Effective since: 27/06/2018 v2

1. GENERAL PROVISION

1.1 VO EUROPE SA (hereinafter: “VO EUROPE”) respects the privacy of its users (hereinafter: the “Users”).

1.2 VO EUROPE processes personal data transmitted to it in accordance with applicable legislation, in particular Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, applicable from May 25, 2018 (hereinafter the “GDPR”).

1.3 Access to the website www.vo-europe.eu (hereinafter, the “Website”) implies the full and unconditional acceptance by the User of this Privacy Policy (hereinafter the “Privacy Policy”), as well as the general terms and conditions of use (hereinafter the “Terms of Use”) and the cookie policy (hereinafter the “Cookie Policy”).

1.4 The User acknowledges having read the information below and authorizes VO EUROPE to treat, in accordance with the provisions of the Privacy Policy, the personal data that he/she communicates on the Website as part of the services made available by VO EUROPE (hereinafter the “Services”).

1.5 The Privacy Policy is valid for all pages hosted on the Website and for the registrations of this Website, as well as all pages managed by VO EUROPE on social networks, which is jointly responsible with the social networks for the processing of personal data of the visitors to the page. This does not apply to pages hosted by third parties to which VO EUROPE may link and whose Privacy Policy may differ. VO EUROPE can therefore not be held responsible for data processed on these websites or by them.

2. RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

2.1 Access to the Website takes place without the need to provide personal data, such as name, surname, postal address, e-mail address, etc.

2.2 As part of the Services, the User may be required to transmit certain personal data. In this case, the person responsible for processing this data is:

VO EUROPE SA
140A, Rue de Stalle, 1180 Brussels
KBO no.: 0849.627.948.

2.3 Any question or request regarding the processing of this data can be addressed to the following address: privacy@vo-europe.eu.

3. PERSONAL DATA COLLECTED

3.1 By completing the contact form, the job form on the Website and using the Services, the User authorizes VO EUROPE to register and store this personal data, in particular for the purposes stated in point 4. It concerns the following personal data :

• identification data, such as first and last name, marital status, email address, date of birth and delivery address;
• the professional data, such as professional experience, diplomas, language skills, hobbies and other documents transferred by the User;
• the bank details required for the Service, such as bank account numbers, IBAN and BIC / SWIFT;
• billing information;
• communication between the user and VO EUROPE.

3.2 The User also authorizes VO EUROPE to process the following information:

• the information voluntarily provided by the User for a purpose specified in the Privacy Policy, the general conditions of sale (hereinafter the “Terms of Sale”), the Terms of Use, the Cookie Policy, on the Website or on any other means of communication used by VO EUROPE;
• receive your personal data from various sources (internet and events);
• the additional information requested by VO EUROPE from the User in order to identify him or prevent him from violating any of the provisions of the Privacy Policy.

3.3 To facilitate navigation on the Website and to optimize technical management, the Website may use “cookies”.

All information regarding “cookies” is contained in the VO EUROPE Cookie Policy.

3.4 When the User visits the Website, the servers consulted automatically record certain data, such as:

• the type of domain through which the User connects to the Internet;
• the IP address assigned to the User (if connected);
• the date and time of access to the Website and other traffic data;
• location data or other data related to the communication;
• the pages visited;
• the type of browser used;
• the platform and/or operating system used;
• the search engine and the keywords used to find the Website.

3.5 No nominative data identifying the user is collected through the cookies and servers that are consulted. This information is only kept for statistical purposes and to improve the Website.

3.6 We collect certain data through the intervention of other companies, mainly with regard to the following sources: Google, Facebook, LinkedIn, Exceleads, TBS Group ( lefac.com ).

4. PURPOSES OF PROCESSING

4.1 We process User data for various purposes. For each processing, only the data relevant to achieving the objective are processed. The processing includes any action (manual or automated) with regard to personal data. VO EUROPE collects, stores and uses the data of its Users in order to provide Services and mainly for the following purposes:

• entering into, performing and executing the contractual relationship with the User;
• to analyze, adapt and improve the content of the Website;
• to provide the Services;
• to allow the User to receive messages;
• to facilitate the provision and use of the Website;
• to personalize the User’s experience on the Website;
• respond to requests for information;
• for all marketing actions and promotions proposed by VO EUROPE to Users who have agreed to this;
• to inform them about the evolutions of the Website and its functionalities;
• to get a more accurate picture of the Users and to offer them a better and more personalized service;
• to be able to send advertising messages based on the interests of the User;
• to allow the User to access the functions related to social media (share, like, connect);
• for any other purpose for which the User has expressly agreed.[KOAN2]

4.2 The legal basis of the processing of personal data of Users is:

• the consent of the User;
• the execution of any request from or an agreement with the User;

Indeed, it is necessary to collect certain data in order to answer any request from the User. If the User chooses not to share your data with us, this could make the execution of the agreement impossible.

