Private Policy
1. General Warning
1.1 Art Of Living (hereinafter "AOL") respects the privacy of its Users (Clients) and occupants (assignees) (hereinafter "Users").
1.2 AOL deals with the personal data transmitted to it in accordance with the legislation in force, and in particular the law of 8 December 1992 on the protection of privacy and its executive decrees.
1.3 Access to the www.artofliving.be (hereinafter the « Website ») implies full and unconditional acceptance by the Users of this Privacy Policy (hereinafter the « Scheme »), as well as its Terms of Use (hereinafter the « Terms »).
1.4 The Users acknowledge having read the information below and authorizes AOL to deal, in accordance with what is specified below, with the personal data they communicate through computerized and paper-based data processing systems and on/to the Website within the framework of the services proposed by AOL (hereinafter the "Services").
1.5 By providing information to Users, AOL may be required to amend and adapt the Scheme, in order to comply with any new applicable legislation and / or regulations (such as the adoption of the new European regulation in dealing with the personal data - Regulation 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 - of 14 April 2016, and applicable as from 25 May 2018), the recommendations of the Belgian Privacy Commission, the guidelines, recommendations and good practice of the European Data Protection Committee and the decisions of courts and tribunals in this field.
1.6 The Scheme is valid for all the hosted pages on the Website and for the savings of this Website as well as on computerized and paper-based data processing systems. It is not valid for the hosted pages by third parties that AOL may redirect to and where their privacy policies may differ. AOL cannot be held responsible for any data processed on these Websites or by them.
2. Responsible for processing
2.1 Access to the Website shall in principle be possible without having to provide personal data, such as, for example, surname, first name, postal address, e-mail address, etc.
2.2 However, as part of the Service, the Users may be required to transmit certain personal data. In such case, the person in charge of processing these data is:
Art Of Living S.A.
Chaussée de Louvain, 431 H / 1380 Lasne / Belgium
VAT 0444.020.072
2.3 Any question or request concerning the processing of these data may be addressed to the following address: artofliving@artofliving.be
3. COLLECTED INFORMATION
3.1. DATA TRANSMITTED TO AOL BY ACTIVE INTERVENTION OF USERS
By browsing the Website, filling out contact details forms, exchanging computerized and paper-based data processing systems linked to AOL, the Users allow AOL to register and maintain, for the purposes mentioned in point 4, the following information's:
- identification data's such as surname and first name, gender, e-mail address, date of birth, preferences and contact information's (landline telephone, mobile phone)
- the banking information required by the Service, such as bank account numbers, IBAN and BIC / SWIFT
- billing information
- communications between Users and AOL
- the additional information requested by AOL from the Users in order to identify or prevent him/her from breaching any of the provisions of the Scheme
- any other information voluntarily transmitted to AOL by the Users for a determined purpose in the Scheme, in the Terms, on/to the Website or on any other communication tool used by AOL
3.2. DATA AUTOMATICALLY TRANSMITTED TO AOL WHEN CONSULTING THE WEBSITE AND EXCHANGING COMPUTERIZED AND PAPER-BASED DATA PROCESSING SYSTEMS.
3.2.1. « COOKIES»
In order to facilitate browsing the Website and optimize technical management, the Website may use "cookies".
A "cookie" is a small file containing information saved by a website on the computer or an application on the user's smartphone. 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 good administration of the Website, in particular to save the User's browsing preferences, or to obtain information on the visited pages and the dates and times of visit.
Most "cookies" only work for a session or a single visit. It is also possible for the User to set up his browser to be informed during each creation of "cookie" or to prevent their saving, individually or not. However, disabling cookies may prevent access to certain parts of the Website or making access more difficult.
Subject to the prior consent of the User, the Website may also allow the use of third-party cookies, including the following:
Facebook, LinkedIn, Twitter, Google +
AOL may use on its Website the social modules of social network providers Facebook, LinkedIn, Twitter and Google +. These social modules establish a direct connection to the server of the social network via the User's browser. The social network provider on which the User has clicked receives information that the User has visited the Website. If the User is registered and identified on the relevant social network, the provider can correlate the profile of the User with the visited Website. The network provider can then establish future interactions. If the User is not registered with the social network, the provider can save the IP address of the User. In order to avoid transferring these data to the social network provider, the User must not click on the button corresponding to the social network.
Google analytics
The Website might also use Google analytics. This service, offered by Google, analyzes the activity of the Website. For these purposes, Google collects information related to web traffic and the number of visitors. This tool would allow AOL to measure the performance of the Website in terms of browsing and to consolidate activity reports and other services.
3.2.2. REGISTERED INFORMATION ON VISITED SERVERS
When the Users access the Website, the visited servers automatically save certain data's, such as the type of domain with which the Users connect to the Internet, the IP address assigned to the Users (when logged in), the date and time of access to the Website and other traffic data's, location data's or other communication data's, viewed pages, type of browser used, platform and / or system, the search engine as well as the keywords used to retrieve the Website, etc.
On the other hand, when the Users exchange electronic data's, the dedicated external server ** automatically save certain data's, such as the type of domain with which the Users connect to the Internet, the IP address assigned to the Users (when logged in), the date and time of exchange and other traffic data's, location data's or other communication data's.
However, no personal data's identifying the Users is collected through these savings. This information is kept for statistical and improvement purposes only.
** External server:
1 Local network is fully segregated from the Internet and protected by a Cyberoam NG firewall.
No incoming connections are allowed in any form (no PAT, VPN, …) and outgoing connections are filtered.
