Privacy Policy

  1. Preamble

    1. This Privacy Policy constitutes an integral part of the General Conditions https://bloot24.nl/cgv, the definitions used in these are also used in this Privacy Policy.
    2. This Privacy Policy is aimed at informing the Members on the way in which their Personal Data is collected via the Platform, how these are processed by the Data Processor and finally the rights of the Members in regards to this Processing as defined hereafter..
  2. Definitions

    The following terms, whether used in the singular or plural in this Privacy Policy are defined as follows:

    Archiving
    Refers to the movement of Personal Data which still presents an administrative interest to the Data Processor, (for example in a contentious case and/or legal obligation case) into a distinct database which is logistically or physically separate, and for which, in either case, access is limited. This archiving is an intermediary step before the deletion of the Personal Data in question, or its anonymization.
    Privacy Policy
    Refers to this confidentiality policy and the protection of Personal Data of Members implemented by the Data Processor which constitutes an integral part of the GTSU.
    GTSU
    Refers to the General Terms of Service and Use https://bloot24.nl/cgv
    Personal data
    Refers to data which is personal to the Member, within the meaning of the Regulation of Personal Data, collected and processed by the Data Processor in the framework of the creation and management of one’s personal Profile and the use of Services.
    Regulations on personal data
    dRefers to Law n°78-17 of the 6th of January 1978 regarding data processing, files and civil liberties and modified on the 7th of October 2016, as well as all regulations that would come to be applied to personal data, in particular in the application of the Community Regulation of the 27th of April 2016 published in the Official Journal of the European Union on the 4th of May 2016 in regards to the protection of individuals with regards to the processing of personal data and the free movement of this data.
    Data Processor
    Refers to the DNX Network Sarl company -
    42 Rue de Hollerich - L-1740 Luxembourg
    Plateform
    Refers to the DNX NETWORK SARL webcams platform
    "Devices"
    Refers to the hardware (computer, tablet, smartphone, phone, etc.) used by the Member and/or the web user to consult or view the Platform and/or any other digital media edited by a third party.
    Processing
    Refers to, within the meaning of the Regulation on Personal Data, any action or set of actions, whether or not they are performed with the help of automated processes, applied to Personal Data, such as collection, registration, organization, structuring, preservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other way of making it available, alignment or interconnectivity, limitation, erasure or destruction.
  3. The legal basis of the Processing

    General regulations for the protection of data.

  4. Purposes of Processing

    The Personal Data of the Member is necessary to allow them access to the Services, the use of these services and their improvement, and to allow the Data Processor to:

    • carry out actions relating to their commercial relationship with the Member, i.e. concerning invoices, accounting, monitoring the "customer relationship" with a Member, such as conducting satisfaction surveys, management of complaints, use of the Platform and more generally Services, etc. ;
    • select Members to carry out studies, surveys and product tests, as well as loyalty, prospecting and promoting activities;
    • personalise their communication for the Members, in particular via email, in accordance with their noted preferences, from their use of the Services;
    • carry out activities relating to prospecting, in other words the management of technical prospecting activities (which notably includes technical activities such as standardization, enhancement and deduplication);
    • carrying out commercial soliciting activities;
    • the development of commercial statistics; analyses and tools in marketing (notably classification, score, etc.)
    • the organisation of contests, lotteries or all promotional activities, excluding online gambling subject to the approval of the Regulatory Authority for Online Games;
    • management of applications for the exercising of rights;
    • management of debts and litigation;
    • management of Members' comments on the Platform and/or on the web pages edited by the Data Processors, such as social network pages;
    • the fight against fraud.
  5. The storage of personal data

    1. The platform is hosted by the companies whose names and details are listed below:
      eBRC Windhof
      3 Rue Pierre Flammang
      8339 Windhof
      Luxembourg
      http://www.ebrc.com/
    2. All precautions have been taken to store the Personal Data of Members in a secure environment and to prevent them from being altered, damaged or for unauthorised third parties to have access to them. The information transmitted by the Member will never be transmitted to a third party with a commercial aim, nor sold or exchanged.
  6. The collection of Personal Data on the Platform

