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The Telenet Safespot privacy policy

Hi there, and congrats to you. You have decided to install Telenet Safespot and invest in your security.

 

How does Telenet Safespot work? Telenet Safespot is a security software for both network security and security on your end devices. Network security is provided by software that is installed on your Telenet modem to protect your entire in-home network. To be more precise, it is installed on the router that is part of your modem. This advanced software scans the internet traffic from and to the devices connected to your modem and accessing internet (like computers, smartphones, smartwatches, smart thermostats, baby monitors, …). It immediately blocks what is not welcome, such as viruses, hacking, phishing, malware and other cyber hazards.

 

When you purchase Telenet Safespot you will receive (via SMS) the code to enable you to install the Telenet Safespot management app. Via the management app you can monitor the activity. Telenet Safespot also enables device fingerprinting, it identifies devices connected to the modem and displays them in a dashboard (visual in the management app). It alerts you when a device leaves or is added. It also enables you to block a device.

 

The protection of end devices is done by the Telenet Safespot guard app which is installed on your end devices. You can only install this app after you have received the invite to do so from the management app (it will send you the installation code). The Telenet Safespot guard app is an antivirus program that blocks phishing and malware locally on your device, through scanning of the internet and e-mail traffic from and to your device. The app protects your devices at home and on the go (when you are not at home and not connected to your modem).

 

No need to say that in order to provide you this service, we need to process your data. 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, you can read in this privacy policy. It is important you thoroughly read through this policy.

1. Who is protected by this privacy policy?

This privacy policy only applies to the personal data that we, as data controller, process from Telenet Safespot (ex)customers and end users.

 

  • We start collecting and processing data when
  • We install the software on your modem & the software starts scanning your traffic data;
  • You install the Telenet Safespot management app;
  • You or another end user install(s) the Telenet Safespot Guard app.

 

This Telenet Safespot specific privacy policy does not apply to the processing of personal data in relation to other Telenet products and services (like our telecom products and TV services). Nor is it applicable on the data we process when you order and purchase the Telenet Safespot product (this is general identification data like name, address, phone number …), when we invoice you for it and when you communicate with us regarding this product. For these activities our general Telenet Privacy Policy should be consulted (https://www2.telenet.be/en/privacy/)

2. What does ‘processing personal information’ mean and who is responsible for this?

A. Definition

‘Processing personal information’ is understood to mean any processing of information, which may identify you as a natural person. Which information this exactly involves, you can read in point 3 of this privacy policy. The term ‘processing’ is broad and, amongst other things, covers the collection, capture, organization, retention, update, editing, querying, consulting, using, distribution or disclosure in whatsoever form, collation, combination, archiving, deletion or eventual destruction of this information.

 

B. Who is responsible for the processing of your data?

Telenet bvba, with its registered office at Liersesteenweg 4, 2800 Mechelen, and registered in the Crossroads Bank for Enterprises (CBE) under number 473.416.418 (hereinafter referred to as “Telenet”) is the data controller of your personal information. This means that Telenet determines the objectives and resources used to process your personal information.

 

You also have some obligations towards the end users that you allow to use the Safespot products that you purchased. These are described in the next bullet.

 

C. Your responsibilities towards end users

It can happen that you, as a Telenet customer, allow end users (such as family members, friends, visitors and employees) to utilize the Telenet products and services. An example is giving them access to your Wi-Fi. That implies that Telenet processes their data and that their devices are subject to the Telenet Safespot scanning as well. Both our general privacy policy (for the use of the Wi-Fi) & the Telenet Safespot privacy policy apply here (for the security scanning). So, your end users should be made aware of this. Inform them when you hand over the Wi-Fi credentials.

 

It is also possible that you, as a Telenet customer and administrator of the management app, let end users install the Telenet Safespot guard app on their devices or install it for them (e.g. when you want to install it on the smartphone of your child). If you install the app, we ask you to confirm that you agree with the Telenet Safespot privacy policy. If you install it for somebody else, this person should be made aware of this installation & of the fact the Telenet Safespot privacy policy applies. In particular, you (as the administrator and user of the management app) can see their devices connected to your Wi-Fi network and the alerts in case of a phishing (or other malware) attempt.

 

To be more precise, you have the following responsibilities:

  • To adequately inform end users that Telenet will process their personal information based upon their use of the Telenet products and services; 
  • To obtain all legally required consents from end users before their personal information is passed on to Telenet to be processed as part of Telenet products and services, which you allow them to use; 
  • To adequately inform end users about the applicability of this privacy policy, in particular in relation to privacy rights and how these may be exercised (see point 8 of this privacy policy); 
  • You are not permitted to use the Telenet products and services to collect personal information, which contravenes the valid privacy legislation, nor to illegally provide yourself with access to the personal information of end users.
     

