Privacy Policy

By “personal data processing” we mean any data processing that can identify you as a natural person. Point 5 of this policy describes precisely what data is involved. The concept of “processing” is broad and covers, among other things, the collection, recording, organisation, storage, updating, modification, request, consultation, use, dissemination or any other form of provision, reconciliation, combination, archiving, erasure or permanent destruction of such data.

To avoid any misunderstanding, personal data processing for business customers is only relevant if the business client is a natural person. If the business client is a legal entity, the privacy policy is only valid for personal data of the natural persons we deal with as part of their relationship with the business customer (such as agents, contact persons and / or end users).

IP Nexia nv, with registered office at 2 Kouterveldstraat, 1831 Diegem and registered with the ECB under number 462.900.331 (hereinafter referred to as “IP Nexia”), is responsible for the processing of your personal data. This means that IP Nexia determines the purpose and resources for processing your personal data.

If, as an IP Nexia customer, you authorise end users (family, friends or employees) to use the Nexia IP products and services covered by this privacy policy, you have the following responsibilities:

• you must adequately inform end users that IP Nexia, through their use of Nexia IP products and services, will process their personal data;
• you must obtain all required end-user authorisations before disclosing their personal data to IP Nexia for processing as part of the Nexia IP products and services that you authorise them to use;
• you must adequately inform end-users about the applicability of this policy, including in terms of privacy rights and how they may be exercised;
• you may not use Nexia IP products and services to collect personal data that is inconsistent with applicable privacy law or to unlawfully access personal data of end users;
• you must take all reasonable steps to ensure the reliability of the end users who have access to the personal data;
• you cannot do, provoke, or authorise anything that could in any way result in a violation of the privacy policy.

Through our Nexia IP products and services, you may also use services from other parties such as third-party websites, forums, Facebook, Twitter, newsgroups and / or apps. IP Nexia has no control over, and assumes no responsibility regarding the information you place there and the way it is processed. It is up to you to use common sense in this regard and to check the privacy policy of these third parties.

• Personal data you share with us: by telephone (for example, when you call customer service to ask a question or to report a problem), in writing (for example, when filling out an order form (online), or when sending us an SMS or an e-mail).
• Personal data collected by our systems (for example, an e-mail address, an IP address, a telephone number, a customer number, login codes, passwords, etc.).
• Personal data that we obtain from third parties (for example, the solvency analysis of prospects that we obtain from credit controllers or data relating to your mobile use abroad that are transmitted to us by other telecom operators so that we can bill correctly).

 

• Categories of personal data: in our systems, we distinguish different types of personal data that can be combined:

• User data: we distinguish personal data that identifies you as a user of our products and services (e.g. your name), personal data that allows us to contact you (for example, your address, your e-mail address and your telephone number) or your billing and payment data (including your credit information) and any other preferences that you communicate via your settings on My IP Nexia, our customer service, social networks, websites and mobile applications, etc.;
• Technical data: we need it to ensure the smooth operation of our products and services. (the model and service number of your modem-routers);
• Traffic data: we need this particular technical data to adjust your traffic on electronic communication networks (e.g. your IP address or MAC address);
• Data about your usage: for example, the (mobile) phone numbers called, the date, time, duration and location of a conversation or an Internet connection, how you use our websites or data relating to the use of our services. We use this data in particular to be able to invoice you correctly as a customer and offer you a better, more personalized experience.

As required by law, we do not process sensitive data, including information about your racial or ethnic origin, political opinions, sexual orientation or health.

We process personal data for various purposes; in this context, we only deal with the data that is essential to achieve the objective.

Thus, we use personal data when it is necessary:

• In the context of the preparation, execution or termination of our contract;
• to comply with the legal or regulatory provisions to which we are subject; and/or
• to defend our legitimate interests (business or business reasons), in which case we always strive to maintain a balance between these interests and respect for your privacy.

If the processing of your personal data is not essential for one of these three reasons, we will always ask for your permission to process this data.

We collect personal data for the following concrete purposes:

Reasons why we use your personal data	Legal basis allowing this use	Our legitimate interests
Supply services to you Communicate with you and send you information about your service or product	Execute contracts Our legitimate interests Your consent	Keeping our archives up-to-date and identifying products and services that might interest you Creating products and services and determining the applicable pricing Identifying or defining customer categories for new products or services To be efficient in the execution of our contracts, providing our services and complying with our legal obligations
Communicate with you and manage the relationship we have with you Personalise and improve your customer experience Inform you about new products that we propose and offers that could interest you	Execute contracts Our legitimate interests Your consent	Keeping our archives up-to-date and identifying products and services that might interest you Creating products and services and determining the applicable pricing Identifying or defining customer categories for new products or services To be efficient in the execution of our contracts, providing our services and complying with our legal obligations
Detect, investigate and prevent fraud and financial offences Manage the risk to us and our customers Respect applicable laws and regulations and how we provide our services Respond to complaints and seek to resolve them	Execute contracts Our legitimate interests Our legal obligations Your consent	To be efficient in the execution of our contracts, providing our services and complying with our legal obligations Identify ways in which we can improve services to our customers
Manage our activities effectively and appropriately Perform our administrative tasks including accounting, billing and audit needs Improve our services Manage our relationships with other companies which offer us, and also you, goods and services. Protect our business interests	Execute contracts Our legitimate interests Our legal obligations	To be efficient in the execution of our contracts, providing our services and complying with our legal obligations Identify ways in which we can improve services to our customers
Develop and manage our brands, products and services Test new products and services	Execute contracts Our legitimate interests Our legal obligations	To be efficient in the execution of our contracts, providing our services and complying with our legal obligations Identify ways in which we can improve services to our customers

