Information about the processing of personal data

General

In the context of your use of the MyTrace app and the related websites owned by ENERGY NV, you will provide us with some personal details.

In the case of publicly organized events, so-called “leaderboards” may be displayed on the MyTrace website, which may be viewed by visitors of the website. These leaderboards may contain rankings in order to increase the user experience within the app and of all participations. Via the MyTrace app you will be able to register your running activities and these can be shared in the app rankings and on the MyTrace website or, in the case of public events, on other ENERGY NV and events-specific media.

In the case of private events that are organized for the employees and invitees of a company, the participant information and results will be communicated to that company, with the purpose of internal communication within that company.

Who processes your data?

Your personal data will be processed by ENERGY NV, a company incorporated under Belgian law, with registered office at Schoebroekstraat8, 3583 8, 3583  Beringen, registered at the Belgian Crossroads Bank for Enterprises under n ° 0872.287.544, and with email address privacy@energylab.be, as data controller.

Which data do we process?

1. The details you enter:

  • Your general personal details such as name, first name, date of birth, gender, chosen communication language,…;
  • your login and password when you create an account;
  • Contact information such as e-mail, address,…;
  • General physical characteristics such as weight,…;

2. Data generated by using the App:

  • Data that can be related to physical condition such as heart rate at rest, maximum heart rate, BMI, …
  • Activity data including distance, duration, speed, GPS location data and this as data throughout the time of your activity.

3. If you make purchases, the data related to these purchases.

Purpose of the processing of your personal data

We process your data to make the use of the App and/or website possible.

We also process your data to send you information that may be of interest to you.

More specifically, we use your data to:

PurposeLegal basis
To allow you to use the app and the website, among other things to give you the opportunity to take part in the MyTrace virtual events, competitions, challenges, prize draws and to collect the prizes that you can win.This is necessary for the use of the app and the website (article 6.1.b) GDPR)
To send you our newsletter if you have actively and explicitly requested to receive this newsletter; if you are already included in our mailing list to receive newsletters, we may use your data to send marketing and other material related to ENERGY NV, its products and/or services.Your consent: you have registered for this in our app (institutions) (Article 6.1.a) GDPR). You have the right to unsubscribe at any time by clicking the unsubscribe link for this purpose, at the bottom of each promotional email message
To communicate with you (for e.g. via push notifications in the MyTrace app) about the evolution of your participation in MyTrace virtual events and about virtual events in general; this may include: communication about challenges and joint participation in events, as well as communication about other activities, workshops, etc. as part of the event (participation to some activities may be subject to specific conditions, including conditions regarding the way your personal data will be processed in the context of these activities: we advise you to read these conditions carefully).This is necessary for the management of the virtual event to which you participate, and for the use of the app and the website (article 6.1.b) GDPR).
In the case of public events: to use your pictures, audiovisual material and testimonies etc in the framework of the events and on the MyTrace website, and for internal communication of Energy NV;

In the case of private events that are organized for the employees and invitees of a company, the aforementioned data will only be shared with that company, with the purpose of internal communication within that company.
This is necessary for the management of virtual events to which you participate (artikel 6.1.b) GDPR) and may also be necessary for our legitimate interests (article 6.1.f) GDPR) and more specifically to communicate about the virtual events and participation in these events via the MyTrace website and to publicize the existence of the virtual events within its organisation and to the outside world.
  
To personalize your use of the website and the app which means a functional personalization (e.g. ‘timeline’ review after the event of photos taken, users’ performance).This is necessary for the use of the app and the website (article 6.1.b) GDPR)
To manage our infrastructure and business policies, and comply with internal policies and procedures, including those regarding control, finance and accounting, billing and debt collection, IT systems, data and website hosting, business continuity, and management of archives, documents and prints; For example, when purchasing lessons packages, your data will be processed to make the purchase and delivery possible.This is necessary for the use of the app and the website (article 6.1.b) GDPR) and may also be necessary for our legitimate interests (article 6.1.f) GDPR) and more specifically to (i) manage our infrastructures and (ii) monitor compliance with our internal policies as well as the security of our network.
To communicate with you regarding the events and to communicate with you if you send us messages and handling complaints and requests for access or correction of data;  This may be necessary for the management of the use of the website and the app (article 6.1.b) GDPR) but also for compliance with legal obligations (article 6.1.c) GDPR). This is also necessary for our legitimate interests: improving our services benefits everyone: both us and you (Article 6.1.f) GDPR).
To conduct market research and analysis, such as satisfaction surveys;  This is necessary for our legitimate interests: to know our services better and to improve them (Article 6.1.f) GDPR).
To comply with applicable laws and regulatory obligations (including regulations that are not those of the country where you live), such as laws relating to anti-money laundering and anti-terrorism; to comply with legal proceedings; to respond to requests from governments (including governments of countries other than the country where you live);  This may be necessary to comply with legal obligations (Article 6.1.c) GDPR).
To establish or defend our rights; to protect our activities or those of companies belonging to the same group or partners; to protect our (or your) rights, privacy, security or property, and / or those of the companies belonging to the same group; and to use the available remedies or limit our damage;This may be necessary to comply with legal obligations (article 6.1.c) GDPR) or be necessary for our legitimate interests (article 6.1.f) GDPR) and more specifically to defend our rights in case of complaints or disputes with you or with third parties.
To provide you with important information regarding changes to our policies, general terms and conditions, the website, a mobile application and other administrative information.  This may be necessary for the use of the website and the app (article 6.1.b) GDPR) but also for compliance with legal obligations (article 6.1.c) GDPR).

Sharing of personal data with third parties

ENERGY NV may share your personal data with other companies of the Golazo Group. However, they will only use your data in accordance with the objectives set out above.

In certain cases, your data may be disclosed to third parties who provide services to us or who provide services in our name and on our behalf (ICT providers [Next Apps] and cloud providers [Amazon Web Services]). Furthermore, ENERGY NV will not disclose your data to other third parties without your prior consent, unless we have a legitimate interest or are obliged to do so on the basis of a legal provision or judicial ruling. In any case, we undertake to ensure the confidentiality of your data, in particular by concluding appropriate contracts with third parties.

Processors and transfers to countries outside the European Union

For the processing of your personal data we sometimes use third parties that operate outside the European Union (email solution providers [SendGrid]). In so far as your data are forwarded to countries outside the European Union that do not provide an adequate level of protection to your data, we have ensured that the companies to which your data are forwarded offer an adequate level of protection. More specifically, we have concluded “Standard Contractual Clauses ” (SCC) with them, or these companies are certified under the “Privacy Shield” program with the United States of America. For more information about these measures send an e-mail to privacy@energylab.be .

Retention period

ENERGY will retain the Personal Information as long as necessary to achieve the purposes set out above unless a longer retention period (i) is required to cover our liability, or (ii) required by law or permitted.

Your rights to your personal data

You have the right to access and correct your personal data as well as the right to oppose to their use for direct marketing purposes, free of charge. You also have the right in certain circumstances to oppose to the use of it or to request the deletion of your personal data and the right to request a limitation of processing as well as the right to request the transfer of your data, as provided for in articles 15 to 20 of the GDPR (General Data Processing Regulation); you have also the right to revoke your consent to the processing of personal data relating to your health at any time (in which case you will not be able to use the app any longer).

If you want to exercise your rights, or if you have questions or comments, send an email to our DPO via privacy@energylab.be.

We would like to point out that some personal data may be excluded from the right of access, correction, objection, or deletion, in accordance with applicable law.

Complaints

If you are not satisfied with our processing of personal data and if you believe that contacting us will not solve the problem, the law gives you the right om to file a complaint with the competent supervisory authority.