Social Media Policy

Version: Jan 2021

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This Social Media Policy applies specifically to the processing of personal data on the social media channels of TRAXGO, with its head office at Holstraat 44, 8570 ANZEGEM, Belgium, CBE no. 0589.624.787 and its branch office at Kaaistraat 24, 7711 Dottenijs, Belgium (hereinafter referred to as "we" or "us").  TRAXGO acts as the Data Controller on its respective Facebook, Instagram, Twitter, LinkedIn and YouTube social media channels.

TRAXGO guarantees the confidential processing of your personal data in accordance with the General Data Protection Regulation or 'GDPR'.

Any questions regarding the applicable legislation and this privacy disclaimer can be sent to our Data Protection Officer ("DPO") at privacy@traxgo.be.

If you come into contact with TRAXGO in a different context, our general privacy policy applies. This can be consulted at www.traxgo.be/en/privacy-policy.

Which categories of personal data do we process and for which purposes?

We process your personal data when you visit TRAXGO on social media. Through our various social media channels, we seek to offer you a wide range of multimedia services and exchange views with you on topics that are important to you. In addition to the respective social network provider, we also collect and process personal user data on our social media channels. Through this notice, we want to let you know which data we collect from you in connection with our social media channels, how we use this data and how you can object to its use. For more about the respective processing purposes and data categories, please refer to the individual social media channels listed in detail below.

Our data processing serves the following purposes:

  • Communicating with TRAXGO social media channel visitors
  • Handling visitor requests via our TRAXGO social media channels
  • Obtaining statistical information about the reach of the TRAXGO social media channels
  • Carrying out customer surveys, marketing campaigns, market analyses, competitions or similar actions or events
  • Resolving disputes and litigation, exercising or defending legal claims or lawsuits

The processing of your personal data is necessary to achieve these purposes.

Unless expressly stated otherwise, the legal basis for our processing is our legitimate interest (GDPR Art 6. 1 f). Our legitimate interest includes the ability to respond to your messages or enquiries and to analyse the reach and usage of our TRAXGO social media channels so we can design them appropriately and optimise them on an ongoing basis. If you wish to enter into a contractual relationship with TRAXGO through your request, the legal basis for such processing is Art 6.1 b of the General Data Protection Act.

If we intend to process your personal data for a purpose other than those stated above, we will inform you prior to such processing.

1. Traxgo on Facebook

The TRAXGO Facebook Fanpages (“Fanpages") are managed by Facebook Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). When you visit our Fanpages, Facebook will process your personal data in accordance with its privacy policy, which can be found here.

We process the following personal data:

  • Your Facebook username, comments posted on our fan pages and messages you send to us via our fan pages
  • Your activity on our Fanpages via the Facebook Insights service, e.g. visits to our site, contributions made, visits and average duration of video views, information on the countries and cities our visitors come from and statistics on the gender ratio of our visitors
  • Other information required to complete requests by our visitors or to unambiguously identify our visitors in our systems

Joint controllership with Facebook

We use the statistical information (visits to our site, contributions made, visits and average duration of video views, information on the countries and cities our visitors come from and statistics on the gender ratio of our visitors) relating to the use of the Fanpages that Facebook makes available in anonymised form via Facebook’s "Insights” service. TRAXGO cannot reach conclusions on individual users or access to individual user profiles.

More information about Facebook Insights can be found here.

Based on the above, TRAXGO and Facebook are considered "joint controllers" within the meaning of the GDPR. As a result, we have entered into a so-called joint controller agreement in order to comply with the requirements of the GDPR. This joint controller agreement is available here. The agreement contains all information relevant to you as a data subject, in particular concerning the exercise of your rights under the data protection legislation.

Apart from the processing of personal data mentioned in this privacy statement, TRAXGO has no influence on the processing of personal data by Facebook in connection with your use of the Fanpages.

