1. General warning
BSP respects the privacy of its Users in accordance with Article 3 of the General Conditions of Use.
BSP processes the personal data transmitted to it in accordance with the legislation in force, and in particular with Regulation (EU) n° 2016/679 of 27 April 2016 (General Data Protection Regulation) (“GDPR”).
Access to the Website implies full and unreserved acceptance by the internet user of this Privacy Charter (hereinafter, the “Charter”), as well as its General Conditions of Use.
The User acknowledges having read the information below and authorizes BSP to process, in accordance with what is specified below, the personal data he communicates in the context of the use of the Website.
BSP reserves the right to modify or complete the Charter and to update it at any time with prior written information to the Users.
This Privacy Charter is valid for all pages hosted on the Website and for registrations of this Website. It does not apply to pages hosted by third parties to which BSP may refer and whose privacy policies may differ. BSP cannot therefore be held responsible for any data processing on these third-party websites.
2. Data controller
The use of the Website, in particular of some of its functionalities (Member area, “shop”) requires the communication of personal data, such as surname, first name, postal address, e-mail address, etc.
The data controller of this data is the the non-profit making organization Belgian Society of Psychanalysis (hereinafter, “BSP”), having registered office at 49 Rue Emile Claus in 1050 Brussels (Belgium), registered with the Crossroad Bank for Enterprises under number 0410.540.820. Any questions or requests regarding the processing of this data may be addressed to the following address: firstname.lastname@example.org
BSP undertakes to use its best efforts to ensure the security and protection of the confidentiality of the User’s personal data, in particular to prevent it from being distorted, damaged or communicated to unauthorized third parties. BSP undertakes to enforce the strictest confidentiality and security in the processes of processing, storing and safeguarding of the User’s personal data by any technical provider acting as a subcontractor, in accordance with the rules of art and in strict compliance with the applicable legislation, including by having recourse to certified/guaranteed suppliers in accordance with the General Data Protection Regulation (“GDPR”).
Subject to these reservations and for the remainder, BSP is in no way responsible for data hosted by third-party companies or solutions that may be used, which remain subject to their respective general conditions and privacy policies.
3. Collected information
3.1. Data that are transmitted to BSP by the active intervention of the User
In particular, by completing the forms provided for this purpose when registering as a User or once registered, the User allows BSP to register and store the following information for the purposes mentioned in point 4:
- identification data such as user name, first and last name, email address and physical contact details (address and telephone number);
certain data are reserved for BSP members (administrative contact details, member status, etc.), the member having the choice of whether or not to display this information publicly on the Website;
- invoicing information (and delivery details if different);
- communications transmitted through the Website and communications addressed to BSP;
- additional information requested by BSP to the User for identification purposes, or if BSP suspects the User to violate any provision of this Charter;
- any other information voluntarily transmitted to BSP by the User for a specific purpose.
3.2. Data that are automatically transmitted to BSP when consulting the Website
In order to facilitate navigation on the Website as well as to optimize technical management, the Website may use “cookies”. A “cookie” is a small file containing information saved by a Website on the computer.
This “cookie” can be retrieved during a subsequent visit to the same application or Website. The “cookie” cannot be read by another Website than the one that created it. The Website uses “cookies” for the purposes of proper administration of the Website, in particular to record the User’s browsing preferences, or to obtain information relating to the consulted web pages and dates and times of consultation.
Most “cookies” only function during a session or visit. It is also possible for the User to configure his browser in order to inform him whenever creating a “cookie” or to prevent their registration, individually or not. Disabling cookies may however prevent access to certain parts of the Website or can make access more difficult.
Subject to the prior consent of the User, the Website may also allow the use of third-party cookies, such as those described below.
3.2.2. The information recorded on the consulted servers
When the User accesses the Website, the consulted servers automatically record certain data that are not made publicly visible on the Website, 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 traffic data, location data or other data relating to the communication, the pages viewed, the type of browser used, the platform and/or the operating system used, the search engine as well as the keywords used to find the Website, …
However, no personal data identifying the User is collected through these records. This information is only stored internally and for statistical purposes and to improve the Site.
As part of its “shop” functionality, the Website uses e-shop “cookies” (“WooCommerce”) that contain information about the User’s shopping cart as part of their purchases on the Website. This information is only available in the Website’s internal database and no personal data is stored in these cookies.
