Privacy policy

This text is a translation. In the event of any discrepancy between language versions, the French text shall prevail.

Article 1 – Purpose and scope

This policy explains how TS-BXL collects, uses, stores, secures and shares the personal data of people who:

• request information or ask for a housekeeper;
• become TS-BXL clients;
• use the ironing centres;
• fill in a form or use a TS-BXL digital portal;
• communicate with TS-BXL;
• act on behalf of a client;
• visit the website www.ts-bxl.be.

It covers data processed electronically, on paper or through an application used by TS-BXL.

It supplements the cookies and other trackers policy.

Specific information may be provided for certain specific processing operations. In the event of any conflict, that specific information prevails for the processing concerned.

Article 2 – Identity of the data controller

TS-BXL Service Vouchers (TS-BXL Titres-Services) is a brand used by:

• Titres-Services Bruxelles-Est srl, CBE 0808.687.020, registered office: Avenue des Lucioles 1, 1170 Watermael-Boitsfort, service voucher approval number: 03640;
• Nine-Eleven srl, CBE 0461.028.429, registered office: Avenue des Lucioles 1, 1170 Watermael-Boitsfort, service voucher approval number: 05176.

The company responsible for processing data relating to the performance of the services is, in principle, the one identified in the agreement, the form, the service confirmation or the document given to the client.

Where data is collected through the website or a form common to the TS-BXL brand, it may be passed on to the relevant company depending, in particular, on:

• the Region in which the service is to be provided;
• the office concerned;
• the approval required;
• the organisation of the service;
• the company employing the worker concerned.

The common point of contact for any question about data protection is: TS-BXL Service Vouchers, Avenue des Lucioles 1, 1170 Watermael-Boitsfort. E-mail: hello@ts-bxl.be. Telephone: 02 675 41 03.

Article 3 – Data subjects

TS-BXL may process the personal data of:

• its clients and former clients;
• people who request a service or information;
• people who fill in a form;
• people living with the client where their identification is necessary;
• trusted persons designated by the client;
• people authorised to give access to the home;
• people authorised to drop off or collect laundry;
• legal representatives, property administrators, family carers or proxies;
• visitors to its websites and portals;
• anyone involved in a complaint, incident or claim.

Data relating to job applicants and workers may be covered by separate information.

Article 4 – Categories of data processed

4.1. Identification and contact data

TS-BXL may process, in particular:

• surname and first name;
• postal address;
• the address of the home where the services are performed;
• e-mail address;
• telephone number;
• language of communication;
• date of birth, where necessary;
• the contact details of a trusted person;
• the capacity of a representative or proxy.

4.2. Data relating to the service voucher system

TS-BXL may process, in particular:

• the Pluxee user number;
• the Region of registration;
• the type of service vouchers used;
• the status of recorded services;
• validations and disputes;
• the number of service vouchers available or missing, where this information is accessible;
• services still to be settled;
• the information needed to comply with regional regulations;
• information relating to a particular quota or status, where needed for the service.

4.3. Data relating to the organisation of the services

TS-BXL may process, in particular:

• the days and times of the services;
• the desired duration and frequency;
• the start date;
• changes to the schedule;
• cancellations;
• replacement requests;
• organisational preferences;
• the information needed to assign a worker;
• the history of services;
• communications relating to the service.

4.4. Information about the home

Request and follow-up forms may contain a brief description of the home to enable TS-BXL to:

• assess the client’s needs;
• determine the reasonable duration of a service;
• identify the equipment needed;
• organise the work;
• protect the worker’s health and safety;
• select a worker who reasonably matches the needs expressed.

This information may concern, in particular:

• the type of accommodation;
• the approximate floor area;
• the number of rooms or floors;
• the presence of stairs;
• the presence of animals;
• whether there is a lift;
• parking or access options;
• the equipment and products available;
• the tasks usually requested;
• any particular difficulties or risks;
• useful information about access to the home.

TS-BXL does not ask for a detailed floor plan, systematic photographs or information unrelated to the organisation or safety of the services.

4.5. Absences, holidays and unavailability

The client may tell TS-BXL the dates on which the services should be interrupted, for example because of holidays, a hospital stay, a business absence or other unavailability.

TS-BXL only asks for the information needed to organise the schedule.

The client is not required to disclose:

• the destination of their trip;
• the exact place where they are staying;
• the people accompanying them;
• the detailed reason for their absence;
• any other information not needed to organise the services.

Where the client volunteers such information, TS-BXL avoids recording it in the schedule when it is not needed.

Information about absences is treated as particularly confidential because of the security risks it may pose.

