How does Ypto process your personal data?

We understand that your privacy matters to you, which is why we do our best to respect it. We would like to start by reassuring you that your personal data will only be used by Ypto S.A. (rue des Deux Gares 84 A, 1070 Brussels). We do not provide your personal data to third parties that want to use them to recommend you their own products or services. Below you can read in detail how we use your data.

When you decide to provide us with your personal data, you acknowledge that you have read this policy.

What data we use, what we use it for and how long we keep it is determined by the reason for which we process the data. More information about this can be found below.

Phone call or contact via the website or via e-mail with a question or complaint

In order for us to be able to process your question or complaint, we collect and process the following personal data:

  • last name, first name
  • phone number or (e-mail) address

In principle, we process at least your last name and your first name. In order to provide you with our reply to your question or comment, we also collect the address at which we can contact you (postal address or e-mail), or your phone number.

Other data

If the specific nature of your question or comment requires it and if we need additional personal data, or if you provide it to us voluntarily, we will use this data.

For which purposes do we use your data?

We use your data to process your question or comment. Without this data, we cannot evaluate your question or comment.

We also process your data in order to continuously improve our services, carry out market research, prevent fraud and develop new products. It is possible that your data will be processed in the context of internal audit activities. These activities stem from Ypto’s legitimate interest. As such, we will always ensure that your interests are given at least as much attention as those of Ypto at all times.

With whom may we share your data?

We may share your personal data with other natural or legal persons who act as subcontractors for Ypto. In that case, they only have access to the data they need to perform their task.

In addition, we may be required to provide your information to competent authorities.

In principle, we only share your personal data with natural or legal persons who are located in a country that offers a level of protection for personal data that is at least equal to the one you enjoy in Belgium. Should we deviate from this rule, we would notify you and request your permission beforehand.

How long do we keep your data?

If we do not need your personal data for processing tasks that require a longer retention period, the above-mentioned data will be kept up to 12 months after your application has been processed.

Application

To process your application and, where appropriate, inform you of any vacancies at Ypto and events that are organised in that context, we process the following personal data:

  • last name, first name
  • phone number
  • e-mail address
  • CV
  • if applicable, a covering letter

If Ypto becomes your employer, this data will be collected/used to complete the recruitment process.

We process this data in order to be able to send you surveys, if applicable.

For which purposes do we use your data?

Your personal data is used to process your application.

These activities stem from Ypto’s legitimate interest. As such, we will always ensure that your interests are given at least as much attention as those of Ypto at all times.

With whom may we share your data?

We may share your personal data with other natural or legal persons who act as subcontractors for Ypto. In that case, they only have access to the data they need to perform their task.

In principle, we only share your personal data with natural or legal persons who are located in a country that offers a level of protection for personal data that is at least equal to the one you enjoy in Belgium. Should we deviate from this rule, we would notify you and request your permission beforehand.

How long do we keep your data?

If your application is unsuccessful, your contact details and CV will be deleted at the latest one year after the application date. This way, we can contact you for another opportunity. Of course, you can have your data deleted sooner, unless we are obliged to keep it for a longer period.

As a supplier or professional customer of Ypto or as a contact person of a supplier or professional customer of Ypto

If you as a physical person are a supplier or professional customer of ours or if you act as a contact person for a supplier or professional customer of ours, we collect and process the following personal data:

  • last name, first name and address
  • phone number or e-mail address

In principle, we process at least your last name and your first name. In order for us to be able to contact you, we process your phone number and e-mail address.

Results of a credit analysis and personal data included in such an analysis.

In order to be able to accept you as a supplier, we are sometimes obliged to carry out credit analyses.

For which purposes do we use your data?

We use your data in order to execute the contract with you or with the supplier or professional customer you represent. We also use it to provide important information to you, including commercial information that is necessary for the execution of the contract.

We also process your data in order to continuously improve our services, carry out market research, prevent fraud and develop new products. It is possible that your data will be processed in the context of internal audit activities. These activities stem from Ypto’s legitimate interest. As such, we will always ensure that your interests are given at least as much attention as those of Ypto at all times.

With whom may we share your data?

We may share your personal data with other natural or legal persons who act as subcontractors for Ypto. In that case, they only have access to the data they need to perform their task.

In addition, we may be required to provide your information to competent authorities.

In principle, we only share your personal data with natural or legal persons who are located in a country that offers a level of protection for personal data that is at least equal to the one you enjoy in Belgium. Should we deviate from this rule, we would notify you and request your permission beforehand.

How long do we keep your data?

If we do not need your personal data for a processing that requires a longer retention period, we will retain your personal data for the duration of the contract with you as a professional customer or supplier or with the professional customer or supplier for whom you are the contact person, plus one year.

Visit to Ypto’s office or premises

If you, as a physical person, visit our office or premises, we collect and process the following personal data:

  • last name, first name and e-mail address
  • phone number, if available

For which purposes do we use your data?

