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Privacy Policy

 

1. Introduction

VZW WE PROMISED (“we”, “us”, “our”, “Subbacultcha”, “Subbacultcha Belgium”) do everything to ensure that our website (“subbacultcha.be") is completely safe for you. We understand that you want the personal information you provide to us to be kept both private and secure, and this privacy policy explains how we will use the personal information you provide us and how we ensure that it is stored securely. If you have any questions about this Privacy Policy or if you do not agree, please contact us at info@subbacultcha.be before using this website. We may change this Privacy Policy from time to time. Check this page to ensure that you are happy with any changes.
 
“Subbacultcha Belgium” respects the Privacy Act. The Privacy Act is the Act of 8 December 1992 for the protection of privacy with regard to the processing of personal data. This law wants to protect citizens against the misuse of personal data. Both the rights and obligations of the person whose data is being processed and the rights and obligations of the processor are determined in the Privacy Act.
 
VZW WE PROMISED Spinmolenplein 264, B-9000 Ghent

 

2. Collection of data

We collect personal data in a number of situations. When you sign up for our mailing list, we ask for your name and e-mail address. We also collect the personal information that you provide when you contact us, when you register for one of our events or when registering for a membership. Finally, we keep an overview of the messages that you send us by e-mail.
 
We collect (customer) information in our CRM system. There we store the customer (full) name, Email address, Photo, Date of birth (if provided), Address information (if provided) and any other logs related to your membership.
 
If you use our website, please note that we may also register the parts of the website that you visit and information about your computer. Such as the browser used, your network location, the type of connection you use and your IP address. We do this by using cookies (although the information we collect through our cookies remains anonymous, so we cannot tell who you are). See our Cookie Policy below for more information about what a cookie is and how we use it on our website.

 

3. Use of data

Except as set out in this paragraph, we will never sell, exchange or disclose your personal information to third parties without your consent. For example, this information allows us to tailor more accurate ads to you. We may disclose your personal information when we believe that it is appropriate to comply with the law or to maintain our terms of use or to protect our rights, property or security or other third parties. We may share your personal information with organisations acting on our behalf and who only use the information to provide that service.
 
The main reason why we use the information we collect about you is to offer better customer service, generate tailored ads, administrative purposes and for tracking activities on our website.
 
Your personal data is processed by the following data processors (who also comply with the GDPR rules):
 
Mollie: We use Mollie as our payment processor. All online payments (for example when signing up for a membership) are processed by Mollie.
 
Mailchimp: For sending newsletters, the data processor is Mailchimp (based in the U.S.A. - Servers running in E.U.). By subscribing to our newsletter you agree to Mailchimp’s terms & conditions. An agreement has been concluded with this data processor to protect your personal data.

Data storage: We use up-to-date cloud storage software and shared web hosting to store all of our data securely. 

Google Analytics & Optimize: We use Google Analytics to record how often you visit the Website, which search engine and search words you use, which link you click on, and how long you visit the Website.
 
Facebook Pixel: We use Facebook Pixel for (re)targeting personalized advertising.
 
Groove: We use Groove for customer support. All communication via memberships@subbacultcha.be and help@subbacultcha.be is processed through Groove.
 
TawkTo: We use TawkTo’s chat module to offer real-time support to all website visitors.
 
Hotjar: We use Hotjar for tracking users when a new feature is implemented into our website.
 
Sumocoders: Sumocoders is our development agency who also has access to all data stored on our web server. 

 

4. Transfer of your data to countries outside the EEA

We will not disclose your personal data to parties who are not in the EEA unless necessary for the business activities you desire from us. It is possible that those countries outside the EEA do not have the same data protection legislation as in the EEA and your personal data are not equally protected. In these cases, however, we ensure that any transfer of personal data to countries outside the EEA is accompanied by adequate protection measures as if the data were to be processed within the EEA and in accordance with the principles of this Privacy policy.

 

5. Marketing

We would like to provide you with information about our memberships, events or any other activities that we think are interesting to you. We may send you such information by mail, digital platforms, social media,  e-mail and/or phone unless you have asked us not to do so.
 
If you are a member of ours or if you were a member in the past, we may send you information by e-mail. However, in any marketing e-mail, we send you, we give you the opportunity to completely opt-out of that mailing list.
 
If you do not want your information to be used for direct marketing purposes, please contact us at info@subbacultcha.be. If you decide that you no longer wish to receive marketing emails from us, use the sign-out form at the bottom of one of our marketing e-mails.

