Privacy Policy CVSO Waalse Krook

Version of May 18th 2021 (V1.0)

Summary of the Privacy Policy

(i) Introduction

Comon, brand name of CVSO Waalse Krook (hereinafter “Comon/CVSO Waalse Krook”) and consisting of City of Ghent, Library De Krook, imec, Ghent University, Urgent.fm, Avansa regio Gent (hereinafter the Partners), highly values your right to privacy and makes every effort to protect your personal data in accordance with current data protection legislation, in particular the General Data Protection Regulation (“GDPR”) and national implementing legislation.

This short summary of our Privacy Policy aims to inform you about how Comon/CVSO Waalse Krook processes your Personal Data in the context of its activities, online or in person. This Privacy Policy should be read together with the Cookie Policy, which you can find here (see article 9). Would you like to know more? Then we invite you to read our full Privacy Policy, explaining everything in detail.

(ii) From whom do we collect personal data in the context of our activities?

Data from visitors of our websites www.dekrook.be and www.comon.gent;
Data from from people who subscribe to our electronic mailings or newsletters;
Data from people who register for our activities;
Data of people who book meeting rooms;
Data of people who fill in the contact form;
Data of people who fill in the challenge proposal form;
Data from people who post a comment on the website;
Data of people who cast a vote through the voting form.

(iii) Which Personal Data do we process?

We collect some personal data (such as identification details and contact details) to the extent that they are relevant to the purposes for which we need them. If certain data are mandatory to fill in, and others only optional, we will clearly indicate this so that you can choose whether or not to provide us with your personal data.

We process personal data of people registering for and/or participating in our activities and events, people booking meeting rooms or visitors to our website. We obtain most personal data directly from those concerned.

We also process certain non-directly identifying data when you visit our website, such as the type of browser you use, the operating system you use, your IP address, etc.

We certainly do not intend to process sensitive data about you. In cases where we do indirectly process sensitive data about you, for example as a result of the events we organise, we will take the utmost care of this data.

(iv) For what purposes do we collect and process your Personal Data?

We collect and process the abovementioned Personal Data to achieve the following purposes:

For the management of our website
For marketing purposes, our electronic newsletter (if you have subscribed)
For statistical purposes
To send you information regarding future activities
For the administrative processing and follow-up of your registration
To provide you with specific information regarding your reservation
For registration for and participation in events
For providing the services of Comon

(v) What do we do to protect your Personal Data?

We take appropriate technical and organisational measures to ensure a level of security appropriate to the specific risks we have identified. We so protect your personal data as best we can against destruction, loss, alteration or any other unauthorised processing.

(vi) How long do we keep your Personal Data?

We keep your Personal Data for the period we are legally obliged to do so or for as long as is essential for the purposes of the processing or for the (contractual) relationship. For more info: see article 5 of the extended privacy statement below or click here.

(vii) What are your rights?

For any processing of your Personal Data, you may exercise the following rights by sending an email to privacy@comon.gent or by post to CVSO Waalse Krook, Platteberg 11, 9000 Ghent. For more info: see article 5 of the extended privacy statement below or click here.

Right of access and insight
Right of rectification, deletion and restriction
Right of objection
Right to withdraw consent
Right to lodge a complaint
Right not to be subject to automated decisions and profiling
Right to free transfer of data

Article 1 - General
Article 2 - Collected Personal Data
Article 3 - Doeleinde van de verwerking
Article 4 - Who has access to your Personal Data?
Article 5 - Duration of processing
Article 6 - Your rights
Article 7 - Safety and Confidentiality
Article 8 - Applicable Law and Jurisdiction of courts
Article 9 - Cookies

Artikel 1 – GENERAL

1.1 Your privacy is very important to us. In the context of our activities, we collect, use, store, share or process Personal Data. This privacy notice has been created to inform you, as a visitor to our website and when you use our services, how we handle your Personal Data, being any information relating to an identified or identifiable person (hereinafter ‘’Personal Data‘’) and how you can exercise control over it. Please read this Privacy Statement carefully as it contains Your rights and obligations towards Comon/CVSO Waalse Krook.

This Privacy Policy is intended to inform you in a transparent manner about the personal data we process in the context of our activities, its purpose, the way we use it and the rights you have in relation to the processing of such Personal Data.

