As data controller, Dstny processes the (standard) personal data of the customer, to the extent necessary for the execution of the agreement between Dstny and its Customers, in order to comply with its legal obligations and, insofar as necessary to serve its legitimate interests.

Nature of the personal data and the purposes for which it is used by Dstny

CONTACT DETAILS AND PERSONAL DETAILS

This is the data that Dstny requests when you purchase a product or service from us or contact us. This means the name of the contact person, their (direct) telephone number and e-mail address.

This category of data is processed in the context of providing information, delivering and managing our services, fulfilling our legal obligations, and conducting marketing, sales and invoicing.

USAGE DATA

This is data about the use of a service or product. This concerns, for example, data traffic, the date, time and duration of the use of the service, the various users of the service and data related to this.

This data is used primarily for invoicing and administrative purposes, meeting legal obligations and in order to guarantee optimal service.

NETWORK DATA

Passwords and login data provided us, license and network data, the MAC address(es) of peripherals such as a modem, and source code are processed by Dstny in the context of providing its services.

These are necessary for the delivery of the service or product, for resolving IT problems, establishing calls or storing your data via the cloud.

TRAFFIC DATA

We process traffic data for the use of our services. Traffic data gives us information about the communication, such as the sender and the recipient number that has been called, the date, time and duration of the call, and the costs that are charged for it.

This also concerns the quantity of data, and in the case of roaming, the foreign network used as well as data necessary to enable connection with the electronic communication networks of other operators.

Based on this traffic data, Dstny can also monitor its fair-use-policy and as necessary, intervene in the event of excessive use or (potential) fraud.

Traffic data is generated and processed automatically. Dstny processes this category of data in the context of providing services, system management, invoicing, legal obligations and reporting.

LOCATION DATA

When you set up a call or data session via a service from Dstny, we process data that allows your current location to be very generally determined. We use this data to determine whether the call or the data session takes place in Belgium or abroad. Dstny processes this category of data in the context of providing service, management, legal obligations, invoicing and reporting.

CONTENT OF COMMUNICATION

The content of conversations is not processed by Dstny unless there are legal or judicial grounds requiring Dstny to do so.

Rights of the Data Subjects (users)

In order to protect the fundamental privacy rights of the data subjects (right of access and rectification or erasure, the right to request restriction of the processing of the data concerning him/her, the right to oppose the processing and the right to data portability), it is the obligation of the customer to promptly and completely inform the data subjects (users of the services/products) in accordance with the provisions of the privacy legislation on the processing of personal data by Dstny, to explicitly inform the data subjects of their rights based on the privacy legislation and to inform them of the data storage periods that Dstny applies to this personal data.

In the event that, in the course of providing service(s) or product(s), Dstny processes personal data for the customer or for a third party designated by the customer, then Dstny acts in the capacity of data processor and the Customer in the capacity of Data Controller, or, in turn, as processor for a third-party Data Controller. In that case, Dstny only processes the personal data on behalf of and strictly for the benefit of the Customer in accordance with their instructions and under their responsibility, unless otherwise required by law. Where appropriate, Dstny will establish a processing agreement with the Customer concerning the terms for the processing of the personal data with the Customer as data controller.

Dstny works with (sub)processors listed below, but not for every type of service purchased. For a complete list of (sub)processors for each type of service, the processor overview can be requested from privacy@dstny.be. 

Microsoft, Salesforce, Wolters Kluwer, Mitel, Equinix, Palo Alto, Symantec, Aruba Networks, HubSpot, DMARC Advisor, Mimecast, Cisco, Jobtoolz, Teneo.

Data about visiting our website and cookie policy

COOKIES

Cookies are small text files that can be stored on your computer or other device when you visit the website of Destiny NV.

There are essential and functional cookies that ensure that the website functions properly. These cookies are not used to identify the user.

There are also non-functional cookies. These are cookies that can be added for statistical, social, targeted or commercial purposes. They have nothing to do with the strictly technical support of the website.

Cookies can be installed by the server of the website that you visit or by partners with whom you work. In other words, there are First party cookies that Destiny NV installed and manages, and there are Third party cookies, that a third party installs and manages. They ensure that certain information is sent to third parties as a result of your visit.

Cookies can have different purposes: there are technical cookies (for example, for keeping track of language settings), session cookies (temporary cookies that expire after one session) and tracking cookies (cookies that monitor and track your behaviour on the Internet, in order to be able to offer you a more optimal user experience).

PURPOSE AND VALUE OF COOKIES

Destiny N.V. aims to inform every visitor to the website as thoroughly as possible about which cookies Destiny N.V. uses.

Destiny NV requests the explicit consent of the user for the use of non-functional or non-essential cookies that (may) relate to personal data. The user has the option to withdraw this consent at any time or to choose which cookies he or she accepts or declines.

TYPES OF COOKIES USED BY DESTINY N.V.

