Privacy statement

Joyn Belgium NV attaches great importance to the protection of privacy and personal data. With this privacy statement (hereinafter referred to as the "Privacy Statement"), Joyn Belgium NV wishes to inform the user in detail about the processing of his/her personal data and the attached rights when using Joyn. Joyn consists of the Joyn Website (hereinafter referred to as the "Website"), the Joyn Card (hereinafter referred to as the "Card") and the Joyn App (hereinafter referred to as the "App"). We recommend you to thoroughly read this privacy statement.

By using Joyn, Joyn Belgium NV receives access to your personal data, which it shall process respecting the user's privacy and in compliance with the Act of 8 December 1992 on the protection of privacy with regard to the processing of personal data (https://www.privacycommission.be/en/privacy-act-and-implementing-decrees), which, from 25 May 2018, will be replaced by the (European) General Data Protection Regulation (also known as the GDPR) (http://eur-lex.europa.eu/legal-content/NL/TXT/?uri=CELEX:32016R0679).

If you wish to receive more information concerning privacy and data protection, please refer to the website of the Commission for the Protection of Privacy (also referred to as the Privacy Commission) via the link: https://www.privacycommission.be/en.

By accepting this Privacy Statement, a general authorisation is given to all processing described in this Privacy Statement for which authorisation is required.

For users younger than 16, we will only process personal data provided parental authorisation has been given. If it comes to our knowledge that personal data of users younger than 16 were collected, we will take the necessary steps to receive the parental authorisation. In the event we cannot receive the parental authorisation, we will delete the account.

As soon as we modify this Privacy Statement, you will be notified via the App and/or the Website. If applicable, you, as a user, will be asked to accept the new and therefore most recent version of this Privacy Statement.

Joyn Belgium NV commits to protect your privacy and personal data. If you have any questions about the Privacy Policy, you can contact us via privacy@joyn.be.

This Privacy Statement was last reviewed on: 24 February 2018

SUBJECTS

WHO DOES THIS PRIVACY STATEMENT APPLY TO?

This Privacy Statement applies to all potential/current/previous Joyn users.

WHICH MEANS...

Point provider and a reward provider

A point provider is an issuer/supplier of additional points - which are not linked to the points of one single Joyn business and - which can be redeemed from a reward provider. The Joyn user receives additional points when interacting with a Joyn business.

For example

  • A shopping centre presents itself as a point provider within Joyn. There are several Joyn merchants located in the shopping centre. This means that with each scan from these Joyn merchants, additional shopping centre points are awarded by the shopping centre, to the Joyn user. These points are not connected to the points awarded by the Joyn business to the Joyn user.
  • A municipality or city presents itself as a point provider within Joyn. There are several Joyn merchants located in this municipality or city. This means that with each scan from each one of these merchants, additional municipality or city points are awarded by the municipality or city to the Joyn user. These points are not connected to the points awarded by the Joyn business to the Joyn user.
  • ...

A reward provider is an issuer/supplier of rewards based on the points awarded by a point provider. The Joyn user can redeem extra rewards using the points received from a point provider.

For example

  • A shopping centre has, in addition to having presented itself as a point provider, also presented itself as a reward provider. This means the shopping centre is awarding rewards based on the awarded shopping centre points, for example: free bathroom visit, free parking space, free shopping bag etc.
  • A municipality or city has, in addition to having presented itself as a point provider, also presented itself as a reward provider. This means the shopping centre is awarding rewards based on points awarded by a municipality or city, for example: free pass for the swimming pool, free ticket to the municipal theatre etc.
  • A parking company has presented itself as a reward provider within Joyn (and has concluded an underlying agreement with a point provider, e.g. a municipality or a city). Using the additional municipality or city points, the Joyn user can get a free parking space from the parking company.
  • A Joyn business who has concluded an agreement with a point provider, has presented itself as a reward provider within Joyn. The Joyn user can receive a free reward from this Joyn business, using the additional point provider points.
Processing of personal data

With 'processing', we mean any processing of data. Some examples: collecting, recording, deriving, saving, structuring, storing, consulting, viewing, sharing, sending, clearing, deleting, archiving...

With 'personal data', we mean any information on an identified or identifiable private individual. This means information, such as details, sound, images..., relating to a person, for example a name, address, location... that makes it possible to directly or indirectly identify a private individual. Anonymised data cannot identify a private individual and, therefore, do not constitute personal data.

