PRIVACY POLICY
ROULARTA MEDIA GROUP

1. GENERAL

Roularta Media Group, Meiboomlaan 33, 8800 Roeselare, and its subsidiaries, are taking the measures contained in this privacy policy to protect your privacy. We consider protecting the privacy of our customers, subscribers, readers, viewers, surfers and users important. With this privacy policy we want to inform you as well as possible about what data we collect, why we do it, and how you can control it.

By purchasing our products or services, or by using our services, websites and applications, you are deemed to be aware of the provisions and measures of this privacy policy, to understand them and to agree to them. Roularta Media Group reserves the right to change this privacy policy at any time, provided it informs the users via the website or e-mail. The changes take effect automatically after publication.

The processing of personal data within Roularta Media Group is subject to Belgian law.

2. COLLECTING PERSONAL DATA

Roularta Media Group collects, registers and processes personal data of its customers, surfers and users of its services and applications, news sites, apps and web shops.
By ‘personal data’ we mean data that relate to an identifiable person (i) that you give us, or (ii) that we assign to you for the use of our products and services, or (iii) that we obtain through the use of our products and services, or (iv) that we have received through third parties.

2.1. Expressly communicated personal data

Certain personal data must be explicitly communicated, such as when taking out a subscription, purchasing products, using some parts of a website or app, registering for an event, participating in a competition or promotion, or the creation of a user account or registration. These data are deemed to have been provided to us voluntarily.

Depending on the service used, these may include the following categories of personal data:

• Name, first name, address, gender, date of birth, language preference or age.
• Postal address, postcode, place of residence, e-mail address, telephone number, mobile number
• Bank account number
• Professional data (occupation, position, …) or data concerning study or training if these can be of importance in view of the nature of the publication or service.
• Data related to the subscription, or indicating the reason for termination of the subscription.
• All preferences or interests that you make known through registration forms, social media, promotions, mobile applications, competitions, etc.
• Answers to questions on feedback about our products and/or services in the context of satisfaction surveys or market research.
• Where relevant: financial data and data related to your creditworthiness.

As required by law, we do not process sensitive data such as data about your racial or ethnic origin, political opinions, sexual preferences and health.

You guarantee that the data you provide is accurate and complete. The communication of incorrect data or data belonging to third parties may result in the user being temporarily or permanently denied access (in whole or in part) to products and services of Roularta Media Group.

2.2. Personal data collected automatically

Other data are collected automatically when using our websites, apps or digital applications, through the use of cookies or other systems that use information such as IP address, device used, use of the site or application, language and type of browser, … registration. For a number of applications, websites or apps you must identify yourself/log in before using the application.

Depending on the service or application used, the following data may be involved:

• When you log on to one of our websites or apps using your social networking user account (Facebook, Linkedin, Twitter, …), we can – insofar as you have given consent to do so – obtain information for the profile that is created on our website.
• When using digital applications (websites, tablet or smartphone applications, …) the following items can be registered:
  • Location data: these data allow us to determine your (approximate) location.
  • Time, frequency and duration of use
  • How you use our newsletters and websites, or which articles, videos, photos, pages you view, read or share.
  • How you ended up on our website (via which referrer or search term).
  • Whether you are a user of adblocker software when visiting our websites
  • Which device, system software or browser you use.

We use these data, among others, to offer you as customer a better and personalised experience and to adapt and improve our offers and products.

2.3. Personal data obtained from third parties.

• We use additional data from external data partners (such as Black Tiger Belgium NV) to confirm or validate the data present in our own database and / or to improve its quality by means of formatting, standardization, correction, addition , updating (in particular by providing a new address, for example after a move) and / or internal linking (matching) of this data. More information about data processing by Black Tiger Belgium NV, Researchdreef 65, 1070 Anderlecht can be found at https://gdpr.blacktigerbelgium.tech.
• We also receive periodic overviews from the DNCM vzw of people who are on the Do not call me list (https://www.dncm.be/) (see more about this in point 10 of this privacy policy).

