Privacy Policy

Your privacy is a priority of PASS-ONLINE.NET (hereinafter referred to as "PASS-ONLINE.NET" or "we"). In this respect, we are committed to protecting the personal data of our online users (hereinafter "you"), deal with the utmost care and ensure the best level of protection in accordance with the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter “GDPR”) and the Law of 8 December 1992 on the protection of privacy in relation to the processing of personal data (hereinafter "Belgian law"). This charter informs you about:

• The personal data we collect about you and the reasons for that collection

• The conditions for use of your personal data

• Your rights over your personal data and how to exercise them

Know that you can oppose its treatment, by making your request via this link

Terms frequently used in this Charter	Definitions provided by the GDPR	Explanations of terms in everyday language
Personal data (hereinafter referred to as "personal data")	Any information relating to an identified or identifiable natural person (hereinafter a "data subject"); an "identifiable natural person" is considered to be a natural person who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, an online identifier or one or more elements specific to his/her physical, physiological, genetic, psychic, economic, cultural or social identity.	All types of information relating to a natural person, i.e. an individual, directly or indirectly identifiable as a person distinct from other persons. For example: a name, a photo, a finger print, an email address, a telephone number, a social security number, an IP address, a voice recording, your browsing data on a website, data linked to an online purchase, etc
Data Protection Officer	The notion of data protection officer is not defined by the GDPR	The data protection officer (DPO) is responsible within the company for compliance with the GDPR and applicable national laws as well as our policies and practices for managing your personal data. He/she is also responsible for liaising with the supervisory authorities. The DPO is your first point of contact for any request concerning your personal data.
Processing	Any operation or group of operations whether or not they are carried out with the aid of automated processes and applied to data or personal data sets, such as the collection, recording, organisation, structuring, conservation, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction;	Any use of personal data, regardless of the process used (recording, organising, conservation, modification, reconciliation with other data, transmission, etc. of personal data). For example, use of your data for the purposes of order management, delivery, sending newsletters, etc.
Data controller	The natural person or legal entity, the public authority, the agency or other body which, alone or in conjunction with others, determines the processing purposes and methods.	The person, public authority, company or organisation which manages your data and decides how it is used, including deciding whether to create or delete a process and determining why your data will be processed and to whom it will be transmitted. The data controller is the main party responsible for compliant protection of your data.
Subcontractor	The natural person or legal entity, public authority, agency or other body which processes personal data on behalf of the controller;	Any natural person or legal entity that carries out processing tasks on the instructions and under the responsibility of the data controller.
Subcontractor	Profiling is any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.	Large-scale collection of personal data relating to the behavior of individuals, an analysis of these data in order to establish a link between certain data and certain behaviors leading to the creation of a profile and the application of a profile to a person

Data controller

The data controller responsible for processing your personal data is PASS-ONLINE.NET with its registered office 1348 Louvain La Neuve, 11a Avenue Albert Einstein, Belgium, registered with the ECB under the number BE859901337.

Designation of an internal data protection officer (DPO)

The controller of your personal data is PASS-ONLINE.NET with its registered office 1348 Louvain La Neuve, 11a Avenue Albert Einstein, Belgium, registered with the ECB under the number BE859901337.

We collect personal data about you for various reasons. In general terms, PASS-ONLINE.NET collects and uses your personal data to function effectively and optimise your experience with its departments. You should also be aware that we can only collect and use your personal data if that use is based on one of the legal grounds determined by the GDPR (e.g. your consent or performance of a contract concluded with PASS-ONLINE.NET). The table below specifically lists the purposes for use of your personal data by PASS-ONLINE.NET, based on the legal grounds.

