1. GENERAL WARNING
1.1 The ASBL/VZW Association of Communication Companies (hereinafter, « Association of Communication Companies ») respects the privacy of their members, the users, providers, (…)(hereinafter, the "Data Subject").
1.2 Association of Communication Companies 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 Data Subject acknowledges having read the information below and authorizes Association of Communication Companies to process, , the personal data in accordance with and as described in the provisions of the Policy. (hereinafter, the "Service").
1.5 The Policy is among others valid for all pages hosted on the Website and for the registrations of this Website. It is not valid for the pages hosted by third parties to which Association of Communication Companies may refer and whose privacy policies may differ. Association of Communication Companies 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 Data Subject may be required to provide certain personal data. In this case, the data controller is:
ASBL/VZW Association of Communication Companies
Rue Saint-Hubert 17, 1150 Brussels
Belgian business registry (BCE) number: 0451546876
VAT Number: BE0451546876
2.3 Any question regarding the processing of this data may be sent to the following address: firstname.lastname@example.org.
3. DATA COLLECTED
3.1 By completing the subscription form on the Website and using the Service, the Data Subject allows, in particular, Association of Communication Companies to record and store, for the purposes mentioned in point 4, the following information:
- identifying data, such as the first name and surname, marital status, e-mail address, date of birth and mobile number;
- invoicing information, such as VAT number
- communications between the Data Subject and Association of Communication Companies, such as newsletters
3.2 The Data Subject also authorizes Association of Communication Companies to record and store the following data for the purposes mentioned in point 4:
- additional information requested by Association of Communication Companies to the Data Subject in order to identify him or to prevent him from violating any of the provisions of the Policy;
- when they have taken up one or other ACC initiative, personal data of teachers and training supervisors such as their identification information (surname, first name, e-mail address), direct number and general number, the name and postal address of their employer ;
- personal data of ACC members such as their identifying information (surname, first name, marital status, e-mail address, date of birth and mobile number), their invoicing details, communications (by email or other), location data or other data relating to the communication, (…);
- Any other personal data passed on to us (e.g. other contact persons in the context of the questionnaire for the Expert Center Young Talent, etc.)
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 Data Subject'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 Data Subject accesses the Website, the servers consulted automatically record certain data, such as:
- the type of domain with which the Data Subject connects to the Internet;
- the IP address assigned to the Data Subject (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 Data Subject is collected through the cookies and servers consulted.This information is kept for statistical purposes only and to improve the Website.
4. PURPOSES OF PROCESSING THE DATA
The Association of Communication Companies collects, stores and uses its Data Subjects’ data for the following purposes, in particular:
- to inform you by means of our newsletters;
- for all activities linked to our Expert Centers, to trainings and to events;
- to launch a survey among all Belgian high schools and universities and better support them in terms of office visits, internships, training packages, guest lecturers, research projects and so on;
- to establish, carry out and conduct the contractual relationship with the Data Subject;
- to analyze, adapt and improve the content of the Website;
- to provide the Service;
- to allow the Data Subject 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 Association of Communication Companies to Data Subjects who have given their consent;
- to inform them about any changes on the Website and its features;
- for any other purpose to which the Data Subject has expressly consented.
5. RIGHTS OF THE DATA SUBJECT
5.1 According to the regulations on the processing of personal data, the Data Subject 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 and verification of data: the Data Subject may, at any time, have access to the data that Association of Communication Companies has on him or check if he is included in the database of Association of Communication Companies.
• Right of objection: the Data Subject may, at any time, object to the use of his data by Association of Communication Companies and by its active partners (...) .
• Right of cancellation and/or modification: the Data Subject may, at any time, notify Association of Communication Companies of corrections to the data concerning him and, where appropriate, request the deletion of his personal data.
• Right of limitation of processing: the Data Subject 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 Data Subject has the right to receive the personal data that he has communicated to Association of Communication Companies and may also ask said company to send this data to another data controller.
5.2 The Data Subject may, at any time, request access to his personal data, verify them, transfer them, and, in some cases as mentioned, limit their processing and rectify them. The Data Subject may also request rectification free of charge and, where applicable, request the deletion of all his personal data from Association of Communication Companies's database - except those which Association of Communication Companies has a legal obligation to keep on record - and object to the use and, where appropriate, request the limitation thereof.
In order to exercise his rights, the Data Subject 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 Saint-Hubert 17, 1150 Brussels
5.3 Association of Communication Companies 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.
6. PERIODE OF STORAGE
6.1 Association of Communication Companies will keep the personal data of its Data Subjects for the duration necessary to achieve the objectives pursued (see point 4).
6.2 Association of Communication Companies may also continue to keep personal data concerning the de-registered Data Subject, including all correspondence or request for assistance sent to Association of Communication Companies in order to be in a position to reply to all questions or complaints that may be sent to it after the order the subscription, and in order to comply with all applicable laws, namely in tax matters.
7. COMPLAINT WITH THE SUPERVISORY AUTHORITY
The Data Subject is informed that he has the right to lodge a complaint with the Belgian Data Protection Authority (GBA/APD):
Address: Rue de la Presse 35, 1000 Brussels
Telephone number: +32 (0)2 274 48 00
Company number: 0694.679.950
8.1 In addition, Association of Communication Companies 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 Association of Communication Companies who have access to this data are subject to a strict confidentiality obligation. Nevertheless, Association of Communication Companies 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 Association of Communication Companies 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 Association of Communication Companies may communicate its Data Subjects’ personal information to third parties to the extent that such information is necessary for the performance of a contract with its Data Subjects. In such case, these third parties will not communicate this information to other third parties, except in one of the two following situations:
- the communication of this information by such third parties to their suppliers or subcontractors to the extent necessary for the performance of the contract;
- where such third parties are obliged by the regulations in force to communicate certain information or documents to the competent authorities in the field of combating money laundering, as well as, in general, to any competent public authority.
9.3 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 NON-EU COUNTRY OR COMPANY
Association of Communication Companies transfers data to a non-EU country or company only when that country provides an adequate level of protection within the meaning of the legislation in force, and, in particular, the 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.
11. PAYMENT SERVICE
11.1 Payment service goes via an invoice, sent by post.
12. DIRECT MARKETING
12.1 The personal data will not be used for direct marketing purposes for articles or services other than those to which the Data Subjects has already subscribed, unless the Data Subject has previously explicitly consented to such use by ticking the boxes provided for this purpose ("opt-in").
On the basis of the preferences you have expressed we may also send you information about related products.
12.2 When the Data Subject 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 Data Subject may simply communicate his request by writing to the following address: firstname.lastname@example.org.
13. NOTE CONCERNING MINORS
Persons under the age of 18 and persons who do not have full legal capacity are not permitted to use the Website. Association of Communication Companies asks them not to provide their personal data.
14. UPDATES AND CHANGES TO THE POLICY
By informing Data Subjects through the Website , Association of Communication Companies may modify and adapt the Policy, in particular to comply with any new legislation and/or regulations applicable, the recommendations of the Belgian Data Protection Authority (GBA/APD), the guidelines, recommendations and best practices of the European Data Protection Board and the decisions of the courts and tribunals on this issue.
15. VALIDITY OF THE CONTRACTUAL CLAUSES
15.1 Failure by Association of Communication Companies 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.
15.2 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. Association of Communication Companies undertakes to substitute this provision with another which, to the extent possible, fulfils the same objective.
16. APPLICABLE LAW AND COMPETENT COURT
16.1 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.
16.2 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.
16.3 Before taking any step towards the judicial resolution of a dispute, the Data Subject and the Association of Communication Companies 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.