Privacy policy

1. Privacy and Security

Bebat attaches great importance to the protection of your privacy and personal data.

Every reference in this privacy policy pertains to the Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR – General Data Protection Regulation)(April 27, 2016).

In other words: It’s important to know that we use and process your personal data exclusively in accordance with the GDPR and other relevant legal provisions that are in effect.

Bebat vzw/asbl will, in accordance with the regulations, to the best of its ability, take appropriate technical and organizational measures to protect your personal data against destruction, loss, accidental alteration, damage, or disclosure.

2. Who is protected by this privacy policy?

2.1. Virtual Visitors

Every individual whose personal data we process, who becomes directly or indirectly identifiable (also called the "User") after visiting our website www.bebat.be, or our portals:

Our social media channels:

- or other applications such as BebatCollect and Recycle!

Visiting our website, portals, social media channels, or applications implies that you consent to possible processing activities. You can read about the details of these data in section 4 of this declaration. For any questions, you can always contact privacy@bebat.be.

2.2. Physical Visitors

Surveillance, monitoring, and CCTV: Every individual whose personal data we process, who thus becomes directly or indirectly identifiable (also referred to as the “Visitor”) when accessing the premises and buildings of Bebat, Villa Pila, or Sortbat. It is possible that camera recordings are made of staff members, external workers, visitors, or other third parties during a visit to our facilities.

3. What is data processing?

A. Processing of Data

The 'processing of data' is broad and covers, among others, collecting, recording, organizing, storing, updating, modifying, retrieving, consulting, using, disseminating, or making available in any other way, aligning, combining, archiving, deleting, or ultimately destroying that data.

B. Data Controller

Bebat vzw, with its registered office at Walstraat 5, 3300 (VAT-BE): 0456.561.776 (hereinafter 'Bebat'), is responsible for the website www.bebat.be and is consequently the data controller. The data controller determines alone, or in collaboration with others, which personal data are collected, and the means for processing these personal data.

For questions or complaints, you can always contact our Data Protection Officer (DPO), by registered letter or viaprivacy@bebat.be

4. Which personal data does this concern?

4.1. Virtual Visitors

We process the personal data that you provide us or that we obtain through others, for example from your employer when your company joins Bebat or when registering as a collection point (such as first and last name, address details, email address, phone number, gender, job title, email correspondence, etc.). The personal data that our systems collect (IP address, location data, pages visited, time and day of website visit). The personal data that we obtain from third parties.

4.2. Physical Visitors

The camera footage is only consulted for security purposes or in case of suspected irregularities.
Reports and records can be made from the content of the footage, or photos can be taken (stills).
Footage that shows irregularities can be shared with external security services and other third parties, such as intra-group, such as other security services and research service providers, such as competent authorities, and other government services, as well as judicial services and counterparties in the context of procedures.

5. What are your personal data used for?

5.1 Virtual Visitors

Bebat collects data to provide every user of our website, platforms, social media channels, and applications with an optimal and personalized user experience. The processing is only for the following purposes:

Providing access to your user profile on, among others, MyBebat, etc.

Offering a general and personalized service concerning: invoicing, newsletters, and various information provision, offers that are useful for the user such as school campaigns, obtaining user evaluations via surveys, and providing support via the contact center.
Offering and improving the provided products and services; personalized and specific products and services based on the information and data obtained.
Detection of and protection against fraud, errors, and/or criminal behavior.
General customer management and processing of contact data.
Processing of forms, orders, collections, information, or contact requests.
Processing claims and billing.
Generating reports, audits, control reports, and contacts with competent authorities in accordance with regulations.
Sending newsletters
Keeping you informed of our activities, via our blogs or our competitions and raffles
Advertising and/or marketing purposes in accordance with regulations
Visitor statistics
Optimization of our various digital platforms.

5.2 Physical Visitors

Bebat uses video surveillance to ensure:

That only authorized or permitted persons gain access to the premises and buildings at the intended times,
That the legitimate interests of Bebat are protected,
That its staff, external contractors, visitors, other third parties, and properties are safeguarded,
That its confidential information is protected,
As well as to investigate and address irregularities,
The images may possibly serve as evidence in legal proceedings or investigations.

You always have the right to object to so-called "direct marketing".

By visiting Bebat's website, you consent to data collection for use as outlined above.

All personal data that you leave with us are treated with care and can only be accessed by persons who have the authority to do so and who handle your privacy correctly.

Bebat does not sell personal data to third parties nor do we pass it on to third parties unless:

To our possible legal successors and affiliated companies (such as subsidiaries and sister companies) for the same purposes as mentioned in this privacy policy.
This is necessary for our service provision.
For some aspects of our products and services, we work with third parties or engage subcontractors. Consider, for example, the collection of a recycling bin, our raffle, our social media channels, our marketing actions, independent consultants, etc.
There is a legal obligation.
There is a justified interest for Bebat or the concerned third party. This only happens provided that your interests or your fundamental rights and freedoms do not prevail.
This is part of Bebat’s mission and societal purpose.
You give us your permission.
If Bebat would pass on personal data to third parties in any other way, this happens with explicit and clear communication, explaining the third party, the purposes of the transfer and processing. Where legally required, we obtain your explicit consent. You also always have the option to object.

The transfer of your data is only for the same purposes as at Bebat itself. We ensure that they, just like us, manage your data safely, respectfully, and with due diligence. Regarding the international transfer of personal data, outside the EU, we protect your data according to the protection level required by European regulation.

Bebat does not make automated decisions based on the personal data provided by the users.

