Privacy Policy

This website (excluding sites linked to it) and the Citymesh services are managed by us, the Citymesh Group, incorporated under the laws of Belgium, with its registered offices in Siemenslaan 13, 8020 Oostkamp, Belgium, represented by Citymesh Integrator, registered at the Crossroads Bank for Enterprises under number 0881.653.685, in its quality as Data Controller (hereinafter “Citymesh”), in compliance with articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter “GDPR”).

Citymesh Group includes:

• Citymesh Integrator NV, Siemenslaan 13, 8020 Oostkamp, Belgium, registered at the Crossroads Bank for Enterprises under number 0881.653.685
• Citymesh Flex BV, Siemenslaan 13, 8020 Oostkamp, Belgium, registered at the Crossroads Bank for Enterprises under number 0650.535.151
• Citymesh 0G NV, Siemenslaan 13, 8020 Oostkamp, Belgium, registered at the Crossroads Bank for Enterprises under number 0632.450.985
• Citymesh Critical Solutions BV, Siemenslaan 13, 8020 Oostkamp, Belgium, registered at the Crossroads Bank for Enterprises under number 0660.612.065
• Citymesh Safety Drones BV, Siemenslaan 13, 8020 Oostkamp, Belgium, registered at the Crossroads Bank for Enterprises under number 0644.634.482
• Citymesh Integrator, Siemenslaan 13, 8020 Oostkamp, Belgium, registered at the Crossroads Bank for Enterprises under number 0881.653.685
• Citymesh Connect BV, Siemenslaan 13, 8020 Oostkamp, Belgium, registered at the Crossroads Bank for Enterprises under number 0712.645.340
• nCentric Europe Belgium, Siemenslaan 13, 8020 Oostkamp, Belgium, registered at the Crossroads Bank for Enterprises under number 0881.653.685
• EDPnet Belgium BV, Bellestraat 30, 9100 Sint-Niklaas, Belgium, egistered at the Crossroads Bank for Enterprises under number 0799.091.641

This privacy statement indicates, among other things, which information on this website and due to the services we offer, are collected by us, how we use this information and how the information is protected.

We also explain how, in the provision of( inter)personal and electronic communication services and/or for the provision of (digital) services activated by you through your contract with a Citymesh Group company (hereinafter the “Services”) as well as, upon the occurrence of the conditions specified below, Citymesh explains (in paragraphs 1 – 8) the purposes and legal basis for which we collect and process your personal data, which categories of data are processed, the transfers of data and modalities they happen, which rights you have as a data subject (hereinafter “data subject”, “you”, “your”, “yours”) and how to exercise them.

Citymesh has appointed a Data Protection Officer (hereinafter “DPO”), pursuant GDPR, who can be contacted by writing for the attention of Data Protection Officer, Siemenslaan 13, 8020 Oostkamp or via [email protected].

1. WHY DOES CITYMESH COLLECT DATA?

1.1. Website use

On certain parts of the website you will be asked to provide your (personal) data, such as your name, e-mail address and/or address details. This information can be used by us for various purposes.

The data will be used by us for the purpose as stated on the website. For example, to be able to participate in a campaign or to be able to answer your questions.

If you have given us permission to do so, we can also use your details to contact you by e-mail and/or text message with news about Citymesh products and promotions.

In addition, we may use your name and address to send you information about Citymesh and products by post. If we want to contact you by telephone, we can use your telephone number (if you have provided us with this).

Furthermore, we may supplement the data with other information that we already have or that we receive from third parties. We do this for marketing purposes and to better tailor our products and services to your needs.

1.2. Products and services

When Citymesh performs certain services to you, we will process your (personal) data for:

1.2.1. For execution of the contract

Your personal data will be processed for the management of the contractual relationship (for example, for the invoicing of fees, handling payments or claims you may submit to us, credit collection, etc.) and to provide the services you have requested. In particular, for this purpose, Citymesh may process the data indicated in paragraph 3.

In case you are a Citymesh Connect/EDPnet customer, Citymesh will process data indicated in paragraph 3, Citymesh will make your data anonymous, as soon as they are no longer necessary for the transmission of the communication, except for fulfilment of legal obligations or for the sole purpose of invoicing or making interconnection payments.

1.2.2. For fulfilment of legal obligations

As telecom provider, Citymesh has certain legal obligations in collecting personal data. Specifically, Citymesh may process your data for the fulfilment of accounting and tax obligations, for the fulfilment of judicial authority orders to prevent and repress crimes.