    1. The Data Processor collects, during the creation of an Account, and as and when this is complete, the following Personal Data, which the Member submits or communicates while browsing, and which is kept for a duration of three (3) years, in an active database, from the last connection of the Member to the Platform :
      • Email address
      • Identifier used on Platform
      • Payment ID
      • If applicable, the reason(s) for the exclusion (all of the elements which demonstrate the actions dating less than one month and which justify the exclusion)
      • Connection data (date, time, IP address, pages visited) of the Member whilst browsing on the Platform
      The Personal Data above is also kept in the Intermediary Archive for a duration of two (2) extra years, in accordance with the common limitation period.
      • Payment Tickets
      • Amount of the transactions carried out as well as the date and time of these transactions
      The Personal Data above are also kept in the Intermediary Archive for a duration of ten (10) extra years, in accordance with the fiscal and accounting obligations of the Data Processor.
    2. Only the Personal Data defined on the Platform as obligatory is indispensable to have an Account.
  7. Recipients or recipient categories if they exist

    Country in which data recipient is establishedNature of transmitted dataPurpose of proposed transferData recipient categoriesLevel of protection offered by the country or exception provided for by the Regulations on Personal Data
    MALTAPaymentPaymentPayment providerSubject to the European GDPR regulation
    EUPaymentPaymentPayment providerSubject to the European GDPR regulation
    IrelandTrackingAnalysis of trafficAnalysis of trafficSubject to the European GDPR regulation
    SwitzerlandTrackingAnalysis of trafficAnalysis of trafficSubject to the Swiss regulation
    USAPersonal DataClient supportCustomer relationship management software
  8. Security of transactions on the Internet

    1. In accordance with the General Conditions, the Platform uses the technology of an external partner, to secure the bank transactions of the Members.
    2. Thus, when paying on the Platform, the bank details of the Member are transmitted encrypted to an external partner, without the Data Processor being able to read them.
    3. The Data Processor does not collect the full number of the Member's bank card, nor the cryptogram.
  9. The rights of Members

    1. The member can, at any time:
      • Oppose and/or cancel and/or limit and/or withdraw their consent to all or part of the Processing of their Personal Data made within the framework of the Services provided on the Platform for legitimate reasons;
      • Access all their Personal Data processed in the framework of the Services, including for portability purposes provided that this is specified
      • Correct and/or update their processed Personal Data in the framework of the Services!
      • get an audio reading of this privacy policy.
    2. Additionally, the Member has the opportunity to define, with the Data Processor, the guidelines for the retention, erasure and communication of their Personal Data after their death, which may also be registered with "a third party whose digital trustworthiness is certified". These guidelines, or "digital will" of sorts, may designate a person to perform them; failing this, the next of kin of the Member will be appointed.
    3. In the absence of any guidance, the next of kin may contact the Company in order to:
      • access data processing which allows for "the organization and settlement of the legacy of the deceased";
      • receive communications of "digital assets" or "data on family memories, communicable to next of kin";
      • proceed to closing their Account and oppose further processing of their Personal Data
    4. In all circumstances, the Member can indicate, at any time, to the Data Processor that they do not wish, in the event of death, to have their Personal Data communicated to a third party
    5. These rights can be exercised at any time with the Data Processor:
      • Via email to the following address: data@dnxnetwork.lu
      • By postal mail to the following address:
        DNX Network Sarl - 42 Rue de Hollerich - L-1740 Luxembourg
    6. For the purpose of asserting their rights under the conditions set out above, the Member must prove their identity by mentioning their surname, forename, e-mail address and accompanying their application for the copy with their identity card.
    7. The Member can also bring a claim before the competent supervisory authority (http://www.cnpd.public.lu/).
  10. The security of your password