• a legal obligation that rests on the controller;

It is actually required to collect and store certain data in order to comply with various legal obligations, mainly tax and accounting obligations.; or

• our legitimate interest to the extent that it is consistent with the interests, freedoms and fundamental rights of Users.

We have a legitimate interest in providing and exchanging this information with Users, mainly in order to answer requests or improve our services, prevent abuse and fraud, check the correctness of our actions, exercise our rights, to defend and indemnify, for example in litigation, as well as to prove any violation of our rights, to manage and improve our relations with Users, to continuously improve our Website as well as our products/services, unless these interests are overridden by interests or freedoms and fundamental rights of the User that require the protection of personal data. In any case, we take care to maintain a balance between our legitimate interest and respect for the User’s private life.

If the legal basis for our processing is consent, the User has the right to withdraw it at any time without affecting the lawfulness of the processing carried out before the withdrawal.

In the context of direct marketing, this means that the User can unsubscribe at any time from our newsletter and other commercial communications from us. The User, therefore, has an “opt-out” and can unsubscribe by sending us an email to the following address: privacy@vo-europe.eu or by clicking on the unsubscribe link as shown at the bottom of each email.

5. RIGHTS OF THE DATA SUBJECT

5.1 According to the regulations regarding the processing of personal data, the User has the following rights:

• Right to information about the purposes of the processing (see above) and the identity of the controller.
• Right of access: the User can at any time have access to the personal data that VO EUROPE processes about him/her or check whether these are included in the database of VO EUROPE SA.
• Right to rectification/correction: We take all reasonable steps to ensure that the information we hold is up to date. We advise the User to use his/her account from time to time (if applicable) or to check with us to ensure that the information is up to date. If the User finds that the data is incorrect or incomplete, he has the right to request us to correct it.
• Right of objection: the User can object at any time to the use of his data by VO EUROPE.
• Right to erasure: the User may request the deletion of his/her personal data at any time, with the exception of those that VO EUROPE is legally obliged to keep.
• Right to restriction of processing: the User may also request the restriction of processing if he/she has objected to the processing, if he/she disputes the accuracy of the data or if the processing of personal data is unlawful.
• Right to data portability (Data portability): The User has the right to receive personal data processed by VO EUROPE and to request that this data be transmitted to another controller.

5.2 The User may at any time request access to his/her personal data, check them, transfer them, limit their treatment in certain cases mentioned above and rectify them. The User can also request rectification free of charge and, where appropriate, request the removal of all his personal data from the database of VO EUROPE – with the exception of those which VO EUROPE is legally obliged to keep – and oppose the use and where appropriate, request its restriction.

He can exercise his rights by sending a written request, accompanied by a copy of his/her identity card or passport, to the data controller:

• by e-mail: privacy@vo-europe.eu
• by post: 140A, Rue de Stalle, 1180 Brussels

5.4 VO EUROPE will take the necessary steps to process each request as quickly as possible and in any case within one month after receipt of the request. If necessary, this period can be extended by two months, given the complexity and number of requests.

6. RETENTION TIME

6.1 VO EUROPE will keep the personal data of its Users for the duration necessary to achieve the objectives pursued (see point 4).

6.2 VO EUROPE may also continue to store personal data relating to the unsubscribed User, including correspondence or assistance requests directed to VO EUROPE, to answer any questions or complaints that may be sent after the order and to comply with all applicable laws, within particular in the field of taxation or in the context of any other legal provisions.

7. COMPLAINT WITH THE SUPERVISORY AUTHORITY

The User is informed that he/she has the right to lodge a complaint with the Data Protection Authority if he/she considers that his/her rights have been violated, to the following address:

Data protection authority
Drukpersstraat 35, 1000 Brussels

commission@privacycommission.be

8. SECURITY

8.1 In addition, VO EUROPE has taken appropriate measures to ensure that the servers containing the processed personal data prevent the following as much as possible:

• unauthorized access to or alteration of this data;
• the improper use or disclosure of this data;
• the illegal destruction or accidental loss of this data.

8.2 The employees of VO EUROPE who have access to this data are subject to a strict obligation of confidentiality. However, VO EUROPE cannot be held responsible for the misuse of this data by a third party, despite the security measures taken.