1.2.3. In pursuit of its own legitimate interest

With reference to the subscription services (Citymesh Connect/EDPnet), in order to carry out the preliminary checks connected with the conclusion of the contract, Citymesh may process:

• the data indicated in paragraph 3 to check your creditworthiness and punctuality of payments by accessing the IT systems of authorised companies that provide credit risk management and fraud control services and that process the data in their capacity as Data Controllers; and
• data relating to the status and punctuality of your payments with reference to contracts already in place.

Citymesh may use the e-mail address you have provided to send commercial communications regarding services and/or products similar to those covered by the contract.

Within the context of art. 9 of the Royal Decree of 12 September 2018 on the obligations applicable to the provision of paid services as referred to in Article 116/1, §2, of the Law of 13 June 2005 on electronic communications, Citymesh may process and share your data with third party services and/or content providers, providers acting in their capacity as data controllers (“third data controllers”) for the purposes of pursuing their own legitimate interests, since you have provided them with your Citymesh mobile number in order to use/subscribe to their services.

Citymesh may record your interactions with the customer care with the exclusive and solely purpose to control the quality of service of its call centres, in compliance with Article 10/1 of Law 30 July 2018 relating to the protection of individuals with regard to the processing of personal data. Furthermore, Citymesh may carry out activities aimed at improving the services provided (including the customer care service) and related to the contractual relationship also by means of technologically advanced tools (i.e. artificial intelligence tools) and also with the help of third parties in quality of Data Recipients.

1.2.4. For marketing purposes, subject to your consent

When you voluntary and freely checked the box (opt-in), Citymesh may use your data in order to send you commercial and marketing communications. These communications may be sent through automated communication channels (e.g. SMS, e-mail) and through traditional channels (operator calls, paper mail). Furthermore, Citymesh may process the data provided by you and those acquired during the use of the services to perform market research and analyse the customer satisfaction level.

1.2.5. For data enrichment purposes, subject to your consent

With your consent, Citymesh may enrich the personal data provided by you and those collected during your use of Citymesh services with data acquired from third parties (e.g. content providers, service providers, social media).

These parties will only disclose your personal data to Citymesh if you have given your specific consent to do so. The enrichment of personal data is functional to improve your experience when using the services and to offer you services in line with your needs.

2. TO WHOM CAN CITYMESH PROVIDE DATA?

It is possible that we commission third parties to collect, process and/or analyse the (personal) data, which are provided on our websites or otherwise. It may also be necessary to provide your information to a third party so that we can provide you with a product or service that you have ordered from us. These third parties may only use the data for the aforementioned purposes. Any other use is prohibited.

For the implementation of the contract, the fulfilment of legal obligations and the pursuit of its legitimate interests, Citymesh may disclose your personal data to the following categories of persons:

• parties that provide services for the management of edpnet’s IT system;
• parties involved in the transmission, mailing, forwarding and sorting of the data subject’s communications;
• parties who carry out debt collection services
• parties who carry out control, audit and certifications on the activities carried out by edpnet also in the interest of its customers and users;
• other telecommunications operators, for the management of interconnection and roaming relationships;
• group companies;
• subsidiary, parent and associated companies;
• credit transferee companies;
• parties who perform technical and organisational tasks on behalf of edpnet;
• sales agents, firms and companies as part of service and consultancy relationships;
• public authorities, if the conditions are met;

Furthermore, Citymesh will not provide your information to other third parties without your prior consent, unless it is obliged to do so pursuant to a statutory provision or a court ruling.

3. WHAT OTHER INFORMATION / DATA IS COLLECTED?

3.1. Website

Certain information is collected by means of cookies. A cookie is a small text file that a server can place on the hard disk of your computer. A cookie contains information about you as a visitor to the website. Cookies can be used to collect certain information during your visit to the website, such as the specific parts of the website that you visited and the services that you use on the website. We collect this information in order to better tailor our website and our services to your interests and needs.

Cookies are also used to remember passwords, usernames and preferences. You have the option to set your browser to refuse cookies. This may adversely affect your use of the website.

Information about your computer, such as your IP address, the type of internet browser and the type of operating system you use, can also be collected and linked to your data.

