Privacy policy

Version 1.0 dated on 1 February 2022

INTRODUCTION

Below you will find the privacy policy of Bulletin Media SRL (hereafter “Bulletin Media” or “we”).

This policy concerns the processing of personal data relating to individuals, ie personal data on all websites, via all (mobile) apps and via all services of Bulletin Media.

This policy does not apply to the processing of personal data relating to legal entities.

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

1. Definitions

Within this policy, we are using some technical terms. This is a brief overview of the definitions and frequently used terms in this section.

Bulletin Media: Bulletin Media SRL, Rue de Sardanson 20A, 5004 Namur, email editorial@thebulletin.be.

Bulletin Media Domain: a website or (mobile) application offered or operated by Bulletin Media.

Click Behaviour: The interests of a User or Registered User, after having obtained his/her consent, are derived from the use of a Service. Click Behaviour mainly includes:

(i) session data, i.e. operating system, device type, browser type, etc.;

(ii) pages visited from which we classify you according to area(s) of interest (e.g. sports, lifestyle, car enthusiast).

Cookies: Text or other files and similar technologies that store or access information on your computer, tablet, smartphone or other devices with which you visit a Bulletin Media Domain.

Data subject: you, the individual whose personal information we process; we explain which rights you have as a data subject under 3.5.

Recommended Content: suggestions about our Services (e.g. articles, offers, etc.) that Bulletin Media aligns with the interests of a User (on the basis of Click Behaviour with his/her consent.

Service(s): access to news, promotions, functionalities for a better User experience, (mobile) apps, Recommended Content or products that Bulletin Media sells, provides or makes available on or through a Bulletin Media Domain. You can enjoy our Services as soon as you visit a Bulletin Media Domain or after installing one of our apps (as a User).

Targeted Advertisements: commercial information that is addressed to a User’s interests (if consented to, then based on Click Behaviour) or a Registered User’s interests (if consented to, then based on Click Behaviour and Registered Data).

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

2. The Controller

Bulletin Media acts as a controller of your personal data if it sells, provides or makes available its respective Service to you, or if you visit Bulletin Media.

3. General Information regarding the Processing of Personal Data by Bulletin Media

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

Bulletin Media processes personal data for specific purposes.

Bulletin Media always acts based on a legal basis set out by law. This is a legal ground that allows the use of personal data. Examples of such legal bases include consent, performance of an agreement, legal obligation and legitimate interest.

The purposes and legal bases for the processing of your personal data differ depending upon your capacity and relationship with us. More information about the applicable purposes and legal grounds can be found in Part 4.

3.2. How does Bulletin Media receive your personal data?

Bulletin Media processes your personal data in the first place because you yourself pass on your personal data in the context of the provision of a Service.

Bulletin Media further receives personal data from public sources, such as official government publications (e.g. the Belgian Official Gazette, the CBE, the NIS (social class)).

3.3. Who receives your personal data?

For each of the specific processing operations listed in Section 4, Bulletin Media will transfer your personal data to:

• subcontractors who work on its behalf and its account (processors);
• its employees in the context of the exercise of their function.

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

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

3.4. Does Bulletin Media transfer your personal data to countries outside the European Economic Area?

The European Economic Area (EEA) includes all countries of the European Union together with Norway, Liechtenstein and Iceland. EU legislation requires additional safeguards if Bulletin Media transfers personal data to other countries situated outside the EEA. In such a case, Bulletin Media will warrant that the transfer is covered by the appropriate safeguards, including a European Commission adequacy decision, or the European Commission’s standard contractual clauses, to ensure the same level of protection for your personal data.

3.5. Which rights do you have as a data subject?

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

• You have a right of access to your personal data. This allows you to verify which personal data a Me Bulletin Media processes about you.
• You always have the right to have your personal data corrected. This allows you to rectify or correct, inaccurate or incorrect personal data Bulletin Media processes about you.
• You have the right to have your personal data erased. This allows you to permanently delete personal data that Bulletin Media processes about you.
• You have the right to limit the processing of personal data related to you. This allows you to ‘freeze’ the use of your personal data by Bulletin Media, without deleting it.
• You have the right to object to a processing of your personal data. This allows you to object to the further processing operations by Bulletin Media of your personal data.
• You always have the right to withdraw your consent whenever the processing of your personal data takes place on the basis of your consent.
• You always have the right to object to the processing of your personal data for direct marketing purposes. Registered Users can amend their newsletter preferences in their account.
• You have the right to data portability. This allows you to easily move, copy or transfer your personal data from one controller to another.

3.6. How can you contact the Data Protection Officer (DPO)?

Bulletin Media has appointed a data protection officer (DPO) for all processing operations which it carries out.

You can always contact the DPO with questions or complaints in connection with any processing of personal data by Bulletin Media. To contact the DPO, email webmaster@thebulletin.be

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

You are entitled to file a complaint with the supervising authority. For Belgium this is: Data Protection Authority, Drukpersstraat 35, 1000 Brussels, Belgium, contact@apd-gba.be, https://www.gegevensbeschermingsautoriteit.be, tel: +32 2 427 48 00.

3.8. Interaction through social media

 If you use any one of the Services of Bulletin Media or visit any of them through your account on social media (e.g. login through your Facebook account) or interact on our social media channels or through buttons or other techniques, then Bulletin Media can receive from the social media entity data (e.g. page statistics). These can be used by Bulletin Media to evaluate its marketing actions or to display Targeted Advertisements on the social media channels.

The use of or interaction with social media is subject to the social media channel’s own rules – no Bulletin Media has any influence over such rules. Consult the user terms and the privacy policy of the social media network concerned to understand how such networks deal with your personal data. Information about data on page insights data for Facebook can be found here.

