Privacy Policy
Updated: October 14, 2021
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Smart Fridges SRL, a privately held company incorporated under the laws of Belgium, whose registered office is at Rue des Atrebatenstraat 61, 1040 Etterbeek, Belgium, registered under company number BE0741376146 ("FrigoLoco" or "We") is committed to protecting and respecting your privacy. This privacy policy sets out the basis on which we process any personal data we collect from you or that you provide to us. Please read this privacy policy carefully to understand our views and practices regarding your personal data and how we will treat it.
1. Who are we?
FrigoLoco is running a pilot project with Fridges. The technological solutions used in the Fridges make it possible for us to record and process which Products you purchase from us. This makes it easier for us to stock the Fridges properly and to know our consumers’ needs. Payments occur through our App. For more information about FrigoLoco and our Products, visit our website www.frigoloco.be.
Our contact details:
E-mail address: [support@frigoloco.be](mailto:support@frigoloco.be)
FrigoLogo acts as the data controller in processing your personal data. That means we determine the purposes for and the means by which your personal data is processed. If you have any questions about this Privacy Notice, the data we process, or if you would like to exercise one of your data protection rights, do not hesitate to contact us.
2. What kind of personal data we collect from you and for what purposes?
*Data we process when you use our mobile app*
Our Fridges should be operated with our App, that can be downloaded from the Apple App Store or Google Play Store. When you use the App for the first time, you are asked to create a user account and provide payment details. The App contains a QR scanner that can be used to unlock the fridge. Payments occur automatically after you have taken Products from the fridge. The App shows your purchases and receipts.
Through the fridge and App, we may collect and process the following information:
- First and last name
- Company where you work
- E-mail address
- Language preference
- Information about your device, including device models, OS versions, configurations and settings, IP addresses, device identifiers, activity logs and click-throughs and other unique identifiers
- Which Fridge(s) you have been using and at which point in time
- The Products and amounts you have purchased from the Fridge(s)
- Payment details, such as bank card (e.g. IBAN or BIC) or credit card number*
We use this information to:
- Identify and authenticate you
- Ensure the use of our services
- Enable interaction with the Fridge(s)
- Provide software updates
- Offer maintenance services and customer support
- Provide (personalized) notifications, alerts, offers and promotions through the App
- Perform order management and inventory management.
- Send you receipts by e-mail, if desired
- Maintain security of our services and to improve it
In other words: we need your information to be able to offer you our services. Besides, we use your information to be able to increase the performance of the Fridge and the App and to improve customer experience. We have a legitimate interest to do so.
*Please note: we do not have access to your payment details. These are processed by our payment service provider, that acts as a data processor in a pseudonymized manner. Our payment service provider has no access to other information we collect about you. Your payment details are only processed after you have given consent.
Your payment data are processed by our payment service provider. We have no access to your payment data. We receive a user-ID from our payment service provider, that we can link to the purchases you have made and the fridge you have been using, but not to you as an individual. We use the information about your purchases and the Fridge to perform order management and inventory management and to improve customer experience.
*Data we process when you contact us*
When you contact us, we process your name, e-mail address, telephone number (when you call us) and other information you provide to us. We use this information to communicate with you, to be able to respond to your questions, remarks and/or requests and to provide support.
*Data we process through social media*
We use social media accounts to promote our business and interact with our customers. When you choose to comment or post content on our social media accounts, we can see your name and profile picture. Also, you might provide personal information in your comment or post. You are not required to provide personal information on social media, so this is your own responsibility. We will not process personal data you provide through social media any further.
3. How long do we store your personal data?
We will not store your personal data any longer than is necessary for the purposes for which is was collected. This means that information will be destroyed or erased from our systems when it is no longer required. We will pseudonymize the information we store as much as possible.
Some information will be stored for a certain period of time because of legal obligations imposed on us. For example, the Tax Authorities require us to store receipts, sales and inventory administration and other information for a legally determined number of years.
If you make use of our App, the personal information you provide is stored indefinitely until you delete your account.
Information you provide in public posts and comments on our social media accounts will be stored indefinitely, unless we delete our social media accounts, or you choose to remove your posts and reactions. You can also contact us if you want us to remove certain information.
4. Data processing by third parties
We make use of third parties to be able to run our business and offer you our services. Those third parties may process your personal data, but only to the extent necessary. The following third parties act as data processors and only process data on our behalf:
- Our technical service supplier has developed our App and back office and stores information collected through the Fridges and the app on their servers.
- Our payment service provider enables us to accept online payments through the App.
