1. Who are we?
REVOLVE is a communication group fostering cultures of sustainability. We communicate and transmit information and knowledge as best and as widely as we can to create a cleaner world.
Revolve Media is a limited liability partnership (LLP) registered with company number BE 0463.843.607 at Rue d’Arlon 63-67, B-1040 Brussels, Belgium (hereafter “REVOLVE”).
Our company website and our Apps are run by REVOLVE (and depending on the complexity of the case by third party subcontractors, under the responsibility of REVOLVE).
Our Data Protection Officer (“DPO”) can be reached by postal mail at DPO REVOLVE, Rue d’Arlon 63-67, B-1040 Brussels, Belgium, or by email at firstname.lastname@example.org
2. Introduction & General Terms
– via following online services:
- anyREVOLVE websitethatlinkstothisPrivacyPolicy
- socialmediaorofficialREVOLVE contentonotherwebsites
- our mobiledeviceapplications (“Apps”)
– via any Bluetooth, Wi-Fi or any similar technology that may communicate with your (mobile) device including identifying its location, in our shopping centers. This includes collecting unique online identifiers such as IP addresses, MAC addresses, which are numbers that can uniquely identify terminal equipment such as a specific computer, handset, tablet or other network device on the Internet.
To provide you with the full range of services, we sometimes need to collect information about you.
– what information REVOLVE may collect about you
– how REVOLVE will use information that we collect about you
– when REVOLVE may use your details to contact you
– whether REVOLVE will disclose your details to anyone else
– your choices regarding the personal information you provide to us
REVOLVE is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with the EU Regulation 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 (hereafter the “GDPR”). Please note that, no website can be completely secure. If you have any concerns that one of your REVOLVE accounts could have been compromised, e.g. someone could have discovered your password, please get in touch immediately.
3. What information does REVOLVE collect?
When you access or sign-up to any of REVOLVE’s services, for example Apps, newsletters, chats with our social media accounts, message boards, web and mobile notifications, telephone or text REVOLVE, we may receive personal information about you.
This can consist of personal information you have provided to us such as, for example, your name, email address, postal address, telephone or mobile number, gender or date of birth, personal interests (e.g. what newsletters you have read), as well as general (aggregate, non-personal) information collected about the way in which visitors make use of REVOLVE on-line services.
If you are the parent or guardian of a child under (16), we may process limited personal data about you so that you can give consent for the child to access some REVOLVE services. We may use your contact details to communicate with you about the child’s account or use of services.
Please note that sometimes we will require you to provide additional personal information, for example when preparing lease or real estate purchase agreements. When we do this we will provide further information about why we are collecting your information and how we will use it.
Some of our services enable you to sign-in via a third-party service, such as Facebook. If you choose to sign-in via a third-party app, you will be presented with a dialog box which will ask your permission to allow REVOLVE to access your personal information (e.g. your full name, date of birth, email address and any other information you have made publicly accessible to the third-party service, such as Facebook). Please note that any information that is not required by the particular service you have opted to use will not be retained by REVOLVE.
4. For what purposes does REVOLVE use the information it collects about you?
REVOLVE will use your personal information for a number of purposes including the following:
– to provide you with our services, including the preparation of real estate lease or purchase agreements
– to provide you with information about our services
– to deal with your requests and enquiries
– to provide you with the most user-friendly online navigation experience
– for “service administration purposes”, which means that REVOLVE may contact you for reasons related to the service or online content you have signed up for
– we may also show you relevant advertising, as set out in Article 7
– to use IP addresses and device identifiers to identify the location of users, to block disruptive use, to establish the number of visits of our websites
– for analysis and research purposes so that we may improve the services offered by REVOLVE
– we also use and disclose information in aggregate (so that no individuals are identified or identifiable) for marketing and strategic development purposes (for example the number of visitors in a shopping center and the heatmap of the direction taken by the crowd of visitors in a shopping center).
Where REVOLVE proposes using your personal information for purposes not mentioned above we will notify you first. Please see Article 18 below for details.
5. Your REVOLVE Account
If you have registered for an REVOLVE account on one of our websites or through an App, this will not automatically allow you to login to other REVOLVE website and apps, as these services might be run by REVOLVE or separate subcontractor chosen by REVOLVE.
Your REVOLVE accounts will always be covered by the policies of this website. But, please be aware that additional policies may apply if your REVOLVE account is linked to another account.
