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Item ref.: 2021-000419

General
1. When using the https://www.onmavole.be website or the ONMAVOLE app (hereinafter referred to as the "online services"), Mr Michael BENEUX, with registered office at Boulevard Emile DELAVELEYE 183 in 4020 LUIK, registered with the KBO/CBE under number 0700.753.239 (hereinafter referred to as "ONMAVOLE.BE"), collects and processes the user's personal data (hereinafter referred to as "the user").
  
  ONMAVOLE.BE processes personal data in application of, and in accordance with, Regulation (EC) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter referred to as the General Data Protection Regulation or GDPR) and the Act of 30 July 2018 on the protection of individuals with regard to the processing of personal data.
  
  By personal data, this privacy policy means any information relating to a natural person who is identified or identifiable; an "identifiable person" means any natural person who can be identified, directly or indirectly, in particular by reference to an identification code, localisation data, an online identification or one or more specific elements linked to their physical, economic, cultural or social identity.
  
  By using the online services, the user acknowledges that he has read this privacy policy and accepts it unreservedly.
2. The person responsible within ONMAVOLE for the processing of personal data is Mr Michael BENEUX.
  
  He can be contacted:
  - From Monday until Friday, from 09 until 17 hours
  - Phone : +32(0)497159767
  - E-mail : info@onmavole.be
3. Here you find a form that you can use for all your questions regarding privacy.
Processing of personal data of the user
1. The purpose of this privacy policy, in accordance with the GDPR, is to have a better understanding of:
  - the processing of personal data necessary for the execution of the contractual relationship between ONMAVOLE.BE and the user, as explained in Article 3 of the privacy policy;
  - the processing of personal data based on the legitimate interest of ONMAVOLE.BE (described in more detail in Article 4 of the privacy policy);
  - the processing of personal data for which the prior, free and explicit consent of the user is required, in accordance with the objectives set out in Article 5.
  The user guarantees that the data and information submitted to ONMAVOLE.BE are correct and up-to-date.
2. ONMAVOLE.BE handles personal data in a manner that is permitted, trustful and transparent with regard to the user concerned. Personal data are collected for specific, explicit and legitimate purposes and are under no circumstances further processed in a way incompatible with these purposes.
  
  ONMAVOLE.BE processes personal data that are appropriate, relevant and limited to what is necessary to achieve the purposes for which they are processed.
  
  ONMAVOLE.BE undertakes to ensure that the data processed are accurate and updated if necessary. All reasonable measures will be taken to ensure that personal data which are inaccurate in relation to the purposes for which they are processed are deleted or rectified without delay.
Processing for the execution of the contractual relations between ONMAVOLE.BE and the user
1. ONMAVOLE.BE processes personal data in accordance with the legitimate purposes described above. This processing of personal data by ONMAVOLE.BE does not require the consent of the user in accordance with Articles 6.1.f) and 10 of the General Data Protection Regulation.
2. The personal data processed are:
  - data required for registering for the online services and creating an account, such as surname, first name, date of birth, language, postal address, password, e-mail address and contact details of the user in accordance with the provisions of Article 1.1;
  - documents, photographs, e-mails, correspondence, etc. submitted by the user to ONMAVOLE.BE within the framework of the execution of the contract concluded between ONMAVOLE.BE and the user in application of the general terms and conditions.
  - Information that may be exchanged between ONMAVOLE.BE and the user by electronic means or within the framework of a purchase via the online services;
  - the user's bank details relating to financial transactions carried out via the online services;
  - information relating to access to the online services and navigation on the website.
3. Processing includes the collection, registration, storage, consultation, organisation, use and compilation of personal data as described in Article 3.2.
4. ONMAVOLE.BE processes the personal data described in Article 3.2 with the following purposes:
  - the management of the registrations and accounts of the users;
  - the management of payments and invoices;
  - to determine the user's needs and to provide high-quality services for those needs for which the user makes use of ONMAVOLE.BE's services.
Les traitements fondés sur l’intérêt légitime d’ONMAVOLE.BE
1. ONMAVOLE.BE has a legitimate interest within the meaning of point 6 f) of the GDPR to process personal data of the user for the following purposes:
  - to inform the user of the services proposed by ONMAVOLE.BE;
  - publicity and marketing, including the sending of printed or electronic newsletters from ONMAVOLE.BE or its partners;
  - carrying out statistical, satisfaction and market research;
  - Invitation to events organised or sponsored by ONMAVOLE.BE (seminars, cocktails, cultural events, etc.).
  These data are automatically stored in the register described in Article 6.1.
2. The personal data processed are:
  - the user's surname and first name, e-mail address or postal address;
  - the customer's opinion of the services provided.
3. The processing includes the consultation, organisation, use and collection of personal data as described in Article 4.2.
4. Processing serves ONMAVOLE.BE’s following legitimate interest:
  - promoting the services offered by ONMAVOLE.BE to users;
  - establishing the degree of satisfaction of the users with a view to improving the services provided.
  ONMAVOLE.BE also automatically processes the following personal data:
  - When navigating on the ONMAVOLE.BE website from the FACEBOOK page, this page keeps certain personal data of the FACEBOOK account of the user concerned (in particular, first name, surname, photo, e-mail address and number of friends on Facebook). This is done in accordance with FACEBOOK's general terms and conditions of use;
  - When the user responds using the functionalities offered on the social networks, such as the "like" function of FACEBOOK;
  - When the user visits the website, ONMAVOLE.BE collects certain "visitor information". These are personal data, such as the IP address, connection data, the type and version of the internet navigator used, the type and version of the navigator plugins, the usage system and the usage platform, data relating to the navigation route on the internet, in particular the access to different URL pages of the site, the content the user visits or consults, the keywords used, the download errors, the duration of a visit to certain pages, the advertising ID of the device used to access the website, the interaction with the website. As one of the technologies used to collect this information, ONMAVOLE.BE uses cookies as further explained in Article 7.
  - Personal data are also collected for statistical purposes relating to the use of online services (number of visits, registrations, instructions, etc.).
Processing of personal data requiring the user's consent
1. By using the online services, i.e. by visiting the website onmavole.be or by downloading and using the app, the user expresses his voluntary, specific, clear and unambiguous wish to grant ONMAVOLE.BE explicit permission for the processing of personal data as referred to in Articles 3 and 4 of the privacy policy, for the purposes specified therein and in accordance with the GDPR and the Act of 30 July 2018 on the protection of individuals with regard to the processing of personal data, as well as within the restrictions laid down in this privacy policy.
  
