Data controller
Av. Van Volxem 264/C1, 1190 Bruxelles
BCE/KBO: 0460.646.961
BTW/TVA/VAT: BE0460.646.961
Email: info@pvresponse.be
1. Data processed
| Category | Data | Purpose |
|---|---|---|
| Identification | Name, email, phone | Account management, invoicing |
| Address | Street, city, postal code, country | Invoicing, documents |
| Business data | Company name, VAT number | B2B invoicing |
| Fine documents | Uploaded PDFs or images | AI analysis for contestation |
| Payment data | Transaction references (Stripe; Mollie until September 2026) | Payment processing |
| IP address | IP address of your connection | Proof of consent, recorded at case creation, security logs (legitimate interest — security) |
| National Registry Number | National Registry Number | Only for driver-identification responses; stored encrypted |
| Signature | Image of your handwritten signature | Signing letters; stored encrypted |
2. Legal bases
Contract performance (Art. 6(1)(b) GDPR) · Legal obligation (Art. 6(1)(c) GDPR) · Legitimate interest (Art. 6(1)(f) GDPR)
3. Retention periods
Account data: until deletion + 12 months · Invoice data: 7 years (statutory retention obligation) · Fine documents and generated letters: until the case or your account is deleted · Visit statistics (first-party): 30 days · Technical server logs: automatic rotation
4. Third-party transfers
Stripe (payments) · Mollie (payments until September 2026) · Anthropic (AI processing) · Combell (EU/Belgium hosting) · Pingen (Pingen AG, Switzerland — prints and posts your letter when you ask us to send it; receives the letter itself for that purpose, with your name and address and those of the recipient) · Brevo (Sendinblue SAS, France, EU — transactional e-mail delivery; receives your e-mail address and the message content) · Open-Meteo (historical weather data — receives only the coordinates and date/time of the violation location, no name or other personal data) · Komoot GmbH (Photon geocoder, Germany, EU — receives the street and municipality of the violation as a fallback when Nominatim finds no match, with no name attached) · Google (Google Ireland Ltd — analytics and advertising measurement, only after consent; see section 7) · OpenStreetMap Foundation (map display — see below). No sale of personal data.
Maps (OpenStreetMap)
On the case page, when your PV lists a location, we display a map of the place of observation. This map uses tiles from OpenStreetMap (OpenStreetMap Foundation, United Kingdom). When the map loads, your browser sends a direct request to tile.openstreetmap.org. Only the following technical data are shared: your IP address, user-agent (browser) and the coordinates of the map viewport. The address itself is converted to coordinates once, server-side, via Nominatim (also OSM infrastructure); this lookup originates from our servers, not from your device. OpenStreetMap sets no cookies and uses no tracking pixels. See their privacy policy for details.
Sign-in via Google or Facebook
If you choose to log in or register via Google or Facebook, you are redirected to that provider, which processes your sign-in under its own privacy policy. After your consent, we receive from the provider only the data needed to create your account and authenticate you: your name, your email address and a unique account identifier at that provider. We do not receive any password and have no access to your wider profile, contacts or messages. This data is used solely for account management and authentication (Art. 6(1)(b) GDPR). Google and Meta (Facebook) act as independent controllers and may process data outside the EU under appropriate safeguards; see their respective privacy policies. You can unlink this connection at any time by deleting your account.
5. Your rights
Access, rectification, erasure, restriction, portability and objection. Requests to info@pvresponse.be. Complaint to the Data Protection Authority.
7. Cookies & tracking
We always use strictly necessary cookies, including a session cookie (pv_session) for authentication and a cookie for your cookie preferences (cookie_consent). In addition, we use cookies for analytics and advertising measurement (Google) — these are set only after you have given explicit consent via the cookie banner. Without that consent, no Google scripts are loaded. In addition, we count page views only in aggregate (number of views per page per day), without cookies, without IP addresses and without any identification — this count contains no personal data. See our Cookie Policy for more information.
8. Automated processing & AI
Your uploaded documents are processed by artificial intelligence (Anthropic Claude) for text recognition (OCR) and drafting objection letters. No fully automated decisions with legal effects within the meaning of Art. 22 GDPR are made. You retain control at all times: the generated objection can be modified, supplemented or rejected by you before use.
9. Data security
We take appropriate technical and organisational measures to protect your data:
- File encryption at rest — all uploaded documents (PVs, signatures) and all generated PDFs are encrypted with AES-256-GCM before being written to disk. The key lives only in an environment variable (not in the database, not in the source code).
- Column-level encryption at rest for sensitive database fields — the following contents are encrypted with AES-256-GCM before storage (prefix
enc:v1:): National Registry Numbers, the full text of every contestation letter (including versions and chat-driven edits), the text and HTML of every incoming or outgoing reply letter, the text and HTML of every email flowing through our infrastructure, and the National Registry Number inside every driver-identification submission. A database dump without the separate encryption key yields only unreadable ciphertext. - Secure connection via HTTPS/TLS — every outbound API call (Anthropic, Stripe, Mollie, Brevo, Nominatim) uses TLS with authentication in the request header, never in the URL.
- Passwords stored hashed with Argon2 (never in plain text).
- Session management with automatic expiry (24 hours).
- Access controls: only authorised staff have access to personal data; access logs are retained for 30 days.
10. International transfers
Anthropic (United States) processes document content for AI analysis. This transfer is covered by Standard Contractual Clauses (SCCs) in accordance with Art. 46 GDPR. Google LLC (United States) processes analytics and advertising-measurement data (only after consent); this transfer is covered by the EU-US Data Privacy Framework. Stripe Payments Europe Ltd (payments, Ireland), Mollie (payments) and Combell (hosting) operate within the EU/EEA. Pingen AG (Switzerland) prints and posts the letters you ask us to send; Switzerland benefits from a European Commission adequacy decision (26 July 2000), so this transfer requires no additional safeguards. OpenStreetMap Foundation (United Kingdom) provides the map tiles; the UK benefits from a European Commission adequacy decision (28 June 2021), so this transfer requires no additional safeguards.
11. Children
Our service is not intended for persons under 18 years of age. We do not knowingly collect personal data from minors. If you become aware that a minor has provided data, please contact us so we can delete it.
12. Data breach notification
In the event of a personal data breach, we will notify the competent supervisory authority within 72 hours in accordance with Art. 33 GDPR. If the breach poses a high risk to your rights and freedoms, you will be notified without undue delay in accordance with Art. 34 GDPR.
13. Changes to this policy
We may update this privacy policy from time to time. In the event of material changes, we will notify you by email. Continued use of the service after notification constitutes acceptance of the amended policy. The most recent version is always available at pvresponse.be/privacy.