Poppy Privacy And Cookie Policy

1. Table of Contents


1.        Table of Contents. 1

2.        Date of Last Revision. 1

3.        Introduction. 1

4.        Policy Scope. 1

5.        Privacy and Cookie Notice. 1

5.1     To Whom does this Privacy Notice apply?. 1

5.2     What does this Privacy Notice cover?. 1

5.3     How do we obtain personal data?. 1

5.4     Which personal data do we collect?. 1

5.5     For which purposes do we process personal data?. 1

5.6     Why are we allowed to use your personal data?. 1

5.7     To whom can we transmit your personal data?. 1

5.8     Which cookies do we use and how can you manage them?. 1

5.9     Are your personal data protected?. 1

5.10      How long will your personal data be saved?. 1

5.11      Will your personal data be used for automated decision-making?  1

5.12      What are your rights?. 1

5.13      How can you contact us?. 1

5.14      Modifications to this Privacy Notice. 1



2. Date of Last Revision

Date of Last Revision: 21/09/2018


3. Introduction

The core activities of Poppy consist of personal data processing related activities such as customer registration, customer service, direct marketing and processing of payments.

Organizations processing personal data should comply with a number of legal requirements. Compliance with data protection legislations is of the utmost importance for Poppy. To demonstrate that Poppy takes its personal data protection responsibilities seriously, Poppy has created a privacy notice. This notice describes which personal data are collected and how and to which aim they are processed.

4. Policy Scope

This privacy notice is applicable to all Poppy customers, Website visitors and Application users. It is an integral part of the terms and conditions.

It is the responsibility of the Data Protection Officer to maintain the content of the privacy notice and to notify the data subjects whenever there are meaningful changes. It is the responsibility of all parties involved to take note of all changes whenever they are communicated.

5. Privacy and Cookie Notice

This website (« Website ») (https://poppy.be) and the Poppy application (« Application ») are the property of and are managed by Poppy Mobility NV (« Poppy »), an environmentally friendly car (« Car ») sharing platform, established at 1050 Elsene, Maliestraat 50, registered under number BE 0681.505.370.

5.1           To Whom does this Privacy Notice apply?

At Poppy we do our utmost to protect and process the personal data that are entrusted to us in a correct and transparent way, more particularly in accordance with the applicable law and especially with the General Data Protection Regulation 2016/679 of 27 April 2016 (« GDPR »).

This policy applies to all individuals of whom we process personal data (=data subjects), such as clients, website visitors and application users.

5.2           What does this Privacy Notice cover?

With this Privacy Notice we wish to inform you about how and why we process your personal data as a controller when we perform our activities or when you visit this Website, use the Application or drive a Car, to whom we transmit this information, what your rights are and who you can contact for more information.

5.3          How do we obtain personal data?

5.3.1      We can obtain such personal data because you have given it to us. Registering on the Website or Application and filling out the fields that request the personal data below make the data immediately available to Poppy.

5.3.2      We can also obtain your personal data through the way in which you interact with us, such as by booking or using a Car or by using our Customer Service.

5.4           Which personal data do we collect?

The personal data that we collect, can include the following elements:

·      Identification information

·      Financial matters

·      Personal characteristics

·      Consumption habits

·      Judicial data

·      National register number

·      Voice recordings

·      Location data

5.5           For which purposes do we process personal data?

Poppy collects, uses, and processes these data for their own purposes:

·      To register customers;

·      To process your Car bookings on the Application and to allow you to use our Cars through the Application;

·      To provide Customer Service;

·      To improve User Experience;

·      To comply with legal obligations;

·      To inform you about our activities and upcoming events, products and services from Poppy or its partners;

·      For reporting and analytics.

5.6           Why are we allowed to use your personal data?

Upon registering for Poppy you ask Poppy to manage your subscription to its environmentally friendly car sharing platform, and to make this happen we need to process your personal data. This means that registration can be considered as an explicit consent to Poppy to use your personal data for the purposes mentioned above. Furthermore, Poppy needs to comply with some legal obligations which require processing of personal data in order to enable you to use its services.

If we are legally bound to obtain your consent to process your personal data for specific purposes, we will only process your data for those purposes when we have received such an authorization from you.

5.7           To whom can we transmit your personal data?

This Website or Application may contain links to other websites. Although we try to only insert links to websites that share our own standards regarding data protection, we are neither responsible for the contents nor for the policy regarding data protection of those websites. This Privacy Notice only pertains to data collected by Poppy.

When you click on links on this Site, we strongly advise to read the Privacy statements on the websites in question first, before sharing any personal data.

5.7.1      To payment providers

In order to process payment for your trips Poppy shares your credit card details with its payment provider. Payments will be settled on a daily basis.