  The user has the right to revoke his consent at any time and must contact the person responsible referred to in Article 1.2 for this purpose.
2. If ONMAVOLE.BE wishes to use the user's personal data for purposes other than those described in Articles 3 and 4 of this privacy policy, ONMAVOLE.BE must ensure that the voluntary, specific, clear and unambiguous consent of the user to process the personal data in accordance with the GDPR has been granted.
Obligation to keep a register
1. As data controller, ONMAVOLE.BE is obliged to keep a register of processing activities. That register must at all times be managed under the responsibility of ONMAVOLE.BE.
2. This register contains the following information :
  - a description of the purposes of the data processing;
  - a description of the categories of persons concerned and of the categories of personal data;
  - the categories of addressees to whom the personal data have been or will be disclosed, including addressees in third countries or international organisations;
  - the time limits laid down for the deletion of the various categories of data;
  - a general description of the technical security measures;
  - a register of any incidents.
Retention of data and duration of data retention
1. ONMAVOLE.BE stores the user's personal data in a form that, if appropriate and secure means are used, allows the identification of the user.
2. The user's personal data will be kept for a period of time that does not exceed the time required for the purposes for which they are kept. Specifically, the personal data will be kept at ONMAVOLE.BE for up to two (2) years after the last processing carried out by the user. Unless otherwise requested by the user, the data will then be deleted from ONMAVOLE.BE's files.
Informations, Droit d’accès, de rectification et d’opposition
1. When personal data relating to the user are collected, ONMAVOLE.BE shall make available the following information at the time of collection:
  - the identity and coordinates of the person responsible for data processing
  - the coordinates of the data-processing supervisor;
  - the purposes of the processing activities for which the personal data are intended and the legal basis for the processing;
  - the addressees or categories of addressees of the personal data where applicable.
2. The user may at all times request all the information referred to in Article 8.1, subject to use of the modalities as mentioned in Article 1.2.; ONMAVOLE.BE shall comply with this request for information within one month, barring special circumstances.
3. The user whose data have been collected may at any time ask ONMAVOLE.BE for access to the information that concerns him and that ONMAVOLE.BE keeps. He may request that information be updated or rectified that is inaccurate or incomplete or he may request that personal data be deleted within the shortest possible period of time. If possible, ONMAVOLE.BE shall inform the user concerned of these rights.
4. The user has the right to receive a copy of the personal data processed. ONMAVOLE.BE may request a reasonable payment for administrative costs for each additional copy requested.
5. The user can obtain a limitation of the processing of personal data when:
  - the data are incorrect;
  - the processing is unlawful;
  - ONMAVOLE.BE no longer requires the data to be processed.
6. The user may object to the processing of data concerning him or to any automated processing of his data, such as profiling, by submitting justifying reasons, provided that this does not make it impossible, or more difficult, for ONMAVOLE.BE to fulfil its obligations or goes against its legitimate interests.
7. The user may always oppose the processing of his personal data for marketing purposes by ONMAVOLE.BE, now or in the future.
8. The user has the right to receive the personal data made available to ONMAVOLE.BE in a structured format. This format must be current and readable by a computer. The user is also entitled to transfer these data to another data controller, without ONMAVOLE.BE being able to object to this.
9. The user may make use of the rights provided for in Articles 8.1 to 8.8 and shall contact ONMAVOLE.BE for this purpose using the coordinates mentioned in Article 1.2.
Responsibility of ONMAVOLE.BE - Subcontractor
1. ONMAVOLE.BE warrants that the processing of the user's personal data is authorised and appropriate and complies with the requirements of the GDPR and applicable Belgian law.
2. ONMAVOLE.BE has taken all appropriate technical and organisational measures to ensure that the processing of personal data complies with the GDPR. These measures include, in particular, the pseudonymisation and restriction of data. Consequently, only the data required to achieve the objectives of ONMAVOLE.BE will be processed.
3. Where data processing is carried out by a subcontractor, ONMAVOLE.BE shall ensure that the subcontractor provides sufficient guarantees for the implementation of appropriate technical and organisational measures to ensure that the processing is carried out in accordance with the requirements of the GDPR and that it is able to guarantee the protection of the user concerned. Processing carried out by a subcontractor meets the requirements set out in Article 28 of the GDPR.
Security and confidentiality
1. ONMAVOLE.BE uses all reasonable means to guarantee the confidentiality and security of the personal data processed. The data will be processed in such a way as to guarantee the security of the personal data, including protection against unauthorised or prohibited processing, loss, erasure or accidental damage. This is done by means of appropriate technical or organisational measures.
2. Where appropriate, ONMAVOLE.BE, with the assistance of the Data Protection Supervisor, shall carry out an impact assessment where the processing may give rise to an increased risk for the user.
  
