This privacy policy describes the use by Double Pass of personal data collected through this website. The Double Pass’ use of personal data in the scope of the services provided to its clients is described in the privacy policies of these clients and on the respective websites where such data is collected by Double Pass. You accept this privacy policy by providing your personal data to Double Pass through this website.

Personal data collected by Double Pass

Double Pass may collect personal data which identifies you as an individual (directly or indirectly through the combination with other information held by Double Pass). In order for you to use certain services provided by Double Pass (for example, to sign up to be a registered user or to buy Double Pass’ services), Double Pass may require that you furnish personal data such as your name, postal address, telephone number and e-mail address. The server hosting this website automatically logs your IP address when you visit this website, along with the time of your visit and the pages visited. Website analytics provided by third parties may store cookies containing a unique identifier on your device.

Double Pass also collects non-personal data such as your computer type, screen resolution, OS version, Internet browser, anonymous demographic data and other information that does not directly or indirectly identifies you as an individual. Double Pass uses and allows third parties to place cookies on the website. If you do not want Double Pass or these third parties to place cookies, you can block cookies in your browser. You can also delete Double Pass and third party cookies, but new cookies may be supplied when you visit this website again.

Use of your personal data by Double Pass

Double Pass may collect and use your personal data for the following specific purposes:

  1. to sign you up as a registered user and to send requested information to you
  2. to provide you with services and contact you regarding these services
  3. to inform you of services that Double Pass believe may be of interest to you
  4. to send you important information regarding the website, changes to Double Pass’ Terms of Use, Privacy Policy or other administrative information
  5. to respond to your problems and comments
  6. for Double Pass’ data analysis (including website analytics) and audits and to investigate potentially unlawful activity on the website

The legal basis for processing your directly identifying personal data (such as your name, telephone number, email address, …) will be your explicit consent. Personal data that does not directly identify you (such as your IP address and unique identifiers contained in cookies) is processed by Double Pass on the basis of Double Pass’ legitimate interests. Your IP address and unique cookie identifier will only be used for the purposes set out in (e) and (f) above and such use will not affect your interests or fundamental rights and freedoms which require protection of personal data.

Double Pass will only collect personal data that is adequate, relevant and not excessive in relation to these purposes.

Third party recipients of your personal data and transfers to other countries

Double Pass may disclose your personal data

  1. to its third party service providers who provide services such as website hosting, data analysis, IT services, and other similar services to enable them to provide these services
  2. other recipients based on legitimate interests as permitted under applicable law
  3. to a third party in the event of any merger, sale or transfer or other disposition of all or any portion of Double Pass’ business
  4. to a third party as permitted by applicable law, to comply with legal procedures, to respond to requests from public authorities, to enforce Double Pass’ Terms of Use and Privacy Policy and to protect Double Pass’ rights

The transfers to a third party will only relate to personal data which is adequate, relevant and limited to what is necessary in relation to the purpose for which it is transferred to such party.

Other than as set forth above, Double Pass will not transfer your personal data to a third party without your explicit consent.

All personal data collected in the European Economic Area through this website will be stored and processed within the European Economic Area.

Security, reliability and retention of your personal data

Double Pass has implemented appropriate technical and organizational measures and integrated the necessary safeguards to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data, and against all other unlawful forms of processing.

Double Pass takes reasonable steps to ensure that your personal data in its possession is accurate, complete, current and reliable for its intended use.

Double Pass will only retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy (unless a longer retention period is required by law).

Your rights with regard to your personal data

You may

  1. ask Double Pass whether it processes personal data about you, for which purposes, the categories of personal data concerned, to which recipients those data have been disclosed, and (where possible) the envisaged period for which those data will be stored or the criteria used to determine that period
  2. inquire with Double Pass about the appropriate safeguards relating to its transfers to third countries
  3. ask Double Pass a copy of the personal data undergoing processing (including for data portability purposes) and have it rectified
  4. object against the further processing on the basis of legitimate interests and request erasure of your personal data
  5. request that the processing of your personal data is restricted by Double Pass
  6. request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you

In order to do so, you should send Double Pass a letter on the below address or an e-mail to privacy@doublepass.com with sufficient proof of your identity. Double Pass will undertake the necessary action without undue delay and typically provide the requested information within 30 days from receipt of the request.

Double Pass NV
Witte Patersstraat 4
1040 Brussel
Belgium

You may also lodge a complaint with a supervisory authority in case of breach of the applicable privacy laws by Double Pass.

Double Pass’ coordinates

Double Pass NV
Witte Patersstraat 4
1040 Brussel
Belgium

privacy@doublepass.com
+32 2 521 63 66

Amendments

Double Pass reserves the right, in its sole discretion, to amend this Privacy Policy at any time by posting amendments on this website.

Date

25 May 2018

Double Pass Education