3. STORAGE AND ACCESS TO PERSONAL DATA

The personal data that are thus explicitly or automatically communicated or collected are recorded and processed in the database of Roularta Media Group NV, Meiboomlaan 33, 8800 Roeselare.

Roularta Media Group is the processing officer for these personal data and controls the processing that other parties carry out at its request.

The data are also automatically accessible to other companies and subsidiaries of Roularta Media Group such as: Roularta Healthcare, Senior Publications, Belgomedia, CTR Media, Storesquare, Studio Aperi Negotium, Belgian Business Television, Regionale Media Maatschappij, De Woonkijker and Regionale TV Media.  See the group structure at: http://www.roularta.be/en/about-roularta/structure

Roularta Media Group will not store your data for longer than is legally permitted and necessary for the purposes stated in this document.

The following retention policy applies to data of subscribers, readers, registered users or receivers of newsletters of one of our publications:

• For tax reasons, data from subscribers are saved up to 7 years after the subscription.
• For non-subscribers, buyers of separate products, readers, registered users, participants in competitions, recipients of newsletters, the data will be deleted if there has been no interaction in the last 5 years.

4. PROCESSING OF PERSONAL DATA

The data collected as described above can be combined to better tailor our offers, products and/or services to your personal needs. Your personal data can be enriched or supplemented with extra data, which are either publicly available or come from external partners or data suppliers.

By ‘processing of data’ we mean each instance of processing of personal data. The term ‘processing’ covers among others collecting, recording, organising, storing, updating, modifying, retrieving, consulting, using, distributing or making available in any way, bringing together, combining, archiving, deleting or ultimately destroying personal data.

We process personal data for various purposes, whereby only the data that are necessary to realise the intended purpose are processed.

We use personal data:

• When we have received consent. In this case, we process your personal data for the specific purposes for which we received consent.
• In the context of the performance of a contract or agreement, for example a subscription to one of our publications, the purchase of products or the performance of a service you have requested.
• To comply with the legal or regulatory provisions to which we are subject, for example tax obligations.
• When Roularta Media Group has a justified interest in this, in which case we always aim for a balance between this interest and respecting the privacy of the person concerned.Roularta Media Group regards the following processing as necessary in the context of its legitimate interest:
  • Direct marketing, in particular promotional communication via e-mail, telephone, post, advertising or other channels to existing customers and subscribers with a view to offering
  • Campaigns, promotions, invitations to events, offers and benefits attached to the title(s) to which they have a subscription
  • Subscription offers for other, similar titles
  • to visitors of events when they were present at a previous similar event
  • to contacts of the advertising agency
  • Direct marketing for prospecting purposes: in particular promotional communication to prospects via telephone, mail, advertising or other channels.
  • Expressly or automatically collecting and combining personal data (as described under Section 2.) in order to gain a better view of the profile and the likely preferences and interests of customers (such as subscribers) and prospects (such as non-paying visitors to websites) and using these data to personalise offers via direct marketing, digital applications (such as websites or apps) or targeted advertising.
  • Controlled circulation: dissemination of a publication to a defined target group that receives the magazine free of charge.
  • Management of business information: the Trends Business Information (TBI) business unit processes business-to-business data on companies with the aim of making these available to other companies in print, online and digital formats, so that they are able to limit their financial risks, prevent fraud, comply with current legislation on money laundering, etc. Since this concerns B-to-B information, it does not fall within the scope of the GDPR. In addition, TBI collects data from business professionals that are also made available for marketing and data management purposes. When collecting these data, the obligation to notify the person concerned is always met. They are informed about the inclusion in the database and the purposes for which these data are being processed. They have the right at all times to access, correction and deletion.

In some cases we use anonymous, aggregated data for commercial purposes or for external reporting. These data can never be traced back to a specific individual.

5. PURPOSES OF THE PROCESSING OF PERSONAL DATA

Provided consent is obtained, we collect and process personal data for the following specific purposes:

• The delivery of products and services:

• Customer administration with a view to delivering products or providing services, such as managing your subscription, sending and delivering a purchased product, or managing registrations for an event or seminar, drawing winners for competitions in which you participated.