3. What personal information can we process?

First of all we want you to know that content is never opened nor processed. Telenet Safespot processes that you visit YouTube, but it does not see which movie you watch on YouTube. Or it processes that you visit the website of a bank, but it does not see your personal customer zone (so it has no access to your bank account). We do not read your e-mails but we scan them to find phishing mails or false ads & block these suspicious e-mails.

 

Location data like your GPS coordinates is never collected. Please note that when you install the management app and/or the guard app on an Apple device, Apple asks you to agree to share your location data. Apple considers the fact that you are connected to the Wi-Fi network and to which Wi-Fi network as location data.

 

Also, we do not process any sensitive data including data about your racial or ethnic origin, political views, sexual preferences and health.

Data processed through the software agent on the modem:


The Telenet Safespot software agent scans your internet traffic, better said, it deep dives into your TCP/IP traffic. It wants to make sure that you do not visit malicious websites (so it analyses the websites you visit) and it monitors the load of your traffic (if your smartwatch suddenly starts to show a high peak in traffic, it may be hacked and used for a DDOS attack, the agent can block this device & make sure it cannot communicate to your other devices on the network). The data processed here is the URL, IP address, MAC address, ports, DNS requests, domain visited (e.g. Facebook), domain category (e.g. social media), date and timestamp, volumes, packet metadata, router ID, overall network bandwidth stats, Tx/Rx packets/bytes, Safespot device ID, hostname, device type, DHCP options, user agent, last connection time, device stats/bandwidth, device wifi signal, connection type (this is a non-limitative list). 


The software agent also identifies the devices connected to your modem (we call this fingerprinting). It allows you to see, in the management app, which devices are connected to your network and which devices are showing strange behaviour. It enables you to block access to your network. It collects several technical data like the hostname, software version, firmware, manufacturer, device creation data, device last update date, model, MAC address, IP address, DHCP request, user agent, UNpN, devices display name (the nickname given to the device), banner grabbing, ICMP, SSDP user agent, device traffic signature data, network ID and Telenet Safespot device ID (this is a non-limitative list).  


Data processed through the Telenet Safespot management app:


In the management app you can monitor the Telenet Safespot activity and see how the devices connected to your network are doing. You can also invite devices to install the Telenet Safespot guard app. 


We also collect and process analytical data on the use of this app like which device installed the app (& when), how you navigate, which features you use & when you use it. For this purpose the following data is collected: the OS of your device, the MAC address, data & timestamp (this is a non-limitative list). 


Data processed through the Telenet Safespot guard app:


This advanced antivirus program that you install on your laptops, tablets and smartphones protects your devices on any internet network, at home and on the go. It protects your device from trojans, viruses, rootkits, spyware, adware and so on. This antimalware protection consists of automatic file scan, real-time email and web traffic scan, real-time monitoring of running applications and on-demand scans. It operates through a local VPN. This means that your traffic is send via the Telenet Safespot guard app for scanning. Please note that this is a local VPN, your traffic does not leave your device for scanning (the scanning is performed on your device). 


The file scan prevents malware threats from entering the system by scanning local and network files when they are accessed (opened, moved, copied or executed), boot sectors and potentially unwanted applications (PUA). The functionality can also be triggered on demand and will identify the same type of threats for the desired location on the local computer. The program continuously monitors applications running on the endpoint for malware-like actions. Advanced Threat Detection will automatically try to disinfect the detected file.


Part of the traffic scan is preventing malware from being downloaded by scanning incoming e-mails and web traffic in real time. Outgoing e-mails are scanned to prevent malware from infecting other end points. 


The data processed is the accessed URL, IP address, MAC address, Telenet Safespot device ID, device type, OS version, ports, DNS requests, date and timestamp, volumes, file path-, name- & attributes, last file write time, signatures version (this is a non-limitative list). 


We also collect and process analytical data on the use of this app like which device installed the app (&when), how you navigate, which features you use & when you use it. For this purpose the following data is collected: the OS of your device, the MAC address, data & timestamp (this is a non-limitative list). 

 

4. What are we using this personal information for and what is our legal ground?

The legal ground for the collection and processing the data retrieved via the software agent, the manager app & end point solution (the Telenet Safespot guard app) is contract performance. We cannot deliver you the service you have purchased if we cannot process your data.

