Privacy policy

Privacy policy Fullup – Website and Application

Version 1.0 – 25 May 2018

Article 1 – GENERAL TERMS

1.1 Your privacy is very important to us. This Privacy Policy (hereinafter “Privacy Policy”) is created to inform you about how we treat your personal data, and how you can exercise control over that data. It defines your legal rights and obligations towards Fullup.

Our Privacy Policy can be subject to future amendment and modification. In this event we will notify you with an invite to take a look at these changes, whom we will clearly indicate in the Privacy Policy

1.2 Fullup SPRL, with registered offices in Belgium, Quai de Meuse 16, 5100 Jambes, and registered at the CBE with number 0651.979.263, (hereinafter “Fullup”) and available via www.fullup.be (hereinafter: the “Website”); takes responsibility for the processing of your personal data on the Application and Website as a “data controller”.

1.3 The collection and processing of personal data is governed by strict conditions, enforced by the law. Fullup acts in accordance with:

  1. the Belgian Privacy Law of 8 December 1992 on privacy protection in relation to the processing of personal data; and/or
  2. the EU Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC;

1.4 This Privacy Policy is applicable, inter alia, to how we handle your personal data through our « Services » being the services offered, following and linked to our « Website » www.fullup.be and the « Application« , being the designated definition in this Privacy Policy for the following as a whole:

  1. The Fullup Dashboard for corporate users;
  2. The Fullup App; and
  3. The Fullup website;

If you want to use our Services, we will first need your express approval (opt-in) of this Privacy Policy. This means you approve of how we collect, use and process your personal data.

You are not obliged to provide us with your personal data, however you must understand that we are not able to deliver you the Services in case you refuse to provide us with certain personal data.

Article 2 – COLLECTED PERSONAL DATA

2.1 Data you communicate to us:

  • Category 1 – Your user details:
    • Information concerning your Fullup e-commerce account, e.g. your name, address, photo number, e-mail address, language, …
    • Information concerning your Fullup app account, e.g. your name, address, photo number, e-mail address, language, …
  • Category 2 – Your communications through our Services
    • Information about the communication you had with Fullup, or through the Application and/or Services, e.g. when you had a problem with the Application and/or Services and asked for support.
  • Category 3 – Your tank data data:
    • Information about your tank location, name, size, additional information, and other health related information such as your consumption, the amount of fuel left in your tank, the fuel offers you accept,…
  • Category 4 – Your usage of our Services:
    • Your usage data obtained by placing cookies (see our Cookie Policy)
    • Information relating to more ‘’technical’’ aspects of your use of the Application and/or Services, e.g. your IP-address (also without registration), which version of the App you use, …

2.2 Fullup can obtain personal data though different means:

  • During your purchase of the Fullup sensor
  • During your registration and use of our Application and/or Services;
  • By filling out questionnaires (for instance when you give us feedback, or when you use our Support function);
  • Via social media (for instance when you like, or contact us on Facebook)
  • Upon the connection of third party devices or services to Fullup, such as other smart devices (but only when you have explicitly and preliminary gave consent).
  • By placing cookies (see our Cookie policy);

Article 3 – PURPOSES OF THE PROCESSING OF DATA

We want to highlight that Fullup collects and processes your personal information for one overarching goal, i.e. to enable you to optimise and fully automate your fuel management.

That being said, your personal data will only be processed for the following purposes:

3.1 General purposes (all categories 1 to 4):

  • To maintain the safety of our Application and/or Services and improve them, as well as to create statistics based on the “legitimate interest” of Fullup to improve the Application and/or Services;
  • In order to manage your account on the Application and to make sure you can enjoy the Application and the services related to the Application fully, based on the execution of the agreement which you requested;
  • In order to properly and easily address or notify you, or to be addressed by you. Also, to be able to follow up on your communication to us – all based on the execution of the agreement, which you requested;

3.2 Research and statistical purposes

Additionally, some of your personal data – including consumption-related information (categories 1 to 4), will be upon collection added to a special database.

Before we do this, the data will be anonymized (= in no way you can be linked to the data ever again), or pseudonymized (= only with extra information can you be linked to the data again), depending on what is possible, or desirable – the latter taken from your perspective.

Fullup chooses to do this because such a database will allow us (as well as other institutions) to conduct further statistical and scientific research.

That is also why we will only store in this database those types of data that are truly relevant and necessary for such research. And, if this research could help us providing you, as an individual, with a better service, we would like to do so.

Yet, Fullup will only sell the anonymized data from this database to institutions (who can also use it only for research and statistical purposes). This means that in no way you can ever be linked to this transferred data.

3.3 Direct marketing:

Your personal data (category 1 to 4); will only be used for direct marketing purposes if you give your explicit and preliminary consent. (“opt-in”).

In case you have given your consent and you are added to Fullup’s direct mailing list, Fullup may use your personal data to send you marketing material as well as other material relating to Fullup, her products and/or services.

Fullup can also transfer some of your personal data to her partners, for direct marketing purposes relating to Fullup, her products and/or services.

This consent can be revoked at all times, for free and without motivation, by clicking the unsubscribe button below every promotional e-mail.

3.4 Transfer to third parties:

In order to process your personal data, we provide access to your personal data to our employees.

Fullup will also appeal to third parties in executing the agreement, to provide the requested service

  • In order to communicate with you
  • In order to capture your opinion on our Application and/or Services
  • In order to optimize your experience with our Application and/or Services
  • In order to be easily addressed we work with social media channels
  • In order to provide your supplier with the data relating to the location of your tank if you ask for the replenishment service.

Yet, personal data is primarily processed for internal purposes within Fullup.

