website
The personal data generated when you use Pickx or data that you provide yourself
in the context of Pickx are processed and included in our databases. We may
process this data to provide you with the Pickx service, to improve our
services, to conduct market studies, to produce statistical reports, to create
user profiles and to bring personalised or non-personalised recommendations.
The Pickx decoder is equipped with software which registers and stores the
operations performed with the decoder. The Proximus Pickx app and website
contain similar functions.
All this data can be processed to:
* allow the successful implementation of the contract;
* correctly deliver the Pickx services and solve technical problems;
* provide you with personalized recommendations relating to Pickx services and
other Proximus services;
* allow customer management;
* conduct market surveys and create user profiles;
* generate statistical reports on viewing behavior for internal purposes and
for reporting to TV channels and the media regulator;
* adapt advertising on Pickx to your profile;
* detect fraud, e.g. breaches of intellectual property rights;
* conduct (personalized) information or promotional campaigns related to
Proximus Group products and services by any means, including by post and/or
e-mail.
If you prefer not to receive any information about our products, services or
promotions via your TV screen, or don't want the advertising on Pickx to be
adapted to your profile or to receive any personalized recommendations relating
to the Pickx services, you can find out how to indicate your preferences in the
section 11 "What are my privacy rights and how can I exercise them?".
In some cases, Proximus may disclose the collected data:
* to partners that help us deliver the Pickx services;
* if such disclosure is necessary for delivering a Pickx service;
* if you have consented to such disclosure.
Using the Pickx app in another EU Member State
You can use the Pickx app when you are temporarily in an EU Member State other
than Belgium, according to the European Regulation on portability, only if you
are a resident of an EU Member State. Proximus therefore verifies your Member
State of residence when you conclude the TV app contract and during the
performance of the contract. Within the limits of the European Regulation on
portability, Proximus decides which verification methods it will use. The
processing of personal data for this verification is limited to what is
considered proportional. The personal data will not be kept longer than is
required for the verification.
9.5. Doktr
The information relating to the processing of personal data in the context of
Doktr can be found in the Privacy PolicyNew window of Doktr.
9.6. Banx
The information relating to the processing of personal data in the context of
Banx can be found in the Privacy Policy(PDF, 327 KB, in dutch) of Banx.
10. What are cookies (and related technologies) and how are they used?
Cookies allow us to recognize you as a visitor on our websites, so that we can
provide you with personalized information.
You can consult our cookie policy via the hyperlink "Cookie policy" at the
bottom of the homepage of our websites.
When you log in to MyProximus, we place a cookie in your browser. This way, we
can recognize you as a visitor on our website and adapt the content of our
websites to your personal situation, even if you don't log in to MyProximus on
your next visit.
If you don't want to receive any personalized messages when you visit our
website www.proximus.be , follow these instructions:
* Click "I am not… (your name)" on the page where you log in to MyProximus;
* Then, click the Proximus logo at the top left; you will then arrive on the
non-personalized version of the website.
For the relevant cookie policy: consult the website (not all websites have all
types of cookies).
If you accepted cookies for targeted advertising by Proximus and third parties
on our websites, We can give our trusted partners access to such cookie
information via its Data Management Platform. The list of partners with whom we
share cookie information is available via the cookie manager on Proximus'
websites.
11. What are my privacy rights and how can I exercise them?
You have the right to inspect, correct and delete your personal data. You can
also object to the use or processing thereof. You can withdraw your consent and
change your choice. Finally, you can register to be included on the Do Not Call
Me list. If you are a Proximus (ex)customer, in most cases you can indicate your
privacy preferences via MyProximus (Web and in the Proximus+ App) or via our
customer service. If you are not a customer, you can always call our customer
service to submit a request to exercice your privacy rights.
To ensure that the request is made by the right person, we ask you to provide
certain information to confirm your identity and to avoid anyone else exercising
your rights. If this information is not sufficient to confirm your identity, we
may ask for additional information to allow us to uniquely identify you or ask
you to send us a copy of the front side of your identity card (you may redact
all information on your identity card that is not relevant to confirm your
identity).
We have one month to respond to your request. This term starts running as soon
as we have all the information we need to meet your request.
