We view protecting your privacy as a matter of the utmost importance. We would like to keep you informed as best as possible, respect you and give you control over what happens to your personal information. Set out below you will find information about what data we collect, why we do so, how long we keep it, what your privacy rights are and how you can exercise these rights.
It applies in respect of processing personal information of our (private and business) customers in relation to our telecoms products and services (including mobile or landline telephony, mobile or wired internet, radio and/or television), as well in respect of the personal information of the end users, who utilize these Telenet services and products through their relationship with our customer (for example: family members, friends, visitors and employees).
B. Data controller
C. Your responsibilities towards end users
D. Your responsibilities towards third-party services
A. The personal information, which you share with us
We process the personal information, which you yourself pass on to us. This may be by telephone (for example, when you call customer services with a question or wish to report a fault), in writing (for example, when you fill in an order form (online), you send us a text message or e-mail, you register for a competition or download a Telenet app), electronically (for example, when reading your e-ID when you enter into a contract) or verbally (for example, in one of the Telenet points of sale).
B. The personal information, which our systems collect
We assign to you personal information for using our products and services (for example, a digibox number, an e-mail address, an IP address, a telephone number, customer number, log-in code(s) and passwords). In addition, our systems also record personal information, which is generated while you are using our products and services (for example, the television programs that you have watched or the identification numbers of the devices linked to your Telenet internet connection), including use by end users (for example, visitors who are linked to your Telenet homespot).
C. The personal information, which we obtain from third parties
D. Categories of personal information
We distinguish in our systems between different types of personal information, which can be combined with one another:
As stipulated by law, we do not process any sensitive data including data about your racial or ethnic origin, political views, sexual preferences and health.
E. Personal information of non-customers
Through various channels, such as for example competitions, promotions/campaigns, our web sites/apps and by purchasing data from specialist big-data firms, we are able to collect personal information about people, who are not (yet) customers of Telenet with the intention of making the most relevant offer possible to these people for Telenet products and services. In so doing, we guarantee your right to information and - insofar as is applicable - in conjunction with your eventual legally required consent contractually enforce this in respect of third parties, who might collect your data (on our behalf) within this context.
A. Proportional processing
We process personal information for a variety of purposes, and in each case we process the data, which is required to achieve the intended goal.
In this way we use personal information when this is necessary:
If processing your personal information is not necessary for one of these three reasons, then we always ask for your consent to be permitted to process your personal information.
B. Our processing activities
We collect personal information for the following specific purposes:
C. Automated decision making
Telenet does not undertake automated decision making - based on or not based on profiling - with which legal consequences are associated for you or in which case any such decision affects you to a significant extent, unless:
In such situations you are informed beforehand about the automated decision that has been made, that you are entitled to demand human intervention and the way in which you are able to contest the decision.
A. Our technical and organizational measures
We work hard to protect your personal information and privacy, both in our offices, in our stores, in our network and in your home.
The software on our products is constantly kept up-to-date. In addition, we offer you individual security settings, which you yourself can manage, such as: a password on your television, a filter on your e-mail inbox and a firewall on your desktop or laptop.
The number of employees in our company that has access to your personal information is restricted and our employees are carefully selected. They are only granted access to your personal information insofar as they require this information to complete their duties properly.
B. Telecommunication secrecy
Your personal communications are confidential. We are able to process metadata (i.e. the data, which is processed to technically facilitate the communication), but the existence and the content of the personal communications, which pass over our network (for example: landline and mobile telephone conversations, e-mails and text messages) are protected by provisions governing telecommunication secrecy. Telecommunication secrecy means that, outside the exceptions summarized by law, Telenet is not permitted to have knowledge of the existence or the content of such communication. Telenet has taken the necessary security measures and given adequate instructions to its staff to observe telecommunication secrecy.
A. Data transfers
We do not sell any personal information to third parties without your consent and we do not pass it on to third parties unless:
B. International processing of your personal information
A few examples:
C. Use of anonymous data
We use anonymous, aggregated data for commercial purposes and internal/external reporting. This data can never be traced back to a specific natural person. Some examples: location reports (‘how many people were in a particular place at a specific time’) for event organizations, supermarkets and towns/villages, viewing statistical reports for TV broadcasters for determining the popularity of certain programs, for example. Telenet in each case guarantees that all of these parties are never able to trace the data received by us back to an identifiable natural person.