This Privacy Policy may be updated regularly. We therefore recommend that you consult it regularly on the Comon website.

1.2 The controller for the processing of your Personal Data is Comon, brand name of CVSO Waalse Krook (hereinafter ‘Comon/CVSO Waalse Krook’), with registered office in 9000 Ghent at Miriam Makebaplein no. 1, registered with the Crossroads Bank for Enterprises, under enterprise number 0819.226.861, (bibliotheek@stad.gent, tel: 09/323.68.00).

1.3 The collection and processing of Personal Data is subject to strict conditions. Comon/CVSO Waalse Krook shall at all times act in accordance with:

i. The European Personal Data Protection Regulation 2016/679 of 27 April 2016; and/or
ii. Any (future) Belgian laws implementing this Regulation.

This privacy notice applies to how we handle your Personal Data as part of our services.

If you wish to use our Services, we require your express approval of this privacy notice. This means that you agree to how we use and process Your Personal Data.

Article 2 – Collected Personal Data

The data we process:

We may collect the Personal Data listed below, insofar as it is relevant to the purposes for which we need it as set out in Article 3 below. Where certain information is mandatory to fill in, and others merely optional, we will clearly indicate this so that you can choose whether or not to provide us with your Personal Data.

Category 1: As a visitor of our website	Identification details	Electronic identification data: browser type, IP addresses, operating system, pages visited on our website, information collected through cookies (read our cookie policy)
Categor 2:You subscribe to our electronic mailings or newsletters.	Identification details	Name, e-mail address, organisation
	Various	Opt-in / opt-out for electronic mailings
Category 3: You subscribe/register for our activities (including workshops, lectures, debates, questionnaires, competitions, project calls,...)	Identification details	name, organisation, company name, address, phone/mobile number, e-mail address, municipality, city, VAT number, billing address, etc....
Category 4: You book a meeting room	Identification details	name, organisation, company name, address, phone/mobile number, email address, VAT number, billing address, etc....
Category 4: You book a meeting room	Various	Data you communicate to us
Category 5: You participated in one of our events	Identification details and images	Pictures and videos
Category 6: You fill in the contact form on the website	Identification details	Name, e-mail address, subject, message
Category 7: You fill in the challenge proposal form on the website	Identification details	Name, e-mail address, title of challenge, description of challenge
Category 8: You post a reaction on our site	Identification details	Name, e-mail address, organisation, response
Category 9:You cast your vote via the voting form on the website	Identification details	E-mail address, IP address
	Various	Opt-in voor marketing purposes

Your Personal Data will be stored on paper (in a locked cabinet and/or secure safe) if you use the registration form and/or electronically (in protected databases on secure European servers) if you use our website.

Article 3 – PURPOSE OF PROCESSING

Comon/CVSO Waalse Krook collects and processes the above Personal Data to achieve the following purposes and on the following legal grounds:

3.1 General purposes and legal grounds

Category	Purposes	Legal ground
Category 1	For managing our website (optimising website and analysing website usage)	Consent and/or Legitimate interests
Category 1, 2	For marketing purposes, our electronic newsletter (if you have subscribed).	Your consent (Opt -in) or legitimate interests
Category 1, 2	Statistical purposes	Your consent (Opt -in) or legitimate interests
Category 3	To send you information relating to future activities of Comon or any of its Partners For registration for and participation in events For the provision of services and services of Comon	Your consent (Opt -in) or legitimate interests For activities of Partners affiliated with Comon's activities: Your consent (Opt -in) or legitimate interests For activities of Partners not related to Comon's activities: explicit consent
Category 3	For administrative processing and follow-up of your registration	Execution of the agreement (and where necessary: your explicit consent)
Category 4	For administrative processing and follow-up of your reservation, as well as to provide you with concrete information related to your reservation	Performance of the agreement (and where necessary: your explicit consent)
Category 5	Marketing purposes, promotion of Comon, publication of the events	Depending on the situation your consent or legitimate interest
Category 6	For the administrative processing of your request as well as direct marketing purposes of Comon	Informed explicit consent.
Category 7	For the administrative processing of your request as well as direct marketing purposes of Comon	Informed explicit consent.
Category 8	For the administrative processing of the response you leave. If you did so anonymously, no identifying data will be processed	Informed consent.
Category 9	For the processing of your vote and also to check that you do not misuse the voting form. As well as for purposes of direct marketing	Informed explicit consent.