5.7.2      To law enforcement bodies

In the event that Poppy receives a request from the police services and when this request is lawful (for example regarding violations of the traffic legislation) your personal data will be shared with the involved police department.

5.7.3      To insurance parties

When you Poppy will share your personal data with its insurance partner in order to verify your right to insurance, as we are legally obliged to.

Also in the event that you would encounter a traffic accident while using a Poppy car this information will be shared with our insurance partner to settle the claim.

5.7.4      To Group Companies

Poppy may disclose and transfer all information collected to its holding companies (D’Ieteren NV and Lab Box NV), any company that is a subsidiary of Poppy or the Poppy’s holding companies, or any company that has a joint venture with Poppy or the Poppy’s holding companies.

5.8          Which cookies do we use and how can you manage them?

5.8.1      This Site uses cookies.

Cookies can be used in certain areas of the Website to record certain information regarding the usage of the Website by visitors/users and their preferences, and to optimize the Website and align it with the needs of returning visitors/users, insofar as required for the optimal operation of the Website. Poppy only uses analytical cookies and will not use cookies to track the surfing behavior of visitors/users on other websites.

Cookies are small text files sent to your browser by Poppy's server, each time you visit the Website. Depending on your browser settings, cookies are stored or rejected. If stored, Poppy's server can recognize your computer. When you return to the Website at a later time, and a password is required for certain functions, a cookie avoids having to re-enter your data. In principle, cookies are no threat to your computer, because they are text files, and not executable applications.

5.8.2      Poppy uses website analytics, customer interaction and advertising trackers on its website

5.8.3      If you block cookies, you may be unable to use certain applications. You can block cookies as follows:

·      Internet Explorer

·      Chrome

·      Firefox

·      Safari

5.9           Are your personal data protected?

Poppy protects the confidentiality, integrity and availability of your personal data. We use various technological and procedural security measures in order to protect your personal data from loss, misuse, alternation or destruction.

5.10      How long will your personal data be saved?

Poppy will not store your personal data longer than required for the above mentioned operations.

As a general rule, the personal data of registered users are saved for:

·      Active customers: a period of 1 year;

·      Inactive customers: a period of 3 years after the last use of the Application.

5.11      Will your personal data be used for automated decision-making?

Automated decisions are decisions about persons which are based solely on the automated processing of personal data without any human intervention and which produces legal effects that significantly affect the persons involved.

Poppy will track data subject’s driving behavior. In case of repeatedly dangerous driving behavior the involved data subject may be blocked. In first instance this will always happen trough a manual intervention, it is in a second phase that this blocking may be the result of automated decision making. However, it will always be possible to bypass the automated decision making by human intervention.

The data subject shall have the right not to be subject to a decision solely based on automated processing, including profiling and to exercise its right to object against automated decision making.

5.12      What are your rights?

You have several rights regarding the personal data that we process. In particular, you have the right:

·      to access your personal data and to make a copy of it;

·      to ask us to update or correct your personal data, if you think it is incorrect or incomplete;

·      to ask to delete your personal data, or to limit the way in which we use those data, if you think that we do not (or no longer) have any legitimate basis to process it;

·      to revoke your consent regarding the processing of your personal data (insofar the processing is based on your consent);

·      to receive your personal data in a structured, conventional and machine-readable form and to transfer it to another party (insofar the processing is based on authorization or the performance of an agreement);

·      to object against the processing of personal data for which we use general interests or the execution of public authority as a legal basis, which, after investigation, we will invoke to stop the processing unless we have overriding compelling justified grounds for the processing.

In view of the exercise of the above-mentioned rights you can:

Send an e-mail to [email protected].

You can also use this contact information if you wish to introduce a complaint regarding to the processing of personal data.

Furthermore, if you think that Poppy did not act in accordance with the legislation concerning the processing of personal data, you can file a complaint with the Data Protection Authority:

    Data Protection Authority
    Drukpersstraat 35, 1000 Brussel
    Tel: +32 (0)2 274 48 00
    Fax: +32 (0)2 274 48 35
    E-mail: [email protected]

5.13      How can you contact us?

If you have any questions regarding this Privacy statement or this Site in general, you can contact us

·      by e-mail: [email protected];

·      by letter: Poppy NV, Maliestraat 50 1050 Elsene, Belgium.

5.14      Modifications to this Privacy Notice

We can modify this Privacy notice at all times. In order to keep you informed of the latest modification of the Privacy statement, we shall adapt the revision date each time it is modified. The modified Privacy Notice shall enter into force as of that date.

Please consult this page regularly to keep informed of any modifications and/or additions.

We will also proactively inform you about important changes to the Privacy Notice.