6. When will REVOLVE contact you?
REVOLVE may contact you:
– in relation to any contractual relation you have engaged with REVOLVE
– in relation to any service, activity or online content you have signed up for, for yourself or for your under 16-year old child in order to ensure that REVOLVE can deliver the services, e.g. to verify your email when you sign up for a REVOLVE newsletter, or to help you reset your password for your accounts on our websites or Apps
– in relation to any correspondence we receive from you or any comment or complaint you make about REVOLVE products or services
– in relation to any job application
– in relation to our legal rights and obligations
– in relation to any personalized services you are using
– in relation to any contribution you have submitted to REVOLVE, e.g. on REVOLVE message boards or via text or voicemail message
– to invite you to participate in surveys about REVOLVE services (participation is always voluntary)
– to update you on any material changes to REVOLVE’s policies and practices
– for marketing purposes, as set out in Article 7.
We will never contact you to ask for your REVOLVE account password, or other login information. If you receive any emails or calls from people asking for this information and claiming to be from REVOLVE please inform our DPO straightaway.
7. Will You be contacted for marketing purposes?
REVOLVE will only send you marketing emails or contact you on REVOLVE platforms when you have agreed to this. You will always be able to unsubscribe by following the procedure set out in Article 12. From time to time we may also contact you to ask your opinion on certain issues affecting REVOLVE. REVOLVE may personalize the message content based upon any information you have provided to us and your use of REVOLVE platforms.
8. Will REVOLVE share my personal information?
REVOLVE will not sell or rent your information to third parties and will not share your information with third parties for marketing purposes.
Generally, we will use your information within REVOLVE and will only share it outside REVOLVE where you have requested it or given your consent, except:
– where disclosure is required or permitted by law (for example to government bodies or law enforcement agencies, including for child protection reasons) by a court order or for the purposes of prevention of fraud or other crime, or
– if REVOLVE or its affiliate ceases to be the data controller in respect of your personal information through the operation of a merger, acquisition or any change of control
– in the limited circumstances described below and in Article 9.
We may pass your information to our third-party service providers, agents subcontractors and other associated organizations for the purposes of completing tasks and providing services to you on our behalf (for example to send you mailings). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service. In addition, our contracts with such third-party service providers require them to keep your information secure and not to use it for their own direct marketing purposes. We will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so.
9. Offensive or inappropriate content on REVOLVE websites
If you post or send content which may reasonably be deemed to be offensive, inappropriate or objectionable anywhere on or to REVOLVE websites, social media pages, or otherwise engage in any disruptive behaviour on any REVOLVE service, REVOLVE may remove such content.
Where REVOLVE reasonably believes that you are or may be in breach of any applicable laws, for example on hate speech, REVOLVE may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. REVOLVE would only do so in circumstances where such disclosure is permitted under applicable laws, including data protection law.
10. What if I am a user aged under 16?
If you are aged 16 or under, please get your parent/guardian’s permission before you provide any personal information to REVOLVE.
11. How long will REVOLVE keep my personal information?
We will hold your personal information on our systems only for as long as is necessary for the relevant activity, or as long as is legally or contractually set out for any relevant contract you hold with REVOLVE. If you delete your REVOLVE account, then your personal information is deleted immediately. For further information about deleting your REVOLVE account, please see Article 12 below.
12. What can you do with the personal data you submitted to us?
You have the right to restrict and the right to object to the use of your personal data; the right to withdraw your consent to the use of your personal data and the right to request deletion of your personal data.
In the context of the shopping centers you can opt-out from the collection of the MAC address of your mobile device by turning off your device Bluetooth and Wi-Fi capabilities of your mobile device or by opting-out via the website of our third-party service providers:
https://pfm-footfall.com/opt-out/ – https://www.fidzup.com/opt-out/
In the context of some of our websites and apps of REVOLVE, these rights are all exercised and obtained by deleting your REVOLVE accounts. You can find out how to delete your accounts onthe respective websites or Apps. As explained in Article 11 above, deleting your REVOLVE account will erase any personal information in your account that we have about you.
In any case, you can exercise your rights by contacting our DPO. You may also adjust your communication preferences or opt out of communications at any time by clicking ‘unsubscribe’ at the bottom of any e-mail, following instructions provided in the communication or changing your preferences within your account or by sending us an e-mail.
You have the right to portability of your personal data. All personal data you directly submitted to REVOLVE, can be sent to you or any third party, at your request made directly to our DPO.