 

The data retrieved via the software agent, the manager app & end point solution (the Telenet Safespot guard app) is solely used

 

  • For the purpose of securing information and networks by correct and efficient operation of the Telenet Safespot product;
  • For the purpose of protecting devices from contacting malicious internet locations or websites and content that has been identified as inappropriate by Telenet Safespot in accordance with the content filters set by Telenet Safespot;
  • For the purpose of identifying device behaviour that may indicate an anomaly or attack;
  • For the purpose of identifying the devices more accurately and to provide more accurate security threat identification;
  • For the purpose of improvement, including by analysing the reported security issues;
  • For the purpose of delivering and customizing related services;
  • For the purpose of creating statistics, SLA’s, bug fixing, analytics and improving the quality of the product.

 

The data retrieved via the software agent, the manager app & end point solution (the Telenet Safespot guard app) is not used for commercial reasons (including profiling you for marketing purposes or providing you direct marketing). Nor is it used for automated decision making with legal consequences or affecting you to a significant extent.

 

We do not need consent as legal ground but we ask you to accept the legal terms & conditions and the privacy policy when you install the Telenet Safespot management app & the Telenet Safespot guard app.

 

If you do not agree with this privacy policy and you no longer want us to use your data for this purpose, we kindly ask you to contact customer service (via the online contact form, via phone or by visiting one of our shops) to stop your Telenet Safespot subscription. This way the software agent on your modem will be disabled and will stop further collection and processing of your data. Also delete the Telenet Safespot management app and the Telenet Safespot guard app to stop them from further collecting and processing your data.

5. How do we protect your personal information?

A. Our technical and organizational measures

The data retrieved via the software agent, the management app & end point solution (the Telenet Safespot guard app) is stored on our well protected cloud hosted by Amazon Web Services. The number of internal and external employees 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. Data transfer proceeds via APIs that are TLS protected.
Our staff are trained in how to correctly handle confidential data. As part of any project the aim of which is to process personal information, an assessment is first made in relation to security and the protection of personal information, in which case your interests take precedence. Our information security policy, our security requirements, and management standards are based on the international ISO27002 standard. To protect your data we have employed specific individuals, who oversee compliance with legislation and our ethical conviction, as set out in this privacy policy. We have also employed specialist individuals, who are responsible for the security of our network, our infrastructure and our information systems. Furthermore, we use all kinds of technical measures to protect your personal information against unauthorized access, unauthorized use and loss or theft of your data, such as: password protection, hard disk encryption software, firewalls, anti-virus, intrusion and anomaly detection and access checks for our employees. Should a data leak occur with negative consequences for your personal information, then you as a customer are personally informed of the circumstances as provided for by law.

 

The software on our products is constantly kept up-to-date.

 

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: e-mails) 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.
 

6. Do we sell your information to third parties or do we pass on your information?

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:

 

  • It is to our legal successors and other companies within the Telenet group
    We pass on your personal information to any of our legal successors and affiliated businesses within the Telenet group (for example, Liberty Global BV and Telenet Group bvba) for the same purposes as is stated in this privacy policy. 
  • This is necessary to provide our service
    We work together with IT vendors like Amazon and with IT-Security vendors like SecuringSam and Bitdefender. Our databases are accessible by them, they work on behalf of us and support us in delivering the service. They are only entitled to access the individual data, the individual data is not physically transferred. 
  • There is a statutory obligation.
  • You give us consent to do so.
    If Telenet were to provide other third parties with personal information in other situations, then this is done with an explicit notification in which an explanation is given about the third party, the purposes of the transfer and data processing.

 

B. International processing of your personal information

Insofar as personal information (on the occasion of data transfers set out in point 6A of this privacy policy) is processed outside of the European Union, through contractual or other measures we ensure that this data is granted an appropriate level of protection there comparable with the protection, which it would be granted within the European Union, in accordance with European regulations.

7. How do you determine which personal information we are permitted to use for commercial purposes and how?

A. Telenet privacy settings

This Telenet Safespot specific privacy policy does not foresee in using your personal information for commercial purposes. As such the four privacy levels, as described in our general privacy policy, are not applicable.

 

Please keep in mind that Telenet is entitled to contact you for service related communication, as part of the performance of your contract or if the law obliges us to do so.

 

This Telenet Safespot specific privacy policy does not apply to the processing of personal data in relation to other Telenet products and services (like our telecom products and TV services). Nor is it applicable on the data we process when you order and purchase the Telenet Safespot product (this is general identification data like name, address, phone number …), when we invoice you for it and when you communicate with us regarding this product. For these activities the possibility to use your data for commercial purposes is regulated in article 7 of our general Telenet Privacy Policy (https://www2.telenet.be/en/privacy/).

8. What are your privacy rights are and how can you exercise them?

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:

 

  •  the purposes of the data processing;
  • the categories of personal information involved;
  • the recipients or categories or recipients (in particular, recipients in third-party countries);
  • if possible, the retention period or, if that is not possible, the criteria to determine this period;
  • the existence of your privacy rights;
  • the right to submit a complaint to the supervisory authority;
  • the information that we have at our disposal about the source of the data if we obtain personal information via a third party; 
  • the existence of automated decision making.