4.6. Keys, badges, codes and means of access

Where the client entrusts a means of access to TS-BXL or to a worker, TS-BXL may process:

• the date of handover;
• the type and number of keys or badges;
• the identity of the person handing them over and receiving them;
• the internal reference assigned to the means of access;
• the instructions strictly necessary for its use;
• the date and arrangements for its return;
• any incidents relating to the means of access.

Keys must not bear the client’s full address.

Alarm or access codes are only collected where they are essential. TS-BXL recommends using a temporary code or a code specific to the worker rather than disclosing a permanent personal code.

Means of access and the information linking them to the home are kept separately as far as possible.

4.7. Data relating to the ironing centres

TS-BXL may process, in particular:

• the client’s identity and contact details;
• the Pluxee user number;
• the reference of the laundry basket or drop-off;
• the date and time of drop-off and collection;
• the quantity or general description of the laundry handed in;
• any special instructions;
• the identity of the person authorised to collect the laundry;
• the service vouchers used;
• any incidents, losses or damage reported;
• confirmation of collection.

4.8. Signature recorded when collecting laundry

When laundry left at an ironing centre is collected, TS-BXL may ask the client, or the person collecting the laundry, to confirm the handover by means of a signature recorded on a tablet.

The signature is linked to a specific transaction, including in particular:

• the drop-off reference;
• the date and time of collection;
• the ironing centre concerned;
• the client’s identity or number;
• the identity of the person collecting the laundry, where necessary.

This signature is used solely to confirm the handover of the laundry and to prevent or resolve any dispute.

TS-BXL does not use it:

• to sign any other document;
• to create a general reusable signature;
• to authenticate the client automatically in other transactions;
• to analyse the physical or behavioural characteristics of the signature stroke;
• to create a biometric template;
• to identify a person by means of an automated recognition system.

In the absence of any technical processing intended to uniquely identify the person, the signature is treated as personal data, but not as biometric data within the meaning of Article 9 of the GDPR.

A reasonable alternative means of confirmation may be offered where a person does not wish to have their signature recorded, for example confirmation by code, e-mail or any other means of documenting the handover.

4.9. Financial, administrative and accounting data

TS-BXL may process, in particular:

• invoices and credit notes;
• administrative fees;
• payments received or outstanding;
• bank details;
• payment mandates and authorisations;
• communications relating to payments;
• reminders;
• the data needed for debt recovery;
• accounting and tax records.

Full payment card details are not stored directly by TS-BXL where they are processed by a specialised payment provider.

4.10. Complaints, incidents, accidents and claims

TS-BXL may process, in particular:

• the circumstances of an incident;
• statements by the people concerned;
• photographs;
• proofs of purchase;
• quotes and invoices;
• communications with the parties;
• information passed on to insurers;
• police report references;
• the data needed to establish, exercise or defend legal claims.

4.11. Data relating to health or safety

In certain situations, the client may disclose information about a contagious disease, an allergy, a functional limitation or another circumstance likely to affect the health or safety of the worker or the organisation of the service.

TS-BXL limits collection to what is strictly necessary.

As far as possible, TS-BXL only records the existence of the risk and the precautions to be taken, without keeping a detailed medical diagnosis.

This information is only accessible to the people who need to know it in order to protect the person concerned or the worker, organise the service or comply with a legal obligation.

4.12. Technical and digital data

When a website, form, portal or application is used, TS-BXL may process:

• the IP address;
• the date and time of connection;
• the type of device and browser;
• technical logs;
• session identifiers;
• cookie choices;
• actions carried out in the portal;
• the information needed for security and troubleshooting.

Further information can be found in the cookies and other trackers policy.

Article 5 – Sources of data

Data may be obtained:

• directly from the data subject;
• through a secure form;
• when the agreement is concluded or performed;
• by telephone, e-mail, post, text message or any other communication channel;
• from a representative, trusted person or authorised relative;
• from the worker performing the service;
• from Pluxee or the competent regional authority;
• from a payment provider;
• from an insurer, adviser or authority;
• through the systems and portals used to organise the services.

Where a person provides the data of a third party, they ensure that they are authorised to do so and, where relevant, invite that third party to read this policy.

Article 6 – Purposes and legal bases

6.1. Pre-contractual measures and performance of the agreement

TS-BXL processes the data needed to:

• respond to a request;
• assess needs;
• prepare and conclude the agreement;
• organise the services;
• assign a worker;
• manage the schedule, absences and replacements;
• manage the ironing centres;
• record and validate services;
• manage service vouchers;
• invoice and receive payments;
• communicate with the client;
• confirm the handover of laundry;
• manage the means of access entrusted to it.