Fullup won’t sell, let, hand out your personal data nor place them at disposal of third parties, except in the situations provided for in this policy, or unless your explicit and preliminary consent (also, see art. 3.2 and 3.3).

Fullup has taken all legal and technical precautions to prevent unauthorized access and use.

We guarantee a similar level of protection by imposing contractual obligations to these third parties that are similar to this Privacy Policy.

In case of whole or partial reorganization or cession of Fullup’s activities, whereby Fullup reorganizes, transfers, ceases her business activity or in case Fullup goes bankrupt, your personal data may be transferred to new entities or third parties.

Fullup will inform you beforehand of the fact that Fullup transfers your personal data to a third person. You must be aware that this is not always possible, because of what is realizable for Fullup, whereas we also need to take technical and commercial reasons into account.

3.5 Legal requirements:

In extraordinary circumstances it may occur that Fullup is obliged to transfer your personal data following a court order, or in order to comply with imperative laws and/or regulations. Fullup will, if reasonably possible, try to inform you on beforehand, unless revealing this information is subject to legal constraints.

Article 4 – DURATION OF THE PROCESSING

We will store and process your personal data during the period necessary, depending on the legal requirements, purposes of the processing, as well as the contractual relationship between you and Fullup.

Therefore, we keep a record of your data for as long as your account is active, or if your personal data is necessary to offer you a particular service.

You may at all times cease to

  • Use the Application and/or
  • Uninstall it and/or
  • Delete your account (in your settings).

If you delete your account, you will be given the choice whether you also wish us to delete any data that you asked us to back up. If you do wish us to delete your data, this means you are pursuing your right to erasure (see art. 5.2).

If you do not delete your account, Fullup will keep the data you have backed up.

Article 5 – YOUR RIGHTS

5.1 Right of access and right to obtain a copy

You have the right to freely obtain at any moment access to your personal data, as well as to be informed about the purpose of the processing by Fullup. We would like to invite you to check our Terms of Use for some extra information on this topic.

5.2 Right to rectification, erasure or restriction

You have the choice to share your personal data with Fullup.

You also have the right to request Fullup to rectify your personal data. Please note that you can change your account information in the Application at any time on the ‘’Settings-Account’’ pages.

You can also request the processing of your personal data to be restricted, if you think your data is inaccurate and you subsequently notified us about this.

Additionally, you have the right to request Fullup to erase your data as far as we were not able to anonymize it.

Yet, with regard to certain personal data provided by you, Fullup is bound by certain legal obligations, pursuant to which Fullup is not allowed to delete the information.

Also, if Fullup cannot access, change or delete your data – e.g. because it is stored on your device – you should understand that we do not really have the time to come and stop by, so it will be up to you to undertake these actions yourself.

Furthermore, you acknowledge that a refusal to share data or a request to erase these data will make the delivery of several Fullup services impossible.

5.3 Right to object:

You have the right to object to the processing of your personal data when you have serious and legitimate reasons to do so.

You also have the right to object to the use of your personal data for purposes of direct marketing. In such case specific reasoning will not be requested.

5.4 Right to data portability:

You have the right to obtain your personal data which is processed by Fullup in a structured, commonly used format and/or to transfer this data to another data controller.

5.5 Right to withdraw consent:

When the processing is based on prior consent you have the right to withdraw this consent.

5.6 Automated decisions and profiling:

You have the right to request us not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

5.7 Exercising your rights:

You can exercise your rights by contacting us with a copy of your ID as attachment,

either through e-mail to privacy@fullup.be;

or by mail to,

Fullup SPRL,

Quai de Meuse 16

B-5100 Jambes.

5.8 Exercising your rights:

You have the right to file a complaint with the Belgian Privacy Commission, which is the Lead Supervisory Authority of Fullup:

Commission for protection of personal life,

Drukpersstraat 35, 1000 Brussels,

Tel +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35,

e-mail: commission@privacycommission.be.

However, you are always free to contact your own European or EU-vested authority thereto.

This does not affect a procedure before the civil court.

If you have suffered damages caused by the processing of your personal data, you can file a claim for damages.

Article 6 – SAFETY AND CONFIDENTIALITY

6.1 We have adopted safety measures which are suited on both a technical and an organisational level to avoid the destruction, the loss, the forgery, the adjustment, the non-authorised access or the notification of the personal data by accident to a third party, as well as the non-authorised processing of these data. Nevertheless, if these events would occur and would affect your personal data, Fullup will inform you of the breach without undue delay, including a summary description of the potential impact and a recommendation on measures to mitigate the possible adverse effects of the breach.

6.2 Fullup shall not be liable in any way for direct or indirect damages caused by a wrongfully or improper use of the personal data by a third party.

6.3 Please note that the automatic transfer of data to the supplier is only possible after the customer has correctly validated an offer through their mobile device. Doing this correctly, is the client’ sole responsibility.

6.4 At the same time, you also share responsibility for maintaining the privacy and security of the Application and/or Services, for example: by not allowing any third party to use your personal Fullup account on the Application and/or Services and avoiding all other non- authorised access to your login and access code. You are solely responsible for the use of the Application and/or Services on your devices, IP-address and identification data, as well as for its confidentiality.

6.5 In any case, you need to immediately notify Fullup of any unauthorized use of your personal Account by sending an e-mail to privacy@fullup.be .

Article 7 – Applicable Law and jurisdiction

This Privacy Policy is managed, interpreted and executed in accordance with Belgian law which exclusively applies to every potential dispute.

The courts and tribunals of Brussels have exclusive jurisdiction to settle any dispute arising out of or in connection to the interpretation or execution of the present Privacy Policy.