PRIVACY AND COOKIES POLICY for BELPEOPLE Websites, Web Applications and Mobile Applications – BC FOODS
For the purposes of the current Privacy and Cookies Policy (hereinafter the “Policy”), “Personal Data” shall mean any information of a personal nature as defined in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“General Data Protection Regulation” or “AVG”), as well as any applicable national implementing or supplementary legislation (collectively, the “Privacy Act”), d. i.e. any information concerning identified or identifiable natural persons.
1- Controller
BC FOODS BV, operator of the BELPEOPLE in Belgium, with a registered office at 1930 Zaventem, Leuvensesteenweg 375, registered with the number 0724808645 (hereinafter “BC FOODS”, “BELCHICKEN” or “BC”) owns and operates the “Staff Application” www.belchicken.com, as well as the “Ad Hoc Sites” temporarily available online for BC competitions and other promotional actions (collectively, the “Websites”). BC also owns and manages the BELPEOPLE® Manager and Staff Application (hereinafter referred to as the “BELCHICKEN® App” or the “Application”).
This Policy describes the conditions under which BC FOODS may, if necessary with your consent, process your Personal Data in relation to your use of the Websites, web, or mobile applications developed by or on behalf of BC (the “Applications”) and as well as associated services. BC FOODS acts as a data controller in accordance with the Privacy Act.
Without prejudice to the generality of the foregoing, special or additional provisions on Ad Hoc Sites and/or Applications may also apply (taking into account the particularities of certain Ad Hoc Sites/Applications), with respect to privacy protection and processing of Personal Data. In case of conflict between this Policy and any special provisions, the latter shall prevail.
Any reference in this Privacy and Cookies Policy to “we/we”, “us” or “our”, shall be deemed to refer to BC.
2 – Importance of this Policy
BC attaches great importance to your privacy and to the protection of your Personal Data.
This Policy applies to the Websites and Applications and explains exactly how BC collects and processes your Personal Data, how it may be used, with whom it may be exchanged, where appropriate, and how it is protected.
BC respects your privacy and the manner in which you choose to provide data. BC recognizes the need for adequate protection and management of Personal Data collected.
BC processes your Personal Data in accordance with General Terms and Conditions of Use, the Special Terms and Conditions of Use for the mobile application “BELPEOPLE® Manager App“, “BELPEOPLE® Staff App“ this Policy, and the Privacy Act.
Please note: By joining the Websites and Applications or when you visit or use the Websites and Applications, you accept the General Terms and Conditions of Use and agree to the application of this Policy. You authorize BC to process your Personal Data in accordance with and for the purposes defined herein. The General Terms of Use and current Policy are available on the Websites and Applications.
If you are under 13 years of age, only a parent or the person who has parental responsibility for you can legally consent to the processing of your Personal Data, as described in this Policy. If we know that you are under the age of 13, we will ask you for confirmation.
3 – What personal data does BC FOODS collect?
BC collects your Personal Data in the course of making the Websites, Applications and related services available. Your Personal Data is collected, processed and used by BC in accordance with current Policy. The Personal Data collected and processed by BC includes the following information:
a. General
The Personal Data related to your general use of the Websites/Applications and related services: identification of the device you use to use the Websites/Applications (MAC address), IP address, selected language, data related to when and how long you use the Websites/Applications, information related to your operating system and type of device, search criteria (such as type of product), pages visited (the “Surfing Data”).
Personal Data related to your use of the BELCHICKEN® App: user account ID (Facebook username and password or email address and password); first and last name, date of birth; country and zip code; email address; the log of acceptance of legal documents; advanced profile data (optional): [gender, if the parent with children over or under 12 and number of children; student/professional; preference for BELCHICKEN® restaurants]; Belchicken QR ID, coupons, stamps, discounts.
The Personal Data pertaining to you, as provided by you or generated by BC during the registration or enrollment process for one of our contests or promotions, such as first and last name, phone number, date of birth, email and postal addresses, password and/or promotion code if applicable, as well as whether you wish to subscribe to the newsletter and log of acceptance of legal documents (the “Subscription Data”).