A. Telenet privacy settings
Each private customer as well as every business customer, which purchases Telenet products and services that are intended for self-employed individuals and small businesses, is able to determine him/herself based on a number of settings how he/she thinks that we may use his/her personal information for commercial purposes. Within the framework of specific telecommunication products and services, certain end users can also create a personal log-in. Anyone using this facility is able to manage his/her privacy settings in the same way.
The processing of personal information can thus be divided into 4 levels:
Level 1: General
With this level you stipulate that Telenet is not allowed to process traffic data or sales profiling on you for the general commercial communication substantiated at this privacy level. For the purposes of complete clarity, we continue to profile to the extent that this is necessary as part of preparing, performing or terminating our contract in order to meet the statutory or regulatory provisions that we are subject to and for the furtherance of our legitimate interests. In the case of the latter we always endeavor to achieve a balance between those interests and respecting your privacy, particularly if you are a minor.
Unless you have set your decoder up differently, your TV viewing behavior will be used to recommend programs to you, which may potentially be of interest to you. Your TV viewing behavior is not used at this level to present additional products or services to you and you won’t qualify for TV advertising adapted to your preferences and interests You will thus only get the standard TV advertising.
Level 2: Focused
If you become a Telenet customer from 25 May 2018 (the date of entry into force of the General Data Processing Regulation, or the “GDPR”), this level 2 standard will apply to you by default. You can always increase or decrease this level in your privacy settings. If, for example, you move to level 1, then we will only send you general commercial communication the legal basis of which is in Telenet’s legitimate interests, to inform you in particular of the optimal use of Telenet products and services that you already have. In any case, no more traffic data will be processed or sales profiling will be used for commercial communication, which you will continue to receive from us, based upon your choice in favor of level-1 privacy.
At level 2 we do the same as at level 1, but over and above that our commercial communication becomes more focused. We also include your traffic data, TV viewing behavior and sales profiling to customize our communication to your preferences and interests. This information is only, however, used for direct marketing for equivalent products and services from Telenet itself. This means that we, for example, can send you an e-mail if a new season of your favorite TV series is about to come out, or you may receive a promotion for our sports entertainment package if we notice that you are interested in sports programs or sports reports. You will continue to only get the standard TV advertising.
Level 3: Personal
If you became a Telenet customer before 25 May 2018 (the date of entry into force of the GDPR), then you are enabled by default for level 3 unless you yourself might have updated your privacy setting to a higher or lower level. Moreover, you can always increase or decrease your privacy level. If, for example, you move to level 2, your TV viewing behavior will no longer be used for adapted TV advertising. Your TV viewing behavior is still processed at this level to keep you commercially informed about (other) Telenet services in a more personalized manner. If you further lower your privacy setting to level 1, then your TV viewing behavior will no longer be processed for general commercial communication, which you then receive from us. . Unless you have set your decoder differently, your TV viewing behavior is only used to recommend programs to you, which may potentially be of interest to you and/or insofar as we are legally obliged, or insofar as the processing of this information is required for the purpose of invoicing and reporting.
At level 3 you are opting for a personal TV experience. We also use your data to customize the TV adverts that you are shown to the preferences and interests of you (and your family). If, for example, you fanatically watch athletics, then you are more likely to fairly quickly see an advertising commercial about sports items.
The collected data about your TV viewing behavior is only used as from this level to show focused TV advertising (as opposed to standard TV advertising). For this purpose we otherwise ask for additional data (for example, socio-demographic data relating, amongst other things, to you as a customer and/or your family, as well as statistical data at neighborhood and street level and consumer information) from an external supplier (currently: Bisnode; more information: www.bisnode.be).
Level 4: Unique
At level 4 you are opting for a completely personalized experience in the sense that we also process data about your internet usage. We do everything we can to customize to the maximum extent both the communication, which you receive from us, and the advertising commercials that you see on the TV to your preferences and interests.
