Privacy Policy
Deze Privacy and Cookie Policy is in het Engels opgesteld. Indien u het Engels niet begrijpt, neemt u contact op met Mbrella (via info@mbrella.eu) alvorens de applicatie ervan te aanvaarden om een vertaling of een verklaring in het Nederlands te krijgen. Door deze Privacy and Cookie Policy te aanvaarden, verklaart u Engels en de inhoud van deze voorwaarden te begrijpen.
La présente Privacy and Cookie policy est établie en anglais. Si vous ne comprenez pas l’anglais, veuillez prendre contact avec Mbrella (via info@mbrella.eu) avant d’en accepter l’application pour recevoir une traduction ou une explication en français. En acceptant la présente Privacy and Cookie Policy, vous déclarez comprendre l’anglais et le contenu des présentes conditions générales.
This privacy and cookie policy (the “Policy”) includes both the privacy policy and the policy on the use of cookies on Mbrella platform (the “Platform”) and on Mbrella Website (the “Website”).
Date of last revision: 17/02/2021
Mbrella SRL/BV is committed to protect your privacy and takes its responsibilities regarding the security of customer personal data very seriously. For more detailed information about privacy legislation, please do not hesitate to read the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC) (the “GDPR”).
Data controller
Your personal data are handled by:
Mbrella SRL/BV (hereafter: “Mbrella”)
Rue du Belvédère/Belvédèrestraat 29
1050 Ixelles/Elsene
Enterprise number: BE776.753.432
To contact us: info@mbrella.eu
To have access to our policies: https://www.mbrella.eu/
1. Scope of application
As used in this Policy, the terms "using" and "processing" of Personal Data (as defined below) include subjecting the personal information to statistical or other analysis and using or handling personal information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring as detailed in this Privacy.
Mbrella ("we" or "us") provides this Policy to inform you of our policies and procedures regarding the collection, use and disclosure of Personal Data of any person who uses the Platform and the services provided thereon or the Website (the “Users” or “you”).
2. What information do we collect?
Mbrella collects and processes three types of information: (i) information you or your employer provide to us, (ii) information relating to your use of the Platform and/or the Website and (iii) information that is shared with us by mobility providers (collectively the “Personal Data”). Personal Data shall have the meaning as ascribed to it in applicable Belgian and European law.
i. Information you or your employer provide to us:
Account:
When you sign up to the Platform and create an account, add an expense you made, send us an email or communicate with our customer service, you are voluntarily providing us with certain Personal Data that we collect and process. Such personal information may include but is not limited to your name, date of birth, physical address, email address, telephone number, past expenses, billing information, bank account or other payment details. Should you give us details about another person, you hereby confirm that you fully respect the GDPR doing so and that you received every necessary authorization therefor.
We may also collect additional information you may choose to provide to us on your account (i.e. personal data which must not compulsorily be given through the registration process), such as photos, descriptions of your interests, commuting habits, languages spoken, who you are, where you live and what you do for a living.
Additionally, your account may contain other necessary information as detailed in the law of 17 March 2019 regarding the introduction of a mobility budget and the executive royal decrees. Said information might be provided directly by you or by your employer in the strict respect of the legislation in place concerning mobility budgets.
Correspondence:
When you contact our customer service or anyone of the Mbrella staff or when you give us feedback, we may keep a record of that correspondence and collect the necessary information to classify your question, respond to it and, if applicable, investigate any breach of our Terms and Conditions or this Policy.
ii. Information we learn about you from your use of the Platform:
We may collect or process your IP address and certain non-personal information or aggregated data about how and when you use the Platform and/or the Website. This information is usually of a technical nature (device settings and information, including but not limited to the type of browser, operating system, keyboard language, screen resolution, IP address, location, etc.) and behavioral nature (the actions taken by you on the Platform and/or the Website, including but not limited to access times, pages requested, actions executed, etc.) and is used to compile statistical data about the use of our Platform and/or the Website.
iii. Information that is shared with us by mobility providers
The Platform serves as an aggregator of all your mobility expenses (included or not in the mobility budget pursuant to the law of 17 March 2019 thereon). As such, mobility providers such as MyMove will share your mobility information with us.
This means that the information on the bookings and expenses you make on these services are transferred to us (bookings, purchases, prices, date of travel, mean of travel, duration, etc.).
Besides, all necessary data that Mbrella is obliged by law to collect and process shall be duly collected and processed (law of 17 March 2019 regarding the introduction of a mobility budget and the executive royal decrees).
3. Purposes of collecting information
Mbrella only collects the Personal Data for the following purposes:
i. Execution of a contract (art. 6, §1, b) of the GDPR):
We process certain Personal Data to execute the contract between you and us allowing us and the concerned service providers to process your purchases and bookings, to allow you to know your booking history and therefore the remaining of the mobility budget you have, and, in a general manner, to ensure the proper execution of the services we provide you.