The Personal Data related to your subscription to the BC newsletter: email address, first and last name, log of acceptance of legal documents (the “Newsletter Data”).
The “Profile Data”: based on the Personal Data above in current article 3, BC will create and store marketing profiles of the User.
The “Consumer Service Data”: the Personal Data that you choose to provide when you want to make comments or ask a question to BC – through the online form available for this purpose on the Permanent Website – after visiting or relating to one of our BELCHICKEN® restaurants: salutation, first and last name, email and postal addresses, telephone number (optional), BELCHICKEN® restaurant visited, date and time of your visit, subject, and content of your message.
The information you provide when you want to apply for a job with BC: first and last name, email and mailing addresses, curriculum vitae information, message/motivation letter, desired job (position and location), log of acceptance of legal documents (the “Recruitment Data”).
The collected data may also include location data, to the extent that you have enabled the geolocation feature on your smartphone and have given us your consent to such processing. The latter is defined as any data processed in an electronic communication network or by an electronic communication service that indicates the geographical position of the device of an end-user of a public electronic communication service. The processed location data is the geographical data provided by the GPS system in order to identify the exact location of the end user’s device. The location data will not be processed (i) for a duration exceeding the period necessary for the purpose described hereinafter, nor (ii) for purposes other than those described hereinafter. You have the right to withdraw your consent to the processing of your location data at any time by turning off the geolocation function on your device. However, BC informs you that this may affect the correct provision of the service(s) and/or the effectiveness with respect to certain functions based on location: i.e., determining the nearest restaurant for your location (the “Location Data”).
BC may also access identification and contact information from external databases that we purchase and combine it with the information that BC itself collects from you in order to have more complete information.
If you click through to our Websites, Applications, or platforms from a social media platform, such as Facebook or Instagram, we may gain access to certain profile information on that media platform. See Section 9 of the Policy for more information on this.
b. Sensitive Data
In connection with your use of the Websites/Applications and connected services, BC does not collect or process any special category of Personal Data from you unless you voluntarily communicate it, for example in the curriculum vitae or cover letter that you freely decide to upload during the online recruitment process or in your messages through the “Contact” section of the Permanent Website. The special categories of Personal Data are often referred to as “sensitive” Personal Data and include information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health or sexual life.
4 – For what purposes is your Personal Data processed and on what legal bases?
General
BC collects and processes your Personal Data solely for the purposes stated in this Policy. The purposes for which BC processes your Personal Data are: making the Websites/Applications and related services available; managing the contractual relationship between you and BC, including your participation in certain competitions, promotional actions or, where applicable, your membership to a loyalty program (such as the BELCHICKEN Loyalty Program) ; verifying that your use of the Websites/Applications complies with all applicable BC terms of use and applicable law; responding to your requests, questions and/or complaints; and, if applicable, processing and responding to your applications for employment at a BELCHICKEN restaurant.
In addition, BC may process your Personal Data in order to monitor the use and visitation of the Websites/Applications and related services, analyze users’ habits, develop enhancements or new features that improve the Websites/Applications, and conduct market studies. To the extent possible, BC will process aggregate data (being data that cannot identify you nor be linked to you, such as statistical data), pseudonymized or anonymized data, instead of Personal Data, when the purposes of such processing can be achieved in this way.Direct marketing and profiling
If you consent to the use of your Personal Data for commercial and advertising communication purposes (direct marketing), BC will use your Personal Data for the purposes for which you have given your consent until your consent is withdrawn. With your express consent, when you communicate your e-mail address and/or your cell phone number, BC may send you commercial and advertising messages about BELCHICKEN® products/services by e-mail and/or SMS, or through personalized “push”/display on certain social networks or other platforms with which you have an account. If you wish your Personal Data to no longer be processed for commercial and advertising communication purposes, you have the right to withdraw your consent in this regard, at any time, free of charge and without giving any reason. The procedure to be followed in such a case is described in article 8 of this Policy.
