Privacy Policy

1. General

Brussels Airport Company NV (hereafter: “Brussels Airport” or “we”) values your privacy and Personal Data (as defined below) and therefore protects and processes your Personal Data only in accordance with the Belgian privacy law of 30 July 2018[1], including changes brought about by the General Data Protection Regulation (GDPR)[2].

This privacy policy shall be applicable to the Website (as defined here below),

2. Definitions

Data Subject means an identified or identifiable natural person, who can be identified, either directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Personal Data means any information relating to an identified or identifiable natural person;

Purpose(s) means the purposes for which the personal data is processed, as set out in detail in this privacy policy;

Third Party means a natural or legal person, public authority, agency or body other than the Data Subject, Brussels Airport, processor(s) of Brussels Airport and persons who, under the direct authority of the controller or processor, are authorized to process personal data;

Website means www. batc .be;

3. Scope

With this privacy policy, Brussels Airport wants to offer full transparency to the Data Subjects whose Personal Data are processed via the Website,. Therefore, Brussels Airport shall set out in this privacy policy when and which Personal Data is processed, and for which purposes it is done so. This privacy policy applies to all processing of Personal Data by or on behalf of Brussels Airport.

4. Personal data we process and why we process it

Brussels Airport may collect several types of Personal Data from Data Subjects visiting the Website and may store it on its servers. Such Personal Data may include:

• Direct identifiers (e.g. your full name)
• Contact information (e.g. your postal address, e-mail address, phone number);
• Information provided in helpdesk support inquiries;
• Web behavior information such as information related to how Data Subjects use the Website(e.g. browser type, domains, page views) collected through cookies and other automated technology (see our Cookie Policy for more information);
• Electronic identifiers, i.e. IP addresses (i.e. a unique string of numbers that identifies each network connected device (e.g. laptop, tablet, smartphone) enabling the communication and exchange of information with other devices over an IP-based network, such as the Internet) to manage the Website and ensure that relevant information is sent to your computer;
• Location information (based upon your IP-address).

We may process general user data, such as most frequently requested pages, which shall not be linked to any identified user, in order to provide comprehensible Websitewhich directly address the needs of the general users. In the event we detect a common pattern, we may be able to place more targeted information on our Website, which is mostly requested and viewed. This way we can further optimize the services we offer to you through our Website.

Brussels Airport (i) collects, (ii) uses, and (iii) maintains the Personal Data provided by the Data Subject or collected by Brussels Airport for all purposes necessary to ensure the proper (technical) functioning of the Website.

In general, Brussels Airport collects your Personal Data for an overarching goal: offering each Data Subject that makes use of the Website a safe, optimal and personalized experience. Dependent on whether the Data Subject makes intensive use of the Website or relies on certain services, the collection of Personal Data may be more or less extensive.

Other purposes for data collection and processing of your Personal Data through the Website may include:

• Providing you access to and participation on the Website and the use of the services provided through the Website, including customer service;
• Diagnosing technical problems and managing technical support and processing inquiries concerning the Website;
• Commercializing the Website;
• Direct marketing purposes, insofar Brussels Airport has obtained the explicit consent of the Data Subject hereto; 
• Performing data analyses (including anonymization and aggregation of Personal Data);
• The operation, evaluation and improvement of the Website (including the development of additional products and/or services, enhancing and improving the current Website, analysis of our Website, quality control activities and performing internal business functions such as accounting and auditing);
• Protecting against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
• Complying with and enforcing any applicable legal obligations, our disclaimer and privacy policy.

5. Security

We shall take appropriate technical, organisational and administrative measures against unauthorized or unlawful processing of any of your Personal Data or its accidental loss, destruction or damage, access, disclosure or use.

In the event of a personal data breach (e.g. breach of security of the Personal Data, or access by an unauthorized person) at Brussels Airport in which your Personal Data is involved, we shall take all necessary measures to mitigate any consequences of such personal data breach, and to avoid such breach in the future. We are required by law to notify you if the personal data breach is likely to affect your fundamental rights and freedoms and constitutes a risk to your privacy.

6. Disclosure to Third Parties

We shall not sell, transfer or otherwise disclose your Personal Data to Third Parties without obtaining your prior explicit consent, unless set out otherwise in this privacy policy, and unless this is necessary for the Purpose(s) as set out in this privacy policy, or unless we are required to do so by law.

We may share Personal Data with cloud service providers and other service providers who help us provide, understand, commercialize and improve our business activities. We do not authorize these service providers to use or disclose your Personal Data, except as strictly necessary to perform any services under our supervision or to comply with applicable legislation. We guarantee that your Personal Data shall only be disclosed to such service provider insofar as necessary for them to perform their specific function.

Such service providers shall in any event be obliged to treat your Personal Data in accordance with the provisions as set out in this privacy policy. However, we cannot be held liable for any damages, whether direct or indirect, that may result from the misuse of your Personal Data by such service providers.

7. Data transfers to countries outside the EEA

In certain cases, Brussels Airport may transfer and/or store your Personal Data in countries outside the European Economic Area. However, in such cases, we guarantee that the transfer shall take place in accordance with the relevant legal requirements and we ensure that the third country shall be able to guarantee an adequate level of protection of your Personal Data. The EU standard contractual clauses shall be utilized where necessary, and appropriate data transfer agreements shall be concluded.

8. Your rights as a data subject

We shall process your Personal Data solely in a fair and lawfully manner, which includes that the Personal Data provided to us shall only be processed for the abovementioned explicit and legitimate Purpose(s). We ensure that the processed Personal Data is adequate, accurate, relevant and not excessive. However, you, as a data subject, are also granted several rights relating to the Personal Data you have shared with us, so that it is you who will remain in full control of your Personal Data.

