Route2school Privacy Statement

Summary

Route2School (hereinafter detailed as Route2School MAP and Route2School Education), located at B-3520 Zonhoven, Moverkensstraat 53, is responsible for the processing of your Personal Data via its websitewww.route2school.beand its apps. Route2School processes data from its (prospective) reporters, students, and Project Managers for the following purposes:
• To perform and offer the services of Route2School (as described in the Terms of Use), including collecting bottlenecks on school routes and the travel behavior of students, as well as offering traffic education;
•        Managing requests for information;
• Statistical research and scientific research;
• Improving the functioning of Route2School, the Website, and its apps
• Requesting permission to send newsletters/advertisements;
• Sending newsletters/advertisements;
• Account administration;
• To provide all other services you have requested;
•        Compliance with applicable legislation. 

You can alwaysobjectto the use of your data for direct marketing purposes by contacting us. In addition, you have the right toaccessand/orcorrect your data. 

Data istransferredto the following recipients:
• Processors that provide statistical research and analysis;
• Processors that provide hosting for this Website and related databases;
• The project managers who provide visualization of identified bottlenecks and school routes;
• Scientific research institutions;
• Google Inc., for Google Analytics via Google Analytics cookies; 

1. Definitions

In this Privacy Statement, the following terms shall have the following meanings:

      1. Route2School: ABEONAconsult BVBA is a company incorporated under Belgian law, with its registered office at Moverkensstraat 53, B-3520 Zonhoven, registered with the Crossroads Bank for Enterprises under number 0551.862.890.

      1. Route2School Map: the specific application for collecting bottlenecks and dangerous/safe/sometimes unsafe routes on the way from home to school. The application can be found atroute2school.be/login.

      1. Route2School education: the specific application for teaching road safety education. The application can be found atroute2school.be/educatie/login.

      1. Website: The Route2School website,route2school.beand derivatives (e.g., Route2School Education) developed and operated by Route2School;

      1. Personal data: Any information relating to an identified or identifiable Reporter or Project Manager.

      1. Users: Natural persons who, through their use of Route2School, provide both personal information and information about bottlenecks and problem areas.

      1. Schools: The school to which the student belongs and which has provided us with information about the student.

    2. Processing of personal data

    Route2School attaches great importance to respecting and protecting your privacy and to the confidentiality and security of your personal data. Your personal data will be processed in accordance with the Act of December 8, 1992, on the protection of privacy with regard to the processing of personal data (hereinafter "the Act of December 8, 1992"). Route2School acts as the controller for the processing.

    "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, and applied to the personal data of natural persons, such as the collection, recording, organization, storage, updating, storage, modification, erasure, consultation, disclosure, and use, provision by means of transmission, dissemination, or otherwise making available, combination, interconnection, blocking, or destruction.

     

    3. What personal data

    Route2School may process the following Personal Data via its Website, including, without limitation, via the contact form and cookies:

        • Information about your computer or mobile device and your visits to and use of the Website, including your IP address, operating system, browser type, and geographic location;

        • Any other information that you decide to provide.

      Route2School may process the following Personal Data:

          • Account details provided to us by the user in connection with Route2School (Map): first name, gender, year of birth, role (student/teacher/parent/other), country, street, house number, postal code.

          • Account details provided to us by the user or by the school in the context of Route2School (Education): email address, municipality, school and class of the user, first name and last name, and a profile photo, if applicable.

          • Information about users' travel behavior: mode of transport, route traveled, and experience of the route

          • Scores achieved on all modules of Route2School education

        Route2School may process the following public information:

            • All information relating to reports about public bottlenecks and routes as provided to us via the Route2School application.

          4. For what purposes

           

          Route2School collects Personal Data and processes it for one or more of the following purposes:

          Purposes Legal basis
          Performing and offering the Services of Route2school (as described in the Terms of Use), including promoting traffic safety in school environments. User Consent
          Management of requests for information; Execution of agreement
          Statistical research and scientific research; Legitimate interest[1]
          Improving the functioning of Route2school, the Website, and its apps; Legitimate interest[2]
          Request permission to send newsletter/advertising; Legitimate interest[3]
          Sending a newsletter/advertisement; Permission
          Account administration; Execution of agreement
          To provide all other services you have requested; Execution of agreement
          Compliance with applicable legislation. Legal obligation

          If Route2School wishes to use personal data for an incompatible new purpose, Route2School will ask for your consent prior to this new use.

          5. Transfer of personal data

           

          Personal data is only processed by Route2school for internal use for the purposes described above. We do not rent or sell your Personal Data to third parties for their own purposes.

          Within Route2school, personal data is only made available to its staff on a "need to know" basis.

          Route2school may use processors to process your Personal Data. Processors are natural or legal persons, public authorities, agencies, or other bodies that process Personal Data on behalf of Route2school.

          Route2school transfers Personal Data to the following (categories of) processors:

              • The project managers who visualize bottlenecks and school routes;

              • Processors that provide statistical research and analysis;

              • Processors who provide hosting for this Website and related databases;

              • Google Inc., for Google Analytics via Google Analyticscookies.

            Route2school may change its corporate structure by changing its legal form, mergers, acquisitions, and sales. In such transactions, Personal Data will be transferred in accordance with this Privacy Statement and applicable data protection laws.

            Anonymous data may always be passed on, whether for commercial purposes or not.

            6. Duration of data retention

             

            Route2school stores Personal Data for the following periods.