  The data shall not be transferred to third parties that are not partners of ONMAVOLE.BE, except if:
  - that were to prove necessary for the provision of the online services by ONMAVOLE.BE;
  - when such a transfer of data is required by law, a legal or administrative authority.
3. ONMAVOLE.BE undertakes to notify the data protection authority of the incident as soon as possible in the event of a security problem affecting the security of the data processed, but no later than 72 hours if required by the GDPR. If necessary, ONMAVOLE.BE will also inform the relevant user.
  
  The user is informed and agrees that the personal data collected will be passed on to ONMAVOLE.BE's partners and suppliers, in particular if the user chooses to use the services of such partners via the online services.
  
  A partner is not considered as a subcontractor within the meaning of the GDPR. ONMAVOLE.BE declines all responsibility for the processing of user's personal data by a partner that provides its own services in its own name and for its own account.
4. Finally, the user declares that he is aware of, and agrees to, the occasional processing of certain data by third parties within the framework of technical services necessary to ensure the operation and updating of ONMAVOLE.BE's online services or other support functions, networks or information tools.

Navigation information and use of cookies

ONMAVOLE.BE may collect and retain certain "visitor information" relating to users of the online services. This information includes, for example, the name of the domain and the address of the host computer from which the users access the Internet, the Internet Protocol (IP) address of the computer used, the date and time of the visit and the URL from which the visitors accessed the online services.

This navigational information is not linked to any data that may render visitors identifiable and is deleted after a certain period of time.

The navigation information is collected via the following cookies :

Cookie name	Expiration	Description	Type
on_ma_vole_session	1 hour	Permits access to the site to the internet user.	Technical cookie
omv_popup_main_consent	365 days	Prevents inappropriate opening of main welcoming pop up frame.	Technical cookie
laravel_cookie_consent	365 days	Prevents inappropriate opening of cookies acceptance banner.	Technical cookie
XSRF-TOKEN	1 hour	Secures the submission of forms on the site.	Technical cookie
_ga	2 years	For site visit statistics.	Visit cookie
_ga_[xxx…x]	2 years	For site visit statistics.	Visit cookie
remember_web_[xxx…x]	5 years	If he chooses the option « Remember me », the internet user will automatically be connected to te site when visiting it using the same web navigator.	Optional cookie

Cookies are text files that an internet server places on the hard disk of computers. ONMAVOLE.BE only uses such information for statistical purposes, to analyse and measure visits to its website and to present certain functions to users.

Navigation data, as described in this chapter, may be processed by third parties, for example by the US Company Google Inc. which uses the "Google Analytics" tool for this purpose.

The data processing supervisor (DPS)
1. ONMAVOLE.BE has appointed Monsieur Michael Beneux as data processing supervisor (hereinafter “DPS”).
2. The task of the DPS is to ensure that ONMAVOLE.BE processes personal data in accordance with all rules and guidelines.
3. The DPS can be contacted directly as follows:
  - From Monday until Friday from 09 until 17 o’clock
  - Phone : +32(0)497159767
  - E-mail : info@onmavole.be
Data Protection Authority

In accordance with Regulation (EC) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and with the Act of 30 July 2018 on the protection of individuals with regard to the processing of personal data.
- Address : Drukpersstraat 35, 1000 Brussels
- Phone : +32 (0)2 274 48 00
- Fax : +32 (0)2 274 48 35
- Email : contact@apd-gba.be