Your Personal Data may also be used to establish user patterns and statistics and to categorize you into a particular consumer group on the basis of your personal characteristics (e.g. gender and age range) (“profiling”).
By using such profiling techniques, BC is able to send you personalized news messages, promotions or offers tailored to your specific needs and can thus provide you with added value. The use of these techniques will in no case have any legal consequences for you, nor any other far-reaching consequences.
If you would like more information about the profiling techniques used by BC and the way in which BC classifies you into a particular group, or if you have any objections to this, you can contact us at any time (see contact details in Article 11).
In accordance with the Privacy Act, the processing activities described in this Section 4 are based on the following legal bases: (i) your consent; (ii) the necessity for the performance of the contractual relationship between you and BC (as well as for the performance of pre-contractual measures taken at your request); and/or the legitimate interest of BC, without prejudice to your rights and freedoms that would rank higher. This concerns in particular the security of the services provided by BC, including the security of BC’s infrastructure and systems and the prevention of fraud in general.
BC reserves the right, on the basis of a legal authorization/obligation or of your consent, to use your Personal Data for new purposes not yet provided for in current Policy. In any case, BC will inform you of the changes to this Policy prior to the use of your Personal Data for other purposes. In case of activities based on consent, BC will offer you the opportunity to not agree to the changes.
5 – How do we protect your Personal Data?
BC has implemented the necessary administrative, technical and organizational measures to protect the Personal Data, obtained through the use of the Websites/Applications and related services, from accidental or unauthorized destruction, from loss as well as from the illegal or unauthorized modification, disclosure or access. BC takes measures to maintain the confidentiality of your Personal Data and to protect it from unauthorized disclosure. BC will not make your Personal Data available to the public without your prior consent.
Without prejudice to the provisions of Article 6, your Personal Data will preferably be stored on servers located within the European Union and will be hosted through a cloud platform. These servers and this cloud platform are appropriately secured against loss, damage or other data breach.
6 – Who has access to your Personal Data?
In the context of (i) the provision of the Websites/Applications and the provision of related services, and (ii) your use of them, BC may use services of suppliers and subcontractors to whom certain Personal Data of yours may be communicated – in the context of the services they provide to BC – and with respect to whom BC has taken appropriate measures for the protection of your Personal Data, in accordance with the Privacy Act. BC uses, on a non-exhaustive basis, such suppliers and subcontractors for the hosting and maintenance of the Websites/Applications, the storage of databases, the management of the underlying platforms for the collection and processing of job applications, the management of satisfaction surveys, competitions and promotional activities, and for marketing campaigns and logistics services.
Your Personal Data may also be transferred to franchisees of BC that operate the BELCHICKEN® restaurants related to your applications. The same applies to Consumer Service Data.
Your Personal Data may also be distributed to affiliated companies of BC and to BELCHICKEN® franchisees of BC. In any distribution, BC will ensure that the contractual safeguards necessary to protect your Personal Data are in place.
Your Personal Data will not be rented or sold to third parties without your prior express consent.
In general, BC will not transfer your Personal Data to third parties, except for the transfer of data authorized by applicable law, or mentioned in this Article 6 or elsewhere in this Policy.
You also consent to the transfer of your Personal Data in the event of the sale or transfer by BC of all or part of its business or assets to a third party.
To the extent that the transfer of your Personal Data involves countries outside the European Economic Area (“EEA”) which have not been determined by the European Commission to provide an adequate level of protection of Personal Data, for the purposes specified in this Policy, BC will ensure that measures are taken in accordance with the Privacy Act, if applicable, by signing the standard contractual clauses made available by the European Commission.
7 – How long do we keep your Personal Data?
Your Personal Data, collected and processed in accordance with the present Policy, will not be kept longer than necessary to achieve the purposes set out in Article 4 above. Without prejudice to the generality of the foregoing, your Surfing Data, Personal Data, Subscription Data, Newsletter Data and Profile Data will be retained for as long as you use BC’s services in connection with which the processing of such Personal Data takes place. We will only retain your Personal Data for a longer period of time if BC has a specific legitimate interest in retaining your Personal Data of this nature (for example, if this is necessary to defend BC’s interests in court, to the extent that the data would be necessary to clear up an alleged breach of third party rights or to comply with a legal obligation).