• (Direct) marketing:

• To contact you for marketing purposes and to inform you about (new) products, services, competitions, promotions and offers from us and other companies within Roularta Media Group.

• Personalisation and targeting

• Matching our website(s), newsletters, digital applications and in particular advertisements to your preferences or profile.
• To be able to send you targeted offers and promotions, appropriate to your preferences or profile, or to prevent us from sending the same message several times via different channels.

• To combat fraud and/or abuse of our digital platforms and applications.

• Market research and analysis

• We can use your data and consumer profile to evaluate our products and services.

• To comply with our legal obligations.

• It may happen that we are legally obliged to keep certain personal data about you and/or to communicate these to government agencies. In the context of a police or judicial investigation, we can be obliged to communicate certain data to the necessary authorities in a confidential manner.
• To track studies, tests and statistics, among others for trend analysis.
  • We may use anonymous, aggregated data to, for example, report internally and externally on the use of our services, for example how much of certain websites, apps or digital services have been used, or whether certain programmes or channels are being watched. The data used for this cannot be traced back to an identifiable individual. We use the information we obtain from these analyses to evaluate our current products and services portfolio and to evaluate our processes and adapt these based on new developments.
• New purposes
  • We may use your data for new purposes, which are not yet provided for in our privacy policy. In this case, we will contact you by e-mail or via the website before using your data for these new purposes, to inform you of the changes to our privacy rules and to give you the opportunity to give or refuse your consent for this.

6. MINORS

Roularta Media Group ensures that the privacy of minors is protected and encourages parents to be actively involved in the online activities of their children.

Roularta Media Group will not deliberately or intentionally collect personal data from minors.

Roularta Media Group encourages minors, if they visit a website of Roularta Media Group, to inform their parents about their online activity and to ask their opinion before forwarding personal data to Roularta Media Group.

Roularta Media Group encourages minors, if they wish to create an account, to carefully read the privacy policy of Roularta Media Group together with their parents.

We advise minors to use a pseudonym in their e-mail address instead of mentioning their real name. We also advise minors to provide only the data required for the online use of the services of Roularta Media Group.

The consent of the parents is also required for the application for subscriptions, products and services offered by Roularta Media Group via the websites. Subscriptions, products and services are always subject to the conditions of Roularta Media Group.

7. SECURITY OF YOUR PERSONAL DATA

Roularta Media Group takes the appropriate and necessary organisational and technical security measures to protect your personal data and privacy, in order to prevent the loss, unauthorised use of or change to the information we receive. This is an obligation of means and not an obligation of result.

The number of employees in our company that have access to your personal information is limited and these persons are carefully selected. These employees are granted access to your personal information to the extent that they need this information to properly perform their duties.

Our websites sometimes contain links to third-party sites (for example: social media, organisers of events that we sponsor) whose terms of use do not fall within the scope of this privacy policy. Carefully read their policies regarding the protection of your personal data.

With regard to the international transfer of personal data, we protect your data in accordance with the level of protection required by European regulations.

8. PASSING ON PERSONAL DATA

We do not sell or pass on personal data to third parties or commercial partners:

• Except to our legal successors and other companies within Roularta Media Group (such as subsidiaries and sister companies) for the same purposes as those stated in this privacy policy.
• Unless the transmission of your data is necessary for our services: for some aspects of our products and services we work together with third parties or we engage subcontractors. The forwarding of your data is limited to the same purposes in effect at Roularta Media Group itself. We ensure that these third parties, like us, manage your data safely, respectfully and with due care.
• Your personal data may, in the context of our legitimate interest, be disclosed to independent controllers to help them provide data quality services to their customers. These third parties only use this data to confirm or validate their data or the data provided by their customers and/or to improve its quality by means of formatting, standardization, minor correction and/or internal linking (matching) of this data. , for the sole purposes of:
  Comply with (or assist their customers in complying with) Article 5.1d) GDPR, which requires the data to be accurate and updated as necessary, and/or assist their customers in carrying out identity checks on individuals with a view to combating money laundering, national/public security, crime prevention and detection, fraud prevention, debt/asset recovery and asset reunification and/or conducting pre-employment screening.
  One of the data quality specialists we work with is Black Tiger Belgium NV, established at 1070 Brussels, Researchdreef 65. Its special AVG webpage https://gdpr.blacktigerbelgium.tech informs you about the processing it does with the personal data it collects, your GDPR rights and how to exercise those rights.
• When you enter your email address on our website (either to log in, or to sign up to a newsletter, or similar) we may share personal or other information that we collect from you, such as your email (in hashed, pseudonymous form), IP address, or information about your browser or operating system, with our partner LiveRamp, Inc. and its group companies, acting as joint controllers. LiveRamp uses this information to create an online identification code for the purpose of recognising you on your devices. This code does not contain any of your identifiable personal data and will not be used by LiveRamp to re-identify you. We place this code in our first party cookie or use a LiveRamp cookie and allow it to be used for online and cross-channel advertising. It may be shared with our advertising partners and other third party advertising companies globally for the purpose of enabling interest-based content or targeted advertising throughout your online experience (e.g. web, email, connected devices, and in-app, etc). Detailed information on LiveRamp’s data processing activities is available in LiveRamp’s privacy policy and opt-out here:https://liveramp.uk/privacy/service-privacy-policy/. You have the right to withdraw your consent or opt-out to the processing of your personal data at any time.
• Unless a legal obligation exists to pass on data at the request of judicial authorities or police services.
• Unless you give us consent for this.

If Roularta Media Group communicates personal data to third parties in a manner different than that mentioned above, this will be done with an explicit communication, in which you will be informed about the third party, the purposes of the transfer and the processing. We will obtain your express consent where required by law. You also always have the possibility to object.

9. RIGHT OF ACCESS AND TO CORRECTION

On our websites you can access and make changes to the following data:

• Your subscriber and subscription data via our customer service portal my.abonnements.be,
• Your registered personal data  via your registration/account on the websites and digital applications of Roularta Media Group: https://myaccount.roularta.be/

You also have the right to inspect, correct, delete and object free of charge to the processing and transfer of your data. You can contact us about this by e-mail: privacy@Roularta.beor by post at: Roularta Media Group (Privacy Office), Meiboomlaan 33, 8800 Roeselare.

In order to exercise your right of access and to prevent any unauthorised disclosure of your personal data, you must provide us with proof of your identity. We therefore ask you to include a copy of the front of your identity card with your written application by e-mail or by post when exercising your right of access.

Roularta Media Group has 30 days to respond to your request. Please note that this period starts only when Roularta Media Group has received your request in writing and has all the information required to fulfil your request.

10. RIGHT TO OBJECT TO THE USE OF YOUR DATA FOR DIRECT MARKETING OR COMMERCIAL PURPOSES

You have the right at all times to object, without giving reason, to the use of your personal data for direct marketing purposes, and to oppose the transfer to third parties.

If you give us your postal address:

• You may receive periodic mailings in the future with information about products, services and events.
• You may receive mailings from commercial partners that offer products or services that might interest you.

If you do not wish this, contact us at privacy@roularta.be, indicating your exact name and address.

If you do not wish to receive letters or mailings from any company, you can register on the Robinson list: www.robinsonlist.be. Roularta Media Group, as a member of the Belgian Direct Marketing Association, takes this into account when approaching non-customers.

If you give us your telephone or mobile number:

• You may receive telephone calls or text messages from us containing information about products, services and upcoming events.
• You may be contacted by telephone by other companies with which we are contractually bound.

If you do not wish this, contact us at privacy@roularta.be

If you do not wish to receive telephone calls from any company, please use the do-not-call-me list: www.bel-me-niet-meer.be

If you give us your e-mail address:

• You may receive e-mail from us containing information about products, services and events.

