Please note: from April 25, 2021 we offer a new version of Safespot (Safespot+) which includes additional security features. You can activate it in My Telenet online. If you purchased Safespot before April 25, 2021, you will continue using Safespot.
Safespot+ is a security software for both network security and security on your end devices.
We also offer a more basic security product called Safesurf to our residential and business customers: in comparison with Safespot+, Safesurf mainly focuses on fingerprinting and DNS filtering of harmful sites. There is no app, and only the software on the customer modem will be installed. When you purchase a ONE, Safesurf is already included in your subscription, but you will need to activate it in My Telenet (you can also deactivate it via My Telenet). When you or another end user visits a website that is flagged as harmful, you can still choose to visit that website. Safesurf does not support Digital Habits feature.
Safespot Pro is the Safespot+ solution intended for our business customers to help them ensure the network and device security for their employees, visitors, and other end users. Safespot Pro does not support Digital Habits.
We start collecting and processing data when
B. Who is responsible for the processing of your data?
You also have some obligations towards the end users that you allow to use the Telenet Safespot products that you purchased. These are described in the next bullet.
C. Your responsibilities towards end users
First of all, we want you to know that we never open or process your content data. Telenet Safespot processes that you visit YouTube, but it does not see which video 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 if you try accessing the link or attachment in the phishing e-mail or store the e-mail attachment locally, we will inspect it and block the harmful content. Please note that we do not protect you from receiving spam e-mails, and you can still read them and open the links in those e-mails. We will however inspect the webpage you are trying to access and will block it in case it is infected.
We do not collect your location data like your GPS coordinates. However, please note that when you install the Safespot app and/or the Safespot Guard app on your mobile device, it asks you to agree to share your location data.
Also, we do not process any sensitive data such as data about your racial or ethnic origin, political views, sexual preferences and health.
Safespot+/Safespot Pro software agent on the modem:
The Safespot+ software agent scans your internet traffic, or better said, it deep dives into your TCP/IP traffic. It makes 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. It allows you to see, in the Safespot 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 Safespot app:
In the Safespot 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 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 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 e-mail and web traffic inspection, real-time monitoring of running applications and on-demand scans. It operates through an external VPN, your traffic leaves your device for scanning by our specialized security vendors. They need that data for the purposes of troubleshooting and error analysis and to ensure a fast and secure connection.
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. Please note that the antivirus protection is only available on Windows and macOS, and not on iOS devices.
Part of the traffic scan is preventing malware from being downloaded by checking incoming e-mails and web traffic in real time. It does not protect you from receiving spam e-mails but we will block the harmful content if you click on the links in the phishing mails or download the e-mail attachment.
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).
Data processed through the Digital Habits:
Digital Habits are meant to protect your family members and help setting boundaries on connected devices to control the internet access and content for them. It regards for example: creating family members profiles, including their avatar, assigning devices and age profile, category blocking, setting time limits for apps and/or websites, blocking specific content. Next to this, it is possible to enable safe search for various search engines, and implement “digital well-being” options: pause/play functionality (applying immediate block on internet usage), usage limit (configuring a certain time limit on internet usage per day, set bedtimes & homework times for internet usage).
Digital Habits are set by the customer in the Safespot app, and these controls are applied on the modem itself and also in the Safespot Guard app. The data is connected in the Telenet cloud to manage policies for devices both in- and out of home. You can set controls to other profiles and change these settings anytime.
We process your user data such as your phone number for sending a mobile application download link, technical data on your connected devices (eg, IP-address, MAC-address, device type, etc), consumption data such as allowed/blocked websites, blocked time, or information on policy violation events (eg, security violations, digital habits violations).
Data processed through Safesurf:
Safesurf also uses the Safesurf security solution but not the full range of its functionality. When Safesurf is installed on your modem, we only process fingerprinting data and DNS blocking data. We collect such data as the IP-address and device information for the purposes of improved customer care. DNS blocking prevents you from visiting malicious websites. In case you attempt to access an unsafe domain, we will check whether it is indeed a phishing website and will block that website. We will collect such data as IP-addresses and the domain name that you are trying to access in order to enable you to surf safely.
The legal ground for the collection and processing the data retrieved via the software agent, the Safespot app & 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 agents, the Safespot app & Safespot Guard app is solely used for the purposes of:
The data retrieved via the software agent, the Safespot app & the 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. Please keep in mind that Telenet is entitled to contact you for service-related purposes, as part of the performance of your contract or if the law obliges us to do so.