3.2. Products and services

Citymesh will process:

1. the personal data provided by you when entering into the contract for the provision of Services;
2. In case of a mobile subscription with Citymehs Connect and/or EDPnet, certain personal data that may be acquired by other means during the course of the contractual relationship, such as:
   1. Name, surname, date of birth, citizenship, gender, eID card and national register numbers, residential or home address and contact details telephone, e-mail address, Facebook and WhatsApp eID;
   2. Telephone and electronic traffic data;
   3. Bank and/or payment data to Citymesh
   4. Data relating to the position of your device determined by GPS coordinates or information about the telephone cells you are connected to while using telecommunication services;
   5. Data provided by third parties in the context of partnerships with Citymesh;
   6. Data on your creditworthiness and payment punctuality, also acquired through the IT systems of authorised companies providing credit risk management and fraud control services;
   7. Data relating to your consumption habits and/or interests;
   8. Data belonging to special categories within the meaning of Article 9 GDPR;
   9. Data relating to suspected criminal activities, within the meaning of Article 10 GDPR, provided by judicial authorities as part of their own requests;
   10. Data processed or generated as part of the provision of electronic communications networks or services.

3.3. Activities, fairs, events and business-related occasions

If you are present at an activity organised by Citymesh, a fair, event or other business-related occasion, or if you meet a Citymesh representative at a commercial event organised by third parties, it may happen that Citymesh will or has photos and/or video material taken. By being present at such occasions, you agree that images of you (photo/video) may be taken and that Citymesh can and may use these for marketing purposes such as but not limited to promotional videos. You also agree that Citymesh may use and publish these images on its website and social media channels such as Facebook and LinkedIn.

4. IS CITYMESH RESPONSIBLE FOR OTHER WEBSITES?

The website may contain references (for example by means of a hyperlink, banner or button) to other sites that relate to a specific aspect of this website. This does not automatically mean that Citymesh is connected to these other sites or their owners. We are therefore not responsible for the compliance of these third parties with the privacy legislation.

5. HOW DOES CITYMESH PROTECT THE DATA?

Citymesh ensures appropriate technical and organizational measures to protect your (personal) data against loss and against any form of unlawful processing, in a manner such as to guarantee the security and confidentiality of the data such as: security of your passwords, encryption software, firewalls, antivirus, intrusion and anomaly detection, as well as control for the Citymesh authorised appointed employees (the number of Employees who have access to your personal data are limited and access is only granted insofar as these specific data are required to perform their tasks properly).

Your data is only processed within the European Union.

6. PROCESSING TERM AND RETENTION PERIOD

Citymesh will only process personal data for the time necessary for the purposes mentioned as set out hereafter:

• Execution of contract

As long as you are a Citymesh customer, or you are a website visitor, your data will be collected during the whole term of collaboration. In case our collaboration stops, we will retain certain personal data during a period of minimum thirty (30) calendar days and a maximum of 7 years.

In case of mobile data use, traffic data will be retained for a maximum period of six months for billing purposes or for making interconnection payments, without prejudice to any further specific retention required as a result of a dispute, including in court.

In the provision of data traffic or location data service, Citymesh limits the processing of your geographic location to the acts and duration necessary to provide the services in question.

• Legitimate interest

The data processed for the pursuit of Citymesh’ legitimate interest will be processed for the time strictly necessary for the pursuit of that interest, namely:

• data collected and needed for a correct execution of the contract, will be processed until the termination of the contract;
• data relating to the status and punctuality of your payments to Citymesh will be retained for the entire duration of the contract and until last payment of the final invoice by Citymesh after termination of the contract;
• Contact information for Marketing purposes for the term of consent (opt-in) until the termination of the contractual relationship, unless you have previously entered a request to opt-out. For what concerns the usage of images/photos, Citymesh has the right to use these images for the duration of its campaign or as long as it deems necessary for commercial and marketing purposes. If they are individual photos, you have the right to have your images removed via a simple request to [email protected]. If your images have been incorporated into promotional videos, however, a request to remove your images is not possible.
• data collected for the purposes to control the quality of service in call centres will be processed for a maximum of one month;
• In case of mobile subscription with Citymesh Connect/EDPnetGeolocation and traffic data
  • for the purpose of proper functioning and security of the network or service, are stored for 12 months from the date of communication, except in the event of a specific security breach of the network requiring the retention of the data concerned to be extended beyond this period;
  • for the purpose of detecting and analysing fraud or malicious use of the network are retained for 4 months, except in the event of specific fraud or malicious use requiring extension the retention of the data concerned beyond this period.
  • Legal obligation.