You can unsubscribe from further commercial or promotional e-mail via the unsubscribe link provided in each e-mail campaign (at the bottom of the e-mail). An unsubscribe link is also provided in editorial newsletters.

To unsubscribe for all possible commercial or promotional mails from Roularta Media Group, please contact us at privacy@roularta.be

Please note: we reserve the right to contact you electronically in the context of the performance of your contract or if the law obliges us to do so. As a registered reader, trial subscriber or subscriber (free or paying) we may contact you by telephone or e-mail in the context of your registration or subscription.

You have the right to lodge a complaint with the Data Protection Authority: Drukpersstraat 35, tel +32 (0) 2 274 48 00, Fax +32 (0) 2 274 48 35, e-mail: contact@apd-gba.be.

11. THE SURF AND COOKIE POLICY OF ROULARTA MEDIA GROUP

11.1. What are Cookies?

When visiting the Internet on a website or using a Roularta Media Group digital application or app, cookies, files and technologies may be used that store information on your terminal equipment (PC, laptop, smart phone, tablet, etc.) or that access information already stored on your terminal equipment.

The visitor gives his / her permission for the use of cookies, files and technologies by our company on a first visit to our website, apps or applications.

These files and technologies may consist of cookies, web beacons or pixel tags, log files, settings and information on your terminal equipment and the like:

o Cookies are small files that are placed and / or read on the terminal equipment of your device when you visit and use our website.

o Web beacons or pixel tags are (invisible) graphic files that are contained in a web page or an email. They are used to understand the behavior of visitors when browsing our website and accessing and reading our information sent by email. Web beacons are part of third party technology that we use to map the activities of visitors to our website. Web beacons allow us to keep track of which computer visited certain parts of the website, when this happened and from which location (country / city).

o Log files can collect information about the activities of your web browser.

o Your PC, laptop, smart phone and tablet, and the applications present on it, may contain information about the type of device, the settings of an application, etc. These settings can be read.

We ensure that the files and technologies used by Roularta Media do not contain viruses or other harmful applications. These files and technologies are sometimes temporary (session cookies, these are deleted when you close the browser), sometimes permanent (persistent cookies, they remain until they expire or you delete them) or sometimes both.

Some of these cookies, files and technologies are placed and managed by third parties and are necessary, among other things, to share information via social media and / or to enable certain applications on our applications. When third parties use such files and technologies via a website of Roularta Media Group to automatically collect, process and possibly enrich data, Roularta Media Group is not responsible for this.

Some of the files and technologies used described here contain information that can directly or indirectly identify you. For more information and your rights regarding the processing of personal data, we refer to our privacy policy.

11.2. What do the Roularta Media Group websites use cookies for?

We can divide the cookies we use into the following categories:

1) Necessary cookies:  These cookies are necessary for our websites and apps to function properly and in a user-friendly manner and to provide access to our services. These cookies are therefore always placed.

Examples are cookies that are placed to:

• Store your preferences or permission to use cookies,
• Not having to enter your username, password or other data again and again,
• save your surfing preferences so that you do not have to enter them every time: your language, your region or location, your subscription, your preferred themes, search preferences,…
• allow you to navigate our website smoothly, load web pages faster or enable interactivity with our websites,
• enable the detection of errors or misuse, guarantee safety,
• remember your purchases or information about different web pages or surfing sessions. For example: products added to an order basket, completed fields in forms.

This information results in descriptive statistics that are added to many (registered or unregistered) users. We cannot therefore trace these back to individual users.

Examples include cookies that:

Register the general use of the websites and apps (eg number of visitors, duration, order of pages visited)
Detect error messages
Design for better user experience testing (A / B testing)
If you consent to the use of Cookies for “Storage of and access to information” and “Measurement”, we can combine these measurements with previously collected data to map the number of unique users of our websites and apps. Without these permissions, we consider each device and domain as a separate user. You can change these preferences at any time via your privacy preferences.