More specifically and without prejudice to the generality of the foregoing,
BC will retain your Surfing Data, Personal Data, Enrollment Data and/or Profile Data for as long as you do not delete the relevant user account (or registration) or, in any event, for no longer than twelve (12) months after your last activity;
Your Payment Data will be retained by MOLLIE for five (5) years after each transaction, in accordance with applicable legislation on the prevention of money laundering and the financing of terrorism. BC does not retain your Payment Data;
Your Newsletter Data will be kept as long as you do not object to its processing by BC (see the procedure to be followed in Article 8 of this Policy);
Your Recruitment Data will be retained for a period of two (2) years from BC’s decision whether or not to hire you. Without prejudice to the generality of the foregoing, your Recruitment Data will be attached to your employment contract and thus retained in accordance with the provisions of that employment contract and the BC Employee Rules, should BC hire you.
BC will carry out regular checks in order to determine which Personal Data are no longer required for the purposes envisaged, and will delete or otherwise anonymize such Personal Data if necessary.
8 – Your rights as a data subject and how to exercise them
As a “data subject” as defined in the Privacy Act, you have the following rights:
Right to information and access to your Personal Data
You can consult your Personal Data, as collected and processed by BC, at any time. You can always ask us for more information regarding BC’s processing activities and about the Personal Data that BC holds about you, as set out in Article 11.
Right to rectification of inaccurate or incomplete Personal Data
You may request rectification of your Personal Data (excluding your date of birth if applicable), in case your Personal Data is incorrect.
Right to data erasure of your Personal Data (“right to be forgotten”)
You may request the erasure of your Personal Data (or in some cases, you may delete it yourself) if the Personal Data is no longer necessary for the purpose(s) in question, as well as in the other cases specified in the Privacy Law.
Right to withdraw, free of charge, your consent to the processing of Personal Data for direct marketing purposes
You may withdraw your consent to the processing of your Personal Data for direct marketing and profiling for marketing purposes at any time, free of charge and without giving any reason.
Right to Transferability of Personal Data
In some cases, you have the right to obtain your Personal Data in a structured, commonly used and machine-readable form. You also have the right to request that your Personal Data be transferred to another controller. This right applies where the processing
is based on consent or necessity of processing for the performance of a contract; and
is performed through automated processes.
In general, you have the right to withdraw your consent to processing based thereon (if applicable) at any time. Such withdrawal of consent shall not affect the lawfulness of the processing based on the consent given before the withdrawal.
If you believe that the processing of your Personal Data is in breach of the Privacy Act, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of the European Union in which you have your habitual residence or your place of work, or the place where the breach took place. The Belgian supervisory authority is the Data Protection Authority (https://www.gegevensbeschermingsautoriteit.be/). In France, this supervisory authority is the National Commission for Computerisation and Freedom or CNIL (www.cnil.fr). In Germany, on the other hand, there is not one central Data Protection Authority but a number of different Authorities for each of the 16 German states which are responsible for making sure that data protection laws and regulations are complied with. Moreover, the German Federal Commissioner for Data Protection and Freedom of Information (Bundesbeauftragte für Datenschutz und Informationsfreiheit – ‘BfDI’) is the Data Protection Authority for telecommunication service providers and represents Germany in the European Data Protection Board. Further information on the different German authorities can be found at https://www.datenschutzkonferenz-online.de/datenschutzaufsichtsbehoerden.html.
To exercise your rights, it is sufficient to send a written and signed request to BC at the email address privacy@belchicken.com, with a copy of the front of your identity card or any other identification document, as well as any document proving that the Personal Data relates to you as a User.
9 – Cookies and social media plug-ins
General: definition and categories of cookies
In order to provide you with an attractive and enjoyable visit to the Websites/Applications, we make every effort to make your experience as individual as possible and to continuously improve the Websites.