 

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.

 

Your right to the erasure of your data (the ‘right to be forgotten’)

You are entitled to have your personal information deleted in the following instances, and without any reasonable delay:

 

  • your personal information is no longer needed for the purposes for which they were collected or have otherwise been processed by Telenet;
  • you withdraw your prior consent to the processing of data and there is no other legal basis that Telenet can invoke for (continued) processing thereof;
  • you object to the processing of your personal information and there are no preeminent, legitimate grounds for (continued) processing of data by Telenet;
  • your personal information is being processed unlawfully;
  • your personal information needs to be deleted to meet a statutory obligation;
  • your personal information was collected when you were still a minor.

 

Remember that we are not always able to delete all personal information that is requested, for example if processing 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 your data. 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:

 

  • you contest the accuracy of this personal information: its use is restricted for a period, which enables Telenet to check the accuracy of the data;
  • the processing of your personal information is unlawful: rather than deleting your data, you request its use to be restricted;
  • Telenet no longer requires your data for its original data processing purposes, but you need it for instituting, exercising or substantiating a legal claim: rather than deleting your data, its use is restricted to instituting, exercising or substantiating the legal claim;
  • while a decision has not yet been made about exercising your right to object against the processing of your data, you request that the use of your personal information be restricted.

 

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. This means you may not enjoy this right for the data retrieved via the software agent, the manager app & end point solution (the Telenet Safespot guard app).

 

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 is based on Telenet's legitimate interests or based on 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).

 

As regards your right of opposition within the framework of direct marketing, see point 7 of this Privacy policy.

 

B. Practical

How do I exercise my privacy rights? Via My Telenet (only for active Telenet customers) 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). The contact persons or authorized representatives of our business customers’ legal entities, who only purchase Telenet products and services intended for large businesses and organizations, need to exercise their privacy rights via the account manager of this business customer. If we cannot confirm your identity with certainty, we will not process your request.

 

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.


Section 10 of this privacy policy explains how you can contact us.

9. How long do we keep your personal information?

We are not permitted to keep your personal information for longer than is necessary to achieve the purpose for which we are collecting it. We have defined retention periods per data category that apply company wide. The applicable data categories are online behaviour (related to the analytics performed on the apps) and traffic data (internet traffic data and device identifiers) for which the retention period is set to 36 months for online behaviour and 24 months for traffic data.

 

After expiry of the applicable retention period(s), your personal information is deleted or anonymized.

10. How can I contact Telenet?

To exercise your privacy rights (such as retrieving what data Telenet has on you or you want to see your data deleted) you as a customer can visit My Telenet. If you do not have a My Telenet or are not a customer, we will be happy to help you in our Telenet points of sales. More information about your privacy rights and the formalities for exercising your rights (e.g. verification of your identity) can be found in article 8 of this Privacy Policy.

 

If you have a question about the processing of your personal data and you cannot find the answer in this privacy policy please contact us using the complaints contact form and include the word ‘privacy’ in the title. You can use this link to the form:
https://www2.telenet.be/fr/serviceclient/forms/reclamation/

 

Are you a Telenet Business customer? Then you can use this form:
https://www2.telenet.be/fr/business/contact/ecrivez-nous/

 

Do you want to report a privacy incident?  You can contact our Data Protection Officer ('DPO') using this link:
https://www2.telenet.be/en/privacy/data-breach-webform

11. Children’s personal information

Our Telenet Safespot service is not directed to, nor do we knowingly collect personal information from children under the age of 16. The Telenet Safespot guard app can only be installed on the end device if the owner of device receives the installation code from the management app. That implies that you as a parent or custodian take the responsibility of the installation of the app on the child’s device.

12. Keep up-to-date on updates

Telenet may amend this privacy policy from time to time, for example in response to market trends and Telenet’s new processing activities... We will then always invite you to view the most recent version of this policy on the Telenet website or in the apps. Of course, we will inform you beforehand via our websites or other current communication channels about each significant change in content and we shall request your prior consent for our (new) data processing activities when required by law.

 

In case of any conflict, our general terms and conditions and the special conditions applicable in respect of specific Telenet products and services take precedence over this privacy policy.

13. Escalation to the supervisory authority

The Data Protection Authority is an independent body that ensures that your personal data are processed in accordance with the law. If you have a complaint regarding the processing of your personal data by Telenet or if you wish to initiate proceedings for mediation, you can contact the authority via https://www.gegevensbeschermingsautoriteit.be/verzoek-klacht-indienen

 

Latest update: 5 December 2019