A Joyn business

A Joyn business is a shop where it is possible to save points and/or redeem rewards within the Joyn programme.

Umbrella organisation

An umbrella organisation (dealer/retailer/chain/purchasing organisation...) is a company that can have a factual or legal decisive influence over the policy of the Joyn business or that is linked to the Joyn business by means of a distribution agreement.

Joyn Loyalty services

This service provides the customers of Joyn Belgium NV with the possibility of saving for Joyn advantages when purchasing products or services from merchants from the Joyn Belgium NV network. In accordance with the applicable offers, these advantages can be exchanged for the advantages described in the offer.

WHO IS RESPONSIBLE FOR THE PROCESSING?

Joyn Belgium NV (hereinafter referred to as "Joyn") is responsible for the processing when processing personal data as part of offering Joyn Loyalty services and this concerning the processing Joyn performs under its own responsibility and authority.

Joyn Belgium NV
Fonsnylaan 46 box 59,
1060 Brussels
Belgium

Company number: 0846.759.718
Phone number:+32 2 302 73 82
Email address: hello@joyn.beor privacy@joyn.be
Website: www.joyn.be

Where Joyn does not determine the purpose of and the means for the processing, Joyn is not responsible for the processing. Examples are specific competitions or raffles organised by a client (e.g. a point provider, a city, a not-for-profit association etc.) where the client is responsible for the processing, and Joyn is the processor.

Joyn offers numerous options to the Joyn business or umbrella organisation as to the processing of personal data. If this Joyn business or umbrella organisation, where you are a customer, by its own initiative, copies your personal data from Joyn and processes these via a different medium, the Joyn business or umbrella organisation becomes responsible for the processing. It is also possible a Joyn business or umbrella organisation receives a copy of its customer database. For each processing based on this copy, the Joyn business or umbrella organisation is responsible for the processing.

The user who wishes to exercise his rights as a party involved, must address the entity responsible for the processing.

WHO IS THE DATA PROTECTION OFFICIAL?

Joyn has appointed a data protection officer in charge of supervising and guarding Joyn's privacy and data protection policy regarding the processing of personal data. You can contact the data protection officer via privacy@joyn.befor any questions concerning privacy and data protection regarding the processing of your personal data and the exercise of your rights.

WHICH PERSONAL DATA ARE PROCESSED BY JOYN WHEN OFFERING THE JOYN LOYALTY SERVICES?

Personal data processed when using the Joyn loyalty services on an anonymous basis.

It is possible to use the Joyn loyalty services on an anonymous basis. No personal information is made available, except the consumer habits developed when using Joyn. The processing of these consumer habits is based on legitimate interest, in order to offer the right loyalty services to the user.

More info

Type of personal data

Receiver

Basis for the processing

Purpose of processing

Explanation

Consumer habits

(For example: time of interaction, Joyn business of interaction, points awarded or redeemed etc.)

Joyn

 

Joyn business

Legitimate interest

With these details, the Joyn business receives:

- an overview of the purchases;

- the possibility to reward customers by awarding points or offering coupons;

 

And the customer can:

- receive and collect points;

- exchange collected points for a reward.

After each interaction, these details are made available to each Joyn business, in order to be able to offer loyalty.

 

 

Personal data processed during the initial online registration process for an anonymous loyalty card.

The email address of an anonymous user is requested in a Joyn business, in order to be able to send an email, so the user can register with Joyn. That way, we want to offer the user the time to go through the registration process when suits (not in a hurry at the cash register in a Joyn business). Processing this e-mail address is based on legitimate interest.

More info

Type of personal data

Receiver

Basis for the processing

Purpose of processing

Explanation

Personal identification details

(Email address)

Joyn

Legitimate interest

Allow user to create online account.

 

Create new card if lost.

This email address is used to send the user an email, so he can complete his online account. As long as the registration process is not complete, this email address will not be used for any other purpose than indicated here.

Personal data processed when creating a Joyn account.

Personal identification details, personal characteristics and security are processed when creating a full online account. After this, the user has full use of the Joyn loyalty services. Here, the processing of personal data is based on your authorisation as well as on Joyn's legitimate interest on behalf of your account's safety.