In some cases, we use anonymous, aggregated data for commercial purposes or for external reporting. These data can never be traced back to an individual. Some examples include Google Analytics, Hubspot, Wingify, etc. Bebat may collect anonymous or aggregated non-personal data, such as browser type or IP address, the operating system you use, or the domain name of the website through which you came to the Bebat website, portals or applications, or from which you leave them. This allows us to continuously optimize the Bebat website, portals, and applications for users.

The legal grounds on which Bebat relies for processing are:

the compliance with national and international regulations on extended producer responsibility, specifically the acceptance duty concerning batteries as set out in Directive 2006/66 EU and its transposition by the Regions into Regional legislation and other applicable laws, and/or,
the protection of the legitimate interests of Bebat, provided that this outweighs the interests or fundamental rights and freedoms of the user; and/or,
the execution of the agreement with Bebat, and/or,
the fulfillment of a task of public interest,
he consent from the user.

6. We also use cookies

During a visit to our site, cookies (the non-edible version) may be placed on your hard disk. Cookies are pieces of information stored on your own computer or mobile device and are generally used to optimize the usability of websites and apps. For example, they can facilitate a language choice or the display of relevant services.

More information about cookies can be found in our Cookie Policy. You can always turn off cookies via your browser settings, although we recommend keeping them enabled for optimal display of the website.

7. What are your privacy rights and how can you exercise them?

A. Right to access / correct / erase personal data

You have the right to know from Bebat (after valid identification – please provide us with a copy of your identity card) whether we process your personal data, and if we do process them, to access those data and receive additional information. The request should be as clear as possible, specifying what you wish to know, correct, or delete, so that we can more easily find the data you are querying. You also have the right to receive a free copy of the processed data, in intelligible form. These requests can be made via privacy@bebat.be or by registered mail. Typically, we will send you the requested information within one (1) month of receiving your request. This period may be extended by an additional month. Bebat may charge a reasonable fee to cover its administrative costs for any additional request or copy you ask for. Any incorrect personal data can always be corrected or erased by the user themselves by adjusting their user profile. You can also exercise your right to correction by sending us an additional statement ( privacy@bebat.be or by registered mail). We will also normally respond to these requests within one (1) month of receipt. This term may be extended by an additional month. The data you deleted from your user profile may still be temporarily stored, without being visible to the user.

Moreover, you as a user have the right to have your personal data erased by us without undue delay in the following cases:

When your personal data is no longer technically necessary for the purposes for which they were collected or processed.
When you withdraw your consent, and there is no other valid legal ground for the processing of your data.
When we do not have overriding legitimate grounds to process your data.
When we process your personal data unlawfully.
When your data must be erased by law.

We will assess the presence of one of the aforementioned cases, and we ask you to clearly justify your erasure request.

B. Right to lawful and safe processing of personal data

Your personal data is only collected and processed in accordance with the described and justified purposes of this privacy statement. The retention periods for cookies can be found in our cookie policy. After the termination of the contract, personal data is kept for the periods mandated by law or for as long as a justified interest of Bebat remains, such as during the legal statute of limitations—wherein the longest period is considered.

In general, camera footage is only kept for a limited period and then destroyed in accordance with the law, unless the footage indicates irregularities. In such cases, the footage can be kept longer for investigative purposes, further treatment, and handling of irregularities, as well as serving as evidentiary material.

C. Right to restrict processing

You have the right to obtain restriction of processing of your personal data if one of the following applies:

You dispute the accuracy of the personal data: its use will be restricted during a period enabling Bebat to verify the accuracy of the data;
The processing of your personal data is unlawful: instead of erasing your data, you request the restriction of its use;
Bebat no longer needs your data for the original processing purposes, but you need them for the establishment, exercise, or defense of legal claims: instead of erasing your data, its use will be restricted for the establishment, exercise, or substantiation of the legal claim;
As long as no decision is made on the exercise of your right to object to processing, you request the use of your personal data to be restricted;

D. Right to object to the processing of your personal data

You have the right to object to the processing of your personal data on the basis of your particular situation if the processing is involved in the justified interest of Bebat or in the public interest. Bebat will stop processing your personal data unless it can demonstrate compelling legitimate grounds for the processing that outweigh your interests, or when the processing of personal data is related to the establishment, exercise, or substantiation of a legal claim (for example, filing a request with a court)

E. Right to data portability

For personal data which is (i) processed in the context of the execution of a contract with you, (ii) provided by yourself, and (iii) processed through automated means, you have the right to obtain these from Bebat in a structured, commonly used, and machine-readable format, as well as to have those data transferred to a new partner or directly transferred, if technically feasible.

F. Right to withdraw consent / right to lodge a complaint

You can always withdraw your consent for the use of personal data by Bebat, in accordance with the law, if processing is based on consent. Moreover, you can also lodge a complaint with the Data Protection Authority (DPA) (the former Belgian Commission for the Protection of Personal Privacy / Privacy Commission). Bebat will then normally respond to your request within one (1) month of receipt. This term may potentially be extended by one (1) month. This must be done by registered mail or via privacy@bebat.be

8. Our websites, portals, and applications

This Privacy Policy applies to the following websites:

Social media channels:

Other (occasional) websites, apps, and other digital platforms of Bebat are covered by the same privacy statement and cookie policy.

Bebat reserves the right to always change the Privacy Statement.

This Privacy Statement was last modified and reviewed on July 8, 2024.

The most recent version of the Privacy Statement can always be found on this page.