We do everything we can to protect your personal data and your privacy.

We protect your personal data against unauthorised access, illegal use, accidental loss, corruption or destruction. We use technical measures like encryption or using passwords to protect your data and the systems on which it is stored. We ensure that these security measures are regularly reviewed, and we rely on industry safety standards to keep us informed of best practices.

Our employees have been trained to handle confidential data correctly. The number of employees in our company with access to your personal information is limited and our employees are carefully selected. They only have access to your personal data for as long as they need this information to properly perform their tasks.

Your personal communications are confidential. We may process metadata (i.e., data that is processed to allow communication from a technical point of view), but the existence and content of personal communications made through our network (for example: landline and mobile telephone conversations, e-mails and SMS) are protected by the provisions on telecommunications secrecy.

This means that IP Nexia, apart from the exceptions listed by law, cannot be aware of the existence or content of such communications. IP Nexia has taken the necessary protective measures and given proper instructions to its employees to respect the secrecy of telecommunications.

We do not sell or transfer personal data to third parties except (if):

• To our successors and other companies within the IP Nexia Group
• It is necessary for our services. We make some of our databases available to third parties who work on our behalf and assist us in the delivery of our products and services. For example, our partner in charge of billing and sending paper invoices, commercial agents, independent technicians and customer service staff (external) who assist our customers on a daily basis. Your data is only transmitted for the purposes for which IP Nexia processes your data itself and this transmission is limited to the data that these third parties need for the task they perform for us. We make sure that they process your data, just like we do, in a safe, respectful and responsible manner and we provide the appropriate contractual guarantees for this purpose.
• There is a legal obligation
• There is a legitimate interest for IP Nexia or the relevant third party We will only transmit your personal data if your interest or fundamental rights and freedoms do not prevail and you will always be informed in full transparency (except in the case of legal exceptions). For example, your personal data may be passed on to credit controllers, collection offices and legal service providers, as well as to partners with whom we collaborate in a specific action.
• You give us your authorisation If IP Nexia provides personal data to third parties in other situations, this is always done with an explicit notification, giving an explanation about the third party, the purposes of communication and the processing. If required by law, we ask for your explicit permission. A few examples: depending on your choice when concluding your contract, your essential subscriber data is transmitted to and listed in the phone book and / or files of the information service.

We do not transmit any personal data outside of national borders and we do not use any aggregated or anonymous data.

We use your data to provide you with our services and for general communications about products that you have with us or that may be of interest to you. At this level, personal data is processed in the context of our legal obligations, our legitimate interests and the proper performance of your contract (including the management of claims and customers, as well as the transmission of information on the network and the service as well as their improvement).

If we wish to collect your personal data for specific purposes, we will always inform you, and if required by law, we will ask for your consent in the communication we provide in this regard.

You always have the right to object, without having to justify yourself, to the use of your personal data for direct marketing purposes. To do so, you can always contact Nexia IP Customer Service and disable our possibility of promotions and / or actions by phone, mail, SMS or e-mail; you can also:

• if you do not want to receive any more commercial phone calls: register on the list “Do not call me anymore” (www.dncm.be/fr/). IP Nexia takes this into account, even if you are already a customer with us;
• if you no longer wish to receive commercial mail: subscribe to the Robinson list ( www.robinsonlist.be ). IP Nexia takes this into account when dealing with non-clients. Likewise, if as a customer you don’t want to receive advertising by mail, you can contact Nexia IP Customer Service;
• if you no longer want to receive commercial SMS: react by sending “STOP” to the number that sent you the SMS;
• if you do not want to receive any more commercial e-mails: use the unsubscribe option in the e-mail in question. In order to improve the effectiveness of e-mail campaigns, we use software to measure whether our e-mails have been opened and which links were clicked;
• if you wish to unsubscribe newsletters: you can unsubscribe from the newsletter by using the opt-out option on the newsletter.

The fact that you no longer wish to receive commercial communications from us is obviously without prejudice to our right to contact you electronically in the performance of your contract or if required by law.

IP Nexia respects:

• Your right to access: You have the right to ask at any time whether IP Nexia processes or not your personal data, and if we do, view data and receive additional information.

 

• Your right to correction: You have the right to immediately correct incomplete, erroneous, inadequate or outdated personal data.