2 Local data is stored on QNAP NAS with RAID1 and AES-256 data encryption.
3 The NAS is installed in an air-conditioned IT room with badge ID access control.
4 Local data is saved to MS Azure with in data in transit and at rest AES-256 encryption.
5 AOL is presently working within the 95/46/EC directive framework and is in the process of achieving GDPR compliance.
4. Purposes of Processing
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4.1. GENERAL PURPOSES
Without prejudice to what has been specified under point 3.2. concerning the automatically transmitted data's, the Website and the computerized and paper-based data processing systems collect, save and process the personal data's of its Users in particular for the following purposes:
-to make a reservation of a Property on a Temporary or Permanent basis
-to register the occupant for utilities connections
-to register occupant for a tenant's liability cover and any other insurance covers requested by the occupant
-to register the occupant at a Bank Branch (opening a Bank account, establishing a bank Guarantee)
-to forward the post-mail while the occupant has left his property in Belgium
-to register occupant (and Family) at Town Hall, social security, (Mutuelle)
-to establish, carry out and conduct the contractual relationship with the Users
-to facilitate the provision and use of the Website and improve the Services offered by AOL as well as the experience of the Users
-to respond to requests for information
-to inform them about the evolutions of the Website and its functionalities
-for any other purpose for which the User has expressly consented.
4.2. COMMUNICATION TO THIRD PARTIES
AOL considers personal data's as confidential information's. It shall not communicate them to third parties under conditions other than those specified in the Scheme or under the conditions in which it is required by law, including the competent authorities who request it.
Are considered as partners of AOL, Bank institutions, Insurance Brokers, Town Hall administrations and any other Public authorities, Real Estates and Landlords, Utilities providers (for water, gas, electricity, fuel, TV, Internet, Telephone) (hereinafter the "Partners"). In this context, AOL may communicate to its Partners, the personal information of its Users, for the purpose of accomplishing the purposes defined in paragraph 4.1.
AOL may transmit to third parties the personal information's of its Users insofar as this information is necessary for the execution of a contract with its Users. In such a case, such third parties shall not communicate this information to other third parties, except in one of the following two situations:
(i) disclosure by these third parties of such information to their suppliers or subcontractors to the extent necessary for the performance of the contract
(ii) where such third parties are obliged by the regulations in force to disclose certain information or documents to the competent authorities regarding the anti-money-laundering, as well as to any competent public authority in general.
The disclosure of such information to the aforementioned persons shall in all circumstances be limited to what is strictly necessary or required by the applicable regulations.
In order to discover new products/packages to its users that maybe of interest to them, AOL may also disclose the personal information of its Users to third parties, insofar as the Users have explicitly consented to it.
4.3. TRANSFER TO A COUNTRY NOT A MEMBER OF THE EUROPEAN ECONOMIC AREA
AOL does not transfer data's to a country which is not a member of the European Economic Area unless it provides an adequate level of protection within the meaning of the law of 8 December 1992 on the protection of privacy, or within the limits permitted by the same law, for example by ensuring the protection of data's by appropriate contractual provisions.
4.4. DIRECT MARKETING
Personal data's will not be used for direct marketing purposes.
5. Security (see also 3.2.2)
5.1 AOL has taken the adequate measures to ensure that the servers hosting the processed personal data prevent, to the extent possible:
-the processing, access or unauthorized modification of these data's
-the inadequate use or disclosure of such data's
-the unlawful destruction or accidental loss of such data's
5.2 In this respect, AOL employees and consultants who have access to these data's are subject to a strict confidentiality obligation. AOL cannot, however, be held liable for any misappropriation of these data's by a third party in spite of the adopted security measures.
5.3 The Users undertake not to commit any acts which may be contrary to the present Scheme, the Terms or, generally, the law. Offenses against the confidentiality, integrity and availability of computer systems and saved data's, processed or transmitted by such systems, or the attempt to commit any of these offenses are punishable by three months to five years' imprisonment and by a fine of twenty-six euros to two hundred thousand euros or by one of these penalties only.
6. Conservation period
AOL will normally keep the personal data's of its Users for the necessary duration for the accomplishment of the pursued purposes (see point 4). AOL may also continue to maintain personal data's concerning the Users, including any correspondence or request for assistance addressed to AOL, in order to be able to answer any questions or complaints that may be addressed to it, and in order to comply with all applicable laws.
7. Rights of the concerned person
7.1The Users may at any time request access, rectification or, if necessary, deletion to/ from his/her personal data's, with the exception of those which AOL would have a legal obligation to keep, by sending a written request accompanied by a copy of his identity card or passport to the data's controller:
-at the following postal address:
Art Of Living S.A. / Legal Department Chaussée de Louvain, 431 H / 1380 Lasne - Belgium
or
- to the following E-mail address:
7.2 AOL will then take the necessary measures to satisfy this request in the best delays.
8. Note concerning minors
Persons under the age of 18 and persons who do not have full legal capacity are not allowed to communicate their personal data's to AOL.
9. Applicable law and competent jurisdiction
9.1 The Scheme shall be governed by the Belgian law to the fullest extent permitted by the applicable rules of private international law.
9.2 In the event of a dispute concerning the validity, application, interpretation or enforcement of the Scheme, the courts of the judicial district of Brussels (Belgium) shall have exclusive jurisdiction, to the fullest extent permitted by the rules of private international law.
9.3 Before undertaking any legal dispute resolution, the User undertakes to resolve the dispute by amicable means by contacting AOL directly, if necessary by mediation, before resorting to arbitration, litigation, or any other means of dispute resolution.