We use your data to track who is in our offices in the event of an incident or disaster. We also use your data to inform the relevant contact person of your visit.

With whom may we share your data?

We may share your personal data with other natural or legal persons who act as subcontractors for Ypto. In that case, they only have access to the data they need to perform their task.

In addition, we may be required to provide your information to competent authorities.

In principle, we only share your personal data with natural or legal persons who are located in a country that offers a level of protection for personal data that is at least equal to the one you enjoy in Belgium. Should we deviate from this rule, we would notify you and request your permission beforehand.

How long do we keep your data?

We will retain your personal data for the duration of your visit and for a maximum of one week after your visit.

(Regular) visit to the Ypto website

When you visit our website, you provide Ypto with certain personal data.

  • Scope

Please read this section of our privacy policy to find out more about how we collect and process your personal data on our website (in particular www.ypto.be).

  • Collection, processing and purpose of personal data on the website

During each visit to the website, various personal data and log files about you are collected, namely your IP address, the website from which you are redirected to our website, the date and duration of your visit, the browser and operating system you are using, your browsing behaviour and, in particular, the pages you visit.

We use this data solely for statistical purposes and in order to analyse and optimise the functioning and use of the website. To that end, we call upon the services of third parties to which this data is communicated for these purposes.

If your visit is not limited to general information gathering, in particular when you contact Ypto via the website or agree to receive certain information about our products and services, additional data is requested and/or collected, including your name, e-mail address and possibly your phone number.

We use this data to process and respond to your question, message or request.

  • Cookies

The website uses “cookies”, which are small information files that are saved temporarily or permanently on your computer or device by a website’s server via the browser, and which simplify, complete and customise the use of the website.

In your browser, you can deactivate the storage of cookies or remove any stored cookies but this may lead to reduced functionality, a slowdown in the service or the inability to use certain parts of the website.

For further information about cookies and how to remove them according to the type of browser used, we refer you to the following website: www.allaboutcookies.org.

We use the following cookies:

  • Strictly necessary cookies

These cookies enable you to consult a website, to use the functions on the website and to obtain access to secured or registered parts. If the use of these cookies is deactivated, you may not be able to use certain parts of the website correctly.

  • Functional cookies

These cookies enable us to remember your choices and preferences (such as language choice), to enhance the user-friendliness of the website and to show you relevant information.

  • Analytical cookies

These cookies are aimed at collecting information about the way you use the website, such as information on the visited pages or the number of error messages shown, in order to analyse and optimise the use of the website.

It is possible that the information resulting from the use of these cookies is collected by a third party. In order to provide Ypto with information to improve its website and services, those third parties act as a subcontractor for Ypto. Below you will find information about these third parties and the way they use the information collected through cookies.

Google Analytics

The website uses Google Analytics. This web analysis service, offered by Google Inc. (“Google”), uses analytical cookies. The information on a visitor’s use of a website collected through cookies is sent to Google, along with the visitor’s IP address, and is stored by Google.

Google can use that information to do the following:

  1. provide advertisers and websites that host advertisements with reports on their advertising activity and making sure that those website publishers are being paid
  2. help website and app owners who use Google Analytics to understand how visitors use their sites or apps
  3. detect and combat fraud and other security risks to protect users and partners, comply with its legal obligations and improve its products
  4. For all those activities, excepting point 2, Google acts as a data controller. The data regarding your use of the website that is collected by Google is therefore processed on Google’s responsibility.

How can you control which information is sent to Google?

You will find below different ways in which you can manage the information shared by your web browser when you visit the website:

  1. If you do not want Google Analytics to be used in your browser, you can install the browser add-on for Google Analytics. More information on Google Analytics and privacy.
  2. If you are logged in to your Google account, you can consult and modify some of the data Google collects about the sites and applications you have visited, depending on your account settings.
  3. The incognito mode in Chrome allows you to browse the internet without storing web pages and files in your browser history. The cookies are deleted once you have closed all incognito windows and tabs. Your bookmarks and settings are stored until you delete them.
  4. The advertisement settings allow you to manage which Google advertisements are displayed on the internet. You can discover how advertisements are selected for you, deactivate customised advertisements and block specific advertisers. More information about advertisements.
  • Advertising cookies

These cookies we use are aimed at offering you personalised and more relevant advertisements, at deciding how many times a certain ad has been shown, at calculating the effectiveness of an advertising campaign, at storing data on a previous visit and at sharing the collected data with the third parties involved, such as the advertisers. They are used on the website and placed on your device by third parties such as companies linked to Ypto and advertisers who are part of the website’s publicity network.

On what basis do we process your data?

In most cases, we will process your data in order to execute the existing contract between Ypto and you.

In addition, in certain cases we are legally obliged to process your personal data.