More info

Type of personal data

Receiver

Legal basis for the processing

Purpose of processing

Personal identification details

(Email, first name, name, phone number, postal code, country, date of birth)

Joyn

Authorisation

Joyn collects and processes these personal data for the following purposes:

 

- Register you as a Joyn platform user;

- Enable service provision regarding Joyn;

- Ensure customer administration;

- Improve the general functioning of the Joyn platform;

- Prevent, detect or investigate illegal activities, fraud or security breaches.

 

 

Personal characteristics

(For example: gender, language)

Joyn

Authorisation

Security

(For example: password)

Joyn

Legitimate interest on behalf of the account's safety

Personal data processed when using the Joyn platform.

When using Joyn, electronic location details (the smartphone's GPS location) and data concerning the used electronic device are processed. The location is only used to correctly perform the search query. The processing of these personal data is based on, respectively, your authorisation and on Joyn's legitimate interest on behalf of the service provision's quality improvement and on behalf of fraud prevention.

More info

Type of personal data

Receiver

Basis for the processing

Purpose of processing

Electronic location details

(For example: GPS location)

Joyn

Authorisation

Used to show Joyn businesses in the neighbourhood; not stored in the Joyn databases.

Details regarding the electronic device

(For example: type of device, operating system, app version)

Joyn

Legitimate interest on behalf of the service provision's quality improvement

Joyn processes this information in order to analyse, assign and resolve issues that occurred (crashes, bugs etc.) more easily.

Electronic identification details (For example: IP address)

Joyn

Legitimate interest on behalf of fraud prevention

Joyn processes this information in order to prevent misuse.

Personal data processed with each interaction between the Joyn user and the Joyn business.

Consumer habits, personal identification details and personal characteristics are processed and transferred with each interaction between a Joyn user and a Joyn business. The Joyn business receives an overview of its purchases and anonymous and non-anonymous customers, can hand out points or coupons, can contact its customers for direct marketing purposes regarding its own, similar products or services... and the Joyn user has the opportunity to collect points from a Joyn business in order to exchange these points for rewards later on. There is an interaction after a purchase in a Joyn business or after redeeming a reward or coupon in a Joyn business. In the event the Joyn business is part of an umbrella organisation, the organisation will also receive these personal identification details. The processing of these personal data is based on your authorisation.

More info

Type of personal data

Receiver

Basis for the processing

Purpose of processing

Explanation

Consumer habits

(For example: time of interaction, Joyn business of interaction, points awarded or redeemed etc.)

Joyn

 

Joyn business

Legitimate interest

With these details, the Joyn business receives:

- an overview of its customers;

- an overview of the purchases;

- the possibility to reward customers by awarding points or offering coupons;

- the opportunity to contact its customers for marketing purposes.

 

And the customer can:

- receive and collect points;

- exchange collected points for a reward.

After each transaction, these details are made available to each Joyn business.

 

The Joyn user can, within the Joyn app, indicate for each individual Joyn business whether or not he wishes to receive notifications from this Joyn business.

Personal identification details

Joyn business

Authorisation

Umbrella organisation

Authorisation

Personal characteristics

Joyn business

Authorisation

Personal data processed when messages are sent to the Joyn user by the Joyn business, Joyn or the umbrella organisation.

Personal identification details are processed in a limited manner when Joyn, the Joyn business or the umbrella organisation contacts you as a customer for promotions or advertisements, to send newsletters, promos and associated communications.

Within Joyn, there is a campaign tool to set up automated email campaigns to a customer database, taking into account individual opt-ins or opt-outs. When using this tool, no personal data are displayed. Only reporting is performed based on customer names.

Sending these messages is authorised based on legitimate interest within the context of the existing customer relationship, to offer a business' own, similar products or services, where the user has, at the time when the electronic contact details are collected, the opportunity to easily object to this processing, free of charge, by changing his account settings.

In the event a Joyn business and/or umbrella organisation sends an email to its customer database outside of Joyn, Joyn is not responsible and the Joyn business or umbrella organisation is responsible for the processing.

More info

Type of personal data

Processor

Basis for the processing

Purpose of processing

Explanation

Personal identification details

 

Joyn business

 

Joyn

 

Umbrella organisation

 

 

Legitimate interest

These personal data are processed by Joyn, the Joyn business or the umbrella organisation in order to send marketing emails to the customer database.

