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PRIVACY POLICY

Below you can read more about how we process and protect your data.

Q8 smiles programme Privacy policy



Smiles NV (“Smiles NV” or “we” or “us”) is committed to safeguarding the privacy
of the personal data gathered from website visitors and clients (“you”) in the
context of managing and promoting the personalized service provided by the Q8
smiles loyalty programme (“the Q8 smiles Loyalty Programme”) in our capacity of
controller.

All terms in the Q8 smiles Loyalty Programme that are upper-cased are defined in
the Q8 smiles General Terms and Conditions. Please read those together with this
Privacy Policy.

We will handle your personal data with care, in accordance with the applicable
privacy and data protection legislation in force. Please read this Privacy
Policy to find out more about the way in which we collect and process your
personal data.

In this Privacy Statement, we will outline the following aspects:

- What personal data are collected,

- For what purposes we can use your personal data and on which legal basis do we
rely for the processing of your personal data,

- to whom we may provide your personal data,

- How long we store your personal data,

- Your rights with regard to your personal data,

- Where you can ask questions or make comments.

What personal data are collected?

If you register to participate in the Q8 smiles Loyalty Programme, we will
collect personally identifiable information about you (“personal data”) at the
time of registration and throughout your participation, including (i)
identification and contact details, (ii) consumption data and (iii) data
regarding the (participating or rewarding) partners with which you have signed
up or identified yourself via your Q8 smiles Medium.

If you have registered via the “Tanken bij Q8” functionality in the KBC mobile
app and you are not yet a Q8 smiles customer, Smiles NV will receive your e-mail
address from Olympus. This e-mail address is processed by Smiles NV as
controller. You are free to choose which e-mail address you pass on to Smiles NV
and this does not necessarily have to be the same e-mail address as you use for
other services within the KBC mobile app. We will only use this information to
send you an activation email. As soon as you click on the activation email, you
are a Q8 smiles customer. All other personal data, except the e-mail address,
that are processed in the context of the “Tanken bij Q8” functionality, are not
shared with Smiles NV. If you have any questions regarding these processing
operations, please consult the privacy policies that can be found in the KBC
mobile app.

If you use the Q8 smiles App, your current location will be processed on your
device in order to offer certain aspects of the Q8 smiles Loyalty Programme and
functionalities of the Q8 smiles App, as set out in the Q8 smiles Terms and
Conditions.

When you simply use our websites, we will in principle collect only limited
technical data (see below), unless you voluntarily choose to provide us with
identification and contact information, for example by sending us a question by
email or by filling in the contact form on the website. Under the heading ‘For
what purposes can we use your personal data?’, you can find further details
about what specific data are collected and processed.

When you use the Q8 smiles App and the Q8 smiles Website, you will also be given
the possibility of indicating another person who is interested in the Q8 smiles
Loyalty Programme, up to a maximum of 12 requests per calendar year. If you
provide that person’s contact information to Smiles NV, you guarantee that you
have obtained the necessary consent of that person (i) to provide Smiles NV his
or her personal data and (ii) for Smiles NV to send that person information
about the Q8 smiles Loyalty Programme by email or other means.

 

 

Non-personal data collected automatically

When you visit our Q8 smiles Website or use the Q8 smiles App, we can collect
technical information that does not identify you, including but not limited to
the type of internet browser and computer operating system; the domain name of
the website that you previously visited; the number of visits, average time
spent and the pages you viewed. We can use this information and share it within
the Kuwait Petroleum Group to analyse the use of our websites and to improve
their content.

For what purposes can we use your personal data and on which legal basis do we
rely?

Within the context of the Q8 smiles Loyalty Programme, the processing of
personal data is necessary to implement the agreement you entered into with
Smiles NV (the Q8 smiles Terms and Conditions), and in particular the
personalized service provided by the Q8 smiles Loyalty Programme. This also
applies to the application of exclusions as provided for in the Q8 smiles Terms
and Conditions.

This personalised service includes processing in order to offer the
functionalities of the Q8 smiles App and the Q8 smiles Website, including the
savings programme, the provision of personalized promotional materials, special
offers and advertisements (via the Q8 smiles App and by email) and offering the
requested services such as the station finder, and so on. If you wish, you can
unsubscribe to Q8 smiles sales communications via email by clicking the
unsubscribe link at the bottom of each email.

