VOO attaches great importance to your privacy and processes your personal data, hereinafter referred to as the “Data”, with the utmost care and transparency. VOO also makes it a point of honour to offer its clientele the best possible security. Below please find information relating to the Data processed by VOO as well as to your rights in respect of these Data.
Who is the party responsible for the processing of your Data (Data Controller) and how to contact them?
Which data is processed by VOO, and for what purpose?
First of all, VOO processes your Data in order to be able to perform the contract it has concluded with you or to put in place steps prior to entering into a contract, such as answering any questions you may have regarding our services. If you do not yet have an account with VOO and you would like us to reply to questions you send in to us through our website, we will need your email address or your telephone number. When you subscribe, VOO collects your identity details, your date of birth, your national register number if you’re Belgian, your postal address(es), your e-mail address, your telephone and/or mobile phone number and your bank details. In order to enable VOO to raise its bills, VOO also processes data relating to the use you make of the various services offered. In order to enter into a contract with you, at a minimum VOO needs to have your identity details and contact details, as the address where the services are to be delivered. In doing so, you will be assigned an account number, an easyswitch identifier, an IP address, a SIM card, modem and/or decoder number, as data which will also be registered by VOO. When you subscribe, VOO also collects data related to your use of our services such as web pages visited (we cannot view any downloads you may have made from our site), destinations called, TV programmes viewed or connection data such as your computer’s IP address, connection and usage logs, data relating to your device configuration, and connection events linked to your equipment. VOO also processes financial data such as payment methods and history.
VOO also processes Data as part of the pursuit of its legitimate interests. This relates to improving our network, ensuring the network is working properly, checking the quality of the data it’s processing and, if necessary, correcting it, gauging your satisfaction as a customer and getting to know you better, responding to your requests, improving our service and websites, for commercial purposes, preventing and detecting any instances of fraud or maintaining security, for example. VOO also keeps a record of all contacts it has had with you through its various channels. Certain phone calls conducted with our services are also recorded to ensure the quality of the responses given to your questions. If, moreover, when asking a question you communicate to us your address, email address or telephone number, unless you object, we will retain your telephone number and address in order to send you information about our services and promotions, and with your consent, we will retain your email address for the same purpose. Your use and consumption habits of our services are collected to build your profile and to enable us to send you TV programme recommendations (for example via VOO TV+), to offer you discounts/benefits or present services and/or options which meet your expectations, to help you choose which of our offers best suits your needs, and to be able to send you targeted offers. In addition, VOO may contact you again over a 6-month period after the expiry of your contract, or for longer with your consent, based on your Data to inform you of its new promotional offers.
VOO does not put in place any fully automated decisions in respect of yourself which could have legal consequences in regard to yourself or that could affect you in a significant manner, such as denying you access to certain products. However, VOO does raise profiles that are used by its agents to enter into contracts, or within the context of the performance of the contracts, in particular to present you with tailored or more advantageous offers or programmes that are likely to interest you. In doing so, evaluations of your socioeconomic situation are compiled, based on your socio-demographic situation and on statistics.
Moreover, numerous statutory and regulatory obligations are in place that require VOO to process and keep certain Data such as the bills (accounting and tax obligations), IP address, the traffic data relating to your communications or location data (obligations specific to telecom operators). In this respect, please rest assured that the latter Data are kept solely for the purposes set out by law, such as in order to comply with the requests from the judicial authorities or the intelligence services, to check the proper operation of the network or to deal with emergency calls, for instance. Under no circumstances will VOO access any videos viewed.
Also, in some cases, VOO will process Data based on your consent, for instance to advertise the photo of the winner of a competition on our Facebook page or to establish your consumption profile to help you find the most appropriate offer for you. In that case, you will be duly and expressly informed, at the time when your consent is sought, of the reasons why VOO would like to use these Data. In addition, you should be aware that you are free to withdraw your consent at any time, without being required to state reasons. However, this will not affect the lawful nature of any processing that has taken place prior to the time you withdrew your consent.
Where are the Data sourced from?
By far the overriding bulk of the Data processed by VOO are collected either from yourself directly, as it was you who provided them, or indirectly as they were gathered whilst you were using the services or while using our websites.
We are also provided with Data by third parties with your consent, or because you have expressed an interest in our telecommunications services, in which case these are contact details (surname, first name, home address and telephone numbers) which enable VOO to contact you to present its services, in case you do not yet have an account with VOO.