To do this, BC uses cookies on the Websites/Applications. A cookie is a small electronic text file that is stored on the user’s device by a specific server via the user’s browser. Cookies contain data about the user and/or his device. As part of the use of the Websites/Applications, cookies may be placed on your device to collect anonymous data and Personal Data about you, as identified in current Policy.
Cookies typically contain a unique code (“name of the server that set the cookie + expiration date + a unique number code”) that allows us to recognize your browser when you visit the Websites or Applications (“session cookies”) or when there are repeated visits (“persistent cookies”). A persistent cookie remains on your server, although you may delete or disable it at any time, as explained below.
More specifically, there are several categories of cookies:
Necessary cookies / technical cookies
These are cookies that are essential for the operation of websites and applications and allow you to use certain parts of them. For example, these cookies allow you to navigate between the different parts of websites and applications, to fill in data, etc. If you disable these cookies, certain parts of the websites and applications will not work, or will not work optimally.
Analytical cookies / statistical cookies
Analytical cookies are used to collect information about how visitors use the websites they visit. These cookies help to understand how visitors interact with websites and applications, and why certain error messages appear. They make it possible to test new features. This information is used to improve the user experience.
Functional cookies / preference cookies
The functional cookies are the cookies that facilitate the functioning of websites and applications, make them more pleasant for the visitor and ensure that you get a more personalized user experience. For example, they are the cookies that remember your language preference.
Tracking / marketing cookies
These cookies are aimed at collecting statistics about visitors and sending personalized commercial messages, advertisements, and promotions.
b. Acceptance of cookies
Upon your first visit to the Website(s) (or Application(s)), information regarding privacy and consent to the use of cookies will appear in a window (cookie pop-up) on the home page. Subject to Article 9.c, you can then accept or refuse the installation of cookies by cookie categories. If applicable, your consent to the use of cookies by BC is retained in your browser. In this way, the information from the cookie pop-up will not need to be reproduced on each page of the Websites/Applications or during a subsequent connection. In the event that your consent is no longer registered in your browser (e.g. in the event of deletion of your cookies), the cookie pop-up will reappear during your next visit to the Website/Application.
c. Use of cookies by BC
BC installs and uses certain cookies on your device that are technically required and do not require your prior consent. Other cookies – such as cookies to improve the navigation experience by saving certain data (this avoids you having to re-enter such data every time you connect) and by adapting the content of the Websites/Applications to your preferences – can be installed and used on the basis of your individual consent. You can, at any time, delete or block cookies in the settings of your browser. However, certain features of the Websites/Applications that require the use of such cookies may no longer be available.
In addition, you can change the settings of your browser so that you are notified each time a cookie is sent to your computer or device, so that you can choose whether or not to accept the installation of that cookie.
BC uses session cookies, which are deleted once you close the browser window or turn off your device. BC also uses persistent cookies that are stored on your device’s hard drive unless deleted as explained above. For more information about cookies, BC refers you to the website www.allaboutcookies.org.
BC uses analytical cookies in order to collect general information about how users use the Websites/Applications (for example: which are the pages they visit most often). Any information collected through those cookies is solely for the purpose of understanding and improving the functionality of the Websites/Applications. BC uses Google Analytics, a web analytics service provided by Google Inc, 1600 Amphitheatre Parway, Mountain View, CA 94043, United States (“Google”). The information relating to your use of the Websites/Applications generated by Google Analytics is usually transmitted to and stored on a Google server in the United States. However, the code ” gat_anonymiseIp(); ” has been added by Google Analytics on the Websites/Applications to ensure the anonymous recording of IP addresses, known as ” IP masking “. The anonymization of the IP address by Google on the Websites/Applications truncates your IP address on the territory of the European Union and the European Economic Area. The full IP address will be transmitted on Google’s server in the United States only in exceptional cases. It will be truncated there. Google will use this information on behalf of BC in order to analyse your use of the Websites/Applications, to compile reports on the activity of the Websites/Applications and to provide BC with other services relating to the Websites/Applications and Internet use. The IP address transmitted by your browser as part of Google Analytics will not be combined with other Google data. You can prevent the transmission of the data generated and stored by the cookie about your use of the Websites/Applications (including your IP address) to Google and prevent their processing by Google by downloading and installing the module available at https://tools.google.com/dlpage/gaoptout. Additional information on the terms and conditions of use and on the privacy policy of Google Analytics is available at the addresses https://www.google.com/analytics/terms/ and https://www.google.com/policies/privacy/partners/. BC also uses certain third-party cookies, such as Google’s DoubleClick, to display advertising messages on other websites you visit after visiting the Websites/Applications (“remarketing”).
