Privacy statement CitySafes

Version: 1 August 2020

Your privacy is central to CitySafes and we do our utmost to protect your privacy at all times, both online and in our branches. In order to provide our services, we hold your personal data. In this privacy statement, we explain what personal data we collect, what we need it for and how we use it.

Our services

CitySafes B.V. offers a solution for keeping your valuables safe by renting out safe deposit boxes. This privacy statement applies to this service.

What personal data is collected?

CitySafes processes personal data within the meaning of the General Data Protection Regulation. We may process data from you when you contact us, visit one of our branches and when you are a customer of ours.

We base the processing of your personal data on the following bases:

• Your consent.

If you have consented to the processing of your personal data, you are free to withdraw this consent. The withdrawal of your consent does not affect the possibility of renting a safe deposit box from CitySafes.

• The processing is necessary for the performance of the rental agreement.

If your personal data are necessary for us to conclude the safe deposit box rental agreement with you, the provision of these data is a necessary condition. If you do not wish to provide these data, the consequence will be that you will not be able to rent a safe-deposit box from CitySafes.

• The processing is necessary to comply with a legal obligation.
• The processing is necessary to pursue our legitimate interest.

We consider the processing of your data to be justified if it concerns our interests with regard to marketing, improving our services, the maintenance, development and incident management of our services, and the performance of general business processes.

Below we set out the personal data we may process:

• Gender
• First name
• Surname
• Date of birth
• Street
• House number
• Postcode
• City
• Country
• Phone number
• E-mail address
• IP address
• Driving licence number
• IBAN
• (If business) Company name
• (If business) VAT number
• (If business) Chamber of Commerce number
• (If business) Personal data of ultimate stakeholders
• A digital copy of the passport photograph of your identification document
• Of your proof of identity, we keep the type of document, the document number, the country and date of issue and until when your proof of identity is valid. We do not keep a BSN number or a full copy of your proof of identity.
• Camera images of our secure areas

Purposes

We use your personal data only for the purposes for which it was collected and, where necessary, to comply with legal obligations. This includes the following purposes:

Execution of agreements. We process your personal data to provide our services. We require personal data to administer, invoice and secure the rental safes.

Customer service. We use your information to support you in using our services.

Customer contact and communication. We use your data to communicate with you in connection with our services via telephone, e-mail, text messages or other electronic media. You will receive messages such as invoices, confirmations of vault visits and appointment reminders from us.

Marketing. We would like to inform you of changes to our branches or services via e-mail, text message or other electronic media. You have the right to unsubscribe from this information service at any time. Depending on your preference, you can unsubscribe yourself from our news service or you can ask our customer service team to unsubscribe you

Safety, security and dispute resolution. We use your data to ensure the security of our services. To this end, we process your data to detect and prevent fraud, theft and other misuse of our services. Where appropriate, we may use your data in the context of dispute resolution, to enforce the contract with you, to enforce our rights against third parties, or to defend ourselves against third-party claims or allegations.

Legal obligations. We may process your information to comply with legal obligations, e.g. record keeping, to fulfil legitimate requests from competent authorities (e.g. police/judiciary) or to combat terrorist financing, money laundering and fraud.

Improving our services. We use your personal data to improve our products and services. For example, insights into click behaviour and search results on our website can help us better design it to serve you better.

Maintenance, development and incident management. If you experience problems with one of our services, we may need to process your personal data, such as your name, date of birth, postcode or house number, to resolve the problem in question. We also process your personal data for some internal operational processes, such as when we migrate customer data to a new database.

Implementation of general business processes, internal management and management reporting. To carry out our business activities, we use your personal data for general business processes. For example, we process your data for archiving, insurance and other administrative purposes.

Handling of insurance claims. When there is an insurance event, personal data will be processed and shared with insurance companies in order to pay the claim.

Third Parties

We also receive information from third-party partners we work with. Although our partners may change, they are currently:

Operators of safe-deposit box rentals.

If we enter into an agreement with an existing safe deposit box provider, we may receive your data directly from that provider. However, this only happens if you:

• Rent a safe deposit box from this provider;
• You wish to switch to CitySafes;
• You have given explicit consent to the transfer of the data.

Cookies

When using our website, we collect data via cookies. Cookies are simple text files placed on your device to store information that is sent back to our servers on your next visit. For more information about the cookies we use, please refer to our cookie statement.

With whom do we share your personal data?

There are a number of cases where we may share your personal data with others. When we provide your data to a third party, we ensure that your data is processed appropriately. We do this by entering into an agreement with the relevant party. We provide your data only when necessary and only with the parties listed below:

• To enforce our agreement with you where appropriate, we may share your data with a collection agency.
• If we have a legal duty to cooperate, your personal data may be shared with police, judicial and tax authorities. Under the Prevention of Money Laundering and Terrorist Financing Act, we may additionally be required to share data with the Financial Intelligence Processing Unit (CFI).
• In order to submit an issue to a law firm, where appropriate, the personal data involved necessary for this purpose may be shared.
• If there is an insurance event, personal data will be shared in order to pay claims.

Where are your personal data processed?

For hosting and maintenance purposes, your personal data is stored in the European Union. Your personal data is mainly processed by our staff at our headquarters and offices in Belgium. Depending on your location and if applicable, certain data may be processed by local offices in other European countries, e.g. for local marketing campaigns. We may also share your data with group companies affiliated to us. These are all based in the European Union.

How long do we keep your personal data?

We keep your personal data only as long as it is needed for the purposes for which it was collected or used and/or as long as required by law.

If you have terminated your contract with us, we will mark you as ‘inactive’ in our database. In this case, we will no longer actively use your account information, for example, to inform you about our products and services. If your account is inactive and the legal retention period has expired, we will delete or completely anonymise your data.

You can also make a request via our customer service to remove your data from our database with immediate effect. This is only possible if you no longer have an active contract and no longer use our services. In this case, we will comply with such a request as soon as possible, but with the exception of the information we are legally obliged to keep. For example, we are legally obliged to keep data such as copies of invoices for seven years.

Access to and management of your personal data

If you wish to access, correct or erase your data, or if you wish to receive a copy of your personal data, object to the processing of your data, or if you wish to submit a request for the restriction of processing, please contact our customer service at info@citysafes.be. We will respond within 30 days of receiving such requests.

Changes to this privacy statement

If necessary, we may amend this privacy notice as appropriate. If these are material changes, we will notify you by sending you an e-mail. Therefore, please ensure that you read any such notification carefully.

Questions and complaints

If you have any questions about how we use your personal data, please contact our customer service department. You can also contact our data protection officer (FG) at dpo@citysafes.be You also have the right to lodge a complaint with the supervisory authority, the Data Protection Authority. You can submit your complaint via the Data Protection Authority’s website.

The entity responsible for storing and processing personal data for CitySafes International B.V. is located at:
Raymond de Larochelaan 15/104
9051 Sint Denijs westeren