Data Protection Policy
Dust Mobile, places great importance on the secure, transparent and confidential collection and processing of your personal data. In particular, we want to protect the data of our clients, suppliers, employees, visitors of our website dustmobile.com (“Website”) and other contact persons against loss, leaks, errors, wrongful access or unlawful processing.
By means of this Data Protection Policy we wish to inform you about the collection and processing of your personal data. We ask that you read this Data Protection Policy carefully, since it contains essential information about how your personal data are processed and for which purposes.
By communicating your personal data, you expressly declare that you have taken knowledge of this Data Protection Policy and that you expressly accept it, as well as the processing itself.
Furthermore, by using any part of the Website, you consent to the collection, use, disclosure and sharing of your information as further outlined in this policy.
- SCOPE OF APPLICATION
This Data Protection Policy relates to all business and services that are provided by (or to) us and to all activities that we perform generally.
Dust Mobile SA/NV, with registered office established at 1050 Brussels, Avenue Louise 523 Louizalaan, BELGIUM, with Belgian company number 0506.792.732, and with registered office established at 92100 Boulogne-Billancourt, 31bis rue des Longs Prés, FRANCE, with French company number 831 238 704, is the data controller of your personal data;
When collecting and processing your personal data, we respect the Belgian and French regulations on the protection of personal data, as well as the General Data Protection Regulation (“GDPR”) as of its entry into force on 25 May 2018.
Depending on your activities and your relationship to our company, we will be processing your personal data. We wish to point out that you bear responsibility for all of the data that you provide to us and that we rely on the accuracy thereof. If your data should no longer be up-to-date, we ask you to report this to us as by return post.
You are not obliged to communicate your personal data, but you understand that the granting of certain services or the collaboration becomes impossible if you do not consent to the collection and processing.
- PERSONAL DATA, PROCESSING PURPOSES AND LEGAL BASIS
5.1 Data of clients
Within the framework of our services and activities, we collect and process personal data of our clients and principals, their personnel, employees, agents and other useful contact persons. We process the following personal data: identification data, financial identification data, data regarding solvency, financial transactions, shareholders data, incorporation data, professional activities, agreements and settlements, company number, client number and segment, etc.
The purposes for such processing are the execution of the agreements with our clients, connecting with electronic communication networks; our client management, the bookkeeping, dispute management, safety, security, legal compliance and direct marketing activities such as the sending of promotional or commercial information or use on social media. The legal bases are the execution of the agreement, compliance with statutory and regulatory obligations and/or our legitimate interest. For direct marketing activities by e-mail, consent will always be requested, and it can also be retracted at any time.
5.2 Data of end-users
If you are using our SIM Cards, as provided to you by one of our clients, we collect and process the following personal data: data on communication traffic, called telephone numbers (landlines and mobile numbers), the date, time duration and location of a call, text message and/or internet connection, the network you have used to make such calls or connections, and more generally all the information available to a telecom operator such as the mobile networks signaling.
The purposes for such processing are the execution of the agreements with our clients, connecting with electronic communication networks, our client management, the bookkeeping, dispute management, safety, security and legal compliance. The legal bases are the execution of the agreement, compliance with statutory and regulatory obligations and/or our legitimate interest.
5.3 Data of suppliers and subcontractors
We collect and process personal data of our suppliers, subcontractors, agents and distributors, their personnel, employees, agents and other useful contact persons. We process the following personal data: identification data, financial identification data, data regarding solvency, financial transactions, shareholders data, incorporation data, professional activities, agreements and settlements, company number, supplier ou subcontractor number and segment, etc.
The reasons for such processing are the execution of this agreement, the management of the suppliers, the bookkeeping and direct marketing activities such as the sending of promotional or commercial information, safety, security, legal compliance and supply management. The legal bases are the execution of the agreement, compliance with statutory and regulatory obligations and/or our legitimate interest.
5.4 Website visitors
(a) Connection data
We register the information about the connection you make to our website dustmobile.com and the software and the device you use to accomplish this. This information includes your IP address, the time of your visit on the website, the type of browser and the type and brand of equipment you use and the pages you visit.
Connection data are used to create statistics and improve the quality of our website and service through analyses of your surfing behaviour on our website. This information may also be used to tailor our offer or the information on the Site to any needs you may have.
(b) Personal data
Access to certain parts or functions of our website may be limited to visitors with an account on our “Selfcare” website, subject to the correct password and login being entered, authorised network access, account previously validated by Dust Mobile and account activation based on local regulation, Dust Mobile rules and ethics compliance. In this case, you can fill in a web form to share your data with us directly. We collect the personal data you provide in response to those web forms. Occasionally, we may also offer opportunities for you to share your data with us such as through a survey, to sign up for a newsletter, or to register for or receive details about an event we are sponsoring. If you participate in those surveys, sign up for a newsletter, or register for an event, we will collect the information you provide to us in doing so.