As Citymesh is legally required to do so, it will retain data processed for the purpose of fulfilling legal obligations to the extent provided for by law and for as long as the need for processing persists in order to fulfil said legal obligations;

The information regarding both incoming and outgoing telephone and electronic communications, excluding the actual content of the communications is retained for 12 months for the purposes (i) to prevent end users of Citymesh from be harmed or bothered and detect fraud and malicious use on their networks and services, pursuant to the Law of 13 June 2005 concerning electronic communications; and (ii) to provide you with the most advantageous alternative tariff plans of Citymesh, if it is applicable pursuant to the Law of 13 June 2005 concerning electronic communications.

For the purposes of safeguarding national security, combating serious crime, preventing serious threats to public security, and safeguarding the vital interests of a natural person Citymesh will retain the data indicated in paragraph 2.b), point x) for a maximum of 12 months, or according to specific geographical areas defined by Law 13 June 2005 concerning electronic communications, for another maximum subsequent 12 months.

7. WHAT RIGHTS DO YOU HAVE?

You have the right to ask Citymesh which (personal) data of you are processed. Citymesh will respond to this request (in writing) within one month.

You can then request Citymesh to complete, correct or delete your personal information or you can indicate that this information may not be used for direct marketing purposes. Your request concerning the cancellation – and/or limitation of processing – of your personal data can be sent by e-mail to [email protected] , and attaching a valid identification document to your request.

We inform you that, in case of a legal obligation, we cannot just stop or delete the processing of certain data. In this case, our response to you will so name it.

If Citymesh lacks to respond within 30 days to your request or if it refuses to do so in your opinion, or if our response does not meet your expectations, you can lodge a complaint with the Belgian Data Protection Authority, Drukpersstraat 35, 1000 Brussels, or via [email protected], who will start a mediation procedure.

8. CAN THIS PRIVACY STATEMENT BE CHANGED?

In the future, Citymesh may decide to amend this privacy statement if, for example, we, to the extent permitted by law, will process other (personal) data and/or provide this data to third parties that are not mentioned in this privacy statement.

If this privacy policy is changed, you can always find the most recently published version on this page. If the law so requires, Citymesh will inform you individually.

9. ADDITIONAL INFORMATION

9.1. GENERAL

Definitions

Anonymised/anonymous data: Personal data made anonymous through a process which is non-reversible within the limits of the technology applicable from time to time.

Consent: means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to them.

Legitimate Interest: any interest of the Data controller or third parties for which the data processing is necessary to achieve it and it is overriding to the interests, rights and freedoms of the data subject.

Traffic Data: the identifier of the origin of the communication; the identifier of the destination of the communication; the precise dates and times of start and end of the communication; the telephone number from which the incoming communication originated; the IP address used to send the incoming communication, the timestamp and the port used; and the precise dates and times of the start and end of the incoming)

Data processed or generated as part of the provisioning of electronic communications networks or Services: Data referred to in Articles 126, § 1 and 126/2, § 2 of Law 13 June 2005 concerning electronic communications.

Legal Disclaimers

This Privacy Notice has been drawn up with due observance of the obligations in GDPR and the provisions of European Directive 2002/58/EC.

Citymesh may use your personal data for new purposes that are not yet provided for in our “Privacy Notice”. In that case, we will contact you before using your data for these new purposes, to inform you of the changes to our regulations for the protection of personal data and to give you the opportunity to refuse your participation.

• EDPNET BELGIUM – CITYMESH CONNECT

Edpnet and Citymesh Connect are both an Other Licensed Operator (OLO). This means that we can develop our own internet access services for use on the Proximus xDSL and Fiber PON network and to market, distribute and sell them under our name and for our account. Proximus is fully responsible for the operation of its copper and fibre network. In the capacity of Proximus as Network Operator, Proximus may process your data on their behalf for purposes such as: (i) the delivery of the Services; (ii) maintenance, repairs, improvement and development of the Proximus infrastructure; (iii) legal obligations.

Edpnet and Citymesh Connect are both Light Mobile Virtual Network Operator (Light MVNO). This means that we can develop our own mobile services on the Orange, resp. Proximus,  mobile network, and to market, distribute and sell them under our name and for our account. Orange, resp. Proximus, is fully responsible for the operation of its mobile network. In the capacity of Network Operator, Orange may process your data for purposes such as: (i) the delivery of the Services; (ii) maintenance, repairs, improvement and development of the Orange, resp. Proximus, infrastructure; (iii) legal obligations.

For further information, we invite you to read the Privacy Notice of our Network Operator Partners.