 

6. Requesting & customising your personal data

You have the legal right to access and correct any of your personal data. By proof of identity (copy id), dated and signed application to VZW WE PROMISED Spinmolenplein 264, B-9000 Ghent or info@subbacultcha.be, you can obtain the status of your personal data. If necessary, you may also ask to correct the data that would be incorrect, not complete or not pertinent.

 

7. Your rights

You have a number of rights related to your personal data and what happens to them. You have the right to:
  • Access your data and look into it. 
  • Improve, supplement or delete certain personal data.
  • Be completely erased from all systems and databases.
  • To file a complaint with the Privacy Committee when you find that your personal data is unlawfully collected and processed.
  • Withdraw your consent and oppose the processing of your data.
  • Restrict the processing of your personal data (temporarily).
  • Transfer your personal data to another person responsible.
  • To have automatic profiling turned off and to oppose decisions based on automated processing.

 

8. Links

Our website and our marketing e-mail messages sometimes contain links to other websites that are not under our control. Our privacy policy applies only to our website, not on these other websites. Once you have left our website or marketing e-mails, we cannot be held responsible for the content and/or protection and privacy you provide to those websites. You should be careful and look at the privacy policy applicable to the relevant website.

 

9. Safety

We think the security of your personal data is very important. In order to prevent unauthorised access or disclosure, we keep your data on secure servers and appropriate security measures have been taken to try to prevent changes, loss or misuse of data under our control. If you suspect at any time or become aware of a security incident (i.e. you receive a suspicious communication from someone who excludes himself as an employee of Subbacultcha or a dupe website who claims to be affiliated with Subbacultcha), send the communication to us or report the incident via e-mail via info@subbacultcha.be or writing to VZW WE PROMISED Spinmolenplein 264, B-9000 Ghent. 

 

10. Changes to this Privacy Policy

We can update this Privacy Policy at any time. We will let you know if we make important changes, but we recommend that you consult this Privacy Policy regularly so that you are aware of the latest version.


This Privacy Policy was last updated on the 1st of July 2020.



Cookies

Cookie Settings

The Website (“subbacultcha.be", “differentclass.be" or any other subdomain) uses cookies. These can be cookies of our own (first-party cookies) or cookies from third parties whose services may be used on this Website (third-party cookies). This Cookie Policy informs you about the use of these cookies.

You can change your cookie preferences at any given moment via your browser. You can find a manual for your browser down below (4. How can I manage/delete cookies?). You can revoke your permission for the placement of these cookies, at any time and even if you had already given permission for these cookies to be placed. We would like to remind you that if you don’t accept some of our cookies, your user experience might be influenced.

 

1. What are cookies?

 

A cookie is a small text file that the website stores on your computer or mobile device when you visit the website. Information is stored in this text file. When you revisit the website later, this information is sent to our servers or third parties. That way the website can recognise your browser and make sure that you can use it according to your personal preferences.

Considering cookies are personal data, its processing is governed by our Privacy Policy (see above). The processing of functional cookies is based on our legitimate interest since the functional cookies are required for the proper functioning and security of the Website. (coming soon: The other cookies will not be placed unless the website has received your permission.)

 

2. How are cookies classified?

2.1. Origin

First-party cookies are cookies that are placed directly on the website by us.

Third-party cookies are cookies that are placed on the website by others because Subbacultcha incorporates elements of those other websites into their own.

 

2.2. Lifespan

Permanent cookies: these stay on your computer or mobile device until the cookies expire. They become activated every time you visit our website.

Session cookies: these simplify and link the actions of the user together during a browser session. Every time you open a browser screen, these cookies are placed temporarily. Session cookies are deleted when the browser is closed.

 

2.3. Function/purpose

A. Functional cookies

Functional cookies make sure that every part of our website functions optimally. These are cookies that are necessary for the proper functioning and security of the website. These cookies can be placed without your permission.

 

B. Non-functional cookies

This type of cookies is placed for statistical, social and commercial purposes and are independent of the technical support of the website. That means that they do not meet the conditions to be exempted from the consent requirement. By using our website you consent to the placement of these cookies.

Analytical cookies: these show how you use the website. Based on this collected information, a statistical analysis is made to make the structure, navigation and content of the website more user-friendly and to improve it.

Marketing cookies: the online advertising offer is personalised via marketing cookies. Based on a profile, based on your click and surf behaviour on the Website, both the website and third parties gain insight into the campaign performance. This also includes social media cookies. You can share the articles and videos that you view on the website via buttons via social media. For the functioning of these buttons, cookies from social media networks are used, so that they recognise you when you want to share an article or video. In addition, social media networks also place cookies when we integrate their content into our articles, for example when an Instagram movie is loaded.