            Data: Duration:
            Website visit data Unlimited
            Account details 10 years
            Information about users' movement behavior (routes) 10 years
            Scores 10 years
            Scores (anonymized) Unlimited

            Public information about reports may be stored and used by Route2school without restriction.

            7. Confidentiality and security

             

            RouteSchool ensures that the Website complies with rules and security measures designed to protect personal data.

            RouteSchool will:

                • make every effort to keep the data up to date and to correct or delete incorrect, incomplete, or irrelevant data;

                • ensure that, for persons acting under its authority, access to data and processing options are limited to what those persons need to perform their tasks or to what is necessary for the needs of the service;

                • inform all persons acting under its authority of the provisions of the Act of December 8, 1992, and its implementing decrees, as well as of all relevant regulations concerning the protection of privacy that apply to the processing of personal data;

                • verify that programs for the automated processing of personal data comply with the information provided in the declaration to the Commission for the Protection of Privacy and that they are not used unlawfully;

                • ensure that any person acting under the authority of the controller or processor, as well as the processor itself, who has access to personal data, processes such data only on the instructions of the controller, except on the basis of an obligation imposed by or pursuant to a law, decree, or ordinance; and

                • make every effort to ensure the security of personal data, and will ask its partners and subcontractors to take appropriate technical and organizational measures necessary to protect personal data against accidental or unauthorized destruction, accidental loss, alteration or access, and any other unauthorized processing of personal data. These measures must ensure an appropriate level of security, taking into account the state of the art, the costs of implementing the measures, the nature of the data to be secured, and the potential risks.

              If the processing is entrusted to a processor, RouteSchool will

                  • choose a processor that offers sufficient guarantees in terms of technical security measures and organizational measures relating to the processing operations;

                  • ensure that these measures are complied with, in particular by stipulating contractual provisions;

                  • set out in the agreement the processor's liability with regard to the controller;

                  • agree with the processor that it shall act only on the instructions of the controller and that it shall be bound by the same obligations as those to which the controller is bound under the law; and

                  • set out the requirements regarding data protection and security measures in the agreement.

                8. Access to your personal data

                 

                a) Right to access and correct your personal data

                Under the Act of December 8, 1992, you have the right to access personal data relating to you. To do so, you can contact RouteSchool, B-3520 Zonhoven, Moverkensstraat 53, with a dated and signed request, accompanied by a copy of your identity card, or you can contact RouteSchool via the email addressinfo@route2school.be, providing your email with an electronic signature.

                RouteSchool will provide you with the requested information without delay and at the latest within 45 days of receiving such a request.

                b) Right to correct or delete your personal data

                You have the right to have your personal data corrected or deleted free of charge. You can use this form for this purpose.

                Within one month of submitting the request, you will be informed of any corrections or deletions that have been made.

                c) Right to object to the processing of your personal data

                Under the Act of December 8, 1992, you also have the right to object to the processing of your personal data for direct marketing purposes. You can do this free of charge and without giving any reason by sending a dated and signed request to Route2school, B-3520 Zonhoven, Moverkensstraat 53, accompanied by a copy of your identity card, or by contacting RouteSchool via the email addressinfo@RouteSchool.be, providing your email with an electronic signature.

                Within one month of submitting the request, you will be informed of the action taken.

                9. Changes

                RouteSchool reserves the right to change this Privacy Statement at any time.

                This Privacy Statement was last amended on April 5, 2019.

                10. Miscellaneous

                If one or more clauses in this Privacy Statement are declared partially or completely invalid or non-binding by a court, this shall not affect the validity of the other clauses or the validity of the Privacy Statement as a whole. If RouteSchool wishes to amend or replace the clause(s) in question, the amended or new clause must correspond as closely as possible to the clause(s) declared invalid or non-binding.

                RouteSchool's failure to insist on strict compliance with the provisions of this Privacy Statement shall not be construed as a waiver or rejection thereof.

                11. Applicable law

                Any dispute or claim relating to the processing of personal data and Privacy Statement or any information contained herein shall be governed by Belgian law and shall fall under the exclusive jurisdiction of the courts and tribunals of Hasselt (Belgium).

                12. Contact

                If, after reading this Privacy Statement, you still have questions or comments regarding the privacy policy or cookies, please contact the contact person at the address B-3520 Zonhoven, Moverkensstraat 53 or via the email addressinfo@route2school.be.

                For additional general information regarding the protection of personal data, please contact the Commission for the Protection of Privacy at 1000 Brussels, Drukpersstraat 35, tel: 02/274.48.00 or via email commission@privacycommission.be (www.privacycommission.be).

                [1]Route2School is a spin-off of Hasselt University. It is in Route2School's interest to be able to continue its research. In addition, Route2School takes measures to protect the rights of those involved, including pseudonymization and aggregation of data.

                [2]Improvement is necessary for the interests of Route2school. Improving the functioning of Route2school is also in the interests of those involved; there is no detriment to the rights and interests of those involved.

                [3]It is in Route2school's interest to be able to offer its services to as many people as possible. Route2school takes the necessary measures to ensure that the interests of those involved are safeguarded. For these reasons, a preliminary email is sent requesting permission for further processing of the data for marketing purposes. This is also prescribed by the FPS Economy in its 'Spamming in 24 questions & answers'. http://economie.fgov.be/nl/binaries/spamming_brochure_nl_tcm325-31741.pd