If you contact us for assistance and/or support for the use of the services of
the Q8 smiles Loyalty Programme (e.g. concerning the Q8 smiles App, the Q8
smiles Website, technical problems with smiles at the station), the following
personal data can be collected and processed:

- (electronic) identity and contact details,

- the country you live in,

- consumption data,

- data on internet behaviour and the use of the device,

- transaction data,

- the number of coupons used and requested,

- data on your Smiles balance,

- language preference,

- images and other annexes added to the contact form.

For purposes of managing and improving the Q8 smiles Website and the Q8 smiles
App, to add new functions and to optimize your user experience, the following
personal data may be processed: (i) device use, (ii) internet behaviour, (iii)
the number of clicks on the website and in emails, (iv) language preference and
(v) app ratings.

In order to enable you to enjoy the full service of the Q8 smiles Loyalty
Programme, the following personal data may be collected and processed: (i)
(electronic) identity and contact details, (ii) data on your personal Q8 smiles
profile, (iii) consumption habits, (iv) transaction data, (v) your activity in
the Q8 smiles Loyalty Programme, (vi) communication history and (vii) images.

If you request a Q8 smiles Medium, your address details will be processed in
order to send you the Q8 smiles Medium you have chosen.

In order to assist you with managing, changing and other issues regarding your
Smiles balance, we process the following personal data: (i) identity and contact
details, (ii) language preference, (iii) address details, (iv) transaction data
and of course (v) your Smiles balance itself.

For the ‘station finder’ function in the Q8 smiles App, you will be asked to
give us access to your location services so we can show you the nearest Q8 Sales
point (using geofencing).

Your customer data with the Q8 smiles Loyalty Programme is also processed in
accordance with the legitimate interest of Smiles NV to carry out customer
management, manage the Q8 smiles Loyalty Programme and collect transaction
information for use in resolving any disputes.

If you provide your personal data to Smiles NV outside of the Q8 smiles Loyalty
Programme, these data will be processed if:

- you have provided us with your freely given, specific, informed and
unambiguous consent to process these personal data in order to respond to your
request.

- we have to process your personal data in order to provide the services you
requested or to enter into or implement an agreement with you (e.g. to be able
to confirm information for purposes of your participation in the Q8 Loyalty
Programme).

- the processing is necessary to fulfil our legitimate interests, and in
particular: economic, commercial and financial interests, business continuity,
the security and confidentiality of customer information and products, and the
security of digital and physical infrastructures, particularly in order to
answer questions about the Q8 smiles Loyalty Programme, to handle any
complaints, remarks or reported malfunctions concerning our forms, and to carry
out surveys in order to gain a better understanding of our customers’ wishes and
profiles.

Your data can also be used for purposes of fraud prevention or detection with a
view to protecting the smooth operation of the Q8 smiles programme in accordance
with the legitimate interest of Smiles NV to guarantee this.

To whom can we send your personal data?

Sharing with partners

Smiles NV shares data and updates about customers of the Q8 smiles Loyalty
Programme with Kuwait Petroleum (Belgium) NV (59 Brusselstraat box 1, 2018
Antwerp, VAT BE 0404.584.525, Register of Companies, Antwerp division),
hereafter KPB NV, with Kuwait Petroleum (Netherlands) BV (50 Schenkkade, 2595 AR
The Hague, VAT NL 0012.50.590.B01, Rotterdam Chamber of Commerce 24025263),
hereafter KPN BV. KPB NV, KPN BV process these data on the one hand as service
provider to Smiles NV in the context of the Q8 smiles Loyalty Programme, and on
the other hand KPB NV also processes them for other purposes (of its own)
provided it has obtained consent. More information about the purposes of the
processing and other information (including the categories of personal data and
your rights as data subject) is provided in the Privacy Statement of KPB NV.

Smiles NV may also share such data with third parties in connection with the
sale of (part of) its business activity, transfer a business or in comparable
circumstances.

Other third parties

Your personal data can be shared with:

- advertising agencies,

- companies providing mailing services,

- IT service providers,

- web analytics tool,

- rewarding partners,

- the contact centre,

- the map and keychain supplier.