The table below lists the cookies owned by BC and the third-party cookies that are used by BC on the following website: www.belchicken.com
Storage | Name | Provider | Category – Type | Purpose | Validity Duration |
Cookie | _ga | Statistical – HTTP | Uses a unique identifier to generate statistics on how visitors use the Website. | 2 years | |
Cookie | _gat | Statistical – HTTP | Used by Google Analytics to manage search traffic. | Session | |
Cookie | _gid | Statistical – HTTP | Uses a unique identifier to generate statistics on how visitors use the Website. | Session | |
Cookies | accept AlertCookie | Functional cookies / preference cookies – http | Stores the user’s choice regarding the installation of cookies in the cookie band. | 12 months | |
Cookie | Collect | Tracking – Pixel | Used to send device and visitor behavior data to Google Analytics. It tracks the visitor through devices and marketing channels. | Session | |
Cookie | r/collect | doubleclick.net (Google) | Tracking – Pixel | Used to send device and visitor behavior data to Google Analytics. It tracks the visitor through devices and marketing channels. | Session |
Cookie | Fr | Tracking – HTTP | Used by Facebook to deliver a range of ads for products, such as real-time auctions, from third-party advertisers. | 3 months | |
Cookie | Tr | Tracking – Pixel | Installed by Facebook to create personalized audiences based on activity on our Website and measure ad conversion activity (which ads lead to results such as purchases). | Session |
Social media plug-ins
BC uses social plug-ins for social networks. BC also uses cookies of the “Pixel” type Facebook as described under the tables in Article 9.c above.
Social plug-ins allow you to “follow” our accounts on social networks such as Twitter, Facebook and Instagram from our Websites/Applications. Social media plug-ins allow us to recognize you based on your profile on the relevant social networks and display personalized advertisements for our products on those social networks.
More information on this can be found in the privacy policies of your social networks. If you do not wish to connect with your social networks, please unsubscribe from them before using our Websites or Applications (and reject/delete cookies from social networks).
BC has no influence on the nature and extent of the data that the social network may collect. Only the website of the social network determines what data is collected through the social plug-ins, for what purposes it is used, and how long it is kept. For more information on the processing of data through the social plug-ins of the social networks, BC refers you to the privacy policy of the respective social network.
Twitter: https://twitter.com/en/privacy.
Facebook: https://www.facebook.com/about/privacy/.
Instagram: https://help.instagram.com/519522125107875.
10 – Links to third party websites
The Websites/Applications may contain hyperlinks or references to other third-party websites. When you use these hyperlinks or references, you are leaving the Websites/Applications. Current Privacy and Cookies Policy does not apply to these other third party websites. BC therefore recommends that you consult the privacy policy applicable to these other websites. BC is not responsible for the privacy policies of third party websites and strongly recommends that you review the privacy policies of each website before providing any Personal Information about yourself.
11 – Contact
If you have any questions, comments or complaints regarding this Policy, or the processing of your Personal Data by BC, please contact us at the email address privacy@belchicken.com.
12 – Amendment of this Policy
We reserve the right to modify this Policy at any time. You undertake to regularly consult the Policy published and accessible on the Websites/Applications. When modifying the Policy, BC will consider your legitimate interests. You will receive a notification when the Policy is updated. By actively using the Websites/Applications after receiving such notice, you acknowledge that you have read the updates to the Policy. If you do not accept the Policy (as amended from time to time), please cease all use of the Websites and Applications.
Last update: April 202 or