Below Zero (“Below”), data holder, informs you about the purposes and methods of processing your data in accordance with applicable national law and General Data Protection Regulation № 679/2016 (“GDPR”).
Using our services, you transmit or share with us some information that permits us in some cases to provide the service, in other cases to satisfy you requirements to make it better. The present document explains you:
- what data we use;
- why and what legal basic we have to collect your data;
- how your data are used;
- which data are obligatory and which are optional;
- for how long your data are stored;
- who can have access to your data;
- who can receive your data;
- where your data can be transferred;
- what rights do you have;
- who is your data holder and who is Data Protection Officer.
1. What data do we use?
In Below Zero we use different types of your personal data (hereinafter “personal data” or “data”), i.e.:
- identifying and insensitive data you provide such as: surname, name, identifying document, fiscal code, address, email, telephone number, credit card and data relating to the Below Zero services you have used. These data were provided when subscribing for Below Zero – also through fiber – to request for services or products of Below Zero (e.g. account activation, subscription services, offers etc.) and later for example if you contact with business partners of Below Zero;
- data connected with your preferences and interests, in particular: use of content, services, functions, time of connection, traffic data, browsing data in site and social profiles of Below Zero or business partners or third parties, IP-address, used device and connection. These data could be collected by cookies and metadata; data identifying your position during user session collected by IP-address and Country Code;
- data obtained by cookies and DTH during user session, among them data connected with access to portal RIV and related services included in your subscription, the use of contents, time of connection, browsing mode, used functions, your preferences, purchased services and traffic data.
2. Why and what legal basic do we have to collect your data?
Data you provide permit us on the one hand to carry out all the contract administrative activities and to satisfy your requests; on the other hand, it helps us to understand your habits, interests and preferences to give you more personalized services and make them evolve according to your needs.
Your personal data are proceeded for the following purposes and on legal basic:
- without your prior permission for the purposes of use, in particular, for execution of a contract or precontracting commitments:
- to activate, provide, suspend and manage your subscription and connected services providing billing, sending and assisting service communications;
- to provide you with commercial offers services of Below Zero;
- to make better technical assistance, customer care activities, our services, contents and products by analyzing statistics aggregated on anonymous basis, e.g. analysis of your conversations with our call center operators. In particular your calls are analyzed anonymously, after alteration and rendering them unidentifiable in the vocal content, using speech technics and keywords analytics;
- to carry out analysis of statistics aggregated on anonymous basis;
- to permit you to download, use, update and maintain App Below Zero in your devices if supported;
- to approve registration, also by websites
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- RIV CASH loyalty program that allows you to manage your business using RIV platform with white label strategy;
- to register on Below Zero websites, manage and update sites and your account, use services offered by Below Zero websites;
- to communicate your personal data to business partner for sales opportunity verification comparing your data with partner database.
The pursuit of a legitimate interest of the owner:
- to manage complaints and disputes, compensate the credits, prevent frauds and illicit activities;
to exercise rights and protect legitimate interests of the Holder or Third Holders, for example, the right of defense in the court;
- to send you commercial messages to the email address you provide, if you are already our client, about services and products of Below Zero similar to those you have already used. Every sent email permits you to refuse further submissions by clicking appropriate link.
the fulfilment of legal obligations:
respect and fulfill obligations provided by law, regulations, orders and requirements of competent authorities.
- only after receiving your permission for other purposes, exactly for:
marketing purpose such as to inform you by ordinary letters, telephone calls, email, web push messages, SMS, MMS, notifications and newsletters about initiatives and offers of Below Zero and to propose you questionnaires and researches of Below Zero market;
profiling purpose such as:
- to analyze, also automatically, your preferences and interests (for example, use of contents and services, including those purchased, used functionalities, connection time, traffic data etc.) and propose you (by ordinary letters, telephone calls, email, web push messages, SMS, MMS, notifications and newsletters) personalized services, contents, initiatives and offers;
- to analyze, also automatically, your preferences and interests in using Below Zero, connection time, traffic data, page visualization and/or video content in Below Zero sites and propose you (by ordinary letters, telephone calls, email, web push messages, SMS, MMS, notifications and newsletters) personalized services, contents, initiatives and offers;
- to analyze, also automatically, data about using of Below Zero services – by your consent providing during the service activation process;
- to analyze your preferences and interests (for example, access, use of contents and services, connection time, the vision of audiovisual contents, used functionalities, traffic data etc.) and propose you (by ordinary letters, telephone calls, email, web push messages, SMS, MMS, notifications and newsletters) personalized services, contents, initiatives and offers.
3. How are your data used?
Your personal data are used for operation of collecting, registration, organization, conservation, consultation, analysis, combination, elaboration, modification, selection, extraction, comparison of databases (for example to check the offer sales opportunity), use, interconnection, crossover, blocking, communication, cancellation and distribution of data. Your personal data are subjected to paper, electronic, automated processing, and are stored on a database.
4. Which data are obligatory and which are optional?
Among the information we collect some is essential to conclude and administer your contract, other helps us to offer you better service every day. In particular:
- provision of your personal data processed for the service purposes, is necessary to subscribe and use the Below Zero services;
- provision of your personal data processed for the other purposes, is optional. Their absence does not prevent you from using Below Zero services, but you will not be able to receive our commercial messages and personalized offers.