For the execution of our services, we rely on third parties providers:
- Data processors: only to the extent required (i.e. to perform specific tasks on our behalf such as the storage of data, the transfer of booking data, targeted communication on the Platform), such third-party service providers (including some located outside of the European Union) will have access to your Personal Data. Once such third-party service provider has completed its specific task and their legal relationship with Mbrella, they will no longer have access to your Personal Data except as required by law. Our subcontractors are listed in a register of processing activities (kept internally). We ensure that all our subcontractors provide the same level of protection for your Personal Data as we do (including subcontractors located outside the EU).
- Joint controllers: as Mbrella aggregates information transferred by mobility third parties, these third parties act as controllers or joint-controllers along with Mbrella and are also responsible for the process of your Personal Data and you should refer, along with this Privacy Policy, to their specific Privacy Policy in this respect. In such a case, Mbrella may transfer your Personal Data to the mobility third party that offered the services you used (such as your email address, name or phone number) in the extent it is necessary to enable you to use the services provided on Mbrella and/or in case of illegal use of the third-party services.
Should you wish to know in more details to which third parties your Personal Data and which Personal Data have been disclosed, please refer to section 6 below (“your rights”).
ii. Compliance with legal obligations (art. 6, §1, c) of the GDPR):
We also process your Personal Data in order to comply with the law, to complete all legally mandatory paperwork in each country/region in which either the User or Mbrella is active or in case of illegal use, when we receive orders from legal authorities. In particular, Mbrella is working closely with employers to offer their employees a mobility budget and must therefore comply with the obligations set out in the law of 17 March 2019 regarding the introduction of a mobility budget and the executive royal decrees.
As such, employers will be granted access to some Personal Data of their respective employees as provided by the law of 17 March 2019 regarding the introduction of a mobility budget and the executive royal decrees.
Finally, we may also verify the respect of your obligations set out in our Terms & Conditions and our Policy and investigate fraud and infringements on all applicable rules and regulations.
iii. Legitimate interests (art. 6, §1, f) of the GDPR):
Beyond the collection of your Personal Data to provide our services to you or to comply with legal obligations, we may collect and use your Personal Data for the following purposes:
a. Improve user experience:
Tracking your use of the Application and/or the Website will allow us to personalize our services to your needs and process uploaded data related to your profile such as tickets and booking preferences or most used travels. It will allow you to correctly use the Application and/or the Website. This will also allow us to learn more about User preferences and general trends on the Application and/or the Website in order to improve the quality of the Application and/or the Website and personalize your experience.
b. Provide customer service:
We may collect additional Personal Data to perform general customer administration of your account by providing you with specific information on available services and by sending you communications about the Platform (e.g. upcoming changes or improvements) as well as our other products and services and respond to your questions, treat your requests or troubleshoot any problems.
c. Perform marketing actions:
We may process your Personal Data to contact you with newsletters, tailored suggestions and information about events, promotions and other products or services as well as communications about the Platform and/or the Website and/or Mbrella.
You can choose to opt-out at any time of marketing promotions sent by Mbrella and/or mail/email correspondence from Mbrella if you do not want your Personal Data to be used anymore for any of the aforementioned purposes. If you do not want to receive commercial communications from us anymore, you can choose to unsubscribe from such commercial communications at any time by sending us an email at info@mbrella.eu.
d. Generate statistics and perform statistical analysis:
We may generate anonymous statistics about the use of the Platform and the Website in order to improve it and to perform statistical analysis.
e. Sharing information with third parties:
Some of your Personal Data could be disclosed to other companies of our companies group to improve our services and could be shared with other mobility services providers such as SNCB or STIB - MIVB to allow the Platform and/or the Website to function properly and to have all necessary mobility data that could be included on the Platform and/or the Website.
No Personal Data will ever be disclosed to third parties for marketing, advertising and promotional purposes. Only anonymous information might be disclosed to third parties for marketing, advertising and promotional purposes as well as for statistical purposes for mobility trends.
Should you wish to know in more details to which third parties your Personal Data and which Personal Data have been disclosed, please refer to section 6 below (“your rights”).
iv. Other processing:
We will always request your consent before using any Personal Data for a purpose other than those that are set out in this Policy.
4. Security of your Personal Data
In order to prevent the loss, misuse and alteration of your Personal Data, Mbrella has implemented a variety of appropriate technical and organizational security measures conform with or exceeding industry standard technologies, in order to safeguard the confidentiality of your Personal Data and ensure your online safety. However, Mbrella cannot guarantee that unauthorized access will never occur.
Mbrella uses its best efforts to protect the confidentiality and security of your Personal Data.
In case of violation of your Personal Data, Mbrella undertakes to notify the Data Protection Authority without delay and not later than 72 hours after becoming aware of such violation.
Mbrella shall in no event be liable for any direct or indirect damages that result from a wrong or illegal handling by third parties.
