Effective since: 01/10/2019 v2
1. GENERAL WARNING
1.1 The VO COMMUNICATION SA (hereinafter, « VO COMMUNICATION ») respects the privacy of its users (hereinafter, the "Users").
1.2 VO COMMUNICATION processes the personal data transmitted to it in accordance with the legislation in force, and, in particular, Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, applicable from 25 May 2018 (hereinafter the "General Data Protection Regulation").
1.4 The User acknowledges having read the information below and authorizes VO COMMUNICATION to process, in accordance with the provisions of the Policy, the personal data that he/she communicates on the Website (hereinafter, the "Service").
1.5 The Policy is valid for all pages hosted on the Website and for the registrations of this Website, as well as all company pages managed by VO COMMUNICATION on social networks, who is jointly responsible with the social network for the processing of data of visitors to the page. It is not valid for the pages hosted by third parties to which VO COMMUNICATION may refer and whose privacy policies may differ. VO COMMUNICATION cannot therefore be held responsible for any data processed on these websites or by them.
2. DATA CONTROLLER
2.1 Simply visiting the Website shall take place without having to provide any personal data, such as first name, surname, postal address, e-mail address, etc.
2.2 As part of the Service, the User may be required to provide certain personal data. In this case, the data controller is:
VO COMMUNICATION SA
Rue de Stalle 140A
Belgian business registry (BCE) number: 0447.856.522
2.4 Any question regarding the processing of this data may be sent to the following address: email@example.com.
3. DATA COLLECTED
3.1 By completing the order form on the Website and using the Service, the User allows, in particular, VO COMMUNICATION to record and store, for the purposes mentioned in point 4, the following information:
- identifying data, such as the first name and surname, gender, e-mail address, date of birth and delivery address;
- professional data, such as experiences, degrees, skills, languages knowledges, center of interests and every document submitted by the User ;
- the banking information necessary for the Service, such as bank account numbers, IBAN and BIC/SWIFT;
- invoicing information;
- communications between the User and VO COMMUNICATION.
3.2 The User also authorizes VO COMMUNICATION to record and store the following data for the purposes mentioned in point 4:
- personal information gathered from various sources (e.g a third party website or an offline event) ;
- additional information requested by VO COMMUNICATION to the User in order to identify him or to prevent him from violating any of the provisions of the Policy.
3.3 In order to facilitate browsing the Website as well as to optimize technical management, the Website may use "cookies". These "cookies" record, in particular:
- the User's browsing preferences;
- the date and time of access to the Website and other data related to traffic;
- the pages visited;
3.4 When the User accesses the Website, the servers consulted automatically record certain data, such as:
- the type of domain with which the User connects to the Internet;
- the IP address assigned to the User (when connected);
- the date and time of access to the Website and other data related to traffic;
- location data or other data relating to the communication;
- the pages visited;
- the type of browser used;
- the platform and/or operating system used;
- the search engine as well as the keywords used to find the Website.
3.5 No nominative data identifying the User is collected through the cookies and servers consulted. This information is kept for statistical purposes only and to improve the Website.
3.6 We also collect some of your data through other companies, including from the following sources: Google, Facebook, LinkedIn, Exceleads, TBS Group (lefac.com).
4. PURPOSES OF PROCESSING THE DATA
4.1 We process your data for various purposes. For each purpose, only the data relevant to the pursuit of the purpose in question are processed. The processing consists of any operation (manual or automated) on a personal data. VO COMMUNICATION collects, stores and uses its Users’ data for the following purposes, in particular:
- to establish, carry out and conduct the contractual relationship with the User;
- to analyse, adapt and improve the content of the Website;
- to provide the Service;
- to allow the User to receive messages;
- to facilitate the availability and use of the Website;
- to personalize the User's experience on the Website;
- to respond to requests for information;
- for any marketing activities and promotions proposed by VO COMMUNICATION to Users who have given their consent;
- to inform them about any changes on the Website and its features;
- to build a more accurate view of its Users and offer them a better and more personalized service;
- to display ads based on the center of interests of the User;
- to give access the User to functionalities related to social networks (share, like, Connect);
- for any other purpose to which the User has expressly consented.
