1. This Privacy Policy applies to the processing of personal data by BUFFL BVBA, a company with registered offices at Stationstraat 55, 2600 Mechelen (Belgium), registered with the Crossroad Bank for Enterprises under number 0688.975.459 (hereinafter referred to as “Buffl”).
2. Buffl highly values the protection of your personal data and your privacy. Your personal data will be processed in accordance with the applicable data protection legislation, as well as this Privacy Policy.
3. This Privacy Policy has the purpose of setting out the categories of personal data collected by Buffl in the context of its commercial activities. Buffl collects personal data via its website (www..buffl.be), its application (hereinafter collectively referred to as the “Platform”) and any other means connected to information- and communication technology, including e-mails, the organisation of contests, interviews, etc. In certain circumstances, Buffl may collect personal data via campaigns organised on websites or sub-domains specifically designed thereto, in particular for its “ad hoc Services”.
This Privacy Policy describes the manner in which your personal data will be processed and shared with third parties. In addition, it defines the measures taken by Buffl in order to guarantee the safety and confidentiality of your personal data.
4. You will get the chance to take note of this Privacy Policy both during and following your registration on the Platform. When this Privacy Policy applies, you will additionally be able to take note of it when taking part in ad hoc Services. The Privacy Policy can be found under the tab “Privacy Policy” on the Buffl website and application. During your account registration or when taking part in ad hoc Services, you will be asked to agree with the terms and conditions of this Privacy Policy. This acceptance is required in order to make use of our Services.
5. Buffl should be considered the controller for the processing of your personal data in respect of the processing activities set out hereinafter. Buffl will act in accordance with the applicable data protection legislation, including the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) and the Act of 30 July 2018 concerning the protection of natural persons in relation to the processing of personal data.
6. Should you have any questions in relation to this Privacy Policy, or should you have the feeling that your interests are not or insufficiently represented, please contact us via: info@buffl.be.
7. In a changing world, where technology is constantly evolving, we wish to point out that this Privacy Policy may be subject to updates. For this reason, we invite you to regularly consult the latest version of this Privacy Policy online. We will contact you via the Platform or other appropriate communication channels (such as per e-mail) regarding any changes pertaining to this Privacy Policy.
8. Please note that the Platform and the webpages used for the ad hoc Services may contain hyperlinks to other websites or internet resources, through which personal data may be collected (e.g.: via the use of cookies or similar technologies). Buffl is never responsible for these website or internet resources over which it does not exercise control. Examples may be Google Hangouts, Skype, etc, which may be used to conduct interviews.
Buffl is never responsible for the collection, use, and dissemination of your personal data by these third parties. We recommend you to read the privacy policies of these respective third-party websites and internet resources in order to understand how these third parties collect and use your personal data.
9. Buffl is not responsible for the processing of the personal data that you choose to share with the Buffl-Customers in the framework of interviews organised by those Customers, even should the Customer be accompanied by a Buffl employee. The Privacy Policy of the Buffl employee will apply.
10. This Privacy Policy only applies to the processing of personal data of which Buffl can be considered the controller. The circumstances in which Buffl acts as the processor, on behalf of a controller, will be set out further in this Privacy Policy. When Buffl acts as the processor of your personal data, the Privacy Policy of the controller will apply to the processing of your personal data.
1. Your personal data are the data that can be used to directly (such as your name and surname) or indirectly (such as your postal code or telephone number) identify you.
2. Through interactions with you, we can collect different types of information, in accordance with our different services:
* Information (such as your e-mail address, name, company name and telephone number) that you may share with us by filling in the contact form on our website: https://landing.buffl.be/contact/;
* When you present us with your business card during in-person meetings;
* When we conclude an agreement with you as a Customer or service provider;
* Your identification data such as your name, date of birth, functions at your company, marital status, etc, that you may share with us when creating an account or using the Platform, or when taking part in our ad hoc Services, as well as your contact information such as your address, e-mail address, username on social media and telephone number;
* We may additionally get this information when you synchronise your Facebook or Google accounts with our services. Through this synchronisation, we gain access to your public data, your social media profile, and your e-mail address;
* Information that you share with us when completing a Survey, either in written form, or during an interview;
* Technical information, such as the time you took to complete a Survey, or which Surveys you chose to open and complete, as well as your IP-address;
* Your location data may be collected on the basis of your IP-address, GPS function, WIFI-access points or other sensors on your devices;
* Your device information (smartphone type, laptop type, etc.) and the browser you used to access our services;
* Information obtained via cookies. For more information regarding our use of cookies, please refer to our Cookie Policy;
* Contact information obtained via Buffl Customer with the goal of contacting you to take part in an ad hoc Service, organised by Buffl on behalf of the Customer.