My right of access

If you are concerned about the Personal Data that is being processed of you, or if you have any questions regarding your Personal Data, you have the right to request access to the Personal Data which Brussels Airport processes or stores about you.

My right to correct inaccurate Personal Data

We commit to keeping all of your Personal Data accurate and up-to-date, however, it is possible that sometimes we miss some updates. Therefore, you are granted the right to request us, free of charge, to rectify and correct any inaccuracies or incompleteness of your Personal Data.

My right to erasure

Under certain predefined circumstances, you shall have the right to request the erasure of your Personal Data without undue delay. It shall be assessed by Brussels Airport on a case-by-case basis whether or not your request qualifies for the erasure of your Personal Data. In the event your request falls under one of the predefined circumstances, and no exceptions as set out in the GDPR apply, your Personal Data shall be erased out of the internal systems at Brussels Airport. However, it is possible that the deleted Personal Data remains temporarily stored in our Brussels Airport’s back-up system. We shall take all reasonable steps to erase all Personal Data to the maximum extent possible.

Closely related to your right to erasure, you shall also have the right to be forgotten in the event that your Personal Data has been made public. Your Personal Data shall then be erased out of the internal system, and reasonable technical and organisational measures shall be taken to erase all links to, and copies or reproductions of, the Personal Data.

My right to restrict data processing

In certain predefined circumstances, you may request Brussels Airport to temporarily halt and restrict the processing of the Personal Data in question. It shall be assessed by Brussels Airport on a case-by-case basis whether or not your request qualifies for the restriction of processing. In the event that your request falls under one of the predefined circumstances, Brussels Airport may still store your Personal Data, however any other further processing of your Personal Data shall be restricted and may only be performed either with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.

In the event that the processing of your Personal Data is restricted following your request, we shall inform you before such restriction of processing is lifted.

My right to object to data processing

In certain predefined circumstances, you may object to the processing of your Personal Data by Brussels Airport. This is in short when the processing is based upon public interest or legitimate interest, when the Personal Data is processed for direct marketing purposes, or when the Personal Data is processed for statistical purposes. It shall be assessed by Brussels Airport on a case-by-case basis whether or not your request to object to data processing meets the requirements.

We may solely use your Personal Data to contact you through mail for direct marketing purposes in the event that you have explicitly consented hereto. If you have consented hereto in the past, and you no longer want to receive suggestions and/or direct marketing through mail, you may at any time oppose to such processing and unsubscribe from the mailing list.

My right to data portability

In the event that your Personal Data is processed on the basis of your consent or on the basis of a contract, and the processing is carried out by automated means, you have the right to receive all your Personal Data in a structured, commonly used and machine-readable format. Where technically feasible, you may also request us to transmit such Personal Data directly to another controller without any hindrance insofar this does not adversely affect the rights and freedoms of others.

My right not to be subject to automated individual decision-making, including profiling

In relation to your right to object to data processing, you shall have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal effects for you, or similarly significantly affects you. However, you shall only have this right in certain predefined circumstances, and it shall be assessed by Brussels Airport on a case-by-case basis whether or not your request is eligible.

Automated processing is to be understood as processing performed by machines without human intervention, such as direct marketing, targeted advertising and e-recruitment processes which are performed electronically rather than by a human and based upon which decisions are made. In other words, in case of individual automated decision-making, there is no (significant) human intervention which could correct possible outcomes.

Profiling, on the other hand, is to be understood as the automated processing of your Personal Data to evaluate certain personal aspects (e.g. performance at work, personal preferences, interests, behaviour, location, movements) relating to you, in particular to be able to categorize you on the basis of your Personal Data. Based on these categorizations, (automated) individual decisions can then be made. Profiling shall be subject to the right not to be subject to automated individual decision-making in the event that the decision-making happens fully automated, without any (significant) human intervention which could correct the possible outcomes.

How can you exercise your rights?

You shall be able to exercise the abovementioned rights, or pose any questions concerning this privacy policy or your Personal Data, through a signed, written request to Brussels Airport, by post to Brussels Airport Company NV, Auguste Reyerslaan 80, B-1030 Schaarbeek, or by e-mail to privacy@brusselsairport.be.

9. Data retention and deletion

We shall not retain your Personal Data for a period longer than necessary for the Purpose(s) for which they have been collected or for which they will be further processed. The retention of certain Personal Data may be subject to a retention period as determined by law, which Brussels Airport shall be obliged to adhere to.

10. Third Party websites or applications

As a user of the Website, you acknowledge and agree that certain content or services provided by Third Parties may be made available to you through the Website, or it may be possible to click through websites of Third Parties via the Website. You agree that autonomous privacy policies of such Third Parties regarding the linked content and/or services may be applicable, for which Brussels Airport cannot be held liable, nor for the compliance thereof. Brussels Airport does not in any way review or endorse the privacy policies and/or practices of such Third Parties, and we advise you to carefully read the privacy policies of such Third Parties, where relevant, as the terms and conditions may vary from our privacy policy.

11. Updates and/or changes to our privacy policy

Brussels Airport reserves the right to modify and amend its privacy policy from time to time. If Brussels Airport would use your Personal Data in a manner that is materially different from that stated at the time of the collection, we will provide you with a notice through means considered most appropriate, and in any event through a notice on our Website indicating that the privacy policy has been changed or updated.

 

Contact details:

Brussels Airport Company NV

Auguste Reyerslaan 80

B-1030 Schaarbeek

privacy@brusselsairport.be

 

Last updated: 12/12/2018

 

[1] Law of 30 July 2018 on the protection of individuals with regard to the procecessing of personal data

[2] Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.