Besides, a number of data processing operations are in the legitimate economic interest of Ypto. Examples include combating fraud and conducting market surveys. In this respect, we always check whether your interests with regard to the protection of your privacy and your rights with regard to your personal data do not conflict with those of Ypto. If that is effectively the case, Ypto cannot process this data or has to modify the processing in order to protect your interests as well.

Finally, we will carry out a number of processing operations based on your consent. This is the case, for example, for electronic direct marketing and the processing of specific categories of personal data, such as the taking of photographs. In the majority of cases, this consent will be evidenced by an unequivocal action on your part (for example, by you providing your personal data to us or to a photographer who asks for your explicit consent to take your picture). You can withdraw your consent at any time. However, the data processing carried out before you withdrew your consent remains valid and justified.

How long do we keep your data?

Where the law imposes a minimum retention period, we are always obliged to retain your data for at least the period in question. Beyond this minimum retention period and if the law does not specify a retention period, when determining the period, we have considered your interests and those of Ypto, so that Ypto’s interests never outweigh yours, as well as the speed at which data ages and the reasons why your data is processed.

If we process your data for different reasons, the longest retention period will always be applied. The possibility for the relevant Ypto services to make use of your personal data will, however, be determined by the specific retention period that applies to that service: if the retention period has expired for the service in question, they will no longer be able to make use of your data.

After the expiry of this period, your data will be removed from our databases or will be anonymised so that it can no longer be linked to you.

You will find above more information about the exact retention period of your data, in the section on information for the specific processing of your data.

How can we help you with your personal data?

  1. You can object to the use of your personal data for direct marketing purposes.

You can object at any time and free of charge to the processing of your data for direct marketing purposes. This applies both to the usual processing and the profiling used in direct marketing.

  1. You can receive an overview of the personal data that regards you and that we process.

You have the right to consult the personal data that regards you and that we process.

This overview can help you to determine whether you also want to exercise your other rights (for example, your right to amend your data).

  1. You can ask us to amend or supplement your personal data.

If you notice that the personal data we hold on you is incorrect or incomplete, you may ask us to amend or supplement it. The latter may be useful if, for example, consequences are attached to the personal data.

  1. You can ask us to delete some of your personal data.

On the basis of the privacy rules, you have the right to ask us to delete certain data. This is only possible if this data is no longer necessary to achieve a particular purpose.

  1. You may ask us to receive your personal data in an electronically readable format to provide it to another organisation or company.

On the basis of the privacy rules, you have the right to the portability of your data. You can therefore request to receive in an electronically readable format all the personal data that you have provided to us.

  1. You may withdraw your consent to the processing of your data.

If the processing is based on your consent, you may withdraw it at any time. Depending on the moment when you withdraw your consent, this may result in us no longer being able to provide certain items to you.

  1. You may request that the processing of your data be restricted to specific purposes.

The privacy rules give you the right to ask us to restrict the processing of your data to specific purposes. However, it will not always be possible for us to comply with this request, for example when we are legally obliged to process your personal data.

How to do that?

You can object to the use of your data for direct marketing purposes by clicking on the “Unsubscribe” button, which you will find in all direct marketing material.

Alternatively, you may send a written request with proof of your identity to Ypto – Privacy, Rue des Deux Gares 84 A, 1070 Brussels or to dpo-ypto@belgiantrain.be.

How do we secure your data?

We have appointed a Data Protection Officer who advises us on the privacy rules and monitors Ypto’s compliance with the privacy rules.

In addition, we ensure that only the individuals who actually need to process your personal data for their professional activities within Ypto have access to your data.

For all important existing processes and all new processing activities, we carry out a Privacy Impact Assessment in which, with the help of our Data Protection Officer (DPO), we check whether the privacy rules are being complied with and whether your personal data is always sufficiently protected. If these assessments lead to points of improvement for us, these will be closely monitored and a solution will have to be found before the data processing begins.

We commit ourselves to take all the appropriate technical and organisational measures needed to protect your personal data from destruction, loss, involuntary modifications, deterioration or disclosure. In order to guarantee this security, we carry out regular back-ups, among other things.

Contact details

Ypto, a public limited company, (registered office) Rue des Deux Gares 84 A 1070 Brussels, RPR Brussels: BE 0821.220.410.

Ypto is responsible for processing this personal data and ensures its confidentiality and security.

You can contact Ypto’s Data Protection Office and Data Protection Officer by writing to Ypto – Privacy, Rue des Deux Gares 84 A, 1070 Brussels or sending an e-mail to dpo-ypto@belgiantrain.be.

If you are dissatisfied with the way Ypto processes your personal data or with the response you have received from our Data Protection Officer to your complaint, you can lodge a complaint with the Data Protection Authority. In the meantime, we refer you to the Data Protection Authority website: https://www.dataprotectionauthority.be/citizen

Ypto reserves the right to modify this privacy policy at any time.