VOO attaches great importance to your privacy and processes your personal data, hereinafter referred to as the “Data”, with the utmost care and transparency. VOO also makes it a point of honour to offer its clientele the best possible security. Below please find information relating to the Data processed by VOO as well as to your rights in respect of these Data.
Who is the party responsible for the processing of your Data (Data Controller) and how to contact them?
The party responsible for the processing of your Data is VOO SA, registered with the CBE under company number 0696.668.549 and with its registered office at rue Louvrex, 95, 4000 Liège, hereinafter referred to as “VOO”.
VOO may be contacted using the form available from the voo.be website under the “Contact us” section, “Administrative” sub-section, to be returned for the attention of VOO’s DPO Office (Office of the Data Protection Officer) at the address specified above, or by email to [email protected].
Which data categories are processed?
Your Data include all information relating to you and on the basis of which you can be identified directly or indirectly.
VOO may process the following categories of Data:
- Identification data: surname, first name, age, gender, date of birth, nationality, national registration number, etc.
- Contact data: postal address(es), product and/or service delivery address, e-mail address, telephone and/or mobile phone number, etc.
- Banking, financial and transactional data: bank details, payment methods, payment references, invoices, payment history, direct debit, etc.
- Commercial data: information relating to the services and/or products supplied or to your contract;
- Technical data: IP address, MAC address, modem your modem configuration, equipment used or connected to your modem, etc
- Location data;
- Consumption data: data resulting from your use of the services such as, but not limited to, the URLs of the web pages visited, the telephone numbers dialled, the date, time and duration of the call/Internet connection, etc.
- Data relating to communications with VOO: telephone conversations, emails, contact forms, questions/opinions posted on social networks and/or website, call-out reports, etc.
- Data collected via cookies;
- Images from video surveillance cameras installed in and around stores;
- Data relating to promotional activities (competitions).
For which purposes are your Data processed?
VOO collects and processes your Data for the specific, explicit and legitimate purposes described below:
- A. In order to reply to your questions outside of any contractual relationship
If you do not yet have an account with VOO and you would like us to reply to questions you send in to us through our website, we will need your email address or your telephone number.
- B. As part of the conclusion/performance of the contract between you and VOO
VOO processes your Data in order to be able to perform the contract it has concluded with you or to put in place steps prior to entering into a contract, such as replying to any questions you may have regarding its services, or to draw up or send you a quote.
As part of the performance of the contract, your Data may specifically be processed by VOO for the following purposes:
- to identify you;
- to supply the products and/or services ordered;
- to manage appointments;
- to manage your subscriber account;
- for billing purposes and, where applicable, to manage outstanding payments and any disputes;
- to answer your questions and/or complaints;
- to provide after-sales service;
- To grant you the social tariff if you are entitled to it;
- to communicate with you.
To this end, VOO collects your identification and contact data, your national registration number, your nationality, your date of birth, your postal address(es), the delivery address of the product and/or service, your email address, your telephone and/or mobile phone number, your banking and financial data, your payment methods and history, as well as data relating to your use of the various services and technical data relating to your use. In doing so, you are assigned an account number, an easyswitch identifier, an IP address, a SIM card, modem and/or decoder number, as data which will also be registered by VOO.
When you subscribe, VOO is also likely to process data related to your use of its products and services such as URLs, web pages visited (however, the content consulted or downloaded on a website are not visible) outgoing or incoming calls or text messages, the duration of your calls, your location, the ratios between outgoing and incoming text messages, TV programmes viewed or connection data such as your computer’s IP address, connection and usage logs, data relating to your device configuration, devices connected to your modem or used to make calls or use the Internet and connection events linked to your equipment.
- C. As part of the legitimate interests pursued by VOO
In certain cases, VOO has a legitimate interest in processing your Data.
To this end, VOO is always careful to maintain a fair balance between the usefulness of processing your Data and respect for your rights and freedoms, in particular the protection of your privacy.