This processing is based on steps taken at the person’s request prior to entering into a contract and on the performance of the agreement.

6.2. Legal and regulatory obligations

TS-BXL processes certain data in order to comply with its obligations, in particular regarding:

• service vouchers;
• employment law;
• health and safety at work;
• prevention and insurance;
• accounting and tax;
• consumer protection;
• debt recovery;
• cooperation with the competent authorities.

6.3. Legitimate interests

TS-BXL may process certain data where necessary for its legitimate interests, in particular to:

• ensure the safety of clients and workers;
• protect homes, keys and means of access;
• prevent fraud and misuse;
• keep proof of the handover of laundry;
• secure its systems;
• ensure the continuity and quality of the service;
• handle complaints and claims;
• establish, exercise or defend its rights;
• produce internal statistics after data minimisation or anonymisation.

TS-BXL balances these interests against the rights, freedoms and reasonable expectations of the data subjects.

6.4. Consent

Where processing cannot reasonably be based on another legal basis, TS-BXL may ask for specific consent.

The person may withdraw their consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.

Consent is not used as a legal basis where the data is objectively necessary for the performance of the service requested.

Article 7 – Whether information is required

Mandatory fields in forms are marked as such.

Where the data requested is necessary for the conclusion or performance of the agreement, failure to provide it may prevent TS-BXL from:

• responding properly to the request;
• assessing needs;
• proposing a worker;
• organising the service;
• ensuring safe working conditions;
• performing the service;
• complying with a legal obligation.

TS-BXL avoids asking for information that is excessive or unrelated to the service.

Data subjects are asked not to enter sensitive information that is not needed in free-text fields.

Article 8 – Recipients of data

To the extent necessary for their tasks, data may be accessible to:

• TS-BXL’s directors and authorised staff;
• the worker performing the service, only for the information they need;
• the TS-BXL company responsible for the service concerned;
• Pluxee and the competent regional authorities;
• hosting, maintenance and IT security providers;
• the providers of the forms, portals and applications used by TS-BXL;
• communication service providers;
• payment providers and financial institutions;
• accountants, insurers, lawyers, bailiffs and professional advisers;
• debt recovery providers;
• public, judicial or administrative authorities where required by law;
• anyone authorised by the data subject.

Providers that process data on behalf of TS-BXL are subject to contractual obligations of confidentiality, security and data protection.

TS-BXL does not sell its clients’ personal data.

Article 9 – International transfers

TS-BXL gives preference to providers that store data within the European Economic Area.

Where a provider processes data outside the European Economic Area, TS-BXL checks that the transfer is based on a mechanism recognised by the GDPR, in particular:

• an adequacy decision;
• standard contractual clauses approved by the European Commission;
• any other legally permitted safeguard.

Where necessary, TS-BXL assesses the risks of the transfer and applies supplementary measures.

Information on the safeguards used may be requested from hello@ts-bxl.be.

Article 10 – Retention periods

TS-BXL does not keep all data for the same length of time.

The following periods apply subject to any legal obligation, dispute or need to defend a right.

10.1. Requests not followed by an agreement

The data of a person who requests a service without becoming a client is kept for a maximum of twelve months after the last relevant contact.

It may be deleted sooner if the person withdraws their request.

10.2. Contract file

The data needed to organise the service is kept for the duration of the contractual relationship.

At the end of the relationship, the data needed to prove the agreement and its performance may be archived, with restricted access, for the applicable limitation period, not exceeding ten years where such a period is justified.

Purely operational data that is no longer of use is deleted sooner.

10.3. Descriptions of the home

The description needed to organise the services is kept for the duration of the contractual relationship and updated when the situation changes.

Information that has become unnecessary or out of date is deleted.

10.4. Absences and holidays

Operational details relating to an absence are deleted or reduced to what is strictly necessary no later than three months after the end of the period concerned, unless there is an incident, a dispute or a particular organisational need.

The fact that a service was cancelled or rescheduled may be kept in the schedule history for a maximum of two years in order to monitor the organisation of the service.

Destinations, detailed reasons and other unnecessary information are not kept.

10.5. Keys and means of access

Keys, badges and codes are kept or used only for as long as they are needed.

Codes are deleted as soon as they are no longer useful or as soon as the service concerned ends.

When a key or badge is returned, the operational register is updated immediately.

Proof of handover and return may be kept for five years in order to document the management of the means of access and to deal with any dispute.