8.3 The Users undertake not to perform any actions that are in violation of this Privacy Policy, the Terms of Use, the Cookie Policy or, in general, the law. Offences against the confidentiality, integrity and availability of computer systems and data stored, processed or transmitted by these systems, or the attempt to commit any of these offences, shall be punishable by imprisonment of three months against five years and a fine of twenty-six euros to two hundred thousand euros or one of those fines alone.

9. NOTICE TO THIRD PARTIES

9.1 VO EUROPE treats personal data as confidential information. These will not be communicated to third parties in the context of situations other than in this Privacy Policy or in the conditions under which the law requires it.

9.2 Access to the data, in principle reserved for the controller and its employees as stipulated in the previous article 8, may in certain cases be granted to certain categories of external recipients, such as providers of technical services, messaging services, hosting service providers, IT companies, consultants, marketing services and VO Group SA for accounting, human resources and direct marketing purposes.

9.3 At any time, the controller may be asked to update the recipients.

9.4 The communication of this information to the aforementioned persons is in all circumstances limited to what is strictly necessary or required by applicable law.

10. TRANSFER TO A COUNTRY OUTSIDE THE EUROPEAN ECONOMIC AREA

VO EUROPE only transfers data to a non-EEA country when that country offers an adequate level of protection within the meaning of applicable law, in particular the GDPR (for more details please see: https://goo.gl/1eWt1V ) or within the limits allowed by the same law, for example by ensuring the protection of data through appropriate contractual provisions.

The information held by VO EUROPE will be transferred or transmitted, or stored and processed, in the United States or in countries other than where you reside, for the purposes described in this Privacy Policy. These transfers of data are necessary for the services or processing specified in this Privacy Policy, and in order to operate our Services and provide them to you around the world. We use standard contractual clauses, approved by the European Commission, and follow the decisions of the European Commission regarding certain countries for data transfers outside the European Economic Area to the United States and other countries. If you have any questions about this, do not hesitate to contact us at the following address: privacy@vo-europe.eu.

11. DIRECT MARKETING

11.1 Personal data will not be used for direct marketing purposes for articles or services that are not identical or analogous to those for which the User has already registered unless the User has previously explicitly agreed by ticking the boxes (“opt-in”).

11.2 Where the User has consented to the use of this information for direct marketing purposes, it reserves the right to oppose such use, at any time, upon request and free of charge. All that is required is that the User sends his/her request to the following address: privacy@vo-europe.eu.

12. MINORS

Persons under the age of 18 and persons who do not have full legal capacity are not permitted to use the Website. VO EUROPE asks them not to provide their personal data. Any violation of this provision must be reported immediately to the following address: privacy@vo-europe.eu.

13. UPDATES AND CHANGES TO THE PRIVACY POLICY

VO EUROPE may change and adapt this Privacy Policy, by providing this information to the Users via the Website, email or any other means, in particular, to comply with any new applicable legislation and/or regulations (such as the GDPR), the recommendations of the Data Protection Authority, the guidelines and recommendations of the European Data Protection Authority and the decisions of the courts and tribunals in this area. It is recommended to consult the Privacy Policy on a regular basis by reference to the last modified date as shown at the top of this document. If a user opposes any change to the Privacy Policy, he must immediately stop using the Website,

14. VALIDITY OF CONTRACTUAL CLAUSES

14.1 The fact that VO EUROPE does not invoke any of the provisions of this Privacy Policy at any time can in no way be interpreted as a waiver of the rights it has under this Privacy Policy.

14.2 The invalidity, voidness or unenforceability of all or part of any of the foregoing or following provisions shall not invalidate the entire Privacy Policy. The provision that is invalid, void or unenforceable in whole or in part is considered unwritten. VO EUROPE undertakes to replace this provision with another that, as far as possible, pursues the same purpose.

15. APPLICABLE LAW AND JURISDICTION

15.1 The validity, interpretation and/or implementation of the Privacy Policy are subject to Belgian law, to the extent permitted by applicable rules of private international law.

15.2 In the event of a dispute regarding the validity, interpretation or implementation of the Privacy Policy, the courts and tribunals of the judicial district of Brussels shall have exclusive jurisdiction to the extent permitted by applicable rules of private international law.

15.3 Before taking a step towards a judicial solution of a dispute, the User and VO EUROPE undertake to try to resolve this in mutual consultation. To this end, they shall first resort, where appropriate, to mediation, arbitration or any other alternative method of dispute resolution.