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Privacy policy

Privacy policy

1. Privacy and security

Bebat places a premium on the protection of your privacy and your personal data. All references in the present Privacy Policy are references 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) (27 April 2016).Put simply: The important thing to remember is that we solely use and process your personal data in compliance with the GDPR and the other applicable statutory requirements.

In accordance with the said laws and regulations, and to the best of its abilities, Bebat shall put in place the appropriate technical and organisational measures to protect your personal data against destruction, loss, accidental alteration, damage or disclosure.

2. Who is protected by the present Privacy Policy?

2.1. Virtuel visitors:  

 All persons whose personal data we process and who, as a result thereof, become directly or indirectly identifiable (also referred to as the “Users”) further to visiting our website at, our portals:


our social media channels: 


 or other applications such as BebatCollect and Recycle!

The sheer fact that you visit and use our website, our portals, social media channels or applications implies that you accept and agree to possible processing operations. Exactly which data are involved is explained under item 4 of the present statement. Please feel free to raise any queries you may have on this matter by e-mail sent to

2.2. Real life Visitors:

Security camera’s, monitoring, CCTV: All persons whose personal data we process and who, as a result thereof, become directly or indirectly identifiable (also referred to as the “Visitors”) when entering Bebat’s, Villa Pila’s or Sortbat’s land or buildings. When visiting our premises it is possible that employees, external contractors and visitors or other third parties appear on camera footage.


3. What is data processing?

A.    Processing of data: 

The ‘processing of data’ is a broad concept which, in amongst other things, covers the collection, recording, storage, updating, adaptation or alteration, retrieval, consultation, use, dissemination or otherwise making available, assembly, combination, archiving, erasure of ultimately the destruction of these data. 

B.    Controller:

Bebat vzw with registered office at 5 Walstraat, 3300 (VAT: BE 0456.561.776) (hereinafter referred to as ‘Bebat’) is the party responsible for the website and consequently acts as the Controller. The Controller establishes, either by itself or in association with other parties, which personal data are collected, and the means and resources for the processing of these personal data. 

Please feel free to address any queries or complaints you may have to our Data Protection Officer (DPO), either by letter sent to the above address by recorded delivery or by e-mail sent to


4. Which personal data are involved?

4.1. Virtuel visitors:

We process the personal data you provide us with yourself or which we obtain from other parties, such as your employer when your company signs up with Bebat or when registering as a collection point. These data include elements such as your first name and surname, your address details, e-mail address, telephone number, gender, job title, e-mail traffic, etc.).The personal data collected by our systems (IP address, location data, which pages were visited, dates and times of your visits to the website).The personal data we obtain from third parties. Bebat informs the participants of the tombola that the personal data obtained through the collection bags only serve to determine the winner or winners without effective processing except for the announcement on the website and various channels.

4.2. Real-life visitors: 

The camera footage is only accessed for security reasons or if we have a reason to believe that certain irregularities have taken place. Reports and accounts concerning the content of the footage may be produced as well as photographs (stills).Camera footage indicating irregularities can be shared with external security services and other third parties, such as our affiliated entities, such as other security services, such as intelligence and investigative authorities or bodies, such as judicial services and competent courts or counterparties in legal proceedings.

5. What are your personal data used for?

5.1 Virtuel visitors:

Bebat collects data to deliver all users of our website, our platforms, social media channels and our applications an optimum and personal user experience. The data collected are processed solely for the following purposes:

  • To gain access to your user profile at myBatbase, myBebat, etc.
  • To offer general and personalised service delivery for the purposes of billing, newsletters and the communication of miscellaneous information, offers that are of interest to the user such as school campaigns, obtaining user feedback through surveys and delivering support through the contact centre.
  • To offer and improve the products and or services supplied; individual and specific products and or services based on the information and data obtained. 
  • To detect and protect against fraud, errors and flaws and/or criminal behaviour.
  • General customer management and the processing of contact details.
  • The processing of forms, orders, collections, information or contact requests.
  • To administer the declaration and billing process.
  • To generate reports, audits and inspection reports and contacts with the competent authorities in compliance with applicable laws and regulations.
  • To dispatch newsletters. 
  • To keep you up to date of our activities, through our blogs, or our competitions and raffles.
  • For publicity and/or marketing purposes in compliance with applicable laws and regulations.
  • Visitor statistics.
  • The optimisation of our various digital platforms.