3. In certain circumstances it may be possible that we collect personal data that may be considered sensitive under the applicable data protection regulation. This information may relate to (a) information on your health and well-being and (b) information relating to minors. We process this information – due to its sensitive character – with particular attention.
1. Data relating to health and wellbeing
Considering specific surveys, we may process data relating to your health and wellbeing, such as medical diagnoses and your consumption of medicinal substances. The processing of this information shall only take place with your prior explicit consent and only for the particular survey for which it has been collected and for the purposes set out therein. Access to the sensitive personal data will in any case be limited to Buffl-employees and subcontractors that have a need to access the information for the purpose set out at the moment of collection of such data.
2. Data relating to minors
Minors who have not reached the age of thirteen (13) years, may only create an account or use our ad hoc Services with the consent of their parent or legal guardian. The parent(s) or legal guardian of the minor is invited to read this Privacy Policy and the Cookie Policy. The parent(s) or guardian will be able to exercise the rights set out hereinafter on behalf of the minor.
In order to organise what is referenced right above, Buffl will require, via e-mail, that the parent(s) or guardian consent to the use by the minor of the Buffl Platform. Buffl will send an e-mail containing all relevant information, relating to the collection and processing of the personal data of the minor as well as its intended purposes. The e-mail will also declare how the parent(s) or guardian can consent and retreat their consent. If the aforementioned consent is not received by Buffl within a reasonable period, all the personal data relating to the minor and its parent(s) or guardian will be permanently deleted.
Minors older than the age of thirteen (13) can log in to the Platform and make use of our ad hoc Services without the consent of their parent(s) or guardian. However, should a minor decide to make use of our services, we recommend it consult with its parent(s) or guardian in order for it to be able to understand the contents of the Privacy and Cookie Policies. Buffl recommends the parent(s) or guardian to supervise the use of the minor of the Buffl services and to make the minor aware of the use that may be made of the personal data in the context of the Buffl services.
1. Communication tool between innovative businesses and the users
1. General
Buffl uses your personal data for the analysis of market- and satisfaction Surveys. This helps the Buffl Customers to develop innovative goods, services, and marketing strategies. These analyses give us a better idea of your point of view and opinions. The personal data is collected via our Platform or a dedicated website or subdomain for our ad hoc Services. We share your answers from a Survey with our Customers in an anonymised form. The information allows them to spot trends and preferences, which may allow them to better their products and services.
Please note that the Buffl Customers will not be able to link the data we share with them back to you. You will, therefore, never be contacted by a Buffl Customer directly, except with your prior, specific (and additional) consent.
Your consent will be used as our legal basis for the compliant processing of your personal data under this processing purpose.
2. Personal data received from Buffl Customers
In certain special cases, we can receive your personal data from Buffl Customers for the further processing thereof by Buffl. The Buffl Customer will, in that situation, always be considered the controller of your personal data. Buffl will be the processor. The collection and further processing of your personal data will be ruled by the privacy policy of the Buffl Customer, to which you should have accepted to be bound when making use of their services or when buying their product.
Please note that the further processing of the personal data provided by the Buffl Customer for ad hoc Services will take place on the basis of the Buffl Customer’s privacy policy as well. Buffl will in that scenario be acting as the processor of your personal data.
2. Improvement of your user experience and quality control of the Buffl Platform
When using our Platform, we may process technical data that may help us offer and improve the functionalities of our website and applications. When you communicate information on our Platform, such as an image or your location, Buffl will process such information in order to offer you the functionalities of the Platform. In addition, we may track the duration of your active session in order to improve the quality of the Surveys you complete.
We base ourselves on our legitimate interest to optimize our services and limit disruption to the bare minimum as the legal basis for the processing of your personal data for this purpose. In addition, we engage in time-tracking because it allows us to reduce the risk of abuse and fraud during the completion process of the surveys. This helps us to provide our Customer with a high quality of the data we share with them. This can usually only be done by tracking the time it takes to complete a survey.
3. E-marketing
When you create an account or take part in an ad hoc Service, you will receive the option to explicitly agree (opt-in) to receiving our marketing communications, or communications from any Buffl partners (this is done without sharing your personal data with the partners). If you accept, Buffl will be allowed to send you e-newsletters containing information of a commercial nature relating to new products, services, promotions and benefits, an invitation to partake in actions and contests, etc.
Should you wish to no longer receive our newsletters, you can, at any time, revoke your consent by clicking the link shown at the bottom of each marketing communication.
4. Push-notifications
When you consent, during your account registration or by clicking “manage your notifications”, to our use of push-notifications, Buffl will be allowed to send you push-notifications when a new survey, contest, or other relevant product or service becomes available.
