Two surfaces of Gunbix record people who have no account, have accepted no terms of use, and in most cases have never heard of the Service:
In both cases the data is not obtained from the person in the course of a relationship with Takion: it is the club that enters or transfers it. Article 14 GDPR applies, and it is more demanding than Article 13 precisely because the person suspects nothing.
The duty to inform falls on the club, which is the controller for these two surfaces (records of processing activities, sheets 15 and 16). Takion is its processor. This document supplies the club with the two texts to use; displaying and sending them remains the club's own act, and Takion has no means of doing it in its place.
Both texts are deliberately short. Article 12(7) GDPR allows layered information: a brief notice that says the essential, and a pointer to the privacy policy for the detail. A notice nobody reads informs nobody.
To be displayed legibly at the counter, where staff sign in a visitor, and to be shown to the person at the moment their name is asked for. Suggested format: a laminated card or an A5 frame, not a line at the bottom of a screen the person cannot see.
Your data in the range register
We have to record every person who shoots here. This is a legal obligation: the Royal Decree of 13 July 2000 requires every approved shooting range to keep this register and to retain it for ten years.
What we record: your surname, your first name, the type and calibre of the firearm used, your exact arrival and departure times, and the member accompanying you. We also record your date of birth and your nationality, in order to check that you are of age and that you have not already shot here this year without a licence; those two items are erased after two years.
If you are shooting on a day card (you have neither a sport shooter's licence nor a possession authorisation), we additionally record your address. The law requires it: this card must bear your name and address, and we must send a copy of it to the governor of your province within seven days. It is retained for ten years, like the register.
Who sees it: those responsible for this club, and nobody else. In the event of an inspection, the authority that approved us. The register is kept on Gunbix, Belgian software (TAKION SRL) which hosts it on our behalf in Europe and makes no other use of it.
Your rights: you may ask to see what is recorded about you, have it corrected, or object to it. Please contact the club secretariat. We cannot erase your entry before ten years have passed, because the law requires us to keep it - we will explain this to you if you ask.
A complaint? Data Protection Authority, Rue de la Presse 35, 1000 Brussels - www.dataprotectionauthority.be
Full detail: gunbix.com/en/privacy
To be completed by the club: the name of the club and the address of its secretariat, in place of the words "this club" and "the club secretariat".
To be sent within one month of the import (Article 14(3)(a) GDPR), by email or by post, to everyone appearing in the file taken over - including those who will not create an account. It is precisely to them that this text is addressed.
Subject: your membership record has moved to new software
Hello,
The club has changed its management tool. Your membership record, which was held in our previous software, has been transferred into Gunbix, a Belgian application published by TAKION SRL. We are telling you because it is your right, even though nothing changes for you.
What has been transferred: your surname and first name, your date of birth, your address and contact details, your membership number, your federation number and your licence dates, together with the history of your visits to the range.
What has not been transferred, and never will be: your national register number, any reference to an extract from the criminal record, any reference to a medical certificate, and your photograph. This information was filtered out automatically before the transfer.
Why: so that the club can continue to keep its membership file and its range register without starting from scratch. The latter we are legally obliged to retain for ten years.
Who has access: those responsible for the club, and nobody else. Takion hosts this data in Europe on our behalf, on our instructions, and makes no other use of it. The data is neither sold, nor passed to a third party, nor used for advertising purposes.
For how long: for the duration of your membership, plus twelve months. The history of your visits to the range, however, is retained for ten years, because the law requires it of us.
Your rights: you may ask to consult your record, have it corrected, request its erasure or object to its processing. Write to the club secretariat, which will reply within one month. If our answer does not satisfy you, you may lodge a complaint with the Data Protection Authority (Rue de la Presse 35, 1000 Brussels, www.dataprotectionauthority.be).
If you wish to use Gunbix yourself, you will be able to create an account and your record will be attached to it. If you do not wish to, there is nothing for you to do: nothing is asked of you.
The committee
To be completed by the club: the name of the club, the address of its secretariat, and the name of the software left behind if the club considers it useful to name it.
dpa.md). No club has done so to date.