3.2 Direct marketing

Your data relating to your identification will only be used for direct marketing purposes (e.g. to keep you informed about novelties in the range of our services), if you expressly and in advance agree to this by ticking a check-box (‘’opt-in‘’) and insofar as such a possibility is offered.

In case you have given your consent and you have been added to the direct mailing list of Comon/CVSO Waalse Krook, the latter may use your Personal Data to send you marketing material as well as material related to its Services. This consent may be withdrawn at any time, free of charge and without justification, by clicking on the cancellation button at the end of each promotional e-mail.

3.3 Transfer to third parties:

3.3.1 Working with subcontractors

Comon/CVSO Waalse Krook will rely on third parties to perform and enable our Services. Examples of these suppliers and service providers include entities that provide analytics, marketing and web hosting services or help improve the diagnostic competences of our Services.

We guarantee a similar level of protection by making contractual obligations opposable to third parties, which are similar to this privacy statement and ensure that security and confidentiality with respect to your Personal Data is observed.

3.3.2 Indirect Marketing

Furthermore, we will not sell, rent, distribute or otherwise make your Personal Data commercially available to third parties unless you give your express consent to do so or if there is a law requiring us to do so. We have therefore taken all legal and technical precautions to prevent unauthorised access and use.

3.3.3 International transfer

In case of international data transfers from the EEA to a country outside the EEA that has been recognised by the European Commission as having an adequate level of data protection, your personal data will be transferred on this basis.

For transfers to countries outside the EEA that have not been recognised by the European Commission as having an adequate level of data protection, we will invoke an applicable derogation depending on the specific situation and implement appropriate technical and organisational measures to ensure that your personal data is protected.

Article 4 - WHO HAS ACCESS TO YOUR PERSONAL DATA?

To fulfil the above-mentioned purposes, there may be cases where we need to inform other parties in order to provide our services as effectively as possible. For example, we may need to disclose your Personal Data to:

Employees of Comon/CVSO Waalse Krook;
Entities that are part of Comon/CVSO Waalse Krook;
Service providers who provide services on our behalf and act as processors for us (PR and marketing experts, IT managers, ...);
To the extent applicable, employees of one of the Partners Other bodies, upon request and to the extent permitted by law.

Article 5 - DURATION OF PROCESSING

The Personal Data will be kept and processed by us for the period we are legally obliged to do so or for as long as this is essential for the purposes of the processing or for the (contractual) relationship between you and Comon/CVSO Waalse Krook.

After the expiry of the retention periods, the necessary appropriate measures will be taken to delete the personal data.

Personal Data	Storage period
Category 1: As a visitor of our website Category 2: You subscribe to our electronic mailings or newsletters. Category 3: You subscribe/register for our activities (including workshops, lectures, debates, questionnaires, competitions, project calls,...) Category 4: You book a meeting room Category 5: You participated in one of our events Category 6: You fill in the contact form on the website Category 7: You fill in the challenge proposal form on the website Category 8: You post a reaction on our site Category 9: You cast your vote via the voting form on the website	Any personal data used for marketing purposes will be kept until you inform us that you no longer wish to receive our mailing. As regards the data of visitors to our website, we also refer to our Cookie Policy, which you can find in article 9 of this Privacy Statement. We do not keep your personal data longer than necessary for the purposes for which they are processed (as described above). Specifically, this means that we will delete your data 5 years after your last active action (registration, participation in event or contact with us).

Personal Data

Storage period

Category 1: As a visitor of our website

Category 2: You subscribe to our electronic mailings or newsletters.

Category 3: You subscribe/register for our activities (including workshops, lectures, debates, questionnaires, competitions, project calls,...)