You can revoke your consent at any time, by making your revocation of consent clear under the “manage your notifications” tab.
5. Participation to contests
Your personal data will be processed in the context of our organisation and follow-up of actions and contests to which you may participate. The personal data processed relates in particular to your contact data and/or information you chose to share with us when taking part in the action or contest. This will allow us to contact you via email in connection with the price you may have won. Without the processing of these personal data, we would not be able to provide you with our services in the framework of such actions or contests.
For the processing of your personal data for this purpose, we base ourselves on the execution of the agreement you have concluded when participating in the action or contest.
Should you take part in our monthly contests and win the applicable prizes, your chosen username on the Platform may be temporarily shared with other users on the Platform. Your username will be visible to other users visiting the page relating to the monthly contest. The purpose of the publication of your username is to engage other users to participate in the monthly contest.
For the processing of your username, we base ourselves on our legitimate interest to promote certain functionalities of our platform in relation to other users.
6. Profiling
We create general or specific user profiles on the basis of the information that you provide to us – for example, when filling in your profile details, taking part in surveys, filling in standardized questionnaires, or on the basis on certain answers you provide us with when taking part in actions or contests on our platform – and on the basis of the technical information relating to your completion of our surveys, for the following reasons:
* To better answer to your needs and expectations and offer you customised services;
* To decide whether or not you match the criteria related to a particular market research;
* For scientific or market-research purposes, the correlation between the answers given in a certain survey, on the one hand, and the different characteristics – tags – collected in profiling, on the other hand, can be examined. This data is always anonymised and will always be used on a community level, excluding its use at the level of your particular profile. The Buffl Customer receiving such data will therefore never be able to correlate this information back to your person in any way.
We base ourselves on our legitimate interest to improve your user experience, analyse your data, create marketing profiles, and organise marketing studies in order to legally process your personal data for the above purposes.
Please note that our profiling will never be used in order to make automated decisions that might negatively impact you.
In accordance with the data protection legislation, you have a right of access, correction, deletion, and portability of your personal data. In certain cases, you also have a right to object to the processing of your personal data or to ask us to restrict our processing. These rights can be exercised at any time and are free of charge.
1. General rights
* Right of access: You have the right to receive access to the personal data relating to you and to receive a copy thereof. This access allows you to check what personal data we collect and process about you.
* Right to rectification: We take the necessary measures so that the personal data we collect is up-to-date and that the personal data that proves to be incorrect or is no longer necessary is removed. We encourage you to regularly open your account (if applicable) and to check the personal data stored on the Platform in order to make certain that these data remain up-to-date. Should you establish that the information is wrong or should be updated, you have the right to ask us to correct it. You will also have the possibility to do this yourself by managing your profile in clicking the “profile” button on the Platform.
* Right to erasure (“right to be forgotten”): In some circumstances (e.g.: when you revoke your consent or when we no longer require the personal data for the purposes set out above) you have the right to ask us to remove the personal data we process about you. Linked to this, you have the right to ask us to remove your account. Please note that removal of your account will not necessarily mean that all your personal information we hold on you will be automatically deleted.
Deletion of your personal data will happen in accordance with the terms of article 8 of this Privacy Policy.
* Right to restrict our processing: You can ask us to restrict our processing of your personal data. This means that your personal data will no longer be processed for the restricted purposes. Please note that your information may still be kept by us when our processing is restricted.
* Right to data portability: You have the right to obtain the personal data you provided to us in a structured and machine-readable format or to have us send the data to another controller of personal data.
* Right to object to our processing: When the processing of your personal data is based on our legitimate interest, you have the right to, at any time, object to our processing. However, please note that we have the right to provide you with our legitimate reasons to continue our processing.
You always retain the right to, free of charge, object to the processing of your personal data for the purpose of direct marketing. We will not be able to oppose such objection. Your right to object additionally includes your right to object to our profiling, should it be linked with our direct marketing purposes.
Should you wish to exercise any of the above rights, please send your request to info@buffl.be.
2. Revocation of consent
Where our processing of your personal data should be based on your consent, you can revoke such consent at any time. The revocation will not impact the validity of the processing of your personal data before the revocation.
In the context of direct marketing, this means that you can unsubscribe from our newsletters and other commercial communications sent out by Buffl. This means that you would be placed on the “opt-out” list. You can unsubscribe by clicking the link at the bottom of each e-mail, or by sending us an e-mail to info@buffl.be.
Please note that this revocation against receiving direct marketing communications only applies to the specific e-mail address. If you receive commercial communications to multiple e-mail addresses, you will have to revoke your consent for each of those addresses and accounts or by clicking the link below in the particular e-mail. The previous should nevertheless never take place, considering that the Terms of Use do not allow you to create multiple user accounts.
1. Buffl supports its Customers in the analysis of its market- and satisfaction research and the development of its marketing strategies. The results of the surveys are shared with the Buffl Customers. Buffl will, however, only share your personal data in anonymised form. This means that no personal data, meaning information that directly or indirectly identifies you, will be shared. This means that, in general, no third party will be able to contact you directly. Buffl only shares non-personal demographic information with its Customers. This allows the Customers to receive insights in the different target groups to which you may belong. No personal data will be shared.
2. For the management of our company and in order to provide you with certain products and/or services, we engage specialised partners that act as our subcontractors and in relation to which we have a contractual bond. They act on our instructions and treat the personal data they receive from us confidentially. They are not allowed to use the personal data for any other purpose than the execution of their obligations in relation to us.
Buffl ensures that the subcontractors:
* Only have access to the information that is strictly necessary for the execution of their tasks; and are bound in relation to Buffl to process the personal data in a safe and confidential manner, and to only use the personal data for the execution of their tasks.
3. Should Buffl - become involved in a merger, sale of assets, financing, liquidation, or bankruptcy, or if part all of our business is sold to another company, we may share your personal data with that company before and after the transaction closes. The company involved will always be bound by an obligation of confidentiality with respect to your personal data.
4. We may share your personal data with judicial authorities, administrative authorities, or other bodies, or to third parties if this should be necessary and/or desirable in order to comply with legal and/or regulatory obligations or for the aforementioned purposes.
5. Other users of our services may see the username of the user winning the monthly contest, as set out in article 3.4. of the Privacy Policy.
1. Buffl takes the necessary precautions to guarantee the confidentiality and safety of your personal data as best as possible. Buffl has implemented the necessary technical and organisational measures in order to protect the personal data against accidental or illegal destruction, accidental loss, damage, modification, disclosure, or unauthorised access, as well as other forms of unlawful processing (including, but not limited to unnecessary collection) or further processing. Examples of the measures taken include but are not limited to IT security policies, staff training, secure servers, and the encryption of your personal data.
1. Buffl does not transfer your personal data to countries outside the European Economic Area that do not guarantee an essentially equivalent level of data protection.
1. Your personal data will only be processed for as long as they may be required for the purposes set out under article 3, or when we asked for your consent, until the moment you revoke it. In this article, we provide you with the information that you require for the analysis of the duration of our storage of your personal data.
2. As a general rule, we de-identify or delete your personal data when it is no longer required for the above purposes, or when the storage term, as described in this article, has been reached. However, we cannot delete your personal data if a legal or administrative obligation, or a legal or administrative order prevents us from deleting it.
3. All personal data that we collect from our interactions on the Platform, social media, phone calls, e-mails, and other digital means of communication, will only be kept for as long as they may be required for our communication, but also for the management of our historical archives of our communications. This helps us revert back to you regarding earlier communications when you reach out to us with new questions, requests, comments, or other input.
4. All personal data collected by us for the purpose of our newsletter, will be kept only for as long as you remain subscribed to our mailing-list or for as long as you remain our Customer.
5. All personal data collected when you hand us your business card will be kept for as long as you do not request us to delete your personal data.
6. All personal data that we collect in the context of our contractual relationship with you or your organisation will be kept for the duration of our contractual relationship or at least until seven (7) years after its termination.
Should you consider that the applicable data protection legislation has been infringed, then you have the right to file a complaint with the competent data protection authority, generally being the:
Belgian Data Protection Authority
Drukpersstraat 35 1000 Brussel
Tel.: +32 2 274 48 00
e-mail: contact@apd-gba.be
Regardless of whether you have an account or are just visiting our Platform, when you make use of our Platform, we may place cookies on your device. A cookie is a small text file that our server sends to your computer, tablet, or smartphone. The cookie is used to identify your device and may collect certain personal data.
We use different types of cookies:
* "Strictly necessary cookies" and "functional cookies": these identify, for example, your country and the language you choose to use in order to make the use of our website as simple and pleasant as possible for you;
* "Performance cookies": these allow us to collect visitor statistics from our site to make it even more user-friendly and to propose content that better meets your needs;
* "Commercial cookies": these allow us to present you with offers adapted to your areas of interest. However, this type of "cookie" will only be stored on your computer if you have specifically agreed to it.
You may refuse the storage of "cookies" on your computer, but such refusal may cause reduced functionality, delays or even prevent access to some services on the Platform.
For more information on "cookies", please read our Cookie Statement.