In some cases, VOO will also collect Data that were made public on the internet. In that case, these are socio-demographic data such as your age, gender, town, data regarding your areas of interest or data relating to your surfing behaviour (number of clicks, duration of visits, pages visited on our voo.be website, on the VOO forums or on our Facebook page. These Data enable us to compile profiles in order to send out targeted advertising messages or to improve the appeal of our services, our websites and platforms. Unless your activities on the VOO forums or on our Facebook page are to do with the performance of your contract or where you provide us with your customer number, these data are collected on an aggregated and consequently anonymised basis without any links being established to yourself.
How long are your Data kept?
The retention period of your Data will vary depending on the reasons why they are processed. The bulk of the Data relating to your contract will be kept on record for the duration of the life of the contract and for a period of what in principle is ten years after the contractual relationship has ended. The data used for the purposes of predictive modelling are kept on record for a duration of 36 months. The traffic data are kept on record until the end of the time period during which you can protest the bill or until the end of the period during which proceedings may be brought to secure payment thereof; the location data are kept on record for the duration necessary to furnish the data traffic or the location services in question. The data relating to the access and to the connection of the terminal hardware to the network and the data intended to identify the user or the account holder are kept on record for twelve months. If you have a MyVOO account, your account will be retained for two years after your contract expires unless you have requested that it be deleted.
The data of the surveillance cameras at some of our points of sale and the conversations with our agents are kept on record for no longer than a month.
Data relating to the prospects are kept on record for a maximum of one year. If you have asked VOO not to use your data for marketing purposes, your data will be retained so as to be excluded from our advertising campaigns.
In some cases, where this is required by law or so as to safeguard VOO’s rights and interests, and particularly in the event of a dispute, Data may be kept on record for longer time spans insofar as this is necessary for the purposes outlined above.
To whom are my data disclosed?
VOO calls on the services of various service providers which, in some cases, may have access to some of your Data. By way of illustration, VOO calls on self-employed installation engineers or technicians. Raising their bills and dispatching these bills is assigned to a third-party service provider. The same applies to part of the management of the VOO website and the VOO forum. The call centres are managed by third party partners or other companies of the Nethys Group. VOO also calls on the services of independent resellers and discloses certain Data to third parties to recover unpaid debts or to analyse data and statistics. Data may also be disclosed to partners as part of marketing campaigns, for instance where prizes are handed out to competition winners or for targeted advertising purposes. Data may also be transmitted to third parties such as insurance companies, injured persons or the police in the event of a claim. In addition, VOO facilitates consultations and invoice payments by working with third-party providers (such as Zoomit and Doccle). These various service providers have access only to the Data they need to perform the duties assigned to them by VOO. On no account are they able to use the Data which they have access to for any other purposes.
In addition, VOO is required by law to disclose Data to the emergency services or to certain authorities. If so requested by you, your data are also transmitted to the publishing houses of telephone directories.
In some cases, Data are transferred to service providers located outside of the European Economic Area for which the European Commission has returned an adequacy decision, acknowledging that these service providers offer an adequate level of protection for the Data transferred to them by a European entity. Your personal Data are then transferred on this basis.
Your data can also be communicated to third parties, including Nethys group subsidiaries, in the event of a merger, acquisition or restructuring involving VOO SA or Brutélé SCRL.
What are your rights and how can you exercise them?
In compliance with the applicable regulation, you have the following rights, which you may exercise free of charge and at any time, except in the event of misuse:
- – The right to request access to your Data (A)
- – The right to have your Data rectified (B)
- – The right to have your Data erased (C)
- – The right to object to your Data being processed (D)
- – The right to request for the processing of your Data to be restricted (E)
- – The right to Data portability (F)
- – The right to file a complaint with the Supervisory Authority (G)
A. Right of access
You have the right to request VOO to confirm whether or not the Data relating to you are processed and, if so, you may request access to such Data. In that case, you will also be provided with the following information:
- the Data categories concerned and the purposes for which they are processed;
- the recipients or the recipient categories to whom the Data were or will be disclosed, in particular the recipients who are located in third countries;
- if possible, the planned retention period of the Data or failing this, the criteria adopted to determine this duration;
- the rights you have in respect of your Data, including the right to file a complaint with the Data Protection Authority;
- where the Data were not collected from yourself, all available information regarding their origin;
- the existence of automated decision-making or the establishment of profiles and, as applicable, useful information regarding the logic behind any such decisions or profiles;
This right is easily exercised through the “Contact Us” section, “Administrative” sub-section on VOO’s website or by writing in to any one of VOO’s DPOs at the addresses specified above. Please be aware that the traffic data relating to your communications may be disclosed only to the authorities specified by law, which is why you are not allowed to have access to these data.