Purpose of collecting your personal data	A lawful basis for processing personal data
Organization of game contests: the data of participants in a contest are processed by PASS-ONLINE.NET in order to ensure the smooth running of the Contest, in particular to get in touch with the winners and give them their prize efficiently and quickly in case of a win.	The execution of a contract concluded with you (article 6.1.b) of the GDPR), in this case a contract to participate in a competition
Co-registration and co-sponsoring: PASS-ONLINE.NET will send you, by email, phone, SMS or voice mail, commercial offers and good deals from partners identified at the time of collection, or send your data to them so that they contact you directly.	Your consent (Article 6.1.a) of the GDPR)
Emailing and telemarketing: your data is used by PASS-ONLINE.NET to send you promotional offers from certain partners that are selected after the collection.	Your consent (Article 6.1.a) of the GDPR)
Email retargeting: using the cookie technique, PASS-ONLINE.NET will send you an email after a visit to a partner site to invite you to an additional visit to the site.	Your consent (Article 6.1.a) of the GDPR)
Data commercialisation. Your data is transmitted by PASS-ONLINE.NET to our partners, so that they or other companies (such as business partners, the charitable sector and associations, the public sector and interest groups and opinions) can offer you possible offers based on your marketing profile or perform market analysis. In this context your data can also be used to validate or link, to complete or correct data already present in their database.	Your consent (Article 6.1.a) of the GDPR)
Your data are used by PASS-ONLINE.NET to enrich the database of a partner in which you are already a customer. PASS-ONLINE.NET will inform you by email and, there does not appear to be any opposition on your part, your data will be transmitted to the partner.s (appending). Your data are used by PASS-ONLINE.NET to enrich the database of a partner in which you are already a customer. PASS-ONLINE.NET will inform you by email and, there does not appear to be any opposition on your part, your data will be transmitted to the partner.	Your consent (Article 6.1.a) of the GDPR)

You should be aware first of all that the personal data we collect about you depends on the nature and number of relationships you have with PASS-ONLINE.NET, whether they are legal (ex. participation in a contest) or not (ex. visit our website). We detail you below the personal data that we collect during each of these interactions for each use we make as well as the reason for the collection, their method of collection (direct or indirect collection, that is to say that your data are provided by you directly or provided by a third party to whom you have given consent to pass on your data to PASS-ONLINE.NET) and the place of treatment:

Purpose of the collection	Enrichment of databases (appending)	Direct or indirect collection of your personal data
Games organization	Personal identification data (surname, first name, postal address, e-mail address, telephone number) Electronic identification data (IP address, cookies, connection log) Demographic characteristics, sex, year of birth, country, language)	In the context of this purpose, the data are collected directly from you.
Co-registration et co-sponsoring.	Personal identification data (surname, first name, postal address, e-mail address, telephone number) Electronic identification data (IP address, cookies, connection log) Demographic characteristics, sex, year of birth, country, language) Hobbies and interests	In the context of this purpose, the data are collected directly from you.
Emailing	Personal identification data (surname, first name, postal address, e-mail address, telephone number) Electronic identification data (IP address, cookies, connection log) Demographic characteristics, sex, year of birth, country, language) Hobbies et intérêts	As part of this purpose, the data are collected directly from you or indirectly via a third party to whom you have given consent to pass on your data to PASS-ONLINE.NET.
Email retargeting	Personal identification data (surname, first name, postal address, e-mail address, telephone number) Electronic identification data (IP address, cookies, connection log) Demographic characteristics, sex, year of birth, country, language)	As part of this purpose, the data are collected directly from you or indirectly via a third party to whom you have given consent to pass on your data to PASS-ONLINE.NET.
Marketing your data: 1) to receive offers based on your marketing profile or conduct market research.	Personal identification data (surname, first name, postal address, e-mail address, telephone number) Electronic identification data (IP address, cookies, connection log) Demographic characteristics, sex, year of birth, country, language) Hobbies et intérêts	As part of this purpose, the data are collected directly from you or indirectly via a third party to whom you have given consent to pass on your data to PASS-ONLINE.NET.
Marketing your data: 1) to receive offers based on your marketing profile or conduct market research.	Personal identification data (surname, first name, postal address, e-mail address, telephone number) Electronic identification data (IP address, cookies, connection log) Demographic characteristics, sex, year of birth, country, language) Hobbies et intérêts	In the context of this purpose, the data are collected directly from you.
Marketing your data: 2) to validate or link, to complete or correct data already present in their database	Personal identification data (surname, first name, postal address, e-mail address, telephone number)	In the context of this purpose, the data are collected directly from you.
Enrichment of databases (appending)	Personal identification data (surname, first name, postal address, e-mail address, telephone number) Electronic identification data (IP address, cookies, connection log) Demographic characteristics, sex, year of birth, country, language) Hobbies et intérêts	In the context of this purpose, the data are collected directly from you.