Thus only in respect of customers, who have actively opted for this level, certain aspects of their web surfing behavior (e.g. areas of interests that are deduced based on categories of web sites visited) are added to their profile and used for commercial communication.
Maybe, for example, you have spent some time online searching for an affordable hotel in Berlin? Then we can provide you with tailor-made attractive offers or send additional information about how and where you can surf the internet free of charge abroad. Furthermore, you may also receive focused TV advertising for sports items, for example, because we have noticed that you are often browsing sports web sites.
In summary: other than by means of cookies etc. (provided you haven’t disabled them) or unless you have actively opted to do so (by activating the “Unique” level), Telenet does not process any information about your web browsing behavior. Unless legally obliged or out of necessity for the provision of the service (for example, as part of quality research by our customer services), we never further process the content of your personal communication (e.g. telephone call, text message, e-mail, chat or social media).
In practical terms you can contact Telenet customer services about your choice of level as well as the Telenet points of sale or change the settings yourself in the section “My Privacy settings” on My Telenet (only for those data subjects who have an active My Telenet account). Your change to a privacy setting can take (max. 72 hours) and does not affect the legitimacy of instances of previous data processing. If we want to collect your personal information for specific purposes, then we will always inform you about this, and where legally required request your consent, in the communication, which we disseminate about this.
Telenet conducts a strict policy regarding the processing of personal information of minors. If we know or need to know that you are younger than 16 (for example, within the context of creating a personal log-in), your personal information will always be automatically processed according to the most restrictive privacy level (privacy level 1 - “General”). Otherwise, insofar as is legally required, Telenet shall request the prior consent of your parent(s) or guardian.
C. Opt-out for direct marketing
You are always entitled to oppose the use of your personal information for direct marketing purposes without having to specify a reason for this.
If you wish to choose the media through which you receive our marketing (e.g. only by e-mail), you can always contact the Telenet customer services or visit one of our Telenet points of sale and disable our feature to receive promotions and/or campaigns by telephone, post, text message or e-mail. Everyone (including prospects) can also use the following external unsubscribe options:
We will only send commercial communications to web site users, who are not Telenet customers, via text message and/or e-mail after they have given their unambiguous consent for this.
Note: the fact that you no longer wish to receive any commercial communications from us does not, of course, affect our right to contact you electronically as part of the performance of your contract or if the law obliges us to do so.
A. Overview of your privacy rights
Your right of access
You are entitled to find out from Telenet at any time whether or not we process your personal information, and if we do process it to have access to this data and to receive additional information about:
You are also entitled to receive a free copy of the data being processed, in some intelligible form. Telenet can request a reasonable payment for covering its administrative costs for any additional copy that you request.
Your right to update personal information
You are entitled to have incomplete, incorrect, inappropriate or out-of-date personal information corrected without delay.
To keep your data up-to-date, we request that you notify us of any change whatever the circumstances, such as a relocation, change of e-mail address or the renewal of your identity card. In the meantime, we provide a periodic pop-up in My Telenet where you are prompted to update your contact details.
Your right to the erasure of your data (the ‘right to forget’)
You are entitled to have your personal information deleted in the following instances, and without any reasonable delay:
Remember that we are not always able to delete all personal information that is requested, for example if processing it is required for instituting, exercising or substantiating a legal claim or because we are obliged on behalf of the judicial authorities and the State Security Services to retain data about customers’ (mobile) telephone traffic for 12 months. We will inform you in more detail of this in our response to your request.
Your right to restrict the processing of data
You are entitled to obtain a restriction on the processing of your personal information if one of the following elements applies:
Your right to the portability of personal information (‘data portability’)
You are entitled to ‘recover’ your personal information, for example to be able to change service provider more easily. This is only possible in respect of the personal information, which you yourself have provided to Telenet, based on consent or pursuant to an agreement. In all other cases, therefore, you may not enjoy this right (for example, if the processing of your data is based upon a statutory obligation).
