New app? Here’s what you need to know

In addition to technological improvements and added user-friendliness, the new Q8 app also brings a significant legal and organisational change. Whereas the current Q8 smiles app is managed and offers a service by Smiles NV, viz. the Q8 smiles loyalty programme, the new Q8 app will be able to integrate services provided by not one but three parties: Smiles NV, KPB and KPL. All three parties are part of the Kuwait Petroleum group (hereafter Q8). The joint offering of these services in the Q8 app means that all three parties will come into contact with the personal data that will be processed in the app. For the processing of personal data in the Q8 app, Smiles NV, KPB and KPL will therefore act as joint data controllers as defined in the General Data Protection Regulation (GDPR for short).

  1. The new app is more user-friendly and saving Smiles is smoother.

  2. The Q8 smiles app you have right now will no longer work as from 30/01/2024.

  3. You can simply log in to your new app with your current account.

  4. And your saved Smiles? They will simply migrate along to the new Q8 app.

 

So get ready to download it.

The Q8 smiles app becomes the Q8 app

 

In addition to technological improvements and added user-friendliness, the new Q8 app also brings a significant legal and organisational change. Whereas the current Q8 smiles app is managed and offers a service by Smiles NV, viz. the Q8 smiles loyalty programme, the new Q8 app will be able to integrate services provided by not one but three parties: Smiles NV, KPB and KPL. All three parties are part of the Kuwait Petroleum group (hereafter Q8). The joint offering of these services in the Q8 app means that all three parties will come into contact with the personal data that will be processed in the app. For the processing of personal data in the Q8 app, Smiles NV, KPB and KPL will therefore act as joint data controllers as defined in the General Data Protection Regulation.

Joint data controllers?

Processing personal data as joint data controllers means that Smiles NV, KPB and KPL will jointly decide how to process personal data in the Q8 app. For instance, they will take joint decisions as to which personal data are processed, for what purposes they are required, how long the data will be retained, ... This joint decision-making process will therefore also apply to the services offered in the new Q8 app, what the app will look like, the parties with whom we collaborate, etc.

What changes for existing Q8 smiles customers?

 

1. Permission to share data of existing Q8 smiles customers

The collaboration of Smiles NV, KPB and KPL as joint data controllers does not apply retroactively and only starts when the new Q8 app goes live and is therefore available to users. Q8 smiles app users who decide to migrate to the new Q8 app will be able to choose between migrating their existing Q8 smiles account to the new app or creating a new account. In the latter case, Smiles saved up to that point will not be transferred to the new account.

Users who decide to keep their existing Q8 smiles account will be asked to give Smiles NV permission to share their personal data with the 2 new parties, KPB and KPL. As soon as they give this permission, all personal data of that user will henceforth be processed by Smiles NV, KPB and KPL as joint data controllers. When a user elects to create a new account, the account details of the old Q8 smiles app will not be migrated and the account and other personal data will be processed from the beginning of the registration in the new Q8 app by Smiles NV, KPB and KPL as joint data controllers.

2. Exercising rights under the GDPR

The joint decision-making process in terms of processing personal data also means that Q8 app users can call on all three parties to answer their queries regarding the processing of their personal data in the app. Users who wish to exercise certain rights under the GDPR (such as the right to erasure or the right to rectification) can also choose to which of the 3 parties they wish to submit this request.

In spite of the joint decision-making process, there is a division of tasks, roles and responsibilities among the 3 data controllers that was contractually stipulated. Users will be able to consult this division of tasks in the new app. And finally, the Q8 app will also contain a privacy statement that clearly explains how Smiles NV, KPB and KPL handle personal data in the Q8, how the roles and responsibilities are divided among the 3 parties and how app users can contact them if they have any questions or wish to exercise their rights.

If you have any questions about this organizational change, please contact us at [email protected] or [email protected].