The Joyn user can, within the Joyn app, indicate for each individual Joyn business or for Joyn whether or not he wishes to receive notifications.

Legitimate interest

In order to improve these messages and associated service for the customer, we analyse, for each receiver, what type of newsletter content he finds interesting.

Details about opening certain content or about clicking behaviour in the newsletter, for example, are registered and analysed.

Personal data processed when redeeming a reward from a reward provider.

In the event the Joyn user redeems a reward (awarded by a point provider) from a reward provider, the reward provider receives the personal identification details and this based on legitimate interest so it can explain itself.

More info

Type of personal data

Receiver

Basis for the processing

Purpose of processing

Personal identification details

Reward provider

Legitimate interest

These personal data are processed as the reward provider must be able to explain who has redeemed the rewards.

Personal data processed when winning a competition or raffle via the Joyn platform.

Joyn organises or offers support to organisers of competitions or raffles on a regular basis. When participating in these competitions or raffles, personal data of the winner(s) are processed in order to contact the winner(s), deliver the prize and publish the winner(s). The processing of personal data is based on your authorisation. When organising a raffle, there is a legal requirement to communicate the personal data of the winner(s) to the organiser.

More info

Type of personal data

Receiver

Basis for the processing

Purpose of processing

Personal identification details

 

Joyn

 

Organiser Competition or raffle

Authorisation

These personal data are processed to be able to contact the winner(s).

Authorisation

These personal data are used in order to publish the winner(s).

Legal requirement

In the event of a raffle, the personal data of the winner(s) are processed and communicated to the organiser in order to comply with the legal requirements.

Personal data processed when filling out the contact form on the Joyn website.

Personal identification details are processed when a visitor contacts Joyn using the website's contact form. This person is looking for more information regarding the loyalty programme, the city programme, or is interested in collaborating with Joyn. For this processing, the processing of personal data is based on the contractual relationship and on the previous contacts.

More info

Type of personal data

Receiver

Basis for the processing

Purpose of processing

Explanation

Personal identification details

 

Joyn

Contractual relationship or associated previous steps

These personal data are used by Joyn in order to reply to the person concerned.

The form to request more information can be found on three separate locations on the website: more info for merchants, cities or municipalities and partners.

Personal data processed when requesting the white papers and subscribing to the newsletter.

When requesting white papers and with the optional subscription to the newsletter on the website, the personal identification details of the applicant are processed. To receive the white papers, the processing of personal data is based on the contractual relationship or the associated previous steps. The applicant grants explicit authorisation for the subscription to the newsletter. Each such communication contains the possibility to unsubscribe, if the user would no longer be interested in the newsletter.

More info

Type of personal data

Receiver

Basis for the processing

Purpose of processing

Explanation

Personal identification details

 

Joyn

Contractual relationship or associated previous steps

These personal data are processed in order to request and receive the white papers.

Once the applicant has filled in his details, he will receive the white papers once.

 

Authorisation

These personal data are processed in order to deliver the newsletter.

The applicant also gives his explicit authorisation by checking the box 'Subscribe to our newsletter' to receive the newsletter.

 

In each such communication, there is an option to unsubscribe.

Personal data processed when requesting information via hello@joyn.be, the helpdesk or social media.

If you are or aren't a user (yet), and you are requesting information through social media channels (such as Facebook, Twitter and Pinterest), via hello@joyn.beor over the phone via the helpdesk, we process personal data such as your first name, name, phone number, only with the purpose of being able to provide an answer to the question. The processing is based on Joyn's legitimate interest, in order to provide a qualitative service provision. If the answer is given via email, personal emails will be used. In that case, it is not possible to unsubscribe.

More info

Type of personal data

Receiver

Basis for the processing

Purpose of processing

Explanation

Personal identification details

 

Joyn

 

 

Legitimate interest on behalf of qualitative service provision

These personal data are only processed with the purpose of contacting this person in order to answer the question.

Personal data will not be used for other purposes such as marketing.

Audio recording

(Phone conversation)

Joyn

Legitimate interest on behalf of qualitative service provision

Conversations are recorded in order to improve the service provision's quality, by, for example, offering adapted training sessions to our Joyn employees, or in order to resolve disputes.

Users who contact the helpdesk are, at the start of the conversation, notified that the conversation will be recorded.