4.2 The legal basis of the processing of your personal data is based on:
- your consent ;
- the execution of any request from you;,
We do need to collect some of your data to answer any request from you. If you choose not to share this data with us, it may render the performance of the contract impossible.
- a legal obligation imposed on the controller ;
We do need to collect and store some of your data to meet various legal requirements, including tax and accounting.
- for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or
- our legitimate interest, provided that it is in accordance with your interests, freedoms and fundamental rights.
We have a legitimate interest in providing you with this information and interacting with you, especially to respond to your requests or improve our services, prevent abuse and fraud, control the regularity of our operations, exercise, defend and preserve our rights, for example in litigation, as well as evidence of a possible violation of our rights, manage and improve our relations with you, continually improve our website and our products/services, unless such interests are supplanted by your interests or your fundamental rights and freedoms requiring the protection of your personal data. We take care in any case to maintain a proportionate balance between our legitimate interest and respect for your privacy.
If the legal basis of our treatment is your consent, you have the right to withdraw it at any time without prejudice to the lawfulness of the processing performed prior to withdrawal.
In the context of direct marketing, this means that you can unsubscribe at any time from newsletters and other commercial communications from us. You will be put in "opt-out". You can unsubscribe by sending us an email at the following address: firstname.lastname@example.org or by clicking on the unsubscribe link at the bottom of each email.
5. RIGHTS OF THE DATA SUBJECT
5.1 According to the regulations on the processing of personal data, the User has the following rights:
- Right to be informed about the purposes of the processing (see above) and the identity of the data controller.
- Right of access: the User may at any time have access to the data that VO COMMUNICATION has on him or check if it is included in the database of VO COMMUNICATION.
- Right to rectification : we take all reasonable steps to ensure that the data we hold is up to date. We encourage you from time to time to access your account (if applicable) or to consult us to check that your data is up to date. If you find that your data is inaccurate or incomplete, you have the right to ask us to correct it.
- Right to object: the User may, at any time, object to the use of his data by VO COMMUNICATION.
- Right to erasure: the user may, at any time request the deletion of his personal data, except those which VO COMMUNICATION has a legal obligation to keep on record.
- Right of limitation of processing: the User may, in particular, obtain a limitation of processing when he has objected to the processing, when he disputes the accuracy of the data, or when he considers that the processing is illegal.
- Right of portability: The User has the right to receive the personal data that he has communicated to VO COMMUNICATION and may also ask said company to send this data to another data controller.
5.2 In order to exercise his rights, the User sends a written request, accompanied by a copy of his identity card or his passport, to the data controller:
- by e-mail: email@example.com
- by mail: Rue de Stalle 140A, 1180 Brussels
5.3 VO COMMUNICATION will then take the necessary steps to satisfy this request as soon as possible and in any case within one month of receipt of the application. If necessary, this period can be extended by two months, given the complexity and the number of requests.
- PERIODE OF STORAGE
6.1 VO COMMUNICATION will keep the personal data of its Users for the duration necessary to achieve the objectives pursued (see point 4).
6.2 VO COMMUNICATION may also continue to keep personal data concerning the de-registered User, including all correspondence or request for assistance sent to VO COMMUNICATION in order to be in a position to reply to all questions or complaints that may be sent to it after the order, and in order to comply with all applicable laws, namely in tax matters or as part of other legal requirements.
7. COMPLAINT WITH THE SUPERVISORY AUTHORITY
The User is informed that he has the right to lodge a complaint with the Data Protection Authority:
Data Protection Authority
Rue de la Presse, 35, 1000 Brussels
Tel : +32 (0)2 274 48 00
8.1 In addition, VO COMMUNICATION has taken the appropriate organizational and technical measures to ensure a level of security adapted to the risk and that, to the extent possible, the servers hosting the personal data processed prevent:
- unauthorized access to or modification of this data;
- improper use or disclosure of such data;
- unlawful destruction or accidental loss of such data.
8.2 In this respect, employees of VO COMMUNICATION who have access to this data are subject to a strict confidentiality obligation. Nevertheless, VO COMMUNICATION may in no way be held liable in the event that this data is stolen or hijacked by a third party despite the security measures adopted.
