Route 1700 App Privacy Policy
This privacy policy sets out how DPW Antwerp Holding NV, with registered office at 9130 Beveren, Molenweg(KAL) and registered in the CBE under number 0406.070.605, (hereinafter referred to as "DPWAH", "we," "us"), which acts as controller, processes your personal data when you use the Route 1700 App.
DPWAH gives great importance to respecting your privacy. DPWAH therefore strives to process your personal data in accordance with the applicable Belgian and European legislation in this regard, in particular the General Data Protection Regulation (Reg. 2016/679, hereinafter referred to as "GDPR") and the Belgian Privacy Act of 30 July 2018 on the protection of individuals with regard to the processing of personal data.
For more information regarding the availability and functioning of the Route 1700 App, we recommend consulting the General Terms and Conditions of the Route 1700 App.
The capitalised terms used in this Privacy Policy have the meaning given to them in the General Terms and Conditions of the Route 1700 App, unless the specific context requires otherwise.
For questions regarding the processing of your personal data through the Route 1700 App or this Privacy Policy, you may contact us by sending an e-mail to privacy.antw@dpworld.com
I. Categories of personal data, legal grounds and purposes of processing
A. General
When using the Route 1700 App, various personal data about you will be collected and further processed, such as:
Personal data:
1. Contact details when creating an account or logging onto Facebook, LinkedIn, GMail, Apple, such as first and last name and email address.
Purpose: For account management, provision of the Route 1700 App, provision of our services and to contact you in this regard; and if you consent, for direct marketing purposes.
Legal ground: Necessary for the performance of our contract (article 6.1. (b) GDPR). Our legitimate interest in advertising our company (article 6.1. (f) GDPR and recital (47) GDPR). Your consent for direct marketing is required on the basis of article XII.13 Code of Economic Law (“CEL”).
2. TAS number
Purpose: Functioning of (certain functionalities of) the Route 1700 App.
Legal ground: Necessary for the performance of our contract (article 6.1. (b) GDPR).
3. Alfapass number
Purpose: Identification (linking driver to TAS number and control of authorisations); safety and security of the terminal.
Legal ground: Our legitimate interest (article 6.1. (f) GDPR).
4. Mobile phone number
Purpose: Receiving notifications in the context of the functioning of certain functionalities of the Route 1700 App.
Legal ground: Necessary for the performance of our contract (article 6.1. (b) GDPR).
5. Technical data on your phone if one or more unique numbers refer to your phone, type of operating system.
Purpose: To improve the user-friendliness of the Route 1700 App.
Legal ground: Our legitimate interest (article 6.1. (f) GDPR).
6. Location data
Purpose: Among other things, to be able to give you the correct route advice, to provide you with traffic information and information about the route taken, to process speed alerts, to display your route history and to give you specific driving advice, to generate traffic information and profiling (on an anonymous basis) and for the functioning of the real-time functionalities of the Route 1700 App.
Legal ground: Necessary for the operation of (some of) the functionalities of the Route 1700 App that do not function without your location data (article 6.1. (b) GDPR).
For other functionalities, your consent (enable location on device) (article 6.1. (a) GDPR).
More generally, and rather in exceptional circumstances, we may also process personal data for the following purposes,
- to be able to settle any disputes that may arise between us, or between us and third parties providing services (article 6.1. (f) GDPR, our legitimate interest to defend our rights);
- other purposes for which you have given us separate consent (article 6.1. (a) GDPR);
- for the promotion of safe traffic behaviour and the possible provision of related products and services by third parties (article 6.1. (f) GDPR, our legitimate interest in road safety at the terminal);
- to enable you to contact us and other users of the Route 1700 App if you desire (article 6.1. (a) GDPR, to fulfil your request);
- for remembering the settings you make in the Route 1700 App so that you can quickly restore them when switching to a new phone, if you would choose to do so (article 6.1. (a) GDPR).
B. Additional Services
The Additional Services may involve additional processing of personal data. What (categories of) personal data will be processed depends on (the nature of) the Additional Services that are enjoyed and will be communicated to you when you purchase or download the Additional Service.
II. Transfer of your personal data to third parties
To the extent required to carry-out the purposes set out above, we may transfer your personal data to third parties such as service providers (such as our IT service provider who has developed and maintains the Route 1700 App), partners, government agencies and others (e.g., we may transfer information at an aggregated / group level, i.e. not traceable to an individual phone/person, such as traffic congestion information or statistical information about the amount of traffic on certain roads).
When purchasing Additional Services, the payment shall be processed through a Store and/or a third party payment services provider who will process your personal data to deliver such services, including the transfer of such personal data to your financial institution. The Store and/or third party payment services provider shall act as controller. For more information on the processing of your personal data in this regard, you should direct yourself to the relevant third party payment service provider.
Your personal data is stored on servers located in Belgium. Should your personal data be transferred to recipients located outside the European Economic Area, we will conclude the necessary safeguards to guarantee an adequate level of protection (e.g. conclusion of EC Standard Clauses or similar contractual provisions). If you have any questions about these safeguards or if you would like a copy of the relevant documentation, please contact us by sending a message to the following e-mail address: privacy.antw@dpworld.com.
If legally justified or required, personal data may also be transferred to competent authorities and/or other law enforcement agencies (e.g. police, investigating judge, Data Protection Authority, etc.).
III. Security of the personal data
In connection with the Route 1700 App, DPWAH will take appropriate technical and organizational measures to protect your personal data against loss or any form of unlawful processing.
IV. Retention period of the personal data
Route 1700 App does not retain personal data longer than necessary. Personal data will be stored for a maximum period of 12 months after the last use (i.e. all your personal data will be deleted if you do not log on to the Route 1700 App for 12 months).
V. Statistical information with third party services
To generate statistics on the use of our Route 1700 App, we use two external services: Google Analytics and Google Firebase.
Google Analytics & Firebase are services of Google (www.google.com). Google processes the personal data collected through Analytics and Firebase in accordance with Google's general privacy policy, which can be read here: http://www.google.com/privacy.html. Route 1700 App has set up Google Analytics and Firebase in accordance with the "Handleiding privacyvriendelijk instellen van Google Analytics" (version July 2015) published by the Dutch data protection authority (Autoriteit Persoonsgegevens).
VI. Withdrawing your consent
Where processing is based on your consent (article 6.1. (a) GDPR or article XII.13 CEL), you have the right to withdraw it at any time.
You can do this yourself in the Route 1700 App. For example, it is possible to disable the processing of your location. Disabling the options has no effect on the (legitimacy of the processing of) personal data that we have already processed; the disabling only applies for the future.
You can always withdraw your consent for direct marketing by following the instructions at the bottom of the commercial messages you receive or by contacting us via privacy.antw@dpworld.com.
VII. Your other rights
You are entitled to access your personal data at any time and correct them (or have them corrected) when inaccurate or incomplete, to have them erased and to object to the processing thereof or have the processing thereof restricted, when the legal conditions thereto are met. You are entitled to obtain a copy of your personal data (in a structured, commonly used, machine-readable format) and to have your personal data transferred to another controller (right to data portability).
To exercise these rights you can contact us via the following e-mail address: privacy.antw@dpworld.com.
If you have a question or complaint with regard to the processing of your personal data, we ask you to first of all address it to DPWAH. However, please note that you have the right to file a complaint with the Belgian national data protection authority (Data Protection Authority (Gegevensbeschermingsautoriteit/Autorité de protection des données à caractère personnel - Drukpersstraat, 35 at 1000 Brussels - contact@apd-gba.be).
Latest version: 1 october 2020