Category 4: You book a meeting room

Category 5: You participated in one of our events

Category 6: You fill in the contact form on the website

Category 7: You fill in the challenge proposal form on the website

Category 8: You post a reaction on our site

Category 9: You cast your vote via the voting form on the website

Any personal data used for marketing purposes will be kept until you inform us that you no longer wish to receive our mailing. As regards the data of visitors to our website, we also refer to our Cookie Policy, which you can find in article 9 of this Privacy Statement. We do not keep your personal data longer than necessary for the purposes for which they are processed (as described above). Specifically, this means that we will delete your data 5 years after your last active action (registration, participation in event or contact with us).

Article 6 – YOUR RIGHTS

6.1 Right of access and viewing

You have the right to know about your Personal Data and the use we make of your Personal Data at any time. This, for example, by requesting a copy of your Personal Data.

6.2 Right of correction, deletion and restriction

You are free to communicate or not communicate certain Personal Data to us.

You always have the right to request us to amend your Personal Data.

You may also request that the processing of your Personal Data be restricted, if you believe that your data is inaccurate and you subsequently notify us accordingly.

In addition, you have the right to request Comon/CVSO Waalse Krook to delete your data insofar as we are not in a position to make them anonymous.

However, if you refuse to communicate certain Personal Data, or if you ask us to remove them, we may no longer be able to offer our Services in an optimal manner.

6.3 Right to object

You also have a right to object to the processing of your Personal Data when you have serious and legitimate reasons to do so.

You also have the right to object to the use of your Personal Data for direct marketing purposes. In this case, no specific justification will be requested.

6.4 Right of free data transfer

You have the right to obtain Your Personal Data processed by us in structured, common and machine-readable form and/or to transfer it to other controllers.

6.5 Right to withdraw consent

You have the right to withdraw your prior consent to the processing of your Personal Data where the processing of your Personal Data is based on your consent.

6.6 Automated decisions and profiling

You have the right to ask us not to be the subject of a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you.

6.7 Exercising of Your Rights

You can exercise your rights by contacting us, via e-mail to privacy@comon.gent or by post to:

CVSO Waalse Krook
Platteberg 11
9000 Ghent

The exercise of these rights is in principle free of charge. In the event of unreasonable or repeated requests, we may charge a reasonable administrative fee for this.

6.8 Right to file a complaint

You have the right to lodge a complaint with the Belgian Data Protection Authority, which is the data protection authority under which Comon/CVSO Waalse Krook falls:

Gegevensbeschermingsautoriteit
Drukpersstraat 35, 1000 Brussel,
Tel +32 (0)2 274 48 00, Fax +32 (0)2 274 48 35,
Email: contact(at)apd-gba.be

This is without prejudice to a civil court remedy, in other words you can still exercise your rights in civil court. If you are from an EU member state other than Belgium, you can also file a complaint with your national data protection authority (for the Netherlands, this is the Autoriteit Persoonsgegevens: https://autoriteitPersoonsgegevens.nl/nl/zelf-doen/gebruik-uw-privacyrechten/klacht-melden-bij-de-ap).

If you were to suffer damages as a result of the processing of your Personal Data, you may bring a claim for compensation.

Article 7 – SAFETY AND CONFIDENTIALITY

We have developed technically, administratively and organisationally appropriate security measures to avoid the destruction, loss, falsification, modification, unauthorised access or inadvertent disclosure to third parties of your Personal Data, as well as any unauthorised processing of such data. However, in the event that this does occur and would concern your Personal Data, Comon/CVSO Waalse Krook will inform you of the breach, including a description of the potential impact and a recommendation to mitigate the possible negative consequences of the breach.

Comon/CVSO Waalse Krook stores Your Personal Data securely on servers located within the European Economic Area.

Under no circumstances can Comon/CVSO Waalse Krook be held liable for any direct or indirect damage resulting from an erroneous or unlawful use by a third party of the Personal Data.

Article 8 – APPLICABLE LAW AND JURISDICTION OF THE COURTS

This privacy statement is governed, interpreted and implemented in accordance with Belgian law, which is exclusively applicable.

The courts of Ghent have exclusive jurisdiction to take knowledge of any dispute that might arise from the interpretation or execution of this privacy declaration.

Article 9 – COOKIES

9.1 What are cookies?

A ‘cookie’ is a small file sent by Comon/CVSO Waalse Krook's server and placed on your computer's hard drive.