As clarified above, the processing of your personal data when using the Joyn platform is possibly based on authorisation. You dispose of the right to revoke your authorisation at any given time. Refer to: What are my participant rights and how can I exercise them?

GOOGLE ANALYTICS

Google Analytics is a web analysis service provided by Google Inc. (hereinafter referred to as "Google"). Joyn uses Google Analytics within the User App, the Merchant App and the Website. Joyn does not communicate any personal data to Google. By analysing these data, based on legitimate interest, Joyn learns how the apps and the website are used, so that Joyn can improve its apps as well as its website.

Google Analytics information: Privacy Policy- Opt out

USING JOYN ANONYMOUSLY

It is possible to use the Joyn App and Joyn Card anonymously. An anonymous user hasn't registered yet and, therefore, hasn't communicated any personal identification details to Joyn. This means certain rights cannot be exercised, unless the user provides the additional data allowing to identify the user.

WHO RECEIVES MY PERSONAL DATA?

Personal data collected by using the Joyn loyalty programme are collected within Joyn. These data may be processed by several entities. An overview:

Joyn

When using the Joyn platform, Joyn processes your personal information.

A Joyn businesses – when interacting in its shop. (Collecting points or redeeming rewards in a Joyn business.)

A merchant can consult, within Joyn, who its customers are and can set up an email campaign for its customers, using Joyn's campaign tool.

Visit https://www.joyn.be/nl/find-a-merchantto view the list of Joyn merchants.

A reward provider

It is possible you automatically receive additional 'point provider points' after scanning in a Joyn business. You can redeem these points from a 'reward provider'. When redeeming a reward from a reward provider, personal identification details and personal characteristics are communicated to the reward provider.

Umbrella organisation

An umbrella organisation manages and processes the Joyn account of all underlying Joyn businesses and can set up an email campaign to the underlying Joyn businesses from this account.

Processors

Joyn relies upon external processors. This means, among other things, we temporarily transfer data to third parties for certain tasks or research queries, if we don't have the means to perform these ourselves, for example hosting website, mail platform, helpdesk tools etc. If we do this, we always ensure your data are processed in a confidential manner and used in a secure manner. We always stipulate this in an agreement concluded with these processors. This means the processor will never be able to use your data on its own initiative and your data must be deleted upon completion of the assignment, unless otherwise provided by law.

Organiser of a competition or a raffle

If the organiser organises a specific competition, a minimum of personal identification details must be communicated to the organiser, in order to contact the (sole) winner of the competition to award the prize and to comply with the legal requirements.

Other

To governments, supervisors and other third parties as part of certain legal requirements, in the event we suspect and/or try to detect certain criminal offences, as part of the enforcement of intellectual property rights of third parties, in the event we are of the opinion you have breached the terms and conditions of use of our website and/or app or in the event we wish to enforce our Privacy Statement.

In the event of a merger, acquisition, sale, joint venture and/or in the event of any other change of control within Joyn, Joyn reserves the right to transfer the personal data processed by Joyn to any third party 'as part of such a merger, acquisition, sale, joint venture and/or any other change of control'.

Your personal data will not be transferred to other external parties without prior authorisation, unless Joyn is obliged to do so by virtue of a legal provision or judicial decision. Your personal data will not be transferred to Joyn's partners.

ARE ANONYMOUS DATA USED FOR REPORTING PURPOSES?

We may use anonymous data for commercial purposes or for external reporting. Anonymous data are personal data that are anonymised to the extent that they no longer relate to an identified or identifiable person or the data is displayed anonymously to the extent that the individual is no longer recognisable.

HOW LONG WILL MY DATA BE STORED?

Joyn will only store your personal data for the minimum period required to fulfil the purposes included in this Privacy Statement, unless to resolve any disputes or if a longer storage period is required by law. Non-personal information can be stored without any limitations in time, for statistical purposes.

Closing a Joyn account is possible based on four reasons: the Joyn user requests to delete* his account, Joyn is notified a user is younger than 16 and the parental authorisation could not be substantiated, a Joyn account is inactive or in the event of fraud.

Type of personal data

Will be deleted

Explanation

Personal identification details

When closing a Joyn account.

 

When gaining knowledge that a user is not 16 years old and when parental authorisation cannot be substantiated.

