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TELENET SAFESPOT PRIVACY POLICY

Hi there, and congrats to you. You have decided to install one of Telenet Safespot solutions and invest in your security. By “Telenet Safespot” we mean the whole spectrum of our security services, such as Safespot+, Safespot Pro and Safesurf. In this privacy policy you will find out how we collect, process and protect your personal data when you are using one or more of Telenet Safespot solutions.

 

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.

How does Safespot+ work?

Safespot+ is a security software for both network security and security on your end devices.

 

  • Network security is provided by the software agent 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 Safespot+ you will receive (via SMS) a code to enable you to install the Safespot app. If you purchase ONEup, Safespot+ is already included in your subscription, but you will need to activate it in My Telenet. Via the Safespot app you can monitor the activity on your network and end devices. Safespot+ also enables device fingerprinting, which means that it identifies devices connected to the modem and displays them in a dashboard (visual in the Safespot 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 Safespot Guard app which is installed on your end devices. The Safespot Guard app protects your devices at home and on the go (ie also when you are not connected to your modem). You can only activate this app after you have received the invite to do so from the Safespot app (it will send you the pairing code). The Safespot Guard app is an antivirus program that blocks phishing and malware locally on your device, through scanning the files on your device to detect any malicious or inappropriate behaviour and internet traffic to and from your device.
  • The Digital Habits feature helps protect you and your family members from potentially inappropriate content. As a household admin, you can configure the settings in your Safespot app and set up a policy for each family member or use default options which set the policies based on their age category. You can activate it on your home network, which means that the Digital Habits will be configured in the router itself and apply to all connected devices at home. In order to enforce the policies also when the family members leave the home network, a Safespot Guard App needs to be installed on their mobile devices. .
How does Safesurf work?

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.

How does Safespot Pro work?

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.

 

No need to say that in order to provide you with 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 that you thoroughly read through this policy.

1. Who is protected by this privacy policy?

This privacy policy applies to the personal data that we, as data controller, process from Telenet Safespot customers, business customers and end users. For complete clarity, the processing of personal information of business customers only occurs if the business customer is a natural person, or – if the business customer is a legal entity – then the privacy policy only applies in respect of the personal information of the natural persons, which we process within the framework of their relationship with the business customer (such as authorized representatives, contact persons and/or end users).

 

We start collecting and processing data when

  • Safespot+/Safespot Pro is installed on your modem & the software starts scanning your traffic data;
  • Safesurf is installed on your modem & the software starts scanning your traffic data;
  • You install the Safespot app;
  • You or another end user install the 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 to the data we process when you order and purchase a 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 BV, with its registered office at Liersesteenweg 4, 2800 Mechelen, and registered in the Crossroads Bank for Enterprises (CBE) under number 0473.416.418 (referred to as “Telenet” in this privacy policy) 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 Telenet 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) & Telenet Safespot privacy policy (for the security scanning) apply here. 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 Safespot app, let end users install the Safespot Guard app on their devices or install it for them (e.g. when you want to install it on the smartphone of your family member or when you install the software on the network to ensure the security of your employees data). 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. We count on you, as a customer and administrator of the Safespot app, to take your responsibility and inform them about it. In particular, you (as the administrator and user of the Safespot app) can see their devices connected to your Wi-Fi network and the alerts in case of a phishing (or other malware) attempt.

 

3. What personal information do we process?

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.

 

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 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:

 

  • securing information and networks by correct and efficient operation of the Telenet Safespot product;
  • protecting devices from contacting malicious internet domains that have been identified as inappropriate by Telenet Safespot product in accordance with the filters set by Telenet Safespot product;
  • ensuring safe search by filtering out explicit or inappropriate search results;
  • identifying device behaviour that may indicate an anomaly or attack;
  • enabling Digital Habits functionality to help you manage internet access and content for you and/or your family members;
  • identifying the devices more accurately and to provide more accurate security threat identification;
  • improvement, including by analysing the reported security issues;
  • delivering and customizing related services;
  • creating statistics, bug fixing, analytics and improving the quality of the product.

 

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.

 

We ask you to accept the legal terms & conditions and the privacy policy when you install the Safespot app & the Safespot Guard app or when you activate Safespot+ or Safesurf in My Telenet

 

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 Safespot app and the Safespot Guard app to stop them from further collecting and processing your data.

 

You may find an overview of our Telenet Safespot solutions and the description of the processing in this table.

5. How do we protect your personal information?

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.

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 NV) 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 Securing Sam Ltd. Our databases are accessible by them, they work on behalf of us and support us in delivering the service, always on the basis of specific agreements.
  • There is a statutory obligation
    As part of a police or judicial investigation, we may be obliged to pass on certain data to the necessary authorities.
  • You give us consent to do so
    If Telenet were to provide 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?

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

 

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

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:

  • 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 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.

 

B. Practical

 

You can exercise your privacy rights in two ways:

 

  • Bent u een Telenet-klant?
    Register via My Telenet and fill in the application via this link. This is only possible for customers who have an active My Telenet account.
  • You are no longer, or have never been a customer?
    Then you can go to a Telenet point of sale to launch your application.

 

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.

 

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 (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.

10. How can I contact Telenet about my privacy?

To exercise your privacy rights, 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 point of sales.

 

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. 

 

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:

 

Telenet BV
Liersesteenweg 4
2800 Mechelen

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. 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.

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 Data Protection Authority via https://www.gegevensbeschermingsautoriteit.be/burger/acties/klacht-indienen

 

Latest update: 19 April 2021