B. Right of rectification
You have the right to have Data relating to you, which are inaccurate or incomplete, rectified at any time. This right is easily exercised through the “Contact Us” section, “Administrative” sub-section on VOO’s website, by calling 078/50.50.50 or by writing in to VOO’s Customer Service at 46 rue Jean Jaurès, 4430 Ans for Nethys account holders, or to 29 rue de Naples, 1050 Brussels for Brutélé account holders.
C. Right to erasure
You have the right to request VOO to erase the Data relating to you in the following cases:
- the Data are no longer necessary for the purposes for which they were collected or where they are processed in another manner;
- you have withdrawn your consent on which the processing rests and no other legal basis for the processing exists;
- you have availed yourself of your right to object, as explained under paragraph D. below;
- your Data have been unlawfully processed;
- your Data are to be erased in order to comply with a statutory obligation;
- your Data were collected as part of an information service addressed to a child;
Where VOO needs your Data for the purposes for which they are processed, they shall not be erased. Nor shall the Data be erased where the processing is necessary for VOO to comply with a statutory obligation, to perform the contract, to contact you or with a view to the establishment, the exercise or the defence of its rights before a court of law.
This right to erasure is easily exercised through the “Contact Us” section, “Administrative” sub-section on VOO’s website or by writing in to any one of VOO’s DPOs at the addresses specified above.
Any data which you have communicated to VOO on platforms such as the VOO forum on via VOO’s social media pages cannot, however, be erased directly by VOO. VOO does not make any connection between its customers and the users of these platforms. If you wish your data to be erased from these platforms, your erasure request should be addressed directly to each of these forums. If you wish your data to be erased from the 1307 directory, please contact VOO. In that case, however, your Data shall be left out of the paper directory only from the next edition. For the digital directory, your number will no longer be available when the 1307 directory next consults our database.
If you wish to expedite matters, please also directly contact the 1307 directory, either by phone on 0800/ 98 033, or by e-mail, sent to email@example.com. Your number will be taken off the www.1307.be website within 48 hours.
D. Right to object to processing
You have the right to object, at any time, for your own reasons, to having your Data processed, including to having profiles compiled of yourself, carried out by VOO in pursuit of its legitimate interests. In this case, VOO shall cease the processing unless this is necessary with a view to the establishment, the exercise or the defence of its rights before a court of law or where VOO is able to show that legitimate and compelling grounds exist that take precedence over your interests and your rights and freedoms.
For that matter, you have an absolute right to object to having your Data processed, including to having profiles compiled of yourself for commercial purposes. Please be aware that, in this case, it may be that you will be contacted again by VOO if, after having erased your Data at the end of the retention period or at your request, VOO is sent your data again from a third party with your consent.
This right is easily exercised through the “Contact Us” section, “Administrative” sub-section on VOO’s website or by writing in to any one of VOO’s DPOs at the addresses specified above.
By way of general information, please be advised that you may object to the use of your landline or mobile telephone number by any businesses for marketing purposes, by signing up to the “ne m’appelez plus” (stop calling me) list at the https://www.dncm.be/fr/ website.
E. Right to restriction of processing
Where the processing is restricted, with the exception of the retention, the Data that are restricted may no longer be processed unless within the context of the restrictions established with your consent or with a view to the establishment, the exercise or the defence of VOO’s rights before a court of law, or with a view to the protection of the rights of another person.
You have the right to request VOO to restrict its processing operations if any one of the following applies:
- you dispute the accuracy of the Data;
- the processing is unlawful but you do not wish to have your Data erased;
- VOO no longer needs the Data for processing purposes but your Data are still needed with a view to the establishment, the exercise or the defence of VOO’s rights before a court of law;
- you have objected to having your Data processed and a check is made as to whether the legitimate interests pursued by VOO prevail over your interests.
This right is easily exercised through the “Contact Us” section, “Administrative” sub-section on VOO’s website or by writing in to any one of VOO’s DPOs at the addresses specified above.
F. Right to Data portability
You have the right to be provided only with the Data relating to you which you supplied us with, with a view to the performance of the contract or with your consent and which are processed by way of automated procedures, and where these were either transmitted to you or to another Data Controller if this is technically possible.
If you wish to exercise this right, please inform us thereof at the time you request to cancel your contract.
G. Right to file a complaint with the Supervisory Authority
You may address all requests or complaints relating to the processing of your Data by VOO with the Belgian Supervisory Authority at:
Data Protection Authority
Rue de la Presse, 35, 1000 Brussels
- Tel : +32 (0)2 274 48 00
- Fax : +32 (0)2 274 48 35
- Email : contact(at)apd-gba.be
Or through its website at: www.autoriteprotectiondonnees.be/contact