If social networking sites place these cookies through our website to collect (your) data, Subbacultcha has no influence on the use of and the way in which they handle this data. You can find more information about this in the privacy statements of the social networking sites, which are each time specified in the list of active cookies below. Keep in mind that these privacy statements can be changed at any time by social networking sites.

 

3. Which cookies does VZW WE PROMISED use?

3.1. Functional cookies – first-party cookies

These cookies are necessary for the proper functioning of this website. These cookies can be placed without permission. Therefore, you cannot refuse them if you want to visit the website.

Cookie Domain Lifespan Purpose
interface_language subbacultcha.be 1 month For storing your preferred language.
frontend_profile_secret_key subbacultcha.be 1 month For storing the security key of the logged in user.
PHPSESSID subbacultcha.be Session PHP session cookie associated with embedded content from this domain.
cookie_bar_hide subbacultcha.be 1 week For storing if you hide the cookie bar.
cookie_bar_agree subbacultcha.be 1 week For storing if you agreed or did not agree to our cookie policy.

 

3.2. Non-functional cookies - third-party cookies

The Website uses Google Analytics and Google Tag Manager. These cookies record how often you visit the Website, which search engine and search queries you use, which link you click on, and how long you visit the Website. This data allows us to compile statistics with which we can gain insight into the way people use the Website so that we can improve its structure and content. You can disable these cookies by surfing to https://tools.google.com/dlpage/gaoptout. You can refuse these cookies if you want to visit the Website.

Cookie Domain Lifespan Purpose
_gid analytics.google.com 1 day Used to distinguish users for Google Analytics.
_ga analytics.google.com 2 years Used to distinguish users for Google Analytics.

 

The Website often uses the Hotjar tracking tool when new features are implemented. These cookies are used to track and analyze the surfing behaviour of visitors to the Website. This data allows us to compile statistics with which we can gain insight into the way people use the Website so that we can improve its structure and content. You can disable these cookies by surfing to https://www.hotjar.com/legal/compliance/opt-out. You can refuse these cookies if you want to visit the Website.

Cookie Domain Lifespan Purpose
_hjid hotjar.com 1 year For Analysis of website visits. This cookie is set when the customer first arrives on a page with the Hotjar script. It is used to retain the Hotjar user ID, unique to that site in the browser. This ensures that behaviour on subsequent visits to the same site is attributed to the same user ID.

 

The Website also uses the Google optimize optimization tool. These cookies are used to track and analyze the surfing behaviour of visitors to the Website. This data allows us to compile statistics with which we can gain insight into the way people use the Website so that we can improve its structure and content. You can refuse these cookies if you want to visit the Website.

Cookie Domain Lifespan Purpose
_gaexp optimize.google.com 2 months Used to determine a user's inclusion in an experiment and the expiry of experiments a user has been included in for Google Optimize.

 

The Website also uses the Tawk To chat module. The cookies set by Tawk To are used to track visitors to the Website. This data allows us to improve our customer experience as we can provide support in real-time.

Cookie Domain Lifespan Purpose
__tawkuuid http://tawk.to 1 year This cookie remembers the end user so that past chat conversations can be identified to improve service.
TawkConnectionTime http://tawk.to 1 year This cookie remembers the end user so that past chat conversations can be identified to improve service.

 

3.3. Non-functional cookies: marketing cookies – third-party cookies

The Website uses marketing cookies originating from third parties, in the function of targeting and advertising. These cookies use your personal data and surfing behaviour to make better ads and target you personally.

Cookies placed by Facebook and the Facebook pixel:

Cookie Domain Lifespan Purpose
presence facebook.com Session The presence cookie is used to contain the user's chat state. For example, which chat tabs are open.
fr facebook.com 3 months Encrypted Facebook ID and Browser ID.
c_user facebook.com 1 year The c_user cookie contains the user ID of the currently logged in user.
dpr facebook.com 1 week This cookie is used by Facebook for performance.
sb facebook.com 2 years This describes if this specific cookie or localStorage is responsible for sharing, collecting or storing personal data.
xs facebook.com 1 year This cookie contains multiple pieces of information: The first value is an up to two-digit number representing the session number; The second portion of the value is a session secret; The third, optional component is a ‘secure’ flag for if the user has enabled the secure browsing feature.
wd facebook.com 1 week This cookie stores the browser window dimensions and is used by Facebook to optimise the rendering of the page.
spin facebook.com 1 day Unkown
datr facebook.com 2 years The purpