Cirklo aims to stimulate the local economy after the COVID-19 health crisis, while working together with local authorities. Therefore, digital gift vouchers can be purchased in the webshop and can be spent afterwards at a local merchant.
The Cirklo Light webshop is being offered by the Studio NV, having its head office at Schildknaapstraat 48 Brussels, BE 0672.741.520, firstname.lastname@example.org. The Studio is the innovation lab and a subsidiary of Belfius Bank NV.
General Data Protection Directive
We respect in all cases the applicable legislation and regulations, a.o. the 2016 General Data Protection Directive with regard to the processing of personal data and on the free movement of such data (hereinafter called the “GDPR”).
If you buy something in our webshop, we gather personal data on you that you provide us with, such as your name, address and e-mail address. The Studio is therefore the controller for the processing of personal data. The processing of personal data includes any possible action related to processing that data, such as collecting, entering, using or storing it. In other words, the Studio always bears the ultimate responsibility towards you as a citizen.
The Studio shall hereby take and apply internal technical and organizational policy measures to ensure that the processing complies with the GDPR requirements and that your rights will always be guaranteed. Such measures could consist, inter alia, of minimising the processing of personal data, pseudonymising personal data as soon as possible, transparency with regard to the functions and processing of personal data, enabling you to monitor the data processing etc.
The Studio can appeal to controllers, such as service providers in software, IT, lawyers etc.
What personal data will be processed?
As a rule, personal data contains all information on you either as an identified or an identifiable person. This data is collected for the buyer during the purchasing process in the webshop and for the merchant during the registration process in the application.
All data the Studio collects, can be combined with each other in order to have our services and offers better adapted to your personal needs.
On behalf of the buyer, who purchases a gift voucher in the webshop, the following personal data is processed:
- E-mail address;
- User ID;
- Postal code;
- Data relating to your individual purchasing behaviour.
On behalf of the merchant (natural person), who registers on the application, the following data is processed:
- Name merchant + merchant owner;
- Official address merchant;
- E-mail address;
- Bank account number.
In accordance with the GDPR we do not process sensitive data such as data relating to your racial or ethnical origin, political opinions or sexual preferences.
Why do we process your personal data?
The Studio can process personal data for the following particular purposes:
- Managing your customer file;
- In order to contact you;
- Executing payment transactions;
- The ongoing improvement of our services, channels and processes;
- Establishing studies, models and statistics;
- Preventing money laundering practices, fraud and financing terrorism;
- Complying with various legal provisions as well as fiscal obligations;
- Answering legitimate questions of the judicial or supervisory authorities in order to gain access to the data;
- Direct marketing.
Yet only those data will be processed that are strictly necessary to achieve the aim intended by the person or authority asking for it.
What is the legal basis for the processing of your personal data?
We process personal data in one of the following cases only:
- When we have asked your permission therefore and when you consented thereto. You can always withdraw this consent. Withdrawing consent applies only to the period after the consent has been withdrawn and hence does not affect the lawfulness of any processing carried out up until the time of withdrawal;
- When we are executing a contract or a precontractual measure;
- When we are obliged to do so legally or on the basis of regulations;
- On the basis of a “justified interest”, for which we conduct a very thorough assessment between the interest of the person or authority asking for it, and your interest, such as the protection of your privacy.
Justified interests are e.g.:
- Preventing fraud and abuse;
- Managing disputes;
- Evaluating the customer relation as a whole;
- Offering products and services that fit as closely as possible with your needs and wishes;
- Improving processes and apps;
Direct marketing, such as:
- Informing our customers on new products and services;
- Establishing a profile of our customers;
- Personalized offers for our customers’ birthday;
- Acquiring new customers, subscribers or members.
To whom may we pass on your personal data?
Personal data shall by no means be sold to, or exchanged or shared with other organizations outside the Belfius group, unless:
- You were informed thereof and you have given your explicit approval;
- This is required for the provision of our services;
- We have a legal obligation in that respect;
- There is a justified interest for a third party involved.
If in that respect we appeal to a firm outside the European Economic Area, we will only do so if we have obtained guarantees as to a similarly adequate protection level with regard to your personal data as would be the case within Europe.
Apart from that, we can use anonymous, aggregated data either for commercial or for internal and external reporting purposes. As a matter of fact, these data can never be traced back to a specific individual.
What are your rights as to the processing of your personal data?
You will always have the right to view the personal data that have been collected on you, and to exercise this right at reasonable intervals, for you to be able to obtain information on the processing and to check the lawfulness thereof. This right may of course not infringe on others’ rights or freedoms, including on the professional secret or the intellectual property, and more specifically on the copyright protecting the software.
You also have the right to withdraw your permission at any time. The withdrawal must be possible for free and without any adverse consequences for you as an individual. The withdrawal must be possible as simply as the permission was given. All data processing founded on this permission, will of course be brought to an end. When otherwise no other legal foundation is available for processing this data, the data will be removed.
If your personal data is processing for direct marketing purposes, you will have at all times the right to object to this processing without any charge. In that case, we will stop immediately processing the personal data for direct marketing purposes.
Furthermore, you have the right to have your personal data rectified. Is your personal data incorrect, incomplete or irrelevant, then you can have it modified or completed. In certain cases you will also have the right to ask for the limitation of the processing of your data for a specific service, as well as the right to object to the use of your data on the basis of a justified interest.
You have the right to have your personal data transferred. On certain conditions you may have paid data you provided us with transferred to another controller or to yourself.
Finally, you have the right to have your personal data to be erased and to have it no longer processed if the personal data is no longer necessary for the purposes it was collected for or in any other way processed, if you have withdrawn your permission or if you have objected to the processing of your personal data, or if the processing of your personal data relating to another aspect no longer complies with this privacy charter.
How can you exercise your rights?
The user can send an e-mail to email@example.com and address his/her request to: The Studio NV, Schildknaapstraat 48, 1000 Brussels.
If you disagree with The Studio’s viewpoint, than you have the right to file a complaint with the Belgian Privacy Commission.
Contact data DPO
You may contact our Data Protection Officer (‘DPO’) by writing him or her at the following address: Belfius, to the attention of the DPO – Karel Rogierplein 11 – 1210 Brussels or by sending an e-mail to firstname.lastname@example.org.
How long is personal data kept?
Your personal data will be kept as long as it is necessary for the aforementioned purposes.
What happens if any changes are made to this privacy charter?
Date of the most recent change: 28/05/2020
 The Belfius Group consists principally of Belfius Bank and the self-employed network of branches (agents-mandataries), Belfius Insurance, Belfius Investment Partners, Crefius, Elantis, Belfius Lease, Belfius Auto Lease, Belfius Commercial Finance, Corona, VDL-Interass, Bureau Laveaux & Martin, Qualitass etc. Of course, the composition of the Belfius Group may change.