On the basis of VOO’s legitimate interests, your Data may in particular be processed by VOO in order to:
- improve its network and ensure that it is running smoothly;
- check the quality of the data it processes and add to it;
- measure your satisfaction and get to know you better;
- respond as effectively as possible to your requests in order to improve its services and websites;
- organise competitions;
- carry out communication and marketing activities to inform you about new products and/or services and promotional offers;
- organise and manage the work schedules of its technicians;
- draw up reports and trends concerning the use of services such as the channels viewed or the volume of internet consumption (VOO uses your Data in an aggregated manner, i.e. anonymously). The information which VOO derives from these analyses is used to appraise and improve our services.
- monitor and/or improve the quality of telephone communications with its services (certain telephone calls made to its services are recorded for this purpose). Generally speaking, VOO keeps a record of all the contacts it has had with you via its various channels;
- prevent and detect any fraud or ensure the security of the network or its stores;
- manage installations/breakdowns. Photographs of the premises may be taken by the technician;
- analyse your use and consumption habits of the services specifically to enable us to send you TV programme recommendations (for example via VOO TV+), to offer you discounts/benefits or present services and/or options which meet your expectations, to help you choose offers best suited to your needs, to be able to send you targeted advertising;
- monitor the use of the Internet and set-top boxes, in particular to determine whether or not you are likely to be at home during an incident. As appropriate, you will receive an alert by text message about the incident;
- check whether or not emails have been opened and whether you have clicked on any links.
In addition, VOO may contact you again over a 24-month period after the expiry of your contract, based on your Data to inform you of its new commercial offers.
- D. With your consent
Your Data may also be processed by VOO when you have given your consent.
By way of example, your Data may be processed to:
- place cookies and tracers on your terminal (telephone, computer, tablet, etc.) from the websites and mobile applications in order to collect information about you. You can find more information about this in our cookies policy available via the following link: https://www.voo.be/en/cookies;
- publish the photo of the winner of a competition on its Facebook page;
- establish your consumer profile in order to direct you towards the most appropriate offer for you;
- transmit your data for your entry in the telephone directory or directory enquiries service.
You will be duly and expressly informed, at the time when your consent is sought, of the reasons why VOO would like to use these Data.
In addition, you should be aware that you are free to withdraw your consent at any time, without being required to state reasons. However, this will not affect the lawful nature of any processing that has taken place prior to the time you withdrew your consent.
- E. As part of its legal and/or regulatory obligations
Numerous statutory and regulatory obligations are in place that require VOO to process and keep certain Data such as the bills (accounting and tax obligations), IP address, the traffic data relating to your communications or location data (obligations specific to telecom operators). In this respect, please rest assured that the latter Data are kept solely for the purposes set out by law, such as in order to comply with the requests from the judicial authorities or the intelligence services, to check the proper operation of the network or to deal with emergency calls, for instance. Under no circumstances will VOO access any content viewed.
Where are your Data sourced from?
By far the overriding bulk of the Data processed by VOO are collected either from yourself directly, as it was you who provided them, or indirectly as they were gathered whilst you were using the services or while using its websites.
We are also provided with Data by third parties with your consent, or because you have expressed an interest in our telecommunications services, in which case these are identification data and contact details (surname, first name, home address and telephone numbers, as well as email addresses) which enable VOO to contact you to present its services, in case you do not yet have an account with VOO.
In some cases, VOO will also collect Data that were made public on the internet. In that case, these are socio-demographic data such as your age, gender, town, data regarding your areas of interest or data relating to your surfing behaviour (number of clicks, duration of visits, pages visited on the voo.be website, on the VOO forums or on its Facebook page or its Instagram or TikTok account). These Data enable VOO to compile profiles in order to send out targeted advertising messages or to improve the appeal of its services, its websites and platforms. Unless your activities on the VOO forums or on its Facebook page or its Instagram or TikTok account are to do with the performance of your contract or where you provide us with your customer number, these data are collected on an aggregated and consequently anonymised basis without any links being established to yourself.
How long are your Data kept?