5.2. Real-life visitors:

Bebat uses security camera’s in order to ensure:

  • That only authorized or competent persons enter our lands and buildings, at the adequate moments, 
  • That Bebat’s legitimate interests are protected,
  • To protect our business (interests), 
  • To protect our employees, external contractors, visitors and other third parties, as well as our properties,
  • To protect the confidential information,
  • To be able to investigate and handle irregularities,
  • The camera footage may serve to establish, exercise or defend our (legal) position in the event of (legal) proceedings or investigations.  

You are within your rights to object to so-called “direct marketing” at any time.

By visiting the Bebat website you accept and agree to the collection of data for the purposes listed above. 

No cause for alarm! All personal data you leave are treated with the utmost care and discretion and may be consulted only by persons who have been authorised to this end and who dutifully deal with your privacy 

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

  • Other than to our legal successor entities and affiliated companies (such as subsidiaries and sister companies) and only for the same purposes as specified in the present Privacy Policy.
  • Unless  this is necessary for our service delivery.
  • For some aspects of our products and services, we work with third parties or call on the services of sub-contractors. Examples include the collection of collection drums, our raffle, our social media channels, our marketing campaigns, self-employed consultants who assist us, etc.

Your data are transferred only for the same purposes as those that apply at Bebat itself. We see to it that these parties administer your data in a safe and respectful manner as a bonus pater familias, in the exact same manner as we do.

  • Unless a statutory obligation exists,
  • Unless a legitimate interest exists on the part of Bebat or the third party concerned. Any data transfer shall occur only provided this is not outweighed by your interests or your fundamental rights and freedoms,
  • Unless this is part of Bebat’s mission and stated object or social purpose,
  • Unless you give us your consent to do so.

If Bebat were to transfer personal data to third parties in any other manner, this shall be made to occur by way of an express and unambiguous communication, which provides information about the third party, and about the purposes of the transfer and processing. Where required by law, we shall seek to obtain your express consent. In addition, you are entirely within your rights to object to such a transfer at any time. 

With regard to international transfers of personal data, outside of the EEA countrieswe act to protect your data in compliance with the protection level required by applicable European laws and regulations.

Bebat does not put in place automated decisions based on the personal data provided by users.

In some cases, we use anonymous, aggregated data for commercial or external reporting purposes. In no event can these data be traced back to a particular individual. Some examples: Google Analytics, Hubspot, Wingify, etc.Bebat may collect anonymous or aggregated data of a non-personal nature, such as browser type or IP address, the operating system you use or the domain name of the website from where you came to the Bebat website, the Bebat portals or applications, or through which you left the said Bebat online platforms. This enables us to optimise the Bebat website, the portals and applications for the users’ benefit on an ongoing basis.

The legitimate grounds which Bebat goes by to process personal data are: 

  • Compliance with the national and international laws and regulations on extended producer responsibility, with specific reference to the take-back obligation for batteries as set out in Directive 2066/66/EC and its transposition by the Regions into Regional decrees and regulations and other applicable legislation, and/or,
  • Upholding Bebat’s legitimate interest(s), insofar as this transcends the interests or the basic rights and fundamental freedoms of the user; and/or,
  • The performance of the agreement with Bebat, and/or,
  • The performance of a task carried out in the public interest,
  • The user’s consent.

6. We also use cookies!

Whilst visiting our site, cookies may be placed on your hard drive (the non-edible version, that is). Cookies are tiny bits of information which are stored on your own computer or mobile device and which are mostly used to optimise the user-friendliness of websites and apps. They are used for things such as remembering your language settings, to show relevant services, etc. Please see our Cookie Policy for more details.You can disable cookies at any time in your browser settings, although we would advise you to simply leave them on. 