5. For how long are your data stored?
Below Zero keeps and use personal data for no more than 10 years from the end of use and for prescribed time required by law; for no more than 13 months from the end of marketing use, for your consent period and for no more than 36 months from profile data collecting. Afterwards your data are made anonymous and are proceeded for aggregated and anonymous statistics analysis.
6. Who can have access to your data?
We care a lot about your privacy and do everything to protect it. Therefore, we share your data only when it is strictly necessary and only with those who help us to offer you better services every day. Your data are accessible to:
- employees and/or collaborators of Below Zero or company Below Zero Group who help to create, maintain and improve all services of Below Zero as representatives and/or internal managers and/or system administrators;
- company Below Zero Group, business partners and service providers who carry out outsourcing activities on behalf of Below Zero, as internal managers carry out instrumental or support activities of Below Zero, for example, management and maintenance of websites and Below Zero Apps contents, client support, customer care and call center services, management of Information Technology systems, editorial services, credit recovery, data processing services for billing, payments with archiving of clients documentation etc.
7. Who can receive your data?
Below Zero can communicate your data without your expressed consent for using purposes to:
- judicial agencies at their request;
- company Below Zero Group and other subjects who need to be communicated by law or by contract to allow fulfilment of above-mentioned purposes (as for example, credit institutions, professional studies, business partners)
Below Zero can communicate your data to company Below Zero Group to allow fulfilment of above-mentioned autonomous marketing purposes: to this purpose, Below Zero asks you specific consent before the communication. These subjects will retain your data as autonomous data holders. In any case, we would like to assure you that your data would not be diffused.
8. Where can your data be transferred?
Your data may be transferred outside the European Union to the subjects specified in paragraphs 6 and 7. To protect your data during these transfers Below Zero adopts appropriate guarantees, among them adequate decisions and standard contractual clauses approved by European Commission.
9. What rights do you have?
Until now we have talked about how we use your data and how we behave; now we are going to talk about your rights in order to control your privacy and information. If there are no restrictions required by law, you have right to:
have confirmation of existence or absence of your personal data even if you have not yet registered and request these data at your disposal in a clear and understandable way;
ask for information and, if necessary, copy of:
- the origins and category of your personal data;
- the use logic in case your information is proceeded with electronic tools;
- the purposes and methods of processing;
- identification details of the Holder or managers;
- subjects or categories of subjects who may be communicated with your personal data or who may be aware of them;
- the period when your data are stored or the criteria used to determine this period when possible;
- existence of the automatized decision-making process, including profiling. In this case you can request for used logic, importance and consequences for you;
- existence of adequate guarantees in case of data transfer to outside EU country or to international organization;
- obtain without justifiable delay updating, modification, correction of your incorrect data or integration of incomplete data you are interested;
cancel, block your data or, where possible, transform them into anonymous form:
- if they are proceeded illegally;
- if they are not needed for the purposes they collected or afterwards proceeded;
- in case of revocation of the consent the proceeding is based on and in case of other legal basis absence;
- in case of your opposition to proceeding and if there are no further legitimate reasons to continue using your data
- in case if it is imposed by law;
- in case related to underage.
The Holder, namely Below Zero, could refuse to cancel your data in case of:
- exercise of the right to freedom of expression and information;
- fulfillment of law obligation, exercise of the public interest task or public authorities;
- reasons of public health interests;
- archiving in public interests, scientific or historical research or for statistics purposes;
- ascertainment, exercise or defense of the right in a court;
limit the proceeding in case of:
- contest of your personal data accuracy, if you did not request to modify, update or correct your data;
- illegal proceeding of Holder, namely Below Zero, to prevent cancellation;
- exercise of your right in court;
- verification of probable dominance of Holder legal reasons towards those of the interested party;
- receive, if the processing is carried out by automatic tools, without impediments and in structured legible and sharing format your personal data provided by your consent or by contract to transfer them to other Holder or – if it is technically feasible – to obtain direct transfer from one Holder to another;
oppose at any moment totally or partly:
- for legal and prevalent reasons related to your particular situation and proceeding your personal data;
- proceeding your personal data in marketing and/or profiling purposes where they are carried out (e.g. you can oppose to sending the advertising or the direct sale or market research or commercial communication, by using automatic call systems without operator intervention, with email and traditional marketing methods, with telephone and paper mail)
For all above-mentioned cases, if necessary, Below Zero will inform third parties that are communicated with your personal data about your possible exercise of rights, with the exception of specific cases (e.g. when such fulfillment appears to be impossible or involve a use of means manifestly disproportionate to the protected right).
At any moment you can modify or revoke a given consent and exercise your rights in different ways: in Personal Area of Below Zero sites, by sending a request to Below Kft. – Data Protection Officer, Batthyány Lajos utca 117 1182 Budapest - Hungary or by sending an email to the following address email@example.com or to our DPO firstname.lastname@example.org
Finally you have right to complain about proceedings mentioned in this notification to Guarantor for the Protection of Personal Data in your country of residence.
10. Who is your data holder and who is Data Protection Officer?
For any requirement, remember that the Holder of your personal data is Below Zero Kft., with registered office in Batthyány Lajos utca 117 1182 Budapest – Hungary
Our Data Protection Officer works in the Legal Department. You can contact him at email@example.com
The updated list of our data holders is available at the Below Zero Kft offices.
This information may be changed. For each update, we invite you to consult our websites and other channels provided by Below Zero.