Specific privacy notice related to the sharing of personal data between Orange Belgium and VOO


Outline of data-sharing agreement between Orange Belgium and VOO to exclude joint customers from direct marketing campaigns and grant them discounts.

1. What are the aims and consequences of this sharing and processing of data?

The purpose of sharing some of your personal data (see below) is to identify customers who have both a VOO contract and an Orange contract. Once this identification has been made, the shared data will be deleted by Orange Belgium.

Joint customers will receive fewer marketing messages from Orange Belgium and will be eligible for discounts as long as they are customers of both companies.


2. Why are VOO and Orange Belgium joint controllers

Orange Belgium and VOO consider themselves as joint controllers for processing your personal data, in that they :

2.1. Jointly define the means of the processing activity

The data subjects: the data of all Orange Belgium and VOO customers, except those who have objected to the use of their data for commercial purposes or to the sharing of their data between Orange Belgium and VOO. 
The type of data processed:
  1. Data enabling to authenticate you: customer number, surname, first name, postal address, date of birth and bank account number,
  2. Data concerning pour VOO products and associated product revenue,
  3. If you are a joint customer of Orange Belgium and VOO, 
The duration of data processing and storage: data is processed for each direct marketing campaign, i.e. for a very limited period of no more than a few hours. Once the data has been compared, the shared data will be deleted by Orange Belgium, except the information that you are a joint customer.

2.2. Jointly define the purposes of the processing activity

The data is processed to enable Orange Belgium not to send direct marketing communications to VOO customers and to grant discounts to joint customers.

3. Context

In the context of the data they exchange, Orange Belgium and VOO act as joint controllers of your data.

In accordance with Article 26 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data ("GDPR"), Orange Belgium and VOO have entered into a joint controllership agreement to govern the processing of your personal data. 

A joint controllership agreement is a mandatory document required by Article 26 of the GDPR when two or more data controllers jointly determine the purposes and means of the processing (as defined in point 3 of this document). This agreement regulates, in a transparent manner, the responsibilities of the joint controllers for compliance with the obligations arising from the GDPR and applicable privacy laws, in particular, regarding transparency obligations and the exercise of data subjects' rights.

VOO and Orange Belgium have further agreed that:
  • they would not use any other subcontractor and would not transfer the data of the persons concerned to any other entity, in particular, any entity located outside the European Union and/or an international organization;
  • they will take all security and confidentiality measures to respect the integrity of the data, prevent any breach and will not seek to re-identify the data subjects to whom the anonymous data relates;
  • in the event that data subjects exercise their GDPR right, the party that collected the data will be responsible for (i) managing requests and (ii) responding to data subjects;
  • since data subjects may exercise their GDPR rights against either party, the parties will always cooperate to the best of their ability to satisfy data subjects' requests as quickly and efficiently as possible.

4. Right to object

If you wish to object to this sharing of data between VOO and Orange Belgium, you can send a request at any time via the following channels:
You will also find full details of how Orange Belgium handles your personal data as an Orange customer in our general privacy policy, available at the following link: https://corporate.orange.be/fr/vie-priv%C3%A9e or https://corporate.orange.be/nl/vie-priv%C3%A9e

For VOO customes, you can object to the sharing of data between VOO and Orange Belgium at any time by clicking on the following link: www.voo.be/optout-orange .


5. Modification of this privacy policy

For customer information purposes, any changes to the Orange Belgium privacy notice will be published on this website.
Version 1 of June 2023