We use this personal data you provide us directly to formulate a response to your inquiry and know how to get back to you with our response. Similarly, if you provide us information directly in response to a survey or when signing up for an event, we will use the data you provide for the reason that you provided it to us and for other purposes that we tell you about at the time when you provided that data
We may send you e-mails in order to keep you informed about existing and new products and services, unless you have exercised your right to object. We uses tools to measure and follow up the impact of these e-mails: has the e-mail been opened or not, has the hyperlink been clicked on or not, etc. These tools are used to increase the efficiency of our e-mail campaigns and to better adapt our offer to your personal needs.
The legal bases are the execution of the agreement, compliance with statutory and regulatory obligations and/or our legitimate interest.
5.5 Other data
Along with the above-mentioned data, we also process personal data of others, such as possible new clients/prospects, applicants, visitors, useful contacts within our sector, network contacts, etc. The reasons for such processing are in the interest of our activities, direct marketing and public relations. The legal basis is our legitimate interest or, in some cases, the execution of an agreement.
- DURATION OF THE PROCESSING
The personal data are kept and processed by us for a period that is necessary as a function of the purposes of the processing and as a function of the relationship (whether or not contractual) that we have with you.
Your data will in any case be removed from our systems after a period of ten years after termination of the agreement, the file, the collaboration or the project, except with regard to those personal data that we, on the basis of specific legislation, must preserve for a longer period or in the event of an ongoing dispute for which the personal data are still necessary. Data on the End-Users’ communication traffic is stored in accordance with the telecommunications regulations.
In accordance with and subject to the Belgian and French data protection legislation and the provisions of the GDPR, we hereby inform you that you have the following rights:
Right to access and inspection: You have the right to access, free of charge, the data we have about you, and to check for what purposes they are used.
Right to rectification: You have the right to rectify (correct) inaccurate personal data, as well as to complete incomplete personal data.
Right to data erasure or restriction: You have the right to ask that we erase your personal data or restrict the processing thereof in the circumstances and under conditions set by the GDPR.
Right to data portability: You have the right to obtain in a structured, common and machine-readable form the personal data you supplied to us. You have the right to transfer these data to another party responsible for the processing.
Right to object: You have the right to object to the processing of your personal data on serious and legitimate grounds.
Right to withdraw consent: You have the right to withdraw the consent given by you.
Automated decision-making and profiling: We confirm that the processing of your personal data does not include profiling and that you are not subject to fully automated decision-making.
You can exercise these rights by contacting our Dust Mobile Privacy & Security Officer via the following contact information:
- by mail in Belgium: Avenue Louise 523 Louizalaan, 1050 Brussels, Belgium.
- by mail in France: 31bis rue des Longs Prés, 92100 Boulogne-Billancourt, France
- by email at privacy @ dustmobile . com
We make every effort to deal with your personal data in a careful and legitimate manner, in accordance with the applicable legislation. If you nevertheless believe that your rights have been violated and your concerns are not addressed by our company, you are free to file a complaint with the competent supervisory authority. Additionally, you may turn to a court in case you feel you suffer any injury as a result of the processing of your personal data.
- TRANSFER TO THIRD PARTIES
Specific end-users personal data that are collected by us will be transferred to and possibly processed by governmental authorities or to third-party such as affiliated companies of Dust Mobile and telecommunications carriers.
The employees, managers and/or representatives of the above-mentioned service providers or institutions must respect the confidential nature of your personal data and can only use these data for the purposes within whose framework they were provided.
If necessary, your personal data can be transferred to other third parties in the case we should be reorganised in whole or part or our activities should be transferred. It is also possible that personal data must be transferred as a result of a court order or in order to comply with a certain statutory obligation. In that event we will make reasonable efforts to inform you in advance about this communication to other third parties. You will nevertheless acknowledge and understand that in certain circumstances this is not always technically or commercially feasible or that legal restrictions may possibly apply.
Lawful Interception (LI) implementation as well as Retained Data (RD) are required by the European Council Resolution from 1995 (Official Journal C 329, 04/11/1996) which allows to prevent crime, including fraud and terrorism. As a legally sanctioned official access to private communications, LI is a security process in which Dust Mobile collects and provides law enforcement officials with intercepted communications of private organizations or individuals. The implementation of such interception is regulated and may be justified in a context of a judicial investigation or a specific Intelligence law case.
We will under no circumstances sell your personal data or make them commercially available to direct marketing agencies or similar service providers.
- TECHNICAL AND ORGANISATIONAL MEASURES
We take the necessary technical and organisational measures in order to process your personal data with an adequate degree of security, so as to protect them against destruction, loss, falsification, change, unauthorised access or erroneous disclosure to third parties, as well as any other unauthorised processing of these data.
Under no circumstances can any of our companies be held liable for any direct or indirect damage deriving from an erroneous or wrongful use by a third party of the personal data or personal data loss due to internal or external cyber attack.
- ACCESS BY THIRD PARTIES
With a view to the processing of your personal data, we grant access to your personal data to our employees, collaborators and agents on the “need to know” basis only. We guarantee an equivalent level of protection by making contractual obligations opposable to these employees, collaborators and agents, which are identical to this Data Protection Policy. A client may also have a full access to its relative end-users data.
- ANY QUESTIONS?
If, after reading this Data Protection Policy, you have further questions or comments regarding the collection and processing of your personal data, you can send an e-mail to firstname.lastname@example.org or contact your usual local company contact.