Privacy and personal data
Zen Car charter for the protection of privacy and personal data
The Zen Car attaches great importance to the privacy of its affiliates. So we are making every effort to comply with the regulations aimed at guaranteeing protection of privacy, both of the affiliate and of any other natural person associated with the affiliate.
Below you will find further information regarding the personal data that we process, and for what purposes they are processed.
1. Personal data processed
Zen Car collects and processes the following personal data, which includes:
- Expressly stated data: the data expressly stated by the affiliate, such as, inter alia, name (first name and surname), postal address, telephone number (including mobile telephone number), office number, fax number and e-mail address.
- Automatically collected data: automatically collected data such as the data subject’s IP address, type of browser and the operating system of their computer.
2. Purposes of processing personal data
These personal data are collected for the following purposes:
- tracking requests by the affiliate under the execution of the contract,
- advertising and/or commercial communication about their products and services,
- informing the affiliate,
- overview of the customer.
3. Data controller and legal bases of processing
Under execution of the contract, the data controller is Serge Starckmann, Zen Car Holding sa (hereafter, “the Controller”), with registered office at Avenue Louise 523, 1050 Brussels, and registered in the CBE [Crossroads Bank for Enterprises] under number BE 0478.548.411.
Processing of personal data of the affiliate (and if applicable of any other natural person associated with the affiliate) is based on
- Article 5 a) (consent) and b) (execution of contract) of the Act of 8 December 1992 on protection of privacy with regard to processing of personal data; and
- Article 6.1. a) (consent) and b) (execution of contract) of Regulation (EU) 2016/679 of 27 April 2016 (General Data Protection Regulation).
4. Access to, modification of or request to delete personal data
Zen Car is committed to guaranteeing a high level of protection of personal data.
Within the limits of the applicable legislation, any natural person may access their data processed by the Controller (and if applicable, by Zen Car companies within the EEA), and, if applicable, request rectification or deletion of their personal data, or even oppose processing thereof, or request limitation of processing of their personal data, and obtain a copy thereof. Furthermore, they are entitled to receive the personal data supplied in a structured, commonly used and machine readable format, and to pass on these data to another controller (right to data portability). They may exercise these rights at any time, free of charge, by way of an e-mail request to firstname.lastname@example.org.
They may, at any time, on request and free of charge, oppose the processing of their data for purposes of commercial prospecting, and/or withdraw their consent for transfer of their data. They may exercise these rights at any time, free of charge, by way of an e-mail request to email@example.com. It shall be dealt with within the statutory deadlines.
There is no legal provision obliging the affiliate to answer questions asked by Zen Car, however depending on the circumstances, failure to answer may result in Zen Car being unable or unwilling to enter into a (pre-)contractual relationship, continue such a relationship or execute an operation requested by the affiliate or by a third party on the affiliate’s behalf.
The personal data communicated by the affiliate are treated by the Controller in the strictest confidentiality, and in compliance with applicable regulations.
However, in case of electronic transfer of such data, since the Internet does not provide complete security, respect for privacy may only be guaranteed if the data are sent via communication channels that are expressly recognised as protected by Zen Car.
The affiliate has the right to lodge a complaint by contacting the Data Protection Authority (Rue de la Presse, 35, 1000 Brussels, Telephone: +32 (0)2 274 48 00, Fax: +32 (0)2 274 48 35, E-mail: firstname.lastname@example.org).
5. Third parties authorised for communicating personal data
The data may be communicated to third parties designated by the Controller, whose involvement is required for one of the purposes stipulated in this contract, and acting exclusively on the Controller’s instructions.
Provided that an affiliate gives his or her express prior consent, his or her data (including e-mail data) will be additionally transferred to existing and future Zen Car companies within the EEA.
6. Purpose of processing
Personal data processed for the purposes of tracking the affiliate’s requests and for an overview of the affiliate under execution of the contract shall be kept during the term of the contract and for a period of one year from the end of the contractual relationship; if necessary, Zen Car also reserves the right to keep them for longer to satisfy its legal obligations (e.g. accounting).
Personal data processed for the purposes of advertising and/or information and Zen Car marketing communication shall be kept during the term of the contract, and for a period of two years following expiration of the contract.