 

• Your right to be forgotten: you have the right, in the following cases, to have your personal data deleted without undue delay:

• your personal data are no longer necessary for the purposes for which they were collected or otherwise processed by IP Nexia;
• you withdraw your previous authorisation regarding the processing and there is no other legal basis that IP Nexia can invoke to continue processing;
• you object to the processing of your personal data and there is no justified basis for IP Nexia to continue processing;
• your personal data is being processed illegitimately;
• your personal data must be erased to fulfil a legal obligation;
• your personal data was collected while you were still a minor.

Please take into account that we cannot always delete all personal data requested, for example when their processing is essential for the finding, exercise or defence of rights in court or because we are required for justice and state security to retain data on mobile and fixed calls from our customers for 12 months.

• Your right to limit processing: you have the right to obtain limitations on the processing of your personal data if one of the following applies:

• you dispute the accuracy of this personal data: their use is limited for a period of time allowing IP Nexia to check the accuracy of the data;
• the processing of your personal data is illegitimate: instead of requesting the deletion of your data, you request that their use be limited;
• IP Nexia no longer needs your data for the initial purposes of processing, but you need it for finding, exercising or defending legal rights: instead of requesting data deletion, their use is limited the finding, exercise or defence of rights in court;
• as long as no decision has been taken regarding the exercise of your right to oppose processing, you request the limitation of the use of your personal data.

• Your right to portability: You have the right to “recover” your personal data, for example to be able to change service provider more easily. This is only possible for personal data that you have provided to IP Nexia yourself, based on an authorisation or a contract.

 

• Your right to oppose processing: You have the right, depending on your particular situation, to object to the processing of your personal data if the processing falls within the legitimate interest of IP Nexia or in the context of the general interest. IP Nexia will suspend the processing of your personal data, unless IP Nexia can demonstrate that there are legitimate and compelling reasons for the processing that prevail over your reasons, or if the processing of personal data is related to the finding, exercise or defence of legal rights (for example, filing an application in court).

Are there any related costs? You may exercise your rights of confidentiality free of charge, unless your request is manifestly unfounded or exaggerated, in particular because of its repetitive nature. In this case, we have the right and the choice – in accordance with privacy legislation – to (i) charge you reasonable fee (taking into account the administrative costs of providing the information or the requested communication and costs associated with taking the requested action), or (ii) refuse to respond to your request.

In which format will I receive an answer? If you submit your application electronically, the information will, if possible, be sent electronically, unless your request states otherwise. In any case, we send you a concise, transparent, understandable and easily accessible answer.

When will I receive an answer? We respond as soon as possible to your request, and in any case within one month of receiving your request. Depending on the complexity of the requests and their number, this period may be extended by two months. In case of extension of the deadline, we will inform you in the month following the receipt of the request.

What can I do if IP Nexia does not respond to my request? We will always inform you, in our response, about the possibility of filing a complaint with the supervisory authority and appealing to the judge.

We cannot store your personal data beyond the time necessary to achieve the purpose for which we collected it. The retention period may therefore differ depending on the purpose and may sometimes be very short. Traffic data for communications and connections is never retained for more than 12 months. Sometimes the retention time can be longer, especially to comply with our legal obligations (to meet our accounting and tax obligations, we are required, for example, to keep your billing data for up to 7 years) or legal necessity to retain certain data (including your contract, your invoices and your correspondence concerning claims on this subject) as proof in case of disputes, up to 10 years after the termination of your contract. This archived data nevertheless has very limited access.

After the applicable retention periods, the personal data are deleted or made anonymous.

Some old customer data may be used for a period of 2 years after the termination of the contract to identify the former customer and inform them of new IP Nexia products and promotions, unless the customer has manifested his/her disagreement regarding that matter in accordance with the procedure of this Privacy Policy.

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You can control and / or delete cookies as you wish. For more information, visit aboutcookies.org .  You have the option to delete all cookies already stored on your computer and configure most browsers to block them. However, in this case, you may need to specify certain preferences each time you visit a site, and some services and features may not be accessible.

If you would like to contact Nexia IP Customer Service about this privacy policy (for example, to adapt your privacy settings), you can do so in writing (by mail or e-mail) or by phone. You will find all information about IP Nexia customer service on: https://www.ipnexia.com/contact/

For more information about this privacy policy or any complaints about the processing of your personal data, you can contact the IP Nexia Data Protection Officer via privacy@ipnexia.com

IP Nexia may change this privacy policy from time to time, for example as a result of market developments and new IP Nexia processing activities.

We therefore invite you to always consult the latest version of this policy on our website (http://www.ipnexia.com/privacy-policy/).

In the event of a conflict, our terms and conditions and the specific terms and conditions applicable to specific IP Nexia products and services prevail over this privacy policy.

For complaints about the processing of your personal data by IP Nexia, you can contact the Commission for the protection of privacy which is the Data Protection Authority, rue de la Presse 35, 1000 Brussels / +32 (0) 2 274 48 00 / commission@privacycommission.be / www.privacycommission.be .