The term of one month may be extended by a maximum of 2 months, depending on the
number and complexity of the requests. We will keep you informed of any delay in
our response within the initial term.
We strive to adapt our systems and databases as quickly as possible. But, in
practice, it may take some time to implement your choice.
If you are not satisfied with our answer, please let us know at the Proximus
Data Protection Office, either by e-mail: privacy@proximus.com or by post:
Boulevard du Roi Albert II 27, 1030 Brussels.
You can submit a complaint to the Data Protection Authority
If you are not satisfied with the answer you receive from Proximus, or you do
not agree with our opinion, you can contact the Data Protection Authority and
submit a complaint. More information: see
https://www.dataprotectionauthority.be/contact-us.
11.1. You can access your personal data
You have the right to request access to your personal data. We will then provide
you with an overview of the personal data we process on you. We will also give
you additional information on, for example, why these personal data are
processed, the origin of the data, the types of third parties with whom we share
your personal data, etc.
Proximus (ex)customer:
Contact the Proximus Data Protection Office by e-mail: privacy@proximus.com, via
this web form or by post: Boulevard du Roi Albert II 27, 1030 Brussels.
Not a Proximus (ex)customer:
Contact the Proximus Data Protection Office by e-mail: privacy@proximus.com or
by post: Boulevard du Roi Albert II 27, 1030 Brussels.
11.2. You can have your personal data corrected
If you notice that certain data that we have about you are no longer correct,
you can have them changed. For this, contact our customer service.
Some personal data, such as contact details, are available in the MyProximus
environment and you can change them there yourself via MyProximus Web (click on
your name or avatar in the top right corner > My account > Edit profile) and/or
MyProximus in the Proximus+ App (click on the settings icon in the top right
corner > Manage your account > Personal data ). If that doesn't work, contact
the Proximus customer service on 0800 55 800 or via chat.
11.3. You can have your personal data deleted
In certain cases (e.g. when you don’t have any Proximus products or services
anymore and you would like to have your contact data deleted), you can ask for
your personal data to be deleted.
We are unable to delete certain personal data (e.g. billing data) because it is
required by law to keep those data.
Contact the Proximus Data Protection Office by e-mail: privacy@proximus.com or
by post: Boulevard du Roi Albert II 27, 1030 Brussels.
11.4. Removal of data from the telephone directory and the 1207/1307 database
If you don’t want to have your contact information published in directory
services or the telephone directory, you can adapt this preference yourself via
MyProximus Web (click on your name or avatar in the top right corner > My
account > Alerts and Privacy) and/or MyProximus in the Proximus+ App (click on
the settings icon in the top right corner > Manage your account > Alerts and
privacy). If that doesn't work, you can submit your request via this webform, by
e-mail: annuaire@1307.be or by post: Service Annuaire, Boulevard Roi Albert II
27, B-1000 Brussels.
11.5. You can object to the use of certain personal data
You can always object (without a motivation) to the use of your personal data
for marketing purposes.
Proximus (ex)customer
You can adapt the channels and preferences regarding communications for
marketing purposes via MyProximus Web (click on your name or avatar in the top
right corner > My account > Alerts and Privacy) and/or MyProximus in the
Proximus+ App (click on the settings icon in the top right corner > Manage your
account > Alerts and privacy) . If that doesn’t work, contact the Proximus Data
Protection Office by e-mail: privacy@proximus.com or by post: Boulevard du Roi
Albert II 27, 1030 Brussels.
You can also follow the instructions in the e-mails and texts you receive from
us to stop receiving such commercial messages in the future.
If you want to completely object to the use of your personal data for marketing
purposes, you can also register this in MyProximus, submit your request via this
webform or contact the Proximus customer service on 0800 55 800 or via chat.
Not a Proximus (ex)customer
You can object to the use of your personal data for marketing purposes by
contacting the Proximus Data Protection Office by e-mail: privacy@proximus.com
or by post: Boulevard du Roi Albert II 27, 1030 Brussels.
The self-employed and SMEs can inform us about their privacy preference via the
toll-free number 0800 55 500.
Medium-sized and larger companies as well as public institutions can call the
toll-free number 0800 55 200.