The Website also uses third-party technology from “Google Analytics” that analyses the activity of the Website. For these purposes, Google collects information related to web traffic and the number of visitors. This tool allows BSP to measure the performances of the Website in terms of navigation and to consolidate the activity reports and other services.
4. Purposes of the processing
4.1. General purposes
Without prejudice to what has been specified in point 3.2. regarding the automatically transmitted data, the Website collects, stores and uses the personal data of its Users for the following purposes:
- to establish, carry out and manage the contractual relationship with the User, in particular within the framework of the “area” reserved for the member and the “shop” functionality of the Website;
- to allow the User to receive emails concerning the organisation of the execution of the service, in particular in the context of various information mailings (“BSP”, “RBP”, …);
- to facilitate the availability and use of the Website and to inform them of changes to the Website and its functionalities;
- to respond to requests for information from Users and to contact them in the course of operating the Website;
- to analyze, adapt and improve the Website, services, content or advertisements of BSP;
- for any other purpose for which the User has given its express prior consent.
4.2. Communication to third parties
The personal data, within the limits of the provisions of this article, are not intended to be communicated to third parties other than:
- Third party tools that BSP expressly uses with the prior express acceptance of the User;
- Persons whose intervention is necessary for the proper performance of the contract or to achieve one of the purposes mentioned in this Charter;
- The competent public authorities in the event of a legal obligation where required by law.
4.3. Transfer to a non-European Union country
BSP does not transfer data to a country that is not a member of the European Union unless that country ensures an adequate level of protection within the meaning of legislation on privacy protection, or within the limits of this legislation, for instance by ensuring the protection of data through appropriate contractual provisions.
4.4. Direct marketing
BSP considers personal data to be confidential information and will not disclose it to third parties under conditions other than those specified in this Charter or under the conditions required by law. This data will not be used for direct marketing purposes for products or services other than those to which the User has already subscribed, unless the User has given his explicit prior consent by ticking the boxes provided for this purpose (“opt-in“).
When the User has given his consent for the use of this information for direct marketing purposes, he retains the right to object at any time, upon request and free of charge, to such use. To do so, the User simply sends his request to the following email address: email@example.com.
In order to guarantee optimal and maximum security, BSP uses secure services that meet high security standards, in particular by using the “HTTPS” and “SSL” protocols. All User accounts are protected by encryption, as a security system used for internal and external connections, so that data cannot be sent or received as readable text.
In particular, BSP has implemented security policies in order for the servers hosting the processed personal data to prevent, to the possible extent:
- unauthorized access or modifications of this data;
- the improper use or disclosure of this data;
- the unlawful destruction or accidental loss of this data.
Any person from BSP or others having access to this data is subject to a strict confidentiality obligation towards it. However, BSP cannot be held liable in any way for any misuse of this data by a third party despite the adopted security measures.
Offences against the confidentiality, integrity and availability of computer systems and data stored, processed or transmitted by such systems, or the attempt to commit any of these offences, shall be punishable by law.
6. Storage period
BSP will normally store the personal data of its Users for the duration necessary for registration as a User and for the duration of registration, to the extent strictly necessary for the use of the Website. BSP may also continue to hold personal data concerning the unsubscribed User, including any correspondence or request for assistance addressed to BSP, in order to respond to any questions or complaints addressed to it after unsubscription, and to comply with all applicable laws.
7. Rights of the data subject
By respecting the principle of transparency and general information, BSP undertakes that no data will be collected without the User’s knowledge.
The User may at any time have access to his personal data and rectify it on the Website by using his user name and password, as well as he may request a copy in a clear and readable format as part of his right to portability of his data.
The User may request, free of charge, that all his personal data, with the exception of those that BSP would be legally required to keep, be corrected and, if necessary, request the deletion from BSP’s database by sending a written request, accompanied by a copy of his identity card or passport, at the following email address: firstname.lastname@example.org (or at the address of BSP – Rue Emile Claus 49, 1050 Brussels). BSP will then take the necessary steps to satisfy this request as soon as possible.
For more information on this Charter and to know the content of the personal data stored, any person can contact BSP via the following email address: email@example.com.
8. Note concerning minors
Persons under 18 years of age and persons not having full legal capacity are not authorized to use the Website and may not communicate their personal data to BSP, which disclaims any liability in this regard.