1. About this Privacy Policy
StreetSmart is a solution developed by Mobile School VZW, a company incorporated and existing under the laws of Belgium, with registered office at BE-3000 Leuven, Brabançonnestraat 25, with VAT/company number BE-0478.688.664 (hereinafter ‘Mobile School’, ‘we’ or ‘us’).
We understand that your trust in us (as the controller of your personal data) is of utmost importance to Mobile School.
This privacy policy (hereinafter referred to as "Privacy Policy") is applicable to the StreetSmart platform and mobile app (hereinafter referred to as the “Platform” and “App”).
Since Mobile School wants you to know which personal data it collects from you and how it collects and uses your personal data, we drafted this Privacy Policy to ensure full transparency regarding the collection, use and protection of your personal data. Furthermore, this Privacy Policy provides you with information regarding your data rights and your right to receive notice of any security breach affecting your personal data.
Mobile School wishes to emphasize that it always attempts to act in accordance with the privacy legislation, namely:
(i) the General Data Protection Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (‘General Data Protection Regulation’);
(ii) Directive 2002/58/EC of the European Parliament and Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (‘e-privacy directive’)
(iii) the Belgian Privacy Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data;
(iv) other applicable rules concerning the processing of personal data.
Accessing the StreetSmart Platform and App implies your explicit approval (through disclosure of your personal information or opt-in) of this Privacy Policy and consequently how we collect, use and process your personal data.
2. Categories, purpose and legal ground of processing personal data:
3. Sharing of personal data to third parties
Mobile School shall not disclose your personal data to third parties, unless it is necessary for one of the aforementioned purposes (including but not limited to database management or cloud services). In this respect, your personal data may be disclosed to software providers and other (cloud) partners.
Processing by the third-party shall be governed by a contract or other legal act under Union or Member State law, that obligates the third-party to handle or process your personal data at least as restrictive as Mobile School itself and that sets out (i) the subject-matter and duration of the processing, (ii) the nature and purpose of the processing, (iii) the type of personal data, (iv) categories of data subjects and (v) the obligations and rights of the third party and Mobile School.
Notwithstanding the foregoing, it is, however, possible that Mobile School discloses your personal data:
- To the competent authorities (i) if Mobile School is obliged to do so under the law or under legal or future legal proceedings, and (ii) to safeguard and defend our rights; or,
- To the party taking over Mobile School, if Mobile School, or the majority of its assets, is taken over by said third party, in which case your personal data – which Mobile School has collected – shall be one of the transferred assets.
If Mobile School does not need to transfer your personal data for the purposes listed in this Privacy Policy, it will not sell, hire out or pass on your personal data to third parties, except when it (i) has obtained your permission to this end and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your personal data. Hence, you can be reassured that these third parties take precautions for the processing of your personal data that are at least as strict the measures Mobile School takes to protect your personal data.
4. Transfers of personal data to third countries
Any transfer of personal data to a third country or international organization shall be subject to an adequacy decision by the Commission or the following safeguards:
✓ A data transfer agreement, which shall contain (i) the standard contractual clauses, as referred to in the 'European Commission decision of 5 February 2010 (Decision 2010/87/EC)', or (ii) any other mechanism pursuant to privacy legislation, or any other regulations pertaining to the processing of personal data. Before the transfer takes place, the recipient of personal data/processor of Mobile School in the third country has to guarantee Mobile School that an adequate level of privacy compliance is ensured in this third party country; and/or
✓ Binding corporate rules. As it is the case for standard contractual clauses, the recipient of personal data/processor of Mobile School in the third country has to guarantee Mobile School that an adequate level of privacy compliance is ensured in the third party country; and/ or
✓ Certification mechanisms.
5. Storage of personal data
Unless a longer storage period is required or justified (i) by law or (ii) through compliance with another legal obligation, Mobile School shall only store your personal data for the period necessary to achieve and fulfil the purpose for which your personal data have been collected.
6. Your privacy rights
In light of the processing of your personal data, you enjoy the following privacy rights:
✓ Right to withdraw consent: you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before the withdrawal.
✓ Right of access by the data subject: you can ask for confirmation of whether or not personal data that relates to you is being processed, as well as more clarifications about the information referred to in this information notice. You have the right to request a copy of the personal data undergoing processing.
✓ Right to rectification: you can request to correct or supplement the data provided to us, if (no longer) inaccurate
✓ Right to erasure ('right to be forgotten'): please be aware that in this context certain services will no longer be accessible (e.g. access to the Mobile School platform) and/or can no longer be provided if you delete resp. request deletion of certain required personal data
✓ Right to restriction of processing: you can object to the processing of your data at any time, unless there are legitimate reasons for proceeding with the processing that prevail over yours, for example for the exercise of a right or our defence in court. The aforementioned limitations do not apply where personal data are processed for direct marketing purposes.
✓ Right to data portability: you can request to receive the data you provided, or to send it to another entity indicated by you, in a commonly used structured format readable by automatic device.
✓ Right to lodge a complaint: in case you are not satisfied with the way Mobile School handled your requests, questions and/or remarks or have any complaints about the way Mobile School collects, uses and and/or processes your personal data, note that you have the right to submit a complaint to or appeal on the Belgian Data Protection Authority (“GBA”).
At any time you can exercise your privacy rights towards Mobile School by contacting us via (i) email (info@mobileschool.org) or (ii) by completing the form for exercising your privacy rights (cf. Annex I) and deliver it to Mobile School by email.
In principle, you can exercise these rights free of charge via the above-mentioned form. In addition, you can always, via your personal account, update, modify and/or verify your personal data that are being processed on your account for the Platform.
7. Security of personal data
The security and safety of your personal data is Mobile School's top priority. Mobile School implements technical, administrative and physical security measures designed to protect your personal data from (i) unauthorized access or disclosure and (ii) loss, abuse or alteration.
The security of your account on the StreetSmart Platform and App will also partly depend on the confidentiality and complexity of your password. Mobile School will never ask for your password, meaning that you will never be required to communicate it personally. If you have nonetheless communicated your password to a third party – for example because this third party has indicated that it wishes to offer additional services - this third party shall have access to your account and your personal data via your password. In such cases, you are accountable for the transactions which occur as a result of the use made of your account. Mobile School therefore strongly advises you, if you observe that someone has accessed your account, to immediately change your password and contact us.
8. Update Privacy Policy
Mobile School is entitled to update this Privacy Policy by posting a new version on the Website whereby Mobile School will indicate the revision date at the top of the first page of this Privacy Policy. As such, it is strongly recommended to regularly consult the Website and the page displaying the Privacy Policy, to make sure that you are aware of any changes.
9. Contact Mobile School
If you have questions and/or remarks about this Privacy Policy or the manner in which Mobile School collects, uses and/or processes your personal data, please contact us:
✓ Via email: info@street-smart.be
✓ Via mail: BE-3000 Leuven, Brabançonnestraat 25, Belgium
In case you are not satisfied with the way Mobile School handled your questions and/or remarks or have any complaints about the way Mobile School collects, uses and and/or processes your personal data, note that you have the right to lodge a complaint with the Belgian Data Protection Authority (‘GBA-APD’).