The retention periods for your Data vary according to the purposes for which they are processed and, without prejudice to any legal or regulatory provisions, the following retention periods apply:
- the data relating to your contract will be kept on record for the duration of the life of the contract and for a period of what in principle is 10 years after the contractual relationship has ended;
- the data used for the purposes of predictive modelling are kept on record for a duration of 36 months;
- the traffic data are kept on record until the end of the time period during which you can protest the bill or until the end of the period during which proceedings may be brought to secure payment thereof or for a period of 12 or 9 months to respond to requests from the authorities;
- the location data are kept on record for the time necessary to provide the traffic or location data service in question and for a period of 12 or 9 months to respond to requests from the authorities;
- the data relating to the access and to the connection of the terminal hardware to the network and the data intended to identify the user or the account holder are kept on record for 12 or 9 months to respond to requests from the authorities;
- If you have a MyVOO account, your account will be kept on record for 2 years after the end of your contract unless you have requested that it be deleted.
- the data from surveillance cameras installed in certain sales outlets are kept on record for a maximum of 1 month;
- the data resulting from recordings of telephone conversations with its services are kept on record for a maximum of 1 month;
- the data relating to the prospects are kept on record for a maximum of eighteen months. If you have asked VOO not to use your data for marketing purposes, your data will be kept on record so as to be excluded from advertising campaigns.
In some cases, where this is required by law or so as to safeguard VOO’s rights and interests, and particularly in the event of a dispute, Data may be kept on record for longer time spans insofar as this is necessary for the purposes outlined above.
To whom are your Data disclosed?
The sharing of your Data with third parties
VOO calls on the services of various service providers which, in some cases, may have access to some of your Data.
By way of illustration, VOO calls on self-employed installation engineers or technicians. Raising their bills and dispatching these bills is assigned to a third-party service provider. The same applies to part of the management of the VOO website and the VOO forum. The call centres are managed by third party partners or other Group companies.
VOO also calls on the services of independent resellers and discloses certain Data to third parties to recover unpaid debts or to analyse data and statistics. Data may also be disclosed to partners as part of marketing campaigns, for instance where prizes are handed out to competition winners or for targeted advertising purposes. Data may also be transmitted to third parties such as insurance companies, injured persons or the police in the event of a claim.
In addition, VOO facilitates consultations and invoice payments by working with third-party providers (such as Zoomit and Doccle). These various service providers have access only to the Data they need to perform the duties assigned to them by VOO. On no account are they able to use the Data which they have access to for any other purposes.
In addition, VOO is required by law to disclose Data to the emergency services or to certain authorities. If so requested by you, your data are also transmitted to the publishing houses of telephone directories.
Data are transferred to service providers located outside the European Economic Area
- for which the European Commission has issued an adequacy decision recognising that these service providers offer an adequate level of protection for Data transferred to them by a European entity
- for which VOO has provided appropriate guarantees, in particular by using the standard contractual clauses drawn up by the European Commission.
Your personal Data are thus transferred on one of these bases.
Outline of the Data Sharing Agreement between Orange and VOO for the purpose of excluding joint customers from direct marketing campaigns and granting them discounts
1. What are the purposes and consequences of this sharing and processing?
The purpose of sharing some of your personal data (see below) is to identify customers who have both a VOO contract and an Orange contract. As soon as this identification has been carried out, the shared data will be deleted by Orange.
Joint customers will receive fewer marketing messages from Orange and can benefit from discounts as long as they are customers of both companies.
2. Why are VOO and Orange joint data controllers?
VOO and ORANGE consider themselves to be jointly responsible for the processing of your personal data, in that they:
- A. Jointly determine the means of processing:
The Data processed: the Data of all VOO and Orange customers except those who have objected to their data being used for marketing purposes or to their data being shared between Orange and VOO.
The type of Data processed:
- Data that enables you to be identified: customer number, surname, first name, postal address, date of birth and bank account number,
- Data relating to VOO products and associate income,
- If you are a joint customer of VOO and Orange,
The duration of Data processing and storage: Data are processed for each direct marketing campaign, i.e. for a very limited period of no more than a few hours. Once the Data has been compared, the shared Data will be deleted by Orange subject to the information that you are a joint customer.