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

A. Right to access / rectification / erasure of personal data

You are within your rights to request Bebat to inform you (further to positive authentication of your identity – please provide us with a copy of your identity card to this end) as to whether or not we process your personal data, and where we do, to be given access to these data, and to be provided with further details. The request must be clear and unambiguous, clearly stating what it is you wish to know, rectify or delete, so as to make it easier for us to retrieve the data which you have questions about. You are also entitled to be provided with a free copy of the data processed, in a comprehensible format. These requests may be submitted by e-mail sent to or by letter sent to the above address by recorded delivery. We normally get back to you with the information requested within one (1) month upon receipt of your request. As necessary, this time limit may be extended by another month. Bebat shall be free to bill a reasonable fee to cover its administrative expenses for each supplementary request or copy requested by you.Any inaccurate personal data may be rectified or deleted at any time by the user him/herself by adapting his/her user profile. You may also exercise your right to rectification by sending us an additional statement (by e-mail sent to or by letter sent to the above address by recorded delivery). We normally comply with these requests within one (1) month upon receipt as well. As necessary, this time limit may be extended by another month. The data deleted by you in your user profile may possibly be temporarily stored for some time, without being visible to the user.Moreover, as a user you are within your rights to have your data erased by us without unreasonable delay in the following cases:

  • Where your personal data are no longer technically required for the purposes for which they were collected or processed. 
  • Where you withdraw your consent yourself and no further legal basis exists for your data to be processed.
  • Where we do have not peremptorily legitimate grounds to process your data.
  • Where we are unlawfully processing your personal data.
  • Where your data are required to be erased by law.

We assess whether either of the aforesaid situations applies, and we would ask you to clearly state the grounds for your request to have your data erased.

B. Right to lawful and secure processing of the personal data

Your personal data are collected and processed only in compliance with the purposes as detailed and justified in the present Privacy Statement.The data retention periods of cookies are detailed in our Cookie Policy.Upon termination of the agreement, personal data are kept on record for the durations imposed by applicable laws and regulations or for as long as Bebat continues to have a legitimate interest, as is the case for the duration of the statutory periods of limitation (time-barred periods) for instance, whereby the longest duration period is observed.As a general rule, we will keep camera footage during a limited period of time, in conformity with legislation, after which period the camera footage is destroyed, except if the camera footage shows some irregularities. In that case, in conformity with legislation, we will keep the camera footage for a longer period of time, to enable us to investigate and handle these irregularities and to serve as element of proof.

C. Right to restriction of the processing

You are within your rights to be granted a restriction of the processing of your personal data where one of the following situations applies:

  • You dispute the accuracy of the personal data: the use of these data will be restricted for a certain time period to enable Bebat to verify the accuracy of the data concerned;
  • The processing of your personal data is unlawful: instead of erasing your data, you request for the use of your data to be restricted;
  • Bebat no longer requires your data for the original processing purposes, but you require these data in order to institute, exercise or corroborate a claim pursued before the courts: instead of erasing your data, the use thereof is restricted to enable the legal claim to be instituted, exercised or corroborated;
  • As long as no decision has been made about the exercise of your right to object to their processing, you have requested for the use of your personal data to be restricted.

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

On the grounds of your particular situation, you are within your rights to object to the processing of your personal data if the processing is conducted as part of Bebat’s legitimate interest or in the context of the public interest. Bebat shall cease processing your personal data, unless Bebat is able to demonstrate peremptory and legitimate grounds for their processing which outweigh your interests or where the processing of the personal data is in connection with the institution, exercise or corroboration of a claim pursued before the courts (e.g., where you file a petition with the court).

E. Right to data portability

For the personal data which (i) are processed as part of the performance of an agreement with yourself, (ii) were provided by yourself and (iii) are processed by way of automated processes, you are within your rights to be provided with the said personal data by Bebat in a structured, commonly used and machine-readable format, as well as to transmit the said data or have them directly transmitted to a new partner, where this is technically possible.

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

As a user, you are free at all times to withdraw your consent for the use of your personal data by Bebat, in compliance with applicable laws and regulations, if the processing is made to occur pursuant to consent. In addition, you may also file a complaint with the relevant Data Protection Authority (DPA) (the former Belgian Commission for the Protection of Privacy / Privacy Commission).In that case, Bebat will normally respond to your request within one (1) month upon receipt. As necessary, this time limit may be extended by one (1) month. Any such withdrawals of consent and complaints must be notified by letter sent to the above address by recorded delivery or by e-mail to

Our websites, portals and applications

The present Privacy Policy applies to the following websites: 


Social media channels:

Other (occasional) websites, apps and other digital Bebat platforms come under the same Privacy Statement and the same Cookie Policy.Bebat reserves the right to amend the present Privacy Statement at any time.

The present Privacy Statement was last amended and revised on 15.05.2018.At all times, this page has the latest version of the Privacy or the Cookie Statement.