Effective since: 13 September 2022

Last update: 13 September 2022

1. Who is responsible for processing your personal data?

1.1.      The Association of Communication Companies ASBL/VZW (hereinafter “ACC”, “us” or “we”) respects the privacy and personal data protection of the visitors (hereinafter the “Visitor(s)”) of its website www.commtozero.be (hereinafter the “Website”).

1.2.      ACC processes the personal data of the Visitors in accordance with the applicable data protection legislations 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 since 25 May 2018 and the Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data (hereinafter the “Data Protection Legislation“).

1.3.      ACC is the Data Controller in the sense of Data Protection Legislation processing the personal data of the Visitors:

The Association of Communication Companies ASBL/VZW (hereinafter “ACC”)

Minervastraat 4

1930 Zaventem

Belgium

+32 2 761 19 99

VAT BE0451546876

1.4.      Access to the Website implies the Visitor’s complete and unreserved understanding of the present Privacy Policy (hereinafter the “Privacy Policy”) as well as Terms of Use of the Website (hereinafter the “Terms of Use”) and the Cookies Policy of the Website (hereinafter the “Cookies Policy”).

1.5.      The Visitor acknowledges having read the information covered by the Privacy Policy and understands that ACC will process, in accordance with the Data Protection Legislation and the Privacy Policy, his/her personal data for the purposes determined hereafter.

1.6.      The Policy is not valid for the pages hosted by third parties to which ACC may refer to and whose privacy policies may differ. ACC can consequently not be held responsible for any data processed by and on these websites. ACC invites the Visitor to consult the respective privacy policies of such third parties.

2. What types of personal data do we process?

ACC will collect the following types of personal data for the reasons defined in the following point:

• Your identification data (i.e., name, surname, e-mail address, address);
• Your internet domain;
• Your IP address;
• The date and time of your access to the Website;
• The pages of the Websites browsed;
• The type of browser, platform, operating system you are using;
• The search engine and the keywords used to find the Website;
• Your browsing preferences.

3. Why do we process your personal data?

We collect your personal data mainly to provide you access to the Website, to improve the Website and more generally, to communicate with you when necessary.

4. How do we collect your personal data?

4.1.      Most of your personal data is collected by us through your active intervention. Other data, such as the date and time of your access to the Website, the pages you have browsed, or your location data, are collected automatically through servers consulted and Cookies placed on the Website.

4.2.      For more information on what a Cookie is, how it is used and the exact data it collects, please consult our Cookies Policy.

5. How do protect your personal data?

ACC makes it a priority to ensure the protection of the Visitors’ personal data. We maintain a strict data protection commitmentand take all appropriate measures to ensure that our servers prevent, to the extent possible, any unauthorized leak, destruction, loss, disclosure, use, access or modification of your data.

6. How long do we store your personal data?

6.1.      We keep your personal data only for the time strictly necessary to accomplish the objectives pursued. Once this goal is achieved, we either delete or anonymize them.

6.2.      ACC may additionally keep your personal data, including correspondence or request for assistance sent to ACC to ensure it can answer to all questions or complaints sent to ACC, and/or in order to comply with all applicable laws or as part of other legal requirements ACC is subject to.

7. Who has access to your personal data, and with whom do we share them?

7.1.      ACC treats personal data as confidential information. We will not communicate your personal data to third parties under any condition other than those specified in the present Privacy Policy, such as to achieve the objectives set out and defined in the Privacy Policy, or under the conditions in which the law requires ACC to do so.

7.2.      ACC may communicate your personal information to third parties to the extent that such information is strictly necessary for the performance of a contract with you, or if you have consented to it or if it serves ACC’s llegitimate interest provided these are not overridden by your interests and fundamental rights.

7.3.      The communication of your personal data to the aforementioned persons shall, in all circumstances, be limited to what is strictly necessary or required by the applicable regulations, and subject to strict contractual obligations.

8. What are your rights and how can you exercise them?

8.1.      In accordance with the Data Protection Legislation, the Visitor has the following rights:

• Right of access: Visitors may, at all times, have access to the data that ACC has on him/her or check if he/she is included in the database of ACC. ACC asks the Visitor to make this request by mail in order to be able to identify him/her with certainty (Please provide ACC your first name, surname, complete address and a valid proof of your identity);
• Right to rectification: we take all reasonable steps to ensure that the personal data we keep is up to date. If personal data is inaccurate or incomplete, Visitors also have the right to ask us to correct it.
• Right of objection: the Visitor may, at all times, object to the use of his/her data by ACC and by its active partners by sending his/her request to ACC.
• Right of erasure: the Visitor may, where appropriate, request the deletion of his/her personal data, except those that ACCmust keep on record (legal obligation, fundamental right/freedom of speech, etc).
• Right of limitation of processing: the Visitor may, in particular, obtain a limitation of processing when he/she has objected to the processing, when he/she disputes the accuracy of the personal data, or when he/she considers that the processing is illegal.
• Right of personal data portability: The Visitor has the right to receive the personal data that he/she has communicated to ACC and may also ask to send this personal data to another data controller.

8.2.      The Visitor may also at all times, request access to his/her personal data, verify them, transfer them, and, in some cases, as aforementioned, limit their processing and rectify them, by writing to ACC accompanied by a valid proof of identity to the following email address: info@commtozero.be  

8.3.      ACC will take all necessary measures to satisfy such a request as soon as possible and in any case within one month of receipt of the request. If necessary, this period can be extended by up to two months, given the complexity and the number of requests.

8.4.      In addition, the Visitor also has the right to lodge a complaint with the Belgian Data Protection Authority:

Autorité de protection des données / Gegevensbschermingsautoriteit

35 Rue de la Presse

1000, Bruxelles

contact@apd-gpa.be

9. Do we transfer your personal data outside the EU?

ACC only transfers personal data to a non-EU country provided that country offers an adequate level of protection within the meaning of the Data Protection Legislation or within the limits permitted by it, for example by ensuring the protection of data by appropriate standard contractual clauses.

10. Do we process personal data about minors?

10.1.    Our website are not targeted to children under the age of 13.

10.2.    If you learn that your minor child has provided us with their personal data without your consent, contact us at the following address: info@commtozero.be  

11. Updates and language versions

11.1.    By informing Visitors through the Website or emails, ACC may modify and adapt the Privacy Policy, in particular to comply with any new legislation and/or regulations applicable (such as the General Data Protection Regulation applicable since25 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 topic.

11.2.    In case of any differences between the available language versions of the present Privacy Policy, the English version must prevail.

12. Validity of the Privacy Policy’s provisions

12.1.    If ACC does not use/invoke one of the provisions of the present Privacy Policy for a period of time, this cannot be interpreted in any way as a waiver to enforce such rights on a later stage.

12.2.    The nullity, interpretation and/or execution of some of the provisions implies by no means the invalidity of all provisions. The provision that is wholly or partially invalid, void or unenforceable is to be considered as unwritten. ACC undertakes to replace this provision by another who, as far as possible, pursues the same goal.

13. Applicable law and competent court

13.1.    The validity, interpretation and/or execution of the Privacy Policy are only subject to Belgian law, to the maximum extent permitted by the prevailing rules of private international law.

13.2.    In the event of a dispute concerning the validity, interpretation or implementation of the present Privacy Policy, the courts of the judicial district of Brussels are exclusively competent.

13.3.    Before launching legal proceedings, the Visitor and ACC will aim to resolve the dispute amicably. That is why they will first contact each other’s, and if appropriate and necessary, reach out for mediation, arbitration or any other alternative dispute resolution method.