- B. Jointly determine the purposes of this processing:
The Data are processed to enable Orange not to send direct marketing communications known as acquisition communications to VOO customers and to grant discounts to joint customers.
As part of the data they exchange, VOO and Orange act as joint data controllers of your Data.
In accordance with Article 26 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“GDPR“), VOO and Orange have entered into a joint responsibility agreement to govern the processing of your personal data.
4. What is a joint responsibility agreement and what does it provide for?
A joint responsibility agreement is a mandatory document required by Article 26 of the GDPR when two or more data controllers jointly determine the purposes and means of the processing (as defined in point 3 of this document). This agreement regulates, in a transparent manner, the responsibilities of the joint data controllers for compliance with the obligations arising from the GDPR and the applicable privacy laws, in particular, with regard to the obligations of transparency and the exercise of the rights of data subjects.
5. What other obligations do VOO and Orange have under this agreement?
VOO and Orange have also agreed that:
- they will not use any other sub-contractor and will not transfer the Data of the data subjects to any other entity, in particular, any entity located outside the European Union and/or an international organisation;
- they will take all security and confidentiality measures to respect the integrity of the Data, prevent any breach and will not seek to re-identify the data subjects to whom the anonymous data relates;
- in the event that data subjects exercise their right to privacy, the party that collected the Data will be responsible for (i) managing requests and (ii) responding to data subjects;
- since data subjects may exercise their privacy rights against either party, the parties will always co-operate to the best of their ability to satisfy data subjects’ requests in the most expeditious and efficient manner.
If you wish to object to this sharing, simply click on the link below: http://www.voo.be/optout-orange.
As far as Orange is concerned, data subject may write to the privacy department of Orange Belgium at Avenue du Bourget n°3, 1140 EVERE, or address an email to [email protected].
You will also find all the information on how Orange processes your personal data in their privacy statement available here.
Are you subject to automated decisions, including profiling?
VOO does not put in place any fully automated decisions in respect of yourself which could have legal consequences in regard to yourself or that could affect you in a significant manner, such as denying you access to certain products. However, VOO does raise profiles that are used by its agents to enter into contracts, or within the context of the performance of the contracts, in particular to present you with tailored or more advantageous offers or programmes that are likely to interest you. In doing so, evaluations of your socioeconomic situation are compiled, based on your socio-demographic situation and on statistics.
What are your rights and how to avail yourself of them?
In compliance with the applicable regulation, you have the following rights, which you may exercise free of charge and at any time, except in the event of misuse:
- – The right to request access to your Data (A)
- – The right to have your Data rectified (B)
- – The right to have your Data erased (C)
- – The right to object to your Data being processed (D)
- – The right to request for the processing of your Data to be restricted (E)
- – The right to Data portability (F)
- – The right to file a complaint with the Supervisory Authority (G)
A. Right of access
You have the right to request VOO to confirm whether or not the Data relating to you are processed and, if so, you may request access to such Data.
In that case, you will also be provided with the following information:
- the Data categories concerned and the purposes for which they are processed;
- the recipients or the recipient categories to whom the Data were or will be disclosed, in particular the recipients who are located in third countries;
- if possible, the planned retention period of the Data or failing this, the criteria adopted to determine this duration;
- the rights you have in respect of your Data, including the right to file a complaint with the Data Protection Authority;
- where the Data were not collected from yourself, all available information regarding their origin;
- the existence of automated decision-making or the establishment of profiles and, as applicable, useful information regarding the logic behind any such decisions or profiles;
This right can be exercised easily via the “Contact Us” section available on the VOO website in the “Administrative” category or by writing to the VOO DPO Office (Office of the Data Protection Officer) at rue Louvrex, 95, 4000 Liège or by email to [email protected]. . Please be aware that the traffic data relating to your communications may be disclosed only to the authorities specified by law, which is why you are not allowed to have access to these data.
B. Right of rectification
You have the right to have Data relating to you, which are inaccurate or incomplete, rectified at any time. This right is easily exercised through the “Contact Us” section, “Administrative” sub-section on VOO’s website, by calling 078/50.50.50 or by writing in to VOO’s Customer Service at 46 rue Jean Jaurès in 4430 Ans.