You may not disclose to or share with any third parties your account. If your account risks being hacked (for example because you lost your computer), please immediately inform us by sending us an email at info@mbrella.eu.
5. Data retention period
We do not process your Personal Data any longer than is necessary for the purposes set forth in this Policy: we do store your Personal Data as long as your account is active or when the processing of your Personal Data is necessary to allow you to make use of our Platform. Your Personal Data are deleted or anonymized maximum seven years after your last use of our Platform or deletion of your account as provided by article 10 of the Royal Decree of 21 March 2019 implementing the law of 17 March 2019 regarding the introduction of a mobility budget.
6. Your rights
Exercise of your rights is free of charge and can be done at any time provided that it is authorised by law. If and to the extent provided under applicable Belgian and European law, you shall have the right:
- to obtain from Mbrella confirmation as to whether or not your Personal Data is being processed and, where that is the case, you shall have the right to access such Personal Data being processed;
- to obtain from Mbrella, without undue delay, the rectification of inaccurate or incomplete Personal Data;
- to obtain from Mbrella the erasure of Personal Data;
- to obtain from Mbrella the restriction of processing of your Personal Data;
- to receive your Personal Data in a structured and commonly used, machine-readable format and have such Personal Data transmitted;
- to object to processing of your Personal Data and to object at any time and without any justification to the processing of your Personal Data and/or to the transmission of your Personal Data to third parties for direct marketing purposes (including profiling).
These rights can be exercised by sending an email to via info@mbrella.eu or sending a letter to Mbrella SRL/BV, Belvédèrestraat/rue du Belvédère 29, 1050 Elsene/Ixelles, Belgium. You can also send this request through your employer with whom Mbrella is always in touch.
Should you consider that the processing of your Personal Data infringes applicable law, you have the right to lodge a complaint with the supervisory authority (the Data Protection authority) by sending an email to contact@apd-gba.be or any other email address provided by the authorized supervisory authority (https://www.dataprotectionauthority.be/contact-us).
7. Modifications to this Policy
We reserve the right to modify this Policy at any time. Any changes to the Policy will be published on the Platform and the Website. In case of significant changes to the Policy that results in Mbrella using your Personal Data in a manner materially different from that stated at the time of the collection, we will provide you with a specific notice on the Platform and/or send you an email notification.
8. Cookies
Mbrella uses cookies. Cookies are small pieces of information that are stored by your browser on your computer's or mobile device’s hard drive. These cookies allow the Platform and the Website to remember information that changes the way the Platform and the Website behave or look, such as your preferred language. Furthermore, the Platform and the Website uses cookies in order to determine the circle of users and to ease the use of and navigation on the Platform and the Website (e.g. cookies are used to prevent you from having to log in every time for personalized services by entering your user name and password). The use of cookies is generally accepted and virtually all important applications and websites use them.
Following cookies are being stored when you visit and use the Website and/or the Platform:
i. Cookies essential for navigation:
These are cookies that are required in order to use the Platform and the Website. Without them certain sections will not function correctly, or not at all. In particular they enable navigation between the various sections of the Platform and our Website, completion of forms and secure verification of your identity before granting access to your Personal Data.
ii. Functional cookies:
Functional cookies are intended to facilitate operation of the Platform and the Website and make using it a more pleasant and personalized experience for you. These are cookies which, for example, store your preferences such as choice of language or your customer segment, collect information in forms for statistical purposes (number of unique visitors, etc.) or enable analysis of how users use the Platform and the Website.
Following cookies are being stored when you visit and use the Website, but not when you visit and use the Platform:
iii. Marketing cookies:
When you visit the Platform and/or the Website, socio-demographic data and profile data are collected and stored anonymously in a marketing cookie. Marketing cookies do not contain any Personal Data and are placed by advertisers when their ad is posted. They prevent you being bombarded by the same advertisements over and over again and help to personalize publicity, but they also measure the effectiveness of our various marketing and publicity actions.
The Platform does not serve any marketing cookies.
iv. Third party cookies:
These cookies are placed via the Website by third parties, for example Google. In particular they improve the Website's content and operation.
The Platform does not serve any third party cookies.
You can configure your internet browser in order to be informed of each cookie sent or systematically refuse them by modifying the parameters of your browser. Mbrella cannot guarantee the access, use and operation of the Platform and the Website if the storage of cookies is disabled. If you want to refuse marketing cookies (including Google among others), you can do this with the help of the following website: http://www.youronlinechoices.com/
9. Legislation and competent courts
This Policy is governed by and construed in accordance with the Belgian legislation that is exclusively applicable to any potential dispute.
Any dispute arising under, or in connection with, this Policy shall be settled exclusively by the competent courts of Brussels, Belgium.
10. Questions
If you have any further questions about this Policy or its implementation, please contact via info@mbrella.eu.