9. COMMUNICATION TO THIRD PARTIES
9.1 VO COMMUNICATION treats personal data as confidential information. It will not communicate them to third parties under any condition other than those specified in the Policy, such as to achieve the objectives set out and defined in point 4, or under the conditions in which the law requires it to do so.
9.2 Access to the data, in addition to that reserved to the data controller and his employees as indicated in Article 8 above, may, in certain cases, be granted to certain categories of external recipients, such as service providers. technical services, messaging services, hosting providers, IT companies, legal advice, marketing services, and VO Group SA for accounting, staff management and direct marketing purposes.
9.3 The updated list of these recipients can be requested at any time to the data controller.
9.4 The communication of this information to the aforementioned persons shall, in all circumstances, be limited to what is strictly necessary or required by the applicable regulations.
10. TRANSFER TO A COUNTRY OUTSIDE OF THE EUROPEAN ECONOMIC AREA
VO COMMUNICATION transfers data to a country outside the European Economic Area only when that country ensures an adequate level of protection within the meaning of the legislation in force and, in particular, within the meaning of the General Data Protection Regulation (for more information on the countries offering an adequate level of protection, see: https://goo.gl/1eWt1V), or within the limits permitted by the legislation in force, for example by ensuring the protection of data by appropriate contractual provisions.
The information processed by VO COMMUNICATION will be transferred or transmitted, or stored and processed, in the United States or other countries other than the country in which you live, for the purposes described in this Policy. These data transfers are necessary to provide the services or processing set forth in the Policy, and to operate and provide you with our Products worldwide. We use standard contractual clauses approved by the European Commission and we rely on the European Commission's adequacy decisions concerning certain countries, where appropriate, for data transfers from the European Economic Area to the United States and other countries. If you have any questions in this regard, do not hesitate to contact us at the following address: firstname.lastname@example.org.
11. DIRECT MARKETING
11.1 The personal data will not be used for direct marketing purposes for articles or services that would not be identical or similar to those to which the User has already subscribed, unless the User has previously explicitly consented to such use by ticking the boxes provided for this purpose ("opt-in").
11.2 When the User has given his consent to the use of this information for direct marketing purposes, the latter retains the right to object to such use at any time, upon request and free of charge. The User may simply communicate his request by writing to the following address: email@example.com.
12. NOTE CONCERNING MINORS
Persons under the age of 18 and persons who do not have full legal capacity are not allowed to use the Website. VO COMMUNICATION asks them not to provide their personal data. Any infringement found in this provision must be reported without delay to the following address: firstname.lastname@example.org
13. UPDATES AND CHANGES TO THE POLICY
By informing Users through the Website or email, VO COMMUNICATION may modify and adapt the Policy, in particular to comply with any new legislation and/or regulations applicable (such as the General Data Protection Regulation applicable from 25 May 2018), the recommendations of the Belgian Data Protection Authority, the guidelines, recommendations and best practices of the European Data Protection Board and the decisions of the courts and tribunals on this issue.
14. VALIDITY OF THE CONTRACTUAL CLAUSES
14.1 Failure by VO COMMUNICATION to invoke - at any given time - a provision of this Policy, may not be interpreted as a waiver to subsequently make use of its rights under the said provision.
14.2 The invalidity, expiration or the unenforceable nature of all or part of one of the above or below mentioned provisions shall not give rise to the invalidity of all the Policy. Any fully or partially invalid, lapsed or unenforceable provision shall be deemed not to have been written. VO COMMUNICATION undertakes to substitute this provision with another which, to the extent possible, fulfils the same objective.
15. APPLICABLE LAW AND COMPETENT COURT
15.1 The validity, interpretation and/or implementation of the Policy are subject to Belgian law, to the extent permitted by the provisions of applicable private international law.
15.2 In the event of a dispute relating to the validity, interpretation or implementation of the Policy, the courts and tribunals of Brussels have exclusive jurisdiction, to the extent permitted by the provisions of applicable private international law.
15.3 Before taking any step towards the judicial resolution of a dispute, the User and VO COMMUNICATION undertake to attempt to resolve it amicably. To this end, they shall first contact each other before resorting, where appropriate, to mediation, arbitration, or any other alternative method of dispute resolution.