2. TRAXGO on Instagram

The TRAXGO Instagram pages are managed by Facebook Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, as the service provider for Instagram. When you visit the TRAXGO Instagram pages, Instagram will process your personal data in accordance with its privacy policy, which can be found here.

We use the statistical information (visits to our site, contributions made, information on the countries and cities our visitors come from and statistics on the gender ratio of our visitors) relating to the use of the TRAXGO Instagram pages that Instagram makes available in anonymised form via Instagram’s "Insights” service. TRAXGO cannot reach conclusions on individual users or access to individual user profiles.

We process the following personal data:

  • Your Instagram username, comments on our TRAXGO Instagram pages and messages you send to us via our TRAXGO Instagram pages
  • Your activity on our TRAXGO Instagram pages via the Instagram Insights service, e.g. visits to our site, contributions made, information on the countries and cities where our visitors come from and statistics on the gender ratio of our visitors
  • Other information required to complete requests by our visitors or to unambiguously identify our visitors in our systems

Based on the above, TRAXGO and Instagram are considered "joint controllers" within the meaning of the GDPR. As a result, we have entered into a so-called joint controller agreement in order to comply with the requirements of the GDPR. This joint controller agreement is available here, with Instagram forming part of Facebook. The agreement contains all information relevant to you as a data subject, in particular concerning the exercise of your rights under the data protection legislation.

3. TRAXGO on Twitter

If you visit TRAXGO on Twitter, Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA collects and processes personal data to the extent described in their privacy policy. This privacy policy can be found here.

We process the following personal data:

  • Your Twitter username, comments posted on our TRAXGO Twitter pages and messages you send to us via our TRAXGO Twitter pages
  • Your activity on our TRAXGO Twitter pages via the Twitter Analytics service, e.g. visits to our site, contributions made, information about the countries and cities our visitors come from and statistics about the gender ratio of our visitors
  • Other information required to complete requests by our visitors or to unambiguously identify our visitors in our systems
  • When you send us a direct message, we do not store or process any of your personal data other than your Twitter username.

Joint processing with Twitter

We use the statistical information (visits to our site, contributions made, information on the countries and cities our visitors come from and statistics on the gender ratio of our visitors) relating to the use of the TRAXGO Twitter pages that Twitter makes available in anonymised form via Twitter’s "Analytics" service. TRAXGO cannot reach conclusions on individual users or access to individual user profiles.

Based on the above, TRAXGO and Twitter are considered "joint controllers" within the meaning of the GDPR.

Apart from the processing of personal data mentioned in this privacy statement, TRAXGO has no influence on the processing of personal data in connection with your use of Twitter company page.

4. TRAXGO on LinkedIn

The TRAXGO LinkedIn pages are managed by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ("LinkedIn"). When you visit the TRAXGO LinkedIn pages, LinkedIn will process your personal data in accordance with its privacy policy, which can be found here.

We process the following personal data:

  • Your LinkedIn username, comments on our TRAXGO LinkedIn pages and messages you send to us via our TRAXGO LinkedIn pages
  • Other information required to complete requests by our visitors or to unambiguously identify our visitors in our systems

Joint processing with LinkedIn

We use the statistical information (visits to our site, contributions made, information on the countries and cities our visitors come from and statistics on the gender ratio of our visitors) relating to the use of our LinkedIn company page that LinkedIn makes available in anonymised form via LinkedIn’s "Analytics" service. TRAXGO cannot reach conclusions on individual users or access to individual user profiles.

Based on the above, TRAXGO and LinkedIn are considered "joint controllers" within the meaning of the GDPR. As a result, we have entered into a so-called joint controller agreement in order to comply with the requirements of the GDPR. This joint controller agreement is available here. The agreement contains all information relevant to you as a data subject, in particular concerning the exercise of your rights under the data protection legislation.

Apart from the processing of personal data mentioned in this privacy statement, TRAXGO has no influence on the processing of personal data in connection with your use of our LinkedIn company page.

5. TRAXGO on YouTube

If you visit TRAXGO on YouTube, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland collects and processes personal data to the extent described in their privacy policy. This privacy policy can be found here.