C. Right to erasure
You have the right to request VOO to erase the Data relating to you in the following cases:
- the Data are no longer necessary for the purposes for which they were collected or where they are processed in another manner;
- you have withdrawn your consent on which the processing rests and no other legal basis for the processing exists;
- you have availed yourself of your right to object, as explained under paragraph D. below;
- your Data have been unlawfully processed;
- your Data are to be erased in order to comply with a statutory obligation;
- your Data were collected as part of an information service addressed to a child;
However, this right is not absolute and VOO may refuse to erase your Data, particularly when processing is necessary:
- to comply with a legal obligation to which VOO is subject
- to perform the contract and contact you
- to establish, exercise or defend legal claims.
This right to erasure is easily exercised through the “Contact Us” section, “Administrative” sub-section on VOO’s website or by writing in to VOO’s DPO at the address specified above.
Any Data which you have communicated to VOO on platforms such as the VOO forum on via VOO’s social media pages cannot, however, be erased directly by VOO. VOO does not make any connection between its customers and the users of these platforms. If you wish your Data to be erased from these platforms, your erasure request should be addressed directly to each of these forums. If you wish your Data to be erased from the directory, please use the contact form available on our website in the “Administrative” category or call 075/50.50.50
D. Right to object to processing
You have the right to object, at any time, for your own reasons, to having your Data processed, including to having profiles compiled of yourself, carried out by VOO in pursuit of its legitimate interests. In this case, VOO shall cease the processing unless this is necessary with a view to the establishment, the exercise or the defence of its rights before a court of law or where VOO is able to show that legitimate and compelling grounds exist that take precedence over your interests and your rights and freedoms. For that matter, you have an absolute right to object to having your Data processed, including to having profiles compiled of yourself for commercial purposes. Please be aware that, in this case, it may be that you will be contacted again by VOO if, after having erased your Data at the end of the retention period or at your request, VOO is sent your data again from a third party with your consent.
This right is easily exercised through the “Contact Us” section, “Administrative” sub-section on VOO’s website or by writing in to VOO’s DPO at the address specified above.
By way of general information, please be advised that you may object to the use of your landline or mobile telephone number by any businesses for marketing purposes, by signing up to the “ne m’appelez plus” (stop calling me) list at the https://www.dncm.be/fr/ website.
E. Right to restriction of processing
Where the processing is restricted, with the exception of the retention, the Data that are restricted may no longer be processed unless within the context of the restrictions established with your consent or with a view to the establishment, the exercise or the defence of VOO’s rights before a court of law, or with a view to the protection of the rights of another person. You have the right to request VOO to restrict its processing operations if any one of the following applies:
- you dispute the accuracy of the Data;
- the processing is unlawful but you do not wish to have your Data erased;
- VOO no longer needs the Data for processing purposes but your Data are still needed with a view to the establishment, the exercise or the defence of VOO’s rights before a court of law;
- you have objected to having your Data processed and a check is made as to whether the legitimate interests pursued by VOO prevail over your interests.
This right is easily exercised through the “Contact Us” section, “Administrative” sub-section on VOO’s website or by writing in to VOO’s DPO at the address specified above.
F. Right to Data portability
You have the right to be provided only with the Data relating to you which you supplied us with, with a view to the performance of the contract or with your consent and which are processed by way of automated procedures, and where these were either transmitted to you or to another Data Controller if this is technically possible. If you wish to exercise this right, please inform us thereof at the time you request to cancel your contract.
G. Right to file a complaint with the Supervisory Authority
You may address all requests or complaints relating to the processing of your Data by VOO with the Belgian Supervisory Authority at: Data Protection Authority Rue de la Presse, 35, 1000 Brussels
- Tel : +32 (0)2 274 48 00
- Fax : +32 (0)2 274 48 35
- Email : contact(at)apd-gba.be
Or through its website at: www.autoriteprotectiondonnees.be/contact