9.2 Why does Comon/CVSO Waalse Krook use cookies?

Websites and applications use cookies and similar technologies to distinguish your usage preferences from those of other users of the website and/or application. This helps us to provide you with a better user experience when you use our website and also allows us to optimise it. For example, cookies help to optimise your visit to our website, to remember technical choices (e.g. choice of language, newsletter, et cetera) or to show you more relevant services and offers.

As a result of the European e-Privacy Directive, all websites and applications targeting certain parts of the European Union are required to seek your consent to the use or storage of non-essential cookies and similar technologies on your computers or mobile devices. This Cookie Statement provides you with clear and comprehensive information about the cookies used by Comon/CVSO Waalse Krook, including their purpose.

The cookies we use are secure. The information we collect using cookies helps us to identify any errors or to show you specific services that we think may be of interest to you.

9.3 Types of cookies

There are many different cookies that can be distinguished by functionality, origin or retention period. Below, we first provide a general description of the types of cookies used on our website.

Type	Functions
Essential/ Strictly necessary cookies	These cookies are necessary for our website to function and cannot be disabled in our systems. They are usually set only in response to actions taken by you, such as setting your privacy preferences, logging in or filling in forms. They are necessary for proper communication and they facilitate navigation (e.g. returning to a previous page, etc.).
Performance/Analytics cookies	These cookies collect data on the use of our website such as the number of visitors, the time visitors spend on a web page and any error messages. They help to improve the performance of the website. These cookies do not identify you as an individual.
Third party cookies	First party cookies are cookies sent from our servers or domains, from which the requested service is provided. Third party cookies are cookies sent to your browser from a server or domain not operated by Comon/CVSO Waalse Krook, but by a collaborating organisation. Only these third parties have access to those cookies and the information collected by the cookie. If you would like to know more about these cookies, please refer to the policies offered by these parties on their respective websites. Please note that we have no influence on the content of these policies or on the content of these third-party cookies.

Third Party Cookies

Google Analytics

Name cookie	Type cookie	Description	Retention time
_ga	Analytical cookie	Used to analyse your use of our website anonymously so that we can tailor functionality and effectiveness to the needs and requirements of users.	2 years
_ga_*	Analytical cookie	This cookie tracks anonymised statistics.	1 year
Cookie-agreed	Essential/ Strictly necessary cookies	Keeps track of whether people have agreed to cookies.	100 days
Cookie-agreed-categories	Essential/ Strictly necessary cookies	Keep track of which cookie categories people have agreed to.	100 days
Cookie-agreed-version	Essential/ Strictly necessary cookies	Keep track of which version of the cookie agreement people have interacted with.	100 days
SESS*	Functional cookie	Temporary session cookie to keep track of which items people voted for, or which responses they reported as inappropriate.	1 session
Cookies van Google Recaptcha v3	Functional cookie	Functionality to verify that you are not abusing the ability to vote on challenges.	1 session
Cookies van Youtube en/of Vimeo bij embedden van video’s	Functional cookies that do not constitute essential cookies. However, these cookies may include marketing cookies	To allow video playback.	Youtube: up to 8 months Vimeo: tot 10 years

9.4 Managing Cookies

You can reject or block these cookies by changing the configuration parameters of your navigation system. Disabling cookies may prevent You from using certain functionalities of our website.

More information on how to set your browser can be found via the following links:

Google Chrome
https://support.google.com/chrome/answer/95647?hl=nl

Safari
https://support.apple.com/kb/PH19214?locale=en_US

Internet Explorer
https://support.microsoft.com/nl-nl/help/17442/windows-internet-explorer-delete-manage-cookies

Mozilla Firefox
https://support.mozilla.org/nl/kb/cookies-in-en-uitschakelen-websites-voorkeuren?redirectlocale=nl&redirectslug=Cookies+in-+en+uitschakelen

Currently, some browsers offer a ‘do not track’ or ‘DNT’ option that sends a signal to visited websites to indicate a visitor's tracking preference.[X] does not currently respond to these signals because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators. The third parties that place cookies on our website may or may not do anything in response to this signal.
Keep in mind that changing settings may cause a website to stop working as expected.

More information on cookies can also be found at the following link: https://www.allaboutcookies.org/

More information on behavioural online advertising and online privacy can be found at the following link: https://www.youronlinechoices.eu/