4. Specific Information regarding the Processing of Personal Data by Bulletin Media

Below you can verify the different processing operations by Bulletin Media. Each of the following processing operations takes place at Bulletin Media, unless otherwise indicated.

Of course, not every processing will apply to everyone.

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

4.1. You are a User or Registered User of one of the Services

If you are a User or Registered User, then Bulletin Media processes your personal data:

• For providing the Service(s) to you based on the need to execute the agreement with you. Here you will find an overview of the different Services for each Bulletin Media Domain and Bulletin Media. When providing the Services we may also use cookies. You can find more information about this use in our cookie policy.

Retention period: up to 10 years after the end of the customer relationship.

• For its client administration based on the need to take pre-contractual measures (recording of orders, follow-up of abandoned shopping cart, etc.) and/or the need to execute the agreement (creation and management of an account, invoicing, collection, etc.).

Retention period: up to 10 years after the end of the customer relationship.

• To invite you to participate in surveys or market research based on its legitimate interest. You are, of course, free to decide whether or not to do so: see section 4.3.
• For sending commercial information (direct marketing): see section 4.3.
• To contact us with a question, request or complaint: see section 4.2.

If you are a Registered User, then Bulletin Media will also process your personal data:

• For showing Recommended Content: if you give your consent through your privacy preferences in your account, then we use Registered Data (i.e. your gender, age and address postal/zip code) to personalise your digital experience and content. These settings are completely optional and separate from settings related to cookies. You can change your choice at any time within your account.

Retention period: up until the moment you withdraw your consent. Click Behaviour will then be kept for a maximum of 13 months.

4.2. You contact us regarding a question, a request for information or a complaint

If you contact Bulletin Media regarding a question, a request for information or a complaint, then Bulletin Media processes your personal data to take pre-contractual measures at your request so as to answer or help you.

Retention period: up to 10 years after your question, request for information or the answer to your complaint has been made.

4.3. You receive commercial information (other than Targeted Advertisements)

Bulletin Media may process your data for direct marketing purposes, in particular:

• To send you the newsletter of a Bulletin Media Domain. This happens on the basis of your consent.
• To provide you with commercial information about Bulletin Media with which you have a relationship (e.g. you are a Registered User, you are participating in a competition or promotional action of Bulletin Media, etc.) based on our legitimate interest in keeping you informed of our activities. If you give us consent through your privacy preferences in your account, then we may use Registered Data (e.g. your gender, age and zip code, current subscriptions, etc.) to more accurately deliver our information to you. We combine this Registered Data with Click Behaviour, where available, to best understand your interests. You can change your selection at any time within your account.
• To send you other commercial information (from Bulletin Media or partners). This action will only happen on the basis of your consent. To be clear: Bulletin Media receives the commercial information from the partner and then decides who to send it to. The partners are not informed of this and, in the case of partner emails, these partners do not receive any information about you.

You always have the right to withdraw your consent. You can do this via your account page or by contacting Bulletin Media.

Retention period: up to 10 years after the end of the relationship with the Bulletin Media Entity that sends you commercial information.

4.4. You are a supplier of Bulletin Media

If you supply products or services to Bulletin Media, then Bulletin Media processes your personal data in the context of supplier management based on the need to perform the agreement with you.

Retention period: up to 10 years after the last delivery.

4.5. You apply for a job at Bulletin Media

If you apply for a job at Bulletin Media, then Bulletin Media processes your personal data for:

• The management and evaluation of the application in the context of the pre-contractual relationship;
• Maintaining a recruitment reserve list based on its legitimate interest. Our justified interest consists of contacting you later for a job opportunity if there is no vacancy immediately available. If you do not wish to be included in the recruitment reserve list, then you can always object to this.

For these processing purposes, we may receive personal data from: the recruitment agency. This concerns the following categories of personal data: contact details, CV, work history, diplomas, training, references and other relevant information for the application.

Retention period: up to 5 years after the application process has ended.

4.6. In any case

If Bulletin Media processes your personal data for one of the purposes set out above, then that entity processes your personal data as well for the following purposes:

• the detection of, prevention of and fight against fraud and abuse based on its legitimate interest. Less fraud and abuse benefits Bulletin Media, its customers and its suppliers.

Additional recipients:

• judicial, police or administrative authorities if the law or the circumstances require it;
• professional advisers (lawyers, consultants, etc.).

Retention period: up to 10 years after the establishment of the facts of fraud or abuse, unless the detection or fight would take longer.

• dispute management based on the law of 30 July 2018 (art. 10§1,1°) and our legitimate interest, as Bulletin Media must be able to safeguard and defend its rights.

Additional recipients:

• judicial, police or administrative authorities if the law or the circumstances require it;
• professional advisers (lawyers, consultants, etc.).

Retention period: up to 10 years after the end of the dispute, unless the management of a specific dispute requires personal data to be kept for a longer period.

• company law transactions and co-operations: personal data may always be processed in the context of discussions, investigations, evaluations, negotiations and implementing measures in connection with a cooperation or corporate transaction (acquisition, merger, sale of shares or assets, joint venture, etc.) by Bulletin Media. This is done based on our legitimate interest to i) enable the legal entities contemplating such an operation to become acquainted with each other’s personal data and ii) for the merger or acquisition to actually take place.

Additional recipients:

• third parties with whom a corporate transaction or cooperation is envisaged;
• professional advisers to the parties concerned (lawyers, consultants, etc.);
• judicial, police or administrative authorities if required by law or circumstances.

Retention period: up to 10 years after the termination of the corporate transaction or cooperation.