General
The Libaro website is operated by Libaro, a private limited company, registered under business number BE 0541.352.248 ("Libaro BV"). In this privacy statement, Libaro informs you about the use of your personal data on the Libaro website ("Privacy Statement").
Libaro is considered a data controller for certain processing activities (see article 3.2) and a data processor for others (see article 3.1). Libaro does not take this responsibility lightly. Libaro handles your personal data in a responsible manner. Your personal data is carefully processed and secured in accordance with applicable regulations, such as the General Data Protection Regulation of 27 April 2016 (also known as "GDPR") and the law on the protection of natural persons with regard to the processing of personal data of 30 July 2018. In particular, the principles of privacy by design and data minimization are strictly observed.
Does Libaro process personal data?
To make optimal use of our services, an account must be created on Libaro for each user. This account requires the registration of your name, email address, password, phone number, and company name, among other things.
In addition, personal data is processed depending on the services used. This processing is necessary for the proper functioning of the service. The services that Libaro offers include:
- Creating a Libaro account;
- Managing store information
- Managing store reservations
Why does Libaro process this data?
Depending on the capacity in which you use Libaro's services (as an employee of one of our customers (your employer), a visitor invited by one of our customers, or a third party), Libaro acts as a processor or a data controller.
Libaro as a processor for customer services
If you are an employee or a visitor invited by one of our customers, and you use the services within Libaro, we process your personal data for providing the services that we make available at the request and on behalf of your employer.
Depending on the services chosen by the employer (see article 2), Libaro will process certain personal data when this service is used via Libaro. For a detailed overview, we refer you to your employer's applicable privacy statement.
This data is processed by Libaro on behalf of and for the account of the employer, who determines the purpose and means of the processing activities. Libaro therefore limits itself to processing this personal data in accordance with and within the limits of the processor agreement concluded with your employer. Libaro therefore acts as a processor here, and not as a data controller. We therefore refer you to your employer's applicable privacy statement.
Libaro as the data controller of your personal data
Billing purposes for the customer
If you are an employee or a visitor invited by one of our customers, and you use the service via Libaro, we process personal data that is necessary to prepare the invoice.
We process the data that allows us to know which services you use and with what frequency, so that we can map out how much your employer has to pay for the services used. This data may, depending on the services you use (see article 2), include, for example, name, email address and location.
For this purpose, we only process the personal data that is strictly necessary to draw up the invoice in order to fulfill our contractual obligations towards our customer (your employer). This processing is therefore necessary for the protection of our legitimate interest, namely to be able to fulfill our contractual obligations towards your employer. In doing so, we ensure that your fundamental rights and freedoms remain respected.
Services to third parties
If you, as a third party, i.e. without being connected to one of our customers, use our services through our Libaro application, a direct contract is established between you and Libaro. In this context, we will then process certain personal data, depending on the services you use (see article 2), to enable this service provision. This processing of personal data is therefore necessary to perform a contract concluded with you.
Analysis for service improvement
As soon as you use our Application (regardless of your capacity), we will collect certain personal data (usage data) with a view to improving our services. The processing of this personal data is based on our legitimate interest, namely improving our services.
Based on these analyses, we can see where the needs of our users lie, and adapt our services accordingly. This processing of personal data also benefits you. In doing so, we also ensure that your fundamental rights and freedoms remain respected.
Direct marketing and profiling
Your personal data will only be used for direct marketing purposes if Libaro has obtained your explicit prior consent ("opt-in") for this when creating your account on our Libaro application.
If you have given such consent, you can withdraw this consent at any time. If you wish to withdraw your consent for direct marketing, you can email the following email address: info@libaro.be.
With whom does Libaro share this data?
Your personal data is kept strictly confidential and is generally not shared with third parties, with the exception of what is stated below.
Where Libaro acts as a data controller, it can use other service providers for the processing of personal data. These service providers will act as processors. They may only process the personal data on our behalf. Libaro has concluded a processor agreement with these processors. This obliges the processor to comply with all legal provisions and the provisions of this Privacy Statement, among other things.
Where Libaro acts as a processor, Libaro can - with the consent of the data controller - engage so-called sub-processors. Libaro will also enter into the necessary processor agreements with these sub-processors, so that your rights as a data subject remain guaranteed. Your personal data is only processed within the European Economic Area.
How does Libaro secure this data?
Libaro continuously takes appropriate technical and organizational measures to secure your personal data to prevent loss, unlawful use, or unlawful processing of your personal data by others, and also to prevent unauthorized access to your personal data. Libaro was developed with due observance of the "privacy by design principle" by, among other things, encrypting visitors' passwords.
How long does Libaro store this data?
Libaro only stores your personal data for as long as this is necessary for the described purposes. In this way, we also prevent irrelevant information from being stored.
Since the contractual liability claim only expires after 10 years, we will archive certain data - only for this purpose - for this period. As you can see below, you can always ask us to delete certain data. Libaro will always comply with this if the legal conditions for this are met (see article 7).
Your rights
You have the right to access the personal data that Libaro holds about you (and to receive a copy of it). You have the right to correct the personal data that Libaro holds about you if it is incorrect or outdated and/or to have it supplemented if it is incomplete.
- You have the right to object, with a reason, to the processing of your personal data where it is based on a "legitimate interest" of Libaro. If Libaro processes your personal data for direct marketing purposes, you do not even need to give a reason for such a request.
- If processing takes place based on the consent you have provided, you always have the right to withdraw this consent.
- You have the right, in principle, to obtain the personal data that Libaro holds about you in a structured, commonly used, and machine-readable format and to transfer it to another data controller.
- In principle, you have the right to ask Libaro to delete your personal data and/or account. However, you also have the right to request that the processing of your personal data be limited (for example: making personal data inaccessible).
To exercise your rights, please contact Libaro by sending an email to info@libaro.be.
Changes
Libaro reserves the right to change this Privacy Statement. The changes will be announced via our website libaro.be. Libaro advises you to view the Privacy Statement regularly.
Questions and complaints
Privacy is a sensitive issue, and rightly so. If you have questions or complaints, do not hesitate to contact Libaro by sending an email to info@libaro.be. You can also file a complaint with the Data Protection Authority via contact@apd-gba.be.