    1. The Data Processor takes all necessary precautions to ensure the secure storage of the password of the Member.
    2. However, the security of this password also depends on its design.
    3. Also, the Member is reminded that their password must be composed of at least 8 characters in order to be valid.
    4. Blocking of multiple tries: account access temporarily suspended after several "captcha" failures
    5. Mnemonic techniques make it possible to create complex passwords, such as:
      • keep only the first letters of the words of a sentence; for example, the phrase "One password is memorable!” becomes the password 1P@im!
      • putting a majuscule if the word is a noun (e.g. Password)
      • keeping punctuation symbols (e.g. !)
      • expressing numbers using figures from 1 to 9 (e.g. one ->1)
  11. The cookies stored on the Device of the Member following their browsing on the Platform

    1. Cookies are used on the Platform
    2. A cookie is a piece of information stored on the Device which allows the Member to access the Platform
    3. Cookies are related to the Member's navigation on the Platform and are used to determine which pages they have viewed, their date and time of viewing.
    4. At no point do these cookies allow the Platform to personally identify the Member.
    5. The duration these cookies are kept in the Device of the web user and/or the Member does not exceed thirteen (13) months.
    6. More specifically, Personal Data collected from cookies issued by the Data Processor or third parties allow:
    7. the establishment of statistics and volumes of frequenting and use of the Platform to improve the interest and ergonomics of our Services;
    8. to adapt the presentation of the Platform to the display preferences of the Member’s Device (language used, display resolution, operating system used, etc.);
    9. to memorize information relating to a form completed by the Member on the Platform (inscription or access to your account);
    10. to allow the Member to access their personal Profile thanks to pre-recorded identifiers;
    11. to implement security measures, for example when the Member is asked to log back into the Platform after a certain amount of time;
    12. Thanks to cookies, the Data Processor collects and processes for the purposes defined here above, all or part of the following Data:
    13. Information linked with the Device of the Member and/or internet user:

      • Device type (Smartphone, tablet, computer, etc.);
      • Operating system of their Device (Mac Os, iOS, Android, Windows, BlackBerry etc.);
      • The categories and versions of the plug-in of their Device,
      • Their internet supplier (Orange, SFR, Bouygues, Free, etc.);
      • The browser they use (Safari, Chrome, Internet explorer, etc.);
      • The advertising identifier linked to the operating system of their Device;
      • The IP address of their Device;
      • The geolocation data of their Device;
      • Their language preferences.
    14. Information on their browsing and their behaviour on the Platform:
      • the statistics on their views of different pages on the Platform;
    15. the complete URL routing to, via and from the Platform;
    16. Information concerning the Member (age or age group, sex, socio-professional category declared and/or inferred, interests inferred, etc.) related to their activity on the Internet and communicated by third parties (advertisers, advertising agencies, etc).
  12. Cookies of the Data Processor

    Service and type of cookieRole of cookie and data collectedDuration
    Site settingsLast used settings for sounds, notifications , visualisation12 months
    Visitor identificationLast used visitor id12 months
    Site session IDID for session trackingsession
    Campaign trackingIdentifiers to track marketing campaigns12 months
  13. Third party cookies

    Service and type of cookieRole of cookie and data collectedDuration
    Google AnalyticsCampaign tracking24 months
  14. Opposition to cookies

    1. The web user and/or Member is informed, from their first visit, that they can reject the storing of cookies which are ancillary to the functioning of the Platform, which they can do by configuring their Internet browser to do this or by exercising their choices on this page (see below).
    2. When the web user and/or Member browses on the Platform, information may be stored, or read, in their Device, according to their choices.
    3. Do you accept the submission and reading of cookies so that we can analyse your interests to customize the website during your visit?

      • Yes
      • No

      Do you accept the submission and reading of cookies so that we can analyse your browsing and allow us to measure the audience on our Site:

      • Yes
      • No

      Do you accept the submission and reading of cookies so that we and our partners can analyse your interests to offer you personalised advertisements?

      • Yes
      • No

      Do you accept the submission and/or reading of cookies to allow you to share the contents of our site with other people or to make known to these other people your browsing or your opinions (Facebook "Like" buttons for example):

      • Yes
      • No
      You can inform us of your choice by sending this questionnaire back to data@dnxnetwork.lu.
    4. You can find more help on the dedicated pages of your browser (the most popular browsers here below):
    5. The web user/Member can also set their browser to send a code informing websites that they don’t want to be tracked (“Do No Track” option):
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