There are 2 aspects associated with this right:
Your right to object against the processing of your personal information
You are entitled to lodge an objection against the processing of your personal information on grounds of your special situation if processing it is in line with Telenet's legitimate interests or in line with general interests. Telenet will discontinue the processing of your personal information unless Telenet is able to demonstrate compelling and legitimate grounds for processing it, which override your grounds or if the processing of personal information is associated with the instituting, exercising or substantiating of a legal claim (for example, submitting an appeal to a court of justice).
How do I exercise my privacy rights? Via My Telenet (only for those data subjects who have an active My Telenet account)) and the Telenet points of sale. To exercise your privacy rights, and to prevent any unauthorized disclosure of your personal information, we need to verify your identity. In case of doubt or unresolved issues we will first ask you for additional information (preferably a copy of the front of your identity card).
Are there costs associated with this? You can exercise your privacy rights free of charge unless your request is manifestly unfounded or disproportionate, in particular due to its repetitive nature. In such a case - in accordance with the privacy legislation - we have the right and choice (i) to charge you a reasonable fee (in which case the administrative costs are taken into account to provide the requested information or communication and the costs, which are associated with taking the requested measures), or (ii) to refuse to follow up your request.
In what format do I receive a reply? When you submit your request electronically, where possible the information is provided electronically, unless you request it otherwise. In any case we will provide you with a brief, transparent, intelligible and easy-to-access response.
When will I receive an answer? We will respond as quickly as possible to your request, and in any case within one month of receipt of your request. Depending on the complexity of the requests and the number of requests, this period may be extended for a further two months, if required. In case of an extension of the period, we will notify you of this within one month of receipt of the request.
What if Telenet does not follow up my request? We will in each case inform you in our response about the option of submitting a complaint to a supervisory authority and lodging an appeal to the court.
We are not permitted to keep your personal information for longer than is necessary to achieve the purpose for which we are collecting it. The retention period may thus vary for each purpose, and sometimes be very short. Thus traffic data relating to communications and connections is never retained for longer than 12 months, your TV viewing behavior for a maximum of 36 months and your calls with Telenet customer services are kept for training purposes for a maximum of 30 days. Sometimes the period may also be longer, for example, to observe our statutory obligations (to meet our accounting and tax obligations, for example, we are obliged to keep your invoicing data for a maximum of 7 years) or as a legal requirement to retain certain data (in particular your contract, invoices and correspondence in connection with complaints about this) as evidence in case of disputes, for up to a maximum of 10 years following termination of your contract. This archived data is, of course, only accessible to a limited extent.
After expiry of the applicable retention period(s), personal information is deleted or anonymized.
If you visit our web sites and use our apps, then we process the following personal information pertaining to you:
The personal information, which we collect via our web sites and apps, is used for the following purposes:
A. What are cookies?
There are various types of cookies, subdivided according to source, function and lifespan. For a complete overview you can consult web sites such as www.allaboutcookies.org.
Thus, for example, as a visitor to our web sites you can be identified the next time you visit and we can enhance user-friendliness by more effectively streamlining our web sites to your requirements and preferences. Cookies can also be used to make the content or publicity of a web site more personal. Thus a customer, who has a particular entertainment package, will see different messages to somebody, who does not have it.
Cookies can be saved both by Telenet and by other parties. If we allow third parties to save cookies on our web sites, then these parties must contractually guarantee a secure connection over which the data is exchanged.
B. What types of cookies do we use?
C. Managing cookies
At any time using the settings on your browser (usually under “Help” or “Internet Options”) you can disable or delete all installed cookies on your computer of mobile device. Each type of browser has its own settings for managing cookies. You can find the information on the web site of the browser, which you use. More general information about managing cookies can be found at http://www.allaboutcookies.org/manage-cookies/. In addition, you can also choose on the following web sites from which companies you no longer wish to receive any cookies: http://www.aboutads.info/choices/#completed and http://www.youronlinechoices.com/.
Remember that changing the settings may result in the Telenet web sites and other web sites no longer functioning properly. The same applies for mobile apps.
Do you want to report a privacy incident? Please send an e-mail to our Data Protection Officer (‘DPO’) at firstname.lastname@example.org.
Latest update: 17 march 2019