We understand that your trust in us, is RAM Mobile Data’s most important asset (hereinafter referred to as “RAM”, “we” or “us”). As such, your privacy is essential for us.
This privacy statement (hereinafter referred to as “Privacy Statement”) is applicable, inter alia, to (i) our website https://www.track-and-trace.eu or https://www.track-and-trace.eu/nl-nl (hereinafter referred to as the “Website”) and (ii) all (commercial) relations between RAM and its customers, prospects and business partners.
This Privacy Statement includes information about the personal data collected by RAM, as well as the manner in which RAM uses and processes this personal data.
RAM wishes to emphasize that it always attempts to act in accordance with (i) the Belgian Privacy Law of 8 December 1992 on privacy protection in relation to the processing of personal data and/or (ii) the EU Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC and (iii) all (future) Belgian laws regarding the implementation of this Regulation.
Visiting the Website implies your explicit approval (through disclosure of your personal information or opt-in) of the Privacy Statement and consequently how we collect, use and process your personal data.
I. Types of personal data
RAM can collect and process the following personal data:
- E-mail address
- Telephone number (landline and/or mobile phone)
- Number of vehicles
- Account name
- Residence address
- Customer number
- National Insurance number
- Birth date
- Birth year
- Social media data
- Company name
- Company address
- Invoicing address
- Communication preference
- Geographical location data
- All personal data provided in the ‘free field’ when completing a contact form
- All personal data freely provided to RAM (e.g. in light of correspondence with RAM).
RAM also automatically collects anonymous information regarding your use of the Website. As such, RAM shall, for example, automatically log which sections of the Website and Platform you visit, which web browser you use, which website you visited when you obtained access to the Website. We cannot identify you through these data, but it allows RAM to draw up statistics regarding the use of the Website.
II. Methods of personal data collection:
These personal data are collected in the context of:
- Visiting the Website
- Collaboration with RAM
- Incoming and outgoing correspondence with RAM
- Visiting the office/building of RAM
- Creation of a (demo-)account
- Requesting an offer, information or a demo
- Subscription to the newsletter (whether or not through the Website)
- Appealing on the services of RAM, whether or not through the Website and/or whether or not via a mobile device
- Subcription to a webinar/seminar/event/etc.
- Exchanging business cards
- Verification of your identity (e.g. when a data subject contacts customer service)
All personal data, collected by RAM, are thus expressly and voluntarily provided by you.
Providing certain personal data is (sometimes) a requirement to be able to enjoy certain services (e.g. to gain access to certain parts of the Website, to subscribe to newsletters, to participate in certain activities and events). In this respect, it shall be indicated which data must be provided mandatory and which data is optional.
You (as admin user) are the controller yourself, so you are responsible for keeping the user accounts of your employees up-to-date within the track-and-trace application. When creating the user accounts of yourself and your employees, you give permission to use the personal data of the aforementioned persons for the purposes as described in chapter III Use personal data below.
III. Use of personal data
RAM can use your personal data for the following purposes:
- Performance of the agreement with RAM (incl. follow-up thereof)
- Responding to questions (whether or not received through the contact form)
- Optimising the quality, management and content of the Website
- Sending newsletters
- Sending invitations for events
- Creating statistics
- Creation of an account (free or paying) and the confirmation thereof
- Providing support/assistance (e.g. in case of problems)
- Send targeted marketing and advertising, updates and promotional offers based on your communication preferences and – where applicable – upon explicit consent
- Conducting customer satisfaction studies, surveys and other market research
- Registration of visitors of the office/building of RAM
- Confirmation of the subscription of a webinar/seminar/event/etc.
- Issuing invoices and the collection thereof
Processing takes place on the following legal grounds, as the case may be:
- U have given consent to the processing of your personal data for one or more specific purposes
- Processing is necessary for the performance of the agreement with RAM or in order to take steps at your request prior to entering into an agreement
- Processing is necessary for compliance with a legal obligation to which RAM is subject
- Processing is necessary in order to protect your vital interests or of another natural person
- Processing is necessary for the performance of a task carried out in the public interest
- Processing is necessary for the purposes of the legitimate interests pursued by RAM or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data (in particular when you are a child).
IV. Disclosure of personal data to third parties
RAM shall not disclose your personal data to third parties, unless it is necessary in the context of performing the agreement and optimisation thereof (including but not limited to RAM). In this respect, your personal data may be disclosed to payment providers, software providers, cloud partner, transport partners.