Objection to the use of mobile network location data for anonymous reporting
You can object to the use of mobile network location data for anonymous
reporting via MyProximus Web (click on your name or avatar in the top right
corner > My account > Alerts and Privacy > Network mobile data) and/or
MyProximus in the Proximus+ App (click on the settings icon in the top right
corner > Manage your account > Alerts and privacy > Network mobile data). If
that doesn’t work, contact the Proximus Data Protection Office by e-mail:
privacy@proximus.com or by post: Boulevard du Roi Albert II 27, 1030 Brussels.
If you have a specific reason (motivated request), you can object to us using
your personal data for purposes other than those required for the performance of
an agreement or for complying with a legal obligation (e.g. fraud prevention).
In case of a justified request, we will stop using your personal data unless we
have compelling grounds to continue using it.
You can submit a request to object to the processing of your personal data for a
specific purpose by contacting the Proximus Data Protection Office by e-mail:
privacy@proximus.com or by post: Boulevard du Roi Albert II 27, 1030 Brussels.
11.6. You can withdraw a consent previously given
Whenever you give us explicit consent to process personal data for specific
purposes (e.g. personalized TV advertisements, personalized advertisements on
web and in mobile applications…), you can withdraw the consent previously given
at any time. You can do this via MyProximus Web (click on your name or avatar in
the top right corner > My account > Alerts and Privacy) and/or MyProximus in the
Proximus+ App (click on the settings icon in the top right corner > Manage your
account > Alerts and privacy) .
If that doesn’t work or if you have another request or question regarding the
withdrawal of consent, you can the Proximus Data Protection Office by e-mail:
privacy@proximus.com or by post: Boulevard du Roi Albert II 27, 1030 Brussels.
11.7. You can sometimes object to the fully automated processing of your
personal data
If we process your personal data in a fully automated way (without human
intervention), you can object to this.
You can submit a request to object to the fully automated processing of your
personal data by contacting the Proximus Data Protection Office by e-mail:
privacy@proximus.com or by post: Boulevard du Roi Albert II 27, 1030 Brussels.
11.8. You can ask to transfer your personal data
You can transfer personal data that you provided to us (e.g. contact details) to
yourself or a third party.
You can submit a request for the transfer of your personal data by contacting
the Proximus Data Protection Office by e-mail: privacy@proximus.com or by post:
Boulevard du Roi Albert II 27, 1030 Brussels.
11.9. You can register to be included on the Do Not Call Me list
If you no longer wish to receive any commercial calls from any company or
organization on your landline or mobile, you can register to have your name put
on the "Do Not Call Me" list. You can do this by calling the number 02 882 19
75.
All companies and organizations that make offers by telephone or mobile phone
are required by law to comply with this list. They have to remove your telephone
number and name from their call files, and are no longer allowed to call you
about their products or services or promotional offers. Each company and
organization is responsible for respecting the "Do Not Call Me" list. We have no
powers to supervise or control this within companies other than Proximus.
For any complaints regarding unsolicited commercial calls, you can contact the
Federal Public Service FPS Economy, SMEs, Self-Employed and Energy, Contact
Center, Rue du Progrès 50, 1210 Brussels, call the toll-free number 0800 120 33,
or contact the hotline: meldpunt.belgie.be, section "Vervelende telefoontjes"
(unsolicited phone calls).
11.10. You can register to be included on the Robinson list
If you no longer wish to receive commercial letters from companies that are
members of the Belgian Direct Marketing Association, you can register for your
name to be put on the Robinson list via www.robinson.be.
12. Changes in the privacy notice
Changes can always be made to our privacy notice. Therefore, consult this site
regularly.
Our privacy notice may be expanded or adapted in the future (e.g. to accommodate
new developments). For this reason, we recommend that you consult the privacy
notice regularly.
13. Contact details of the Data Protection Officer
If you have questions about our privacy notice, you can contact the Proximus
Data Protection Officer.
How do you contact the Proximus Data Protection Officer?
E-mail: privacy@proximus.com
Address: Boulevard du Roi Albert II 27, 1030 Brussels
Web form: link to web form
Full text of the Privacy notice(PDF, 750 KB)
Last update: 16/10/2024
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