You may find an overview of our Telenet Safespot solutions and the description of the processing in this table.
A. Our technical and organizational measures
The data retrieved via the software agent, the Safespot app & 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 information security policy is fully based on the international ISO 27002 standard, and contains guidelines with regards to access control, data encryption, security of operations, security of communications, physical security, etc. A specialized security team is responsible for the implementation and follow-up of the guidelines, so that the security of our databases, networks, infrastructure, and information systems is guaranteed.
Access control is an important aspect of our information security policy. Telenet has implemented procedures to limit access to our databases, systems, equipment, and networks to those persons who strictly need this access to perform their job. These persons must observe a strict obligation of confidentiality and comply with all guidelines for ensuring the protection of personal data. Telenet also provides privacy and security-specific training for its employees in order to clarify the guidelines and procedures to its employees and to make them aware of the risks involved in processing personal data.
Telenet also imposes high security requirements on its partners and suppliers who process your personal data on our behalf. Partly by means of contractual guarantees, we ensure that, just like us, they process your data safely and with respect for the privacy legislation. We therefore expect our partners and suppliers to implement an information security policy and security measures that are grafted onto international standards and best practices.
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.
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. Overview of your privacy rights
Your right of access
You have the right to request access to your personal data. We will then provide you with an overview of the personal data we process about you. We will initially provide you with an automatically generated standard report. If this does not meet your expectations, or if you need specific information, you can make an additional request via the link included with the standard response.
Your right to update personal information
You are entitled to have incomplete, incorrect, inappropriate or out-of-date personal information corrected without delay. In order to keep your data up-to-date, we would ask you to notify us of any change, such as a move, a change of e-mail address or a renewal of your identity card. We already provide a periodic pop-up in My Telenet, where you are asked to update your contact details.
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:
Remember that we are not always able to delete all personal information that is requested, for example if processing is required for the provision of your service, for the exercise of a legal claim, or because the data is necessary in order to comply with a legal obligation or to fulfil a task of general interest.
Your right to restrict the processing of data
In specific cases, you have the right to obtain the limitation of the processing of your personal data. This is the case, for example, when you dispute the correctness of personal data or when your data is no longer necessary in order to achieve the purposes of the processing, but you need it for the establishment, exercise or substantiation of a legal claim.
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.
Your right to object against the processing of your personal information
You have the right to object when Telenet uses your personal data for purposes other than those necessary for executing an agreement or that are necessary for complying with a legal obligation. You must then submit a substantiated request (containing the specific reasons why you wish to object to the processing) and Telenet will, in the event of a justified request, stop the use of your personal data unless we have compelling reasons for not doing so.
You can exercise your privacy rights in two ways:
To ensure that the request is made by the right person, we will need to verify your identity. If you launch your request via My Telenet, your successful login and password will serve as your identification. If you make your request in a Telenet point of sale, we will ask you to identify yourself by means of your identity card. If we cannot identify you with certainty, we will not respond to your request.
Please note that due to the complexity, a different application procedure applies to the exercise of the right to restrict the processing of data. If you wish to exercise this right, please submit your request to the Data Protection Officer (or "DPO") using this form. clearly indicating ‘privacy’ in the title. We will also ask you to identify yourself.
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. 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 (eg, internet traffic data and device identifiers) for which the retention period is set to up to 180 days.
After expiry of the applicable retention period(s), your personal information is deleted or anonymized.
Do you want to report a privacy incident? You can contact our Data Protection Officer using this form.
You can also send your question, complaint or request by letter to the attention of the Data Protection Officer:
Our Telenet Safespot service is not directed to, nor do we knowingly collect personal information from children under the age of 16. We have no way to validate the age of the person in question, but in any case, we will not collect any sensitive information or data other than what is necessary to enable the service. We also do not use any personal data for the marketing purposes and do not create commercial profiles of Telenet Safespot users. We do not subject you or your family members to an automated decision-making with legal consequences or affecting you to a significant extent.
The Safespot Guard app can only be activated on the end device if the owner of the device receives the pairing code from the Safespot app. That implies that you as a parent or custodian take the responsibility of the activation of the app on the child’s device. As a household admin, you are responsible for ensuring that you have obtained all necessary consents prior to setting Digital Habits for other devices. You need to also inform your family members or other end users using the Safespot Guard app, about processing of their personal data, their privacy rights including the right to object, and provide to them clear and understandable information.
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 Data Protection Authority via https://www.gegevensbeschermingsautoriteit.be/burger/acties/klacht-indienen
Latest update: 19 April 2021