We distinguish the following types of cookies, according to their purposes:

• Essential / necessary cookies:

These cookies are necessary to enable the website to function and cannot be disabled in our systems. They are usually only enabled in response to actions you have taken, such as setting your privacy preferences or filling in forms. They are necessary for smooth communication and facilitate navigation (for example, returning to a previous page, etc.).

• Functional cookies:

These cookies allow the website to offer enhanced functionality and personalisation. They can be enabled by us or by external providers whose services we have added to our pages.

• Analytical cookies:

These cookies allow us to track visits and traffic so that we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and how visitors navigate through the website.

• Targeting / advertising cookies:

These cookies can be installed by our advertising partners via our website. They can be used by those companies to create a profile of your interests and show you relevant ads on other sites. We use our own cookies, on one hand, plus cookies from carefully selected partners with whom we collaborate and who advertise their services on our website, on the other.

Technical details about which type of cookies and storage periods per type can be requested via privacy@dstny.be.

Applying for a job with Dstny (via the website)

When you apply for a job (via our website), we process your personal data: name, telephone number, e-mail address, your CV and the reports of the assessment-interviews we conduct with you. See also “Privacy Statement – applying for a job with Dstny”.

Presence at the offices of Dstny

When you visit our offices as a guest, we register your visit. We do this for security reasons and in order to be able to respond effectively in the event of a calamity.

Training and instruction

When you contact our support department, your call may be recorded for training purposes. If so, we will clearly indicate this in advance.

In context of providing service

Contact details and personal details are stored for the duration of the agreement and for a period of 2 years after its termination. The data used in the context of our financial administration is retained for a period of 10 years. Unless Dstny is subject to legal obligations to the contrary, Usage data, Network data, Traffic data and Location data is retained for the duration of the agreement and for a period of 2 years after its termination. This data is retained in the context of our financial administration for a period of 10 years. Dstny does not store your personal data longer than is strictly necessary to achieve the objectives and/or fulfil the legal obligations for which your data is collected. Certain categories of data are stored for a shorter period of time: this concerns categories of personal data for which the storage period is established by law, such as in Directive 2002/58/EG, as amended (the e-Privacy Directive) and the Law of 13 June 2005 (the Telecom law). Any changes, restrictions or deletions of personal data will only be incorporated into our active (address) files, never in previously created backups or archive files.

Outside of the framework of providing the service

Data about visitors to our website is retained for 1 year, unless you oppose this. If you have applied for a job (via the website) with Dstny and were not selected, we will retain the personal data you provided for 4 weeks, unless you agree to be included in our recruitment reserve, in which case we will retain your personal data for 1 year in relation to any opportunities that may arise later.

With regard to the personal data in question, Dstny takes appropriate technical and organisational measures to enable adequate security to be provided and to ensure that this personal data cannot be subject to unauthorised or unlawful processing. Our focus on security includes hardware, software, physical security, policy rules, awareness raising and settings in hardware and software. To this end, Dstny uses advanced techniques (such as firewalls, spam filters and virus scanners, two-way factor authentication and device management applications) to protect against security breaches, viruses, spam and malware.

Dstny only discloses your personal data to third parties (sub-processors) if this is necessary for the execution of the agreement with you, or to comply with a legal obligation. Sub-processors (such as providers, suppliers and partners) must sign a mandatory processor agreement with Dstny ensuring the appropriate processing of the data provided.

The Ombudsman (http://www.ombudsmantelecom.be) is responsible for investigating the case of any individual who claims to have been the victim of malicious use of an electronic communication network or service, and for obtaining information about the identity and the address of the users of electronic communication networks or services who have targeted them, in so far as such data is available. The Ombudsman will accept the request if the facts appear to be clearly established and the request concerns precise data. If the Customer has received malicious calls and wishes to discover the identity of the suspected perpetrator of these calls, the customer may file a complaint with the Ombudsman.

Would you like to review the personal data that we, as data controller, process about you? Do you have an objection to the processing? Would you like to submit a request for rectification or deletion of your personal data or would you like to exercise your right to data portability? You can contact us via

privacy@dstny.be

or

Destiny NV

Belgicastraat 17

1930 Zaventem

Belgium

If you have a complaint about the way in which we process personal data, you can also submit your complaint to the aforementioned e-mail or postal address. We will then reply to you within the legally stipulated deadline, after valid identification. If you are not satisfied with the handling of your complaint, then you may submit a written complaint to the Data Protection Authority (Gegevensbeschermingautoriteit or GBA):

Gegevensbeschermingautoriteit

Drukpersstraat 35, 1000 Brussel

+32 (0)2 274 48 00

+32 (0)2 274 48 35

contact(at)apd-gba.be

Dstny reserves the right to modify this privacy policy at any time. The privacy policy on https://www.dstny.be/ is the most recent version and replaces any previous privacy policies.