We can use the following social media plug-in applications on our Website:
Facebook, Instagram and Google (“Social media services”) via which certain
personal data may be shared with these parties. These services can collect your
IP address and the webpage you visit on our Website, and they can place cookies
in order to enable the services to work properly. In addition, you also have the
option of registering with the Q8 smiles Loyalty Programme using your Facebook
or Google login. Social media services and Widgets are hosted either by a third
party or directly on our Website. This Privacy statement does not apply to those
services. Your interaction with those services is governed by the privacy
statement of the companies providing them. You can find more information about
third-party cookies in our Cookie Policy.

Links to other websites

The Q8 smiles Website may contain links to other websites that are not owned,
controlled or maintained by us. We cannot be held responsible for the privacy
statement of other websites, nor for the implementation of their statements,
even if:

- you accessed the third-party website via a link on our websites, or

- you were referred to our website via a link on a third-party website.

We recommend that you check the privacy statement of each site you visit and to
contact the controller if you have any questions or remarks.

How long do we store your personal data?

Your personal data will be retained for as long as necessary to achieve the
purpose for which it was collected.

Unless otherwise specified in the General Terms and Conditions, for Registered
Customers with the Q8 smiles Loyalty Programme this means the period of
participation in the Q8 smiles Loyalty Programme and 10 years thereafter (for
evidentiary purposes).

For non-registered customers this period is in principle no longer than 1 year,
except for situations where the applicable expiry date allows Smiles NV to
retain the data for a longer period for evidentiary purposes.

What are your rights with regard to your personal data?

Under the data protection legislation, you have the right, under certain
conditions, to access your personal data as well as the right to rectify,
complete and/or erase incorrect data. If you wish to exercise one of these
rights, please send us a request to privacy@Q8smiles.lu. We will make the
necessary efforts to take the following essential steps:

- rectifying errors in the data we hold;

- deleting any data for which we no longer have a legal basis to use;

- where applicable, provide you with a copy of the data you have supplied us
with.

To facilitate our response to your request, it would be helpful if you could let
us know the context in which you provided your personal data.

Furthermore, where processing is based on consent, you have the right to object
to the use and processing of your personal data by sending us a request to
withdraw your consent. You can also require us to restrict the processing of
your personal data while a complaint is being investigated.

Furthermore, you also have the right to object to any processing, including
profiling, based on the legal ground of legitimate interests, unless our reasons
for the processing outweigh any prejudice to your rights and freedoms.

Your exercise of these rights is subject to a number of restrictions to
safeguard the public interest (e.g. fraud prevention or detection). If no
restriction applies, we will process your request and in most cases respond
within one month. We can charge a reasonable fee for “repeated requests”,
“manifestly unfounded or excessive requests” or “further copies”.

If you are dissatisfied with our use of your personal data or you do not agree
with our response to the exercise of one of the above rights, you have the right
to submit a complaint via the Belgian Data Protection Authority.

Within the limits of the law, you also have the right to transfer the personal
data you have provided to another organization (data portability).

Cookies

When you visit our Q8 smiles Websites or the Q8 smiles App, we can store cookies
and other automatic means of data collection on your computer. A cookie is a
small text file that is placed on your computer, tablet or smartphone when you
visit a website. Cookies can automatically recognize you the next time you visit
and can enable you to adjust a website to better match your interests or to save
your password so that you do not have to re-enter it each time. If you choose
not to be recognized, please check the settings of your internet browser to
erase cookies from your computer, block all cookies or receive a warning before
a cookie is placed. For more information and details about cookies used on our
website, please consult the Cookie Policy on this website.

Changes

We reserve the right to change this Privacy Statement if necessary, for instance
to comply with changes in the legislation, regulations, new practices and
procedures or obligations imposed by the supervisory authority. The latest
version is always available via this link. The date when this text was last
updated is indicated at the bottom of this statement. We will keep you informed
of any significant changes to the Privacy Statement.

Where can you ask questions and make comments?

If you have questions or would like more information, you can send an email to
privacy@Q8smiles.be.

Smiles NV

310 Vilvoordselaan

B - 1130 Brussels

VAT BE 0720.542.130

www.Q8smiles.be

Tel. 0800 11 323 or from abroad: 0032 23 022 645

This Privacy Policy was last updated on 28 april 2020.

   
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