10.6. Laundry collection signatures

The signature associated with the collection of laundry is kept for one year from collection.

In the event of a dispute, claim or proceedings, it may be kept until the file is finally closed and, where necessary, until the expiry of the period applicable to establishing or defending the parties’ rights.

When the applicable period expires, the image of the signature is deleted or made permanently inaccessible.

10.7. Complaints, incidents and claims

Data is kept for as long as necessary to handle the file.

The information needed to defend the parties’ rights may then be archived until the applicable limitation periods expire.

10.8. Accounting and tax data

Invoices, payments and supporting documents are kept for ten years or for any other period required by the applicable legislation.

10.9. Direct marketing

Data used for marketing communications is kept for the duration of the relationship with the client and, after it ends, for a maximum of three years from the last relevant interaction, unless the person has objected earlier.

The information strictly necessary to respect an objection may be kept on a suppression list.

10.10. Technical logs

Security and connection logs are kept for a period proportionate to their purpose, in principle six months, unless a security incident or specific obligation justifies keeping them longer.

Article 11 – Security and confidentiality

TS-BXL implements technical and organisational measures proportionate to the nature of the data and the risks involved.

Depending on the systems used, these measures include:

• encryption of communications;
• securing of forms;
• user authentication;
• restriction of access rights;
• use of individual accounts;
• logging of access and sensitive operations;
• protection of backups;
• software updates;
• protection against malware;
• separation of certain sensitive information;
• confidentiality undertakings;
• incident management procedures;
• secure deletion of data at the end of its retention period.

Particular attention is paid to:

• information about absences;
• keys, badges and codes;
• descriptions of the home;
• signatures;
• health-related data;
• bank details;
• documents relating to claims.

Workers only receive the information they need to perform their services.

Keys are not identified by the client’s full address. As far as possible, the key reference and the corresponding address are kept separately.

Signatures recorded on a tablet are linked to a specific transaction. Ordinary users of the system must not be able to freely download, copy or reuse them.

Article 12 – Automated decisions

TS-BXL does not take any decision based solely on automated processing that produces legal effects concerning a client or similarly significantly affects them.

Tools may assist with organising, scheduling or sorting requests, but important decisions concerning the relationship with the client may be subject to human intervention.

Article 13 – Marketing communications

TS-BXL may inform its clients about services similar to those they use, within the limits permitted by law and on the basis of its legitimate interest.

A person may object to direct marketing communications at any time, without having to give a reason.

Where consent is required, no marketing communication is sent before it has been obtained.

Communications necessary for the performance of the agreement, safety, the services, payments or regulatory obligations are not marketing communications.

Article 14 – Cookies and other trackers

The website www.ts-bxl.be may use cookies and similar technologies.

Cookies that are not strictly necessary are only used with the visitor’s prior consent.

Information about:

• the categories of cookies;
• their purposes;
• their providers;
• their duration;
• how to accept or refuse them;
• withdrawing consent,

can be found in the cookie policy and in the “Cookie settings” module.

Article 15 – Rights of data subjects

Under the conditions laid down by the GDPR, any data subject may request:

• access to their data;
• rectification of inaccurate data;
• erasure of their data;
• restriction of processing;
• portability of the data they have provided;
• to object to processing based on a legitimate interest;
• to object to direct marketing;
• to withdraw their consent;
• information about international transfers;
• human intervention regarding any automated decision.

These rights are not absolute. TS-BXL may, in particular, retain certain data where it is necessary:

• to comply with a legal obligation;
• to perform the agreement;
• to establish, exercise or defend a legal claim;
• to protect the rights of another person.

Any request may be sent to hello@ts-bxl.be or by post to the address given in Article 2.

TS-BXL may request the information reasonably necessary to verify the identity of the person making the request.

The request is handled within the time limit laid down by the GDPR.

Article 16 – Complaints

Anyone who believes that their data is not being processed correctly may contact TS-BXL.

They may also lodge a complaint with the Data Protection Authority, Rue de la Presse 35, 1000 Brussels, www.dataprotectionauthority.be.

Submitting a complaint to TS-BXL does not prevent the person from applying directly to the Data Protection Authority or the competent court.

Article 17 – Changes to this policy

TS-BXL may amend this policy, in particular because of:

• a change in its services;
• a change in its tools;
• a change in law or regulations;
• a recommendation from an authority;
• the addition or removal of a provider.

The applicable version is identified by its date and number.

Where a change substantially affects the way data is processed, TS-BXL informs the data subjects by appropriate means.

Previous versions are kept in order to document how TS-BXL’s practices have evolved.