In the course of our activities, we may need to share your personal data with IT providers who help us provide our services from a purely technical point of view. Obviously, whenever we do so we always ensure optimal protection of your personal data, Sharing your personal data with our service providers and other subcontractors

Subcontractor involved in the sharing of your personal data	Location of the subcontractor	Reason for sharing your personal data
Transactional email service providers	France	Emailing
Providers of technical solutions that allow PASS-ONLINE.NET to use email retargeting	France	Email retargeting
Providers of technical solutions that allow PASS-ONLINE.NET to use email retargeting	France, Royaume-Uni	Appending

With public authorities,

in response to legal requests, including to respond to national security requirements or application of the law.

In the context of a transaction,

such as a merger, acquisition, consolidation or sale of assets, we may need to share your personal data with buyers or sellers.

With your prior authorization, we use your data for the benefit of our partners. This is the main activity of PASS-ONLINE.NET. Either we pass your data to our business partners who will then contact you. In this case, we encourage you to read their own Data Protection Charter (for example when receiving emails they send you or via the links provided in this charter). Or we use your personal data for the benefit of our business partners and your data remains in our possession. At the moment you have agreed to receive offers from our partners, it is specified whether the data remain in the possession of PASS-ONLINE.NET or if they are transmitted to the chosen partner. Please note that you may withdraw your consent in whole or in part at any time by following the procedures described here

PASS-ONLINE.NET has determined precise rules concerning how long we retain your personal data. This length of time varies depending on the different purposes and must take into account any legal obligations to retain some of your data.

Reason for the collection	Categories of personal data collected	Retention period
Organization of quizzes	Personal identification data Electronic identification data Demographic characteristics	(3 years from the last reaction of the participant)
Co-sponsorship and co-registration	Personal identification data Electronic identification data Demographic characteristics Hobbies and interests	(3 years from the last reaction of the participant)
Emailing	Personal identification data Electronic identification data Demographic characteristics Hobbies and interests	(3 years from the last reaction of the participant))
Emailing retargeting	Personal identification data Electronic identification data Demographic characteristics Hobbies and interests	(3 years from the last reaction of the participant)
Marketing data	Personal identification data Electronic identification data Demographic characteristics	(3 years from the last reaction of the participant)
Data enrichment (appending)	Personal identification data Electronic identification data Demographic characteristics Hobbies and interests	(3 years from the last reaction of the participant)

We wish to inform you as clearly as possible of your rights over your personal data. We would also like to make it as easy as possible for you to exercise those rights.

• Access right

  You can ask us to access all of the following information concerning:

  • The reasons we use it
  • The categories of persons to whom your personal data has been or will be communicated, particularly persons located outside Europe
  • The length of time we retain your personal data in our systems
  • Your right to ask us to correct or delete your personal data or limit the use we make of your personal data and your right to object to that use
  • Your right to file a complaint with a European data protection authority
  • Information concerning their source, when we have not collected your personal data directly from you,
  • The way in which your personal data is protected when it is transferred to non-European countries

  How to exercise your right to access ?

  By making a request via this link

• Right to rectification

  You can ask PASS-ONLINE.NET to correct and / or update your personal data.

  How can you exercise your right to rectification ?