We use the statistical information (visits to our site, contributions made, average duration of video views, information on the countries and cities our visitors come from and statistics on the gender ratio of our visitors) relating to the use of the TRAXGO YouTube channel that YouTube makes available in anonymised form via the "Analytics" service. TRAXGO cannot reach conclusions on individual users or access to individual user profiles.

We process the following personal data:

  • Your YouTube username and comments on our TRAXGO YouTube channel
  • Your activity on our TRAXGO YouTube channel via the YouTube Analytics service, e.g. visits to our site, contributions made, average duration of video views, information on the countries and cities our visitors come from and statistics on the gender ratio of our visitors
  • Other information required to complete requests by our visitors or to unambiguously identify our visitors in our systems

When you send us a direct message, we do not store or process any of your personal data other than your YouTube username.

Who do we share your personal data with?

Within our company, only those people and entities who need your personal data in order to fulfil the above purposes are granted access to this data.

Comments and messages you leave on our social media channels are handled by our staff on the social media platform itself.

Please note that when data is processed via our social media channels, your personal data may be processed outside the territory of the European Union. This may pose risks to users, as it may be more difficult to enforce user rights, for example. For more details, please refer to the privacy policies of the social media channels. With regard to US providers bound by European Standard Module Clauses, we would like to point out that these providers are committed to complying with EU data protection standards.

We may transfer personal data to supervisory authorities, courts or law firms to the extent necessary to ensure compliance with the applicable legislation or to exercise, assert or defend legal rights, if permitted by law.

How long do we retain your personal data?

If not explicitly stated otherwise (e.g. in a specific consent form), we will delete your personal data as soon as it is no longer needed for the purposes listed above, unless such deletion or blocking violates our legal obligations to provide and retain data (including the retention of data for periods stipulated by commercial or tax law, for example). Any messages you send via our social media channels will be deleted at least 3 months after the end of the conversation, if your query has been answered and if there are no other grounds giving us the right or obligation to retain these messages.

Which data protection rights do you have?

Our visitors can request information about the personal data we store and process about them at TRAXGO. In addition, under specific circumstances, our visitors may demand that we correct or delete personal data we hold about them. They may also have the right to restrict the processing of personal data, as well as the right to obtain disclosure of the data they have provided in a structured, commonly used and machine-readable format.

To exercise your rights, please contact us at privacy@traxgo.be.

Right to object

If our processing is based on consent, our visitors have the right to object at any time to the processing of personal data in relation to them. If we process personal data of our visitors in order to protect our legitimate interests, our visitors may object at any time to such processing on grounds relating to their particular situation. In the event of an objection, we will cease processing the personal data of the person concerned, unless we can provide compelling reasons that override the interests, rights and freedoms of our visitors or prove that the processing serves the formation, exercise and defence of legal claims or disputes.

  • With regard to the processing of personal data via the "Insights" service offered by Facebook, Facebook has assumed primary responsibility concerning the processing of Insights data and the exercise of data subjects' rights. As such, we would appreciate it if you could contact Facebook directly in relation to all obligations under the GDPR regarding the processing of Insights data. You can certainly exercise your rights against us, but we will pass your questions on to Facebook.
  • With regard to the processing of personal data via the "Page Insights" service offered by LinkedIn, LinkedIn has assumed primary responsibility concerning the processing of "Page Insights" data and the exercise of data subjects' rights. As such, we would appreciate it if you could contact LinkedIn directly in relation to all obligations under the GDPR regarding the processing of “Page Insights” data. You can certainly exercise your rights against us, but we will pass your questions on to LinkedIn.

Where can you file a complaint?

Every visitor has the right to file a complaint with the relevant supervisory data protection authority if you believe that the processing of your personal data contravenes the GDPR.

Data Protection Authority, Drukpersstraat 35, 1000 Brussels, Belgium

e-mail: contact@apd-gba.be