1. Object and purpose

Fost Plus respects your privacy and therefore always acts in accordance with the applicable regulations on data protection (including the General Data Protection Regulation - GDPR).

This Privacy Statement contains more information on how the personal data of The Click-users are collected, used and processed by the Click app available in your appstore ("App" or "the Click"), under the responsibility of Fost Plus and, whether they are transferred to third parties.

By providing your personal data to us, you acknowledge that you are aware of the following terms and conditions under which Fost Plus processes and transfers personal data.

If you provide us with the personal data of other individuals, you guarantee that (i) the data subject was informed of this Privacy Statement, and that; (ii) insofar as certain processing requires consent, you have obtained the relevant consent from the data subject for this processing by Fost Plus. 

More information about the use of cookies can be found in our Cookie Policy.

2. Data Controller

The data controller is: Fost Plus vzw (non-profit organisation)

Registered office: Olympiadenlaan 2 Avenue des Olympiades, 1140 Brussels

Business number: 0447.550.872

Telephone: 0032 (0) 2 775 02 50

E-mail: privacy@fostplus.be


3. Personal data, purposes and legal grounds

Fost Plus collects and processes different categories of personal data concerning you (or the relevant data subject). This may be done, among other things, by filling out the online registration form for the App, by using the App, by registering your location during an event where the App is active, by exchanging CircularUCoins for vouchers or by contacting Fost Plus by using the contact form available via the Website or via e-mail.

The table below lists what personal data we process, for which purpose and the applicable legal ground.


Processed personal data

Legal ground

Your registration with the Click and first use

Identification data (name, e-mail, password)

Necessary in order to take steps at your request prior to entering into a contract (i.e. the terms of use of the Click)

Your use of the Click: scanning litter within a geographic zone where the Click is active

Location data (longitude and latitude) and time data (date and time of submission)
Device data IP-address, used browser and operating system)

Necessary for the performance of a contract (i.e. the terms of use of the Click) with you


Your use of the Click: exchanging CircularUCoins for vouchers in the shop

Transaction data ( amount of CircularUCoins collected/ spent, purchased vouchers, voucher code, transaction history)

Necessary for the performance of a contract (i.e. terms of use) with you

To be able to deal with your question, notification or request and if necessary, to respond to it (e.g. to provide you with requested information)

Identification data (name and e-mail)

When responding to your data subject request under the GDPR: Necessary to comply with a legal obligation imposed on Fost Plus.

Other possible situations: necessary for our legitimate interests to improve our services and your experience while using the Click.

To send you newsletters, personalised marketing or information via e-mail

Identification data ( name and e-mail,…)




Upon every use of the Click, various personal data and log files about you may be collected automatically, including your IP address, the date and length of your use of the App, your browser and your operating system. These data are used exclusively for statistical purposes and to monitor, analyse and optimise the working and use of the Click, in accordance with our legitimate interest in improving the App and our services. Such data are in principle not kept for longer than one year. 

We collect and process your location data only with the aim to verify whether you, when using the Click, are indeed situated within a geographic zone where the Click is active. These data are not stored or processed after the completion of the verification. 

The Click needs access to the camera of your device in order to allow you to take pictures of litter or to scan the barcodes of litter. Users are encouraged not to reveal other personal data concerning the user itself and other natural persons, especially no special categories of data, when uploading pictures to the Click. When a user uploads such information about him-/herself or others, the user is responsible for ensuring a legal ground for disclosing such information. 


4. Transfer to third parties

In the context of the fulfilment of the purposes set out above, Fost Plus calls upon third party service providers, e.g. IT service providers (Digital Fibre, Amazon Web Services). If necessary, to carry out their task, your personal data may also be transferred to these third-party service providers. In that case, they process your personal data solely in accordance with the instructions of Fost Plus and in line with the applicable regulations.

Fost Plus may also transfer certain personal data to external parties for processing for their own purposes while using their own means. In that case, these third parties act as the data controller under the applicable data protection legislation. This includes the transfer to competent authorities in the context of urgent or pending legal proceedings, in the context of judicial investigations and requests of information, at the request of the government or to comply with other legal obligations.


5. Transfer to countries outside of the EEA

We currently do not transfer your data to parties in countries outside the European Economic Area (EEA). If this would change in the future, we will ensure that your personal data is only transferred to parties that apply an appropriate level of data protection (e.g. by including the so-called EU standard contractual clauses of the European Union in the agreement with the recipient subject to an appropriate risk assessment).


6. Your rights as a data subject

As a data subject, you have the following rights:

Right to access – You have the right to consult your personal data that we process, as well as the right to obtain a copy of these personal data (barring certain exceptions).

Right to data portability – Under certain conditions, you have the right to receive the personal data you provided, in a structured, commonly used and machine-readable format, so you can transmit those data to another party.

Right to rectification and erasure – You have, at all times, the possibility of having your data corrected or deleted by us free of charge, provided the legal conditions are met. Data that we need for the establishment, exercise or defence of legal claims or which we are legally obliged to keep, are exempt from the right to erasure.

Restriction of the processing – Provided that the valid legal conditions are fulfilled, you can demand that we restrict the processing of your personal data.

Right to object – You may object, at any time, to processing of your personal data for direct marketing purposes or to processing that relies on our legitimate interest as the legal ground. When objecting to the processing of personal data for direct marketing purposes, you do not need to provide us with a reason.

Withdrawal of your consent – If we process your personal data on the basis of your consent, you have the right to withdraw this consent at any time. However, this withdrawal will not influence the legality of the processing of your personal data for the period prior to the moment of this withdrawal and processing activities that are based on another legal ground.

Complaint to the competent authority – You have the right at all times to contact the data protection authority in Belgium and, if appropriate, lodge a complaint.

To exercise the above rights, send an e-mail to privacy@fostplus.be. This e-mail must be accompanied by your full contact details and a means of verification of your identity (e.g. a copy of the front of your identity card or driving licence). Fost Plus may, however, refuse requests which it considers excessive or to be an abuse of the relevant law.

7. Storing your data

In principle, Fost Plus keeps your personal data only for as long as this is necessary for the purposes described above (bearing in mind the applicable legal prescription periods). For instance, personal data contained in questions that you ask us, are in principle only kept for a period of two years after receipt of the question. However, the data that we process – to the extent that you wish so – to keep you informed of our initiatives, etc. are kept up to date and processed for as long as you do not object to receiving newsletters, (digital) marketing or other information. Personal data that are linked to contractual documents (e.g. identification or transaction data) are kept for as long as your account on the Click is active and for a maximum period of ten years after the termination of the contract with Fost Plus, barring legal exceptions. After these periods, the data will be deleted.

Your account will remain active, until you request its deactivation or deletion.


8. Modifications

Fost Plus reserves the right to modify the Privacy Statement at any time, among other things to adapt it to changes in the services provided or amendments to the legal and/or regulatory requirements. Modifications to this Privacy Statement come into force at the time of publication. We advise you to always consult the most recent version. This Privacy Statement was published on July 25th,2020 and last updated on June 25th, 2021. 


9. Contact details of data protection manager and authorities

For questions about the processing of your personal data or exercising of your rights as a data subject, you can contact our Data Protection Manager (DPM) at any time. Our DPM was appointed, among other things, specifically to act as the contact person for persons whose data we process.

You can reach our DPM by e-mail (privacy@fostplus.be), by telephone on +32 2 775 03 50 or by sending a letter to: Fost Plus Data Protection Manager, Olympiadenlaan 2 Avenue des Olympiades, 1140 Brussels, Belgium.

You can also contact the Belgian Data Protection authority with any questions or complaints (https://www.dataprotectionauthority.be/).