  By making a request via this link

• You can ask us at any time to delete your personal data held by us, in one of the following situations:

  • Your personal data is no longer necessary in respect of the reasons for which it was collected or otherwise processed;
  • You have withdrawn the consent you provided as a basis for processing your personal data by PASS-ONLINE.NET;
  • For your own reasons, you consider that one of the forms of processing infringes your privacy and causes you excessive harm;
  • You no longer wish to receive marketing communications from us;
  • Your personal data is not processed in accordance with the GDPR and Belgian law
  • Your personal data must be deleted to comply with a legal obligation stipulated in European Union law or national law applicable to PASS-ONLINE.NET;

• Right to object

  You have the right to object to us processing your personal data if, for your own reasons, you consider that one of the forms of processing infringes your privacy and causes you excessive harm. You can object to the use of your personal data for the purposes of marketing communications and particularly advertising. You can also object to profiling if it is linked to marketing communications (e.g. when we send you personalised content). You cannot prevent us from processing your data:

  • if its processing is required to conclude or perform your contract. For example, your data must be processed to validate your participation in our quizzes;
  • if its processing is required by law or a regulation. That is particularly the case when you move to another address;
  • if its processing is required to officially record, exercise or defend rights in legal proceedings.

  How can you exercise your right to object ?

  By making a request via this link

• Right to withdraw consent

  When you have given your consent to the treatment, you always have the right to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. In particular, regarding the withdrawal of your consent regarding treatment for commercial prospecting purposes, we remind you that our business partners are responsible for the use they make of your personal data and the consideration of your rights, including that of no longer receiving offers from them.

  How to exercise your right to withdraw consent ?

  By making a request via this link

• Right to data portability

  This right gives you the possibility of more easily managing your personal data yourself, specifically:

  • retrieving your personal data processed by us, for your personal use, and storing it on a device or in a private cloud for example.
  • transferring your personal data from us to another company, either by you, or directly by us, subject to that direct transfer being « technically possible ».

  That right covers both your actively and knowingly declared data, such as your data supplied to create your online account (e.g. email address, first name and last name, age) and the information collected by PASS-ONLINE.NET.

  ow to exercise your right to data portability ?

  By making a request via this link

• Right to restriction of processing

  You have the right to ask us to limit your data, that is to say the marking (for example, a temporary move of your data to another processing system or a lock of your data making them inaccessible) of your personal registered data, in order to limit future processing. You can call upon this right when:

  • the accuracy of the data in question is disputed;
  • your personal data is not processed in accordance with the GDPR and Belgian law;

  In the case of a restriction on processing, your personal data shall no longer be subject to any processing without your prior agreement, with the exception of its retention (storage). Your personal data may nevertheless still be processed for the purpose of ascertaining, exercising or defending legal rights, or for the protection of the rights of another legal or natural person, or for important reasons of public interest in the Union or the Member State. In case of limitation of the treatment of some of your personal data, we will keep you informed about the timing when the measures will be lifted.

  How to exercise your right to restriction of processing?

  By making a request via this link

Data transfer within Europe

Yes, some data are transferred to our established subcontractors or their servers in the territory of the European Economic Area. Within the European Economic Area (hover over: 28 EU members states, Iceland, Norway, Liechtenstein) personal data will benefit from the same level of protection.

Data transfer outside Europe

Yes, some data are transferred to our established subcontractors or their servers in the territory of the European Economic Area. Within the European Economic Area (hover over: 28 EU members states, Iceland, Norway, Liechtenstein) personal data will benefit from the same level of protection.

Do not hesitate to let us know by contacting us by email at privacy@pass-online.net, or by mail at: PASS-ONLINE.NET, Av. A.Einstein, 11A, B-1348 Louvain-la-Neuve, Belgium. We would be delighted to hear from you and it will be a pleasure to respond as soon as possible.

This Personal Data Protection Charter may be amended at any time, particularly to take account of any changes to the law or regulations or changes to our services. Major changes made will be notified via our site or by email, as soon as possible and at least 30 days before they come into force.

When we publish notifications to this Charter, we will revise the “last updated” date at the top of the confidentiality policy and describe the changes in the “Version history” page. We encourage you to regularly consult this Charter to find out how PASS-ONLINE.NET is protecting your personal data