13. Can I find out what personal information REVOLVE holds about me?
Under the GDPR you have the right to access to and the right to correct the personal information REVOLVEholds. These rights can be exercised by:
– logging into your REVOLVE account regarding the information we hold about you in the context of that account;
– contacting our DPO directly, who will then use reasonable efforts consistent with our legal duty, to supply, correct or delete personal information about you that may be held on our files.
We will endeavour to provide you with access to your personal information wherever possible.
14. What if I am unhappy with the way REVOLVE is managing my personal data?
You have the right to complain to the Belgian Data Protection Authority:
– By postal mail: Belgian Data Protection Authority Rue de la Presse, 35, 1000 Bruxelles.
– By telephone: +32 (0)2 274 48 00
– By fax: +32 (0)2 274 48 35
– By email: email@example.com
15. Web browser cookies
a. What is a cookie?
A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet or mobile phone (all referred to here as a “device”) web browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your web browser if your browser’s preferences allow it.
Many websites do this whenever a user visits their website in order to track online traffic flows. Similar technologies are also often used within emails to understand whether the email has been read or if any links have been clicked. To inform you fully, REVOLVE will ask your consent for the receipt of cookies. However, you can change your cookie settings at any times in your web-browser (see our Cookies Policy below for more information).
On REVOLVE websites, cookies record information about your online preferences and allow us to tailor our websites to your interests.
b. REVOLVE cookies and how to reject cookies
It is important to note that if you change your settings and block certain cookies, you will not be able to take full advantage of some features of REVOLVE services, and we might not be able to provide some features you have previously chosen to receive.
c. Other information collected from web browsers
Your web browser may also provide REVOLVE with information about your device, such as an IP address and details about the browser that you are using.
16. Do Not Track (DNT) browser setting
DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. Our websites do not currently respond to DNT requests.
When you download or use an REVOLVE app on your mobile device, information may be accessed from or stored to your device. Most often this is used in a similar way to a web browser cookie, such as by enabling the app to ‘remember’ you or provide you with the content you have requested.
Your web browser or device may also provide REVOLVE with information about your device, such as a device identifier or IP address. Device identifiers may be collected automatically, such as the device ID, IP address, MAC address, IMEI number and app ID (a unique identifier relating to the particular copy of the app you are running).
When you sign in to a REVOLVE app, your sign-in details may be stored securely on the device you are using, so you may in the future, if you wish to do so, access other REVOLVE ‘apps’ on the same device without needing to enter your sign-in details again.
If you have any concerns about the information which might be accessed from or stored on your device by REVOLVE, you may wish to only access REVOLVE content through a web browser and review your web browser settings.
19. Transferring your information outside of Europe
As part of the services offered to you through the REVOLVE websites and Apps, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to Belgium. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights as set out in this Policy continue to be protected.
If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
1. About our Cookies policy
This Cookies Policy provides further information about several types of computer and mobile cookies and why we use them. The information below is intended to give you a better understanding of what cookies are and what role they play when you use our mobile application.
2. What is a cookie?
A cookie is a small file that is placed on the device used by a visitor to a website to facilitate the communication between the visitor’s device (whether a computer, smartphone, video-games console or other device) and the site server. In this limited sense the cookie fulfills the role of a simple ‘witness’ to the web-site/visitor exchange by storing certain information.
Thereafter, technological developments have allowed the purposes of cookies to be extended to, for example: performance of the site, user statistics for the site, remembering preferences and in some cases targeted advertising.
In this broader sense, the word ‘cookie’ refers to all the files that store extracts of the information conveyed or generated during exchanges between a site and its visitors, whether they are stored on the visitor’s device or on a server. It is in this wider sense that the term is used here.
Cookies help us improve our site and provide a better and more personalized service to you, by, for example, storing information about how you are using our website, which pages you visit the most. You may refuse to accept cookies by activating the settings of your internet browser. However, if You select such settings certain parts of our site may not work or may not work as well.
a. What information do we collect?
The information we collect may consist of IP addresses, browser version, number of visits, which pages You visit, and Your viewing preferences. Information about the duration of the cookies that we usually use can be found here.
Information supplied by cookies can help us to better understand our visitors and improve your user experience.
c. Third-Party Cookies in embedded content on REVOLVE pages
Please note that during your visits to the REVOLVE website you may notice some embedded content that is not itself related to REVOLVE. This may include YouTube, Twitter, Facebook, Instagram, Pinterest and LinkedIn icons. When you visit a page containing such content via an embedded link, you may be served with third party cookies that may track your use of REVOLVE’s website. REVOLVE does not control the provision of such cookies and you should check the relevant third-party’s privacy and cookies policies for more information. Nevertheless, we will always ask your permission regarding the use of these Third-Party Cookies.