If it is necessary that RAM discloses your personal data to third parties, the third party concerned is required to use your personal data in accordance with the provisions of this Privacy Statement.
Notwithstanding the foregoing, it is however possible that RAM discloses your personal data:
- To the competent authorities (i) if RAM is obliged to do so under the law or under legal or future legal proceedings and (ii) to safeguard and defend our rights
- If RAM, or the majority of its assets, are taken over by a third party, in which case your personal data – which RAM has collected – shall be one of the transferred assets
In all other cases, RAM will not sell, hire out or pass on your personal data to third parties, except when it (i) has obtained your permission to this end and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your personal data.
V. Cross-border processing of personal data
Any transfer of personal data outside the European Economic Area (EEA) to a recipient whose domicile or registered office is in a country which does not fall under the adequacy decision enacted by the European Commission, shall be governed by the provisions of a data transfer agreement, which shall contain (i) the standard contractual clauses, as referred to in the ‘European Commission decision of 5 February 2010 (Decision 2010/87/EC)’, or (ii) any other mechanism pursuant to privacy legislation, or any other regulations pertaining to the processing of personal data.
VI. Storage of personal data
Unless a longer storage period is required or justified (i) by law or (ii) through compliance with another legal obligation, RAM shall only store your personal data for the period necessary to achieve and fulfil the purpose in question, as specified in the Privacy Statement under ‘Use of personal data’.
VII. Your privacy rights
In light of the processing of your personal data, you enjoy the following privacy rights:
- Right of access to your personal data
- Right to rectification, completion or update of your personal data
- Right to delete your personal data (‘right to be forgotten’). (RAM wishes to point out that in this context certain services will no longer be accessible and/or can no longer be provided if you delete resp. request deletion of certain required personal data)
- Right to limit the processing of your personal data
- Right to transferability of your personal data
- Right to object to/oppose the processing of your personal data
If you wish to invoke your privacy rights please contact firstname.lastname@example.org.
In principle, you can exercise these rights free of charge via the above-mentioned form. In addition, you can always, via your personal account, update, modify and/or verify your personal data, which you were required to submit when creating your account.
If you no longer wish to receive newsletters or information about the services of RAM, you can unsubscribe at any time by clicking the “unsubscribe” button underneath each of RAM’s emails.
VIII. Security of personal data
RAM undertakes to take reasonable, physical, technological and organisational precautions in order to avoid (i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data.
RAM shall store all personal data, which it has collected in the cloud with data centre(s) in EU, Onsite.
Notwithstanding RAM’ security policy, the checks it carries out and the actions it proposes in this context, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the internet, or any method of electronic storage is 100% secure, RAM is, in this context, not in a position to guarantee absolute security.
Finally, the security of your account will also partly depend on the confidentiality and complexity of your password. RAM will never ask for your password, meaning that you will never be required to communicate it personally. If you have nonetheless communicated your password to a third party – for example because this third party has indicated that it wishes to offer additional services – this third party shall have access to your account and your personal data via your password. In such cases, you are liable for the transactions which occur as a result of the use made of your account. RAM therefore strongly advises you, if you observe that someone has accessed your account, to immediately change your password and contact us.
IX. Update Privacy Statement
RAM is entitled to update this Privacy Statement by posting a new version on the Website. As such, it is strongly recommended to regularly consult the Website and the page displaying the Privacy Statement, to make sure that you are aware of any changes.
X. Other websites
The Website may potentially contain hyperlinks to other websites. When you click on one of these links, you may be redirected to another website or internet source that could collect information about you through cookies or other technologies. RAM does not bear any responsibility, liability or control authority over these other websites or internet resources, nor about their collection, use and disclosure of your personal data. You must check the privacy statements of these other websites and internet sources in order to be able to judge whether they act in accordance with the Privacy Legislation.
XI. Contact RAM
If you have questions and/or remarks about this Privacy Statement or the manner in which RAM collects, uses and/or processes your personal data, please contact us:
- Via e-mail: email@example.com
In case you are not satisfied with the way RAM handled your questions and/or remarks or have any complaints about the way RAM collects, uses and and/or processes your personal data, note that you have the right to lodge a complaint with the Privacy Commission.