- We work together with companies that provide services such as administration, billing, sending e-mails on our behalf, customer contact centers, advertisements and website and email hosting.
- Affiliate companies which we control.
We may also share information with the following third parties:
- Food suppliers, to offer you fresh food from our fridges.
- Companies that can repair our fridges when they are broken or do not function properly.
We limit the disclosure of personal data to those parties as much as possible. We guarantee a similar level of protection by making contractual obligations opposable to these subprocessors, who are similar to this privacy policy.
We may share analytical data with our food suppliers, but we will not share anything that can be related to individuals with them. If you notify us of a defect in one of our Fridges by e-mail or telephone, we may occasionally share your contact details with repair and service companies. We will ask for your consent before we do so. Normally, we do not share personal information with such companies.
We may also disclose personal information to third parties when we are required to do so by the courts or to comply with other legal, statutory or regulatory obligations.
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5. Data transfer outside the European Economic Area
We try to limit data transfer outside the EEA as much as possible. Some of the third parties mentioned above may transfer or store your data in countries outside the EEA. We make sure these third parties have appropriate safeguards in place.
6. Protection of your personal data
To keep your personal data safe and secure, we have implemented administrative, technical and physical security measures appropriate to the size and nature of our business. For example, we protect our devices with passwords and other security measures, keep our websites, devices and operating systems up to date, use firewalls against viruses, cyberattacks and unauthorized access and our website uses a SSL certificate for secure online communications. Also, the third parties that process data on our behalf all take your privacy very seriously. We have closed data processing agreements with them to ensure that your personal data is protected properly.
7. Your rights
As a data subject, the GDPR provides you with certain rights concerning your personal data these rights are the following:
*A) Right of access and right to obtain a copy*
You have the right to freely obtain at any moment access to your personal data, as well as to be informed about the purpose of the processing by us.
*B) Right to rectification, erasure or restriction*
You have the choice to share your personal data with us. You always have the right to ask us to amend your personal data. You can also request the processing of your personal data to be restricted if you think that your data is inaccurate and you subsequently notified us about this. Furthermore, you acknowledge that a refusal to share data or a request to erase there data will make the delivery of several services impossible.
*C) Right to object*
You have the right to object to the processing of your personal data when you have serious and legitimate reasons to do so.
*D) Right to data portability*
You have the right to obtain your personal data which is processed by us in a structured, commonly used format and/or to transfer this data to a data controller.
*E) Right to withdraw consent*
When the processing is based on prior consent you have the right to withdraw this consent.
*F) Automated decisions and profiling*
You have the right to request us not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
*G) Right to file a complaint*
You have the right to file a complaint with the Belgian Data Protection Authority:
Data Protection Authority
Drukpersstraat 35, 1000 Brussels
Tel +32 (0)2 274 48 00
Fax +32 (0)2 274 48 35
e-mail: contact@apd-gba.be
If you want to exercise one of your rights, please contact us at [support@frigoloco.be](mailto:support@frigoloco.be). To identify yourself, this e-mail must be accompanied with a copy of your ID or passport. We will get back to you within 1 month from the receipt of your request. When you use our App, you can also access and rectify some of your personal data from there.
If there is a dispute, we prefer to resolve it mutually. If we are unable to find a solution together, you can submit a complaint to the Belgian data protection authority:
Data Protection Authority
Drukpersstraat 35, 1000 Brussels
Tel +32 (0)2 274 48 00
Fax +32 (0)2 274 48 35
E-mail: contact@apd-gba.be
8. Third-party websites
Our website or App may contain hyperlinks to third-party websites. Our privacy policy does not apply to any of those third-party websites. Therefore, we cannot guarantee that those third-party websites process your personal data in a safe or responsible way. If you land on a third-party website by clicking on a hyperlink, we recommend that you read the privacy policy of this third-party website to be informed on how they process your personal data.
9. Updates to this Privacy Notice
The services we offer might change from time to time. Laws and regulations may change as well. Therefore, we may update this privacy policy periodically without prior notice to you. We will publish the revised privacy policy on our website and/or in our App. We recommend that you check our privacy policy regularly to stay informed of changes that may affect you. If the way we process your personal data changes significantly, we may communicate these changes directly to you through the App, messages on the fridge or per email.
10. Applicable Law and Jurisdiction
This Privacy Policy is managed, interpreted and executed in accordance with Belgian law which exclusively applies to every potential dispute.
The courts and tribunals of Brussels have exclusive jurisdiction to settle any dispute arising out of or in connection to the interpretation or execution of the present Privacy Policy.