There are many web-sites, which contain extensive information on what cookies are and how they work. For example, you can find out more about cookies and changing your cookie settings by visiting: www.youronlinechoices.eu.
Where REVOLVE embeds content from social media and other third-party websites, some websites may use Google Analytics to collect data about user behavior for their own purposes. REVOLVE does not control this. For more information, see the Google webpage “How Google uses data when you use our partners’ sites or apps” on www.google.com/policies/privacy/partners/.
Most web browsers are set to accept cookies but, if you do not want to receive cookies, you can change your browser settings to notify you when cookies are sent or you can reject the cookies altogether. To do so you may, for example, consult:
Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
If you would like to unsubscribe (Opt-out) from third-party cookies related to behavioural advertising, please visit www.youronlinechoices.eu. Note that opting out does not mean you will not receive online ads anymore. It does mean that the company or companies you have left through opt-out will no longer deliver marketing tailored to your web preferences and usage patterns.
6. Other information collected from web browsers
Your web browser may also provide REVOLVE with information about your device, such as an IP address and details about the browser that you are using.
7. Do Not Track (DNT) browser setting
DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third-party ad networks, social networks and analytic companies. Our websites do not currently respond to DNT requests.
8. Additional information: categories of cookies used on our website:
a. User experience cookies
Category 1: Strictly Required Cookies
These cookies are essential to enable you to move on the website and use its features, such as access to secure areas of the website. Without these cookies, services that you ask, like all shopping cart items, cannot be provided. We do not use these cookies to collect information about you, which can be used to sketch a profile, to advertise or to remember where you have been on the internet.
Category 2: Performance Cookies
These cookies collect information about how visitors use our website. For example, which pages visitors visit the most, and if you get error messages from web pages. These cookies do not collect information that you identify as a visitor. All information gathering these cookies is aggregated and therefore anonymous. It is only used to improve how a website works.
Category 3: Functional Cookies
These cookies remember the choices you make like the country you visit our website and the language you speak or region you are in. These can then be used to give you an experience that looks more on your selections and to make the selections more tailor made and enjoyable. The information collected by these cookies can be anonymized and these cookies cannot track your browser activity on other websites.
b. Third party cookies
Category 4: Targeting cookies or advertising cookies
These cookies collect information about your browsing habits to make advertising more relevant to you and your interests. They are also used to limit both the number of times you see an ad and how to measure the effectiveness of an ad campaign. The cookies are usually placed by third party advertising networks with the approval of the website operator. They remember the websites you visit weekly and that information is shared with other parties like advertisers. Quite often, targeting or advertising cookies will be linked to the site functionality provided by the other organization.
Category 5: Social Media Cookies
These cookies allow you to share what you have done on the website on social media such as Pinterest, Facebook, Instagram, Twitter or LinkedIn. We have no control over these cookies. This information can be linked to targeting / advertising activities. We would like to refer you to the relevant social media privacy policies to read how their cookies work.
Third party cookies are not used unless you allow their use. If you choose not to allow the cookies, we guarantee that the personal data that is collected by these cookies will not be passed on to third parties to use for their own purposes. However, in that case the function is not available on our website or the app concerned (e.g. functionalities for share and like buttons, along with playback on our website of a video hosted on Vimeo or YouTube, are disabled). You can view the video concerned directly on the website or app of the third party in question
II. Use of Web Beacons
Some of our webpages can contain electronic images (called web beacons) that among other things allow us to count the number of visitors who visit these pages. Web beacons collect only limited information, including a cookie number, time and date of page viewing, and a description of the page on which the web-page resides. We may also use web beacons posted by third party advertisers. Normally these beacons do not contain personally identifiable information and are only used to track the effectiveness of particular marketing campaigns. In case a web beacon is used to collect personal information, they will be considered as a ‘Third party cookie’ for which your consent will be asked in advance.
9. Changes to our cookies policy
We reserve the right to modify, or otherwise update this Cookies Policy to take account of best practice at any time. We will notify you of any changes by updating the date that appears at the top of the Cookies Policy. Feel free to contact us any time for additional information:
Data Protection Officer (DPO)
Rue d’Arlon 63-67, B-1040 Brussels, Belgium
T : +32 2 318 3984 | E : dpo@REVOLVE