 

If the Joyn account is no longer used.

 

In the event of fraud.

These personal data are stored as long as necessary in order to fulfil the purposes included in this Privacy Statement in order to be able to offer loyalty, and in order to be able to offer the necessary service.

Personal characteristics

Security

Audio recording and helpdesk exchanges

Consumer habits

If the Joyn account is no longer used.

Electronic location details

 

Not applicable: location is only processed in real time.

* When the user requests to delete his account, the account will be suspended for 30 days, offering the user the required reflection period. Within these 30 days, the user can reactivate the account. After these 30 days, the above table will be applied.

SECURITY AND STORAGE OF DATA

Joyn acknowledges that the protection of personal data is a part of data protection. Joyn therefore takes the appropriate technical and organisational measures to protect your personal data against unauthorised processing or unauthorised access in order to prevent misuse.

With any transfer of personal data to a processor outside of the EEA, Joyn will perform such transfer in accordance with this Privacy Statement's conditions and Joyn will comply with the applicable law and regulations regarding data protection in order to sufficiently ensure guarantees.

COOKIES

Cookies are text files that are placed on your computer in order to collect standard Internet logging information and behavioural information. This information is used to track visitor behaviour on the website and to draw up statistical reports about the website.

For more information about Joyn's cookie policy: www.joyn.be/en/cookie-policy.

WHAT ARE MY RIGHTS AND HOW CAN I EXERCISE THEM?

How can I exercise my rights?

You can exercise your rights by sending an email to privacy@joyn.be. In order to prevent each and every unauthorised disclosure of your personal data, it is compulsory to send your request from the email address linked to your Joyn account. In addition, this email must also include your unique Joyn ID located under the QR code you use to scan.

Joyn shall dispose of one month to respond to your request. This period shall commence when Joyn has received your request and disposes of all the necessary information to respond to your request.

Joyn shall provide the requested information free of charge. In the event requests are unfounded or disproportionate, in particular due to their repetitive character, Joyn may charge a reasonable compensation or Joyn may refuse the request.

If, for any reason, you assume Joyn has not treated your request appropriately, you can contact Joyn's data protection official via privacy@joyn.be. Together, you will look for a solution.

For the sake of completeness, we would like to inform you that in the event Joyn does not respond to or refuses your request or if Joyn's response does not meet your expectations, you have the right to file a complaint with the Commission for the Protection of Privacy (Privacy Commission), Drukpersstraat 35 in 1000 Brussels or commission@privacycommission.be.

What rights can I exercise?
  • Right of access:You can ask us which personal data of yours we process, why we process them, which personal data categories we process, with which third party categories we share your personal data, where the processed data came from and - if applicable - which reasoning we use when processing personal data automatically.
  • Right of rectification:Every Joyn user can currently correct his own account details via the Joyn platform. In order to keep your details up to date, we request you personally edit your details.
  • Right of erasure:You can ask us to delete your account. By doing so, you will no longer be able to use the Joyn platform. After your request, Joyn will suspend your account for a period of 30 days, offering you the required reflection period. After that, your account will be permanently deleted. Also refer to: How long will my data be stored?
  • Right of limitation of processing: In the cases provided for in Belgian and European privacy legislation. When the processing within the Joyn platform is limited, your personal data (except for storage) will only be processed with your authorisation or for the establishment, exercise or defence of legal claims or for the protection of the rights of another private individual or legal entity or for reasons of public interest. After obtaining this processing limitation, Joyn will always notify you before the processing limitation is lifted.
  • Right of transmission of the data:You have the right to receive the personal data provided by you in a conventional, structured and machine-readable form and you have the right to transmit these personal data to a different controller, where the processing is based on the legal bases authorisation or contractual relationship.
  • Right of retracting one's authorisation:If the processing of personal data is based on an authorisation basis, you, as a user, have the right to retract your authorisation at any given time. You can do so by cancelling your account.
  • Right of objection:You have the right to object to the processing of your personal data only if the processing is based on public interest or a legitimate interest. You also have the right to object to the processing of your personal data for marketing purposes. This is currently possible by opting out for the desired Joyn business in the Notifications tab within the App.

ARE MY DATA USED FOR AUTOMATIC DECISION-MAKING?

There is no automatic decision-making, including profiling, within the Joyn platform.