Privacy Statement Mediafin NV

Trustmedia-Bepublic Group (B2B)

Last updated: 13/10/2020

1. Introduction and scope

Mediafin NV with registered office at Havenlaan 86C box 309, 1000 Brussels, company number 0404.800.301 (hereinafter “Mediafin”, “we” or “us”), acts as controller for the processing of personal data in the context of its advertising management (hereinafter “Trustmedia-Bepublic Group”) and in particular when providing certain B2B Services as described below.

Explanation of the scope – This privacy statement for Mediafin’s Trustmedia-Bepublic Group (hereinafter “Privacy Statement”) applies specifically when Trustmedia-Bepublic Group manages, operates and commercializes advertising space in newspapers, magazines, on websites, (mobile) applications, events, mailings, products and services offered by Mediafin (hereinafter referred to as “Services”), or from a third party for whom Trustmedia-Bepublic Group acts as external management, and where these Services are offered to professional customers / B2B (hereinafter “you” Or ” your“).

Since Mediafin also acts as a controller in the context of providing services to end users/ readers of its services, we also refer to Mediafin privacy statement for De Tijd/ L’Echo for completeness.

Please consult the privacy statement that applies to you.

Please read this privacy statement to learn more about what personal data we process, for what purposes and what your rights are in this regard.

2. Applicable Privacy Law

Mediafin undertakes to process and protect your personal data in accordance with the applicable legislation on the protection of personal data, in particular Regulation 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 regarding the free movement of such data and repealing Directive 95/46 EC (“GDPR”) as well as national or international law or regulation which introduces or supplements the General Data Protection Regulation and any other applicable data protection legislation (hereinafter jointly “Applicable privacy legislation”).

For the purposes of this statement, terms such as “personal data”, “controller”, “processing”, “data subject” have the meanings given to them in the Applicable privacy legislation.

3. Entities within the Mediafin Trustmedia-Bepublic Group
The following entities are part of Mediafin Trustmedia-Bepublic Group:

• Trustmedia Beyond Advertising
• Content Republic
• Comfidens
• News Services
• Befirm
• Bereal
• Bepublic

4. Categories of personal data, purposes and legal basis for the processing

Categories of personal data	Purposes of the processing	Legal basis
Identification data and (electronic) contact details (name, first name, email address, telephone number, billing information)	Use of personal data for billing purposes Trustmedia-Bepublic Group	Necessity for performance of the agreement
Identification data and (electronic) contact details (if applicable, name, first name, email address, telephone number)	Setup and maintenance, including prevention and resolution of problems of the Services of Trustmedia-Bepublic Group (e.g. Publishing an advertisement, providing a communication service)	Necessity for performance of the agreement
Identification data and (electronic) contact details (name, first name, e-mail address, telephone number)	To answer questions about support or information related to Mediafin NV or Services	Necessity for performance of the agreement
Identification data and (electronic) contact details, gender, company, function and language	Participation in Trustmedia-Bepublic Group events	Necessity for performance of the agreement
Electronic contact details, identification details, gender, company and position	Mailings Trustmedia-Bepublic Group: Informing by email or telephone about advertisements or promotions	Legitimate interest of Mediafin in the context of Trustmedia-Bepublic Group
Identification data and (electronic) contact details (name, first name, e-mail address, telephone number)	Customer management for Trustmedia-Bepublic Group.	Legitimate interest of Mediafin in the context of Trustmedia-Bepublic Group
	Better understanding the Services Mediafin offers through Trustmedia-Bepublic Group, improve them and identify general trends.	Legitimate interest of Mediafin in the context of Trustmedia-Bepublic Group
	To get to know you better across the Services	Legitimate interest of Mediafin in the context of Trustmedia-Bepublic Group
	To keep you informed of advertising related to Trustmedia-Bepublic Group’s own similar products and services	Legitimate interest of Mediafin in the context of Trustmedia-Bepublic Group
	Improve security and prevent and detect abuse or fraud.	Legitimate interest of Mediafin in the context of Trustmedia-Bepublic Group
	Protect Mediafin’s rights and property (enforcement of Privacy Statement, Cookie Statement and Terms of Use).	Legitimate interest of Mediafin in the context of Trustmedia-Bepublic Group
E-mail address	Sending newsletters Trustmedia-Bepublic Group	Consent
E-mail address	To keep you informed of advertising related to non-similar products and services of Trustmedia-Bepublic Group or products and services of third parties.	Consent
Customer identification data (name, first name, email address, telephone number)	Passing on data to third parties outside of Mediafin for marketing purposes.	Consent

If the processing or the provision of personal data as described above is a legal or contractual obligation or a necessary condition for entering into an agreement, a refusal to communicate the personal data may prevent us from entering into an agreement with you and / or providing the Service.

Processing of personal data by using cookies

Mediafin can also collect and process personal data by using cookies on the Trustmedia-Bepublic Group website. We process personal data collected in the context of “strictly necessary cookies” on the basis of our legitimate interest. In other cases (i.e. “not strictly necessary cookies”), we ask your permission before placing these cookies and processing your personal data in this context. For more information on this, please read our Cookie Statement.

5. With who do we share your personal data?

The personal data are processed by Mediafin via Trustmedia-Bepublic Group and can be shared with:

• Entities within Mediafin: We can share your personal data with other entities within Mediafin.
• Suppliers: Personal data may be transferred to other companies, intermediaries or service providers (“Suppliers”) to perform certain services on our behalf. For example, Mediafin uses Suppliers to deliver marketing, communications, infrastructure and IT services, to process market research results. By default, we only let our suppliers process your personal data insofar as this is necessary for the delivery of their services.
• Business Transfers: We reserve the right to transfer data, including personal data, in connection with any restructuring, merger, sale, or other transfer of company assets, provided that the receiving party agrees to process your personal data in accordance with this Privacy statement.
• Authorities: We may also share or transfer personal information, including the content of your communication:

O To comply with the law or to respond to legal process or requests, including law enforcement and government agencies;

O To detect, prevent or otherwise address fraud and technical security vulnerabilities; or

O To protect and safeguard Mediafin’s rights, including the enforcement of our terms of use.

• Furthermore, Mediafin will not provide your data to other third parties without your prior permission, unless Mediafin is obliged to do so on the basis of a legal provision or a court decision or if this is justified in the context of its legitimate interests.

6. How are your personal data secured?

We are committed to protecting the security of your data. We use a variety of security technologies and procedures to appropriately protect your information from unauthorized access, use or disclosure. For example, we store personal data on computer systems that have limited access and are housed in secure buildings.

7.How long do we keep your personal data?

Mediafin does not keep the personal data longer than necessary depending on the purposes for which it is collected (see Title 4 above). In certain cases, however, Mediafin is legally obliged to keep your personal data longer or the retention period is in the context of the legitimate interests of Mediafin.

After the expiry of the retention period, Mediafin deletes or anonymizes the personal data. If the deletion or anonymization is not possible, Mediafin will separate the personal data from further processing until deletion or anonymization is possible.

For more information about the retention period that applies to your personal data, please contact Mediafin via privacy@mediafin.be.

8. What are your rights?

If applicable and in accordance with Applicable privacy legislation, you have the following rights in connection with the processing of your personal data by Mediafin via Trustmedia-Bepublic Group:

• Right of access to your personal data:

You have the right to receive information about whether or not personal data are processed about you, and where this is the case to access it and to obtain a copy.

• Right to correct your personal data:    
  You have the right to have incomplete, incorrect or outdated personal data removed or corrected.     
• Right to erasure of your personal data:           
  You have the right to obtain erasure of the personal data concerning you in certain cases. For example, when the use of your personal data is based on consent and you have withdrawn your consent, when this personal data must be deleted due to a legal obligation or when the personal data has been processed incorrectly.
• Right to restrict the processing of your personal data:

You have the right to restrict the processing of the personal data concerning you in certain cases. This can be, for example, if you do not think the personal data is correct and this during the period that we need to check the accuracy of this personal data or when the processing is unlawful but you do not want the personal data to be erased.         

• Right to object to the processing of your personal data:       
  You have the right to object to the processing of your personal data in certain cases, for example when the processing is based on our legitimate interest.

• Right to portability of your personal data:      
  You have the right in certain cases to obtain the personal data concerning you, which you yourself have provided to Mediafin, in a structured, common and machine-readable form, and to transfer this to another controller.          
• Right to withdraw consent at any time:

Insofar as the processing is based on consent, you have the right to withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of any processing that we performed prior to the withdrawal or processing of your personal data that is performed on lawful grounds other than your consent.

• Right to object to the processing of your personal data for direct marketing purposes:

You can exercise this right by clicking on the “unsubscribe” link in the marketing emails we send you. Please contact us at privacy@mediafin.be. to unsubscribe from other forms of marketing.    

• Right to lodge a complaint with a data protection authority:

If you have a complaint or are concerned with how we process your personal data, we will endeavor to resolve these concerns. If you believe that we have not addressed your complaint or concern adequately, you have the right to complain to a supervisory authority about our collection and use of your personal data. For more information, please contact the supervisory authority.

If you wish to exercise your rights, you may contact Mediafin at privacy@mediafin.be.

We will handle and respond to your request in accordance with Applicable Privacy Laws.

You have the right to lodge a complaint with a supervisory authority, for this you can contact the Belgian Data Protection Authority. 

By mail:           Drukpersstraat 35, 1000 Brussel.     
By phone:       +32 (0)2 274 48 00    
Via email:        contact@apd-gba.be

9. Changes to the privacy statement
Mediafin reserves the right to change this Privacy Statement at any time. We will notify you of these changes, taking into account their importance and our legal obligations in this regard. In any case, we recommend that you consult this Privacy Statement regularly, so that you are aware of any changes and that you always know how your personal data can be used.

10. Contact

If you have a question about this Privacy Statement, you can contact us in the following way:

By post:           Mediafin NV, Havenlaan 86C bus 309, 1000 Brussel           
Via email:        privacy@mediafin.be

By phone:       +32 (0)2 423 16 11    

11. Applicable law territorial jurisdiction  

Belgian law applies to this Privacy Policy. Disputes regarding this privacy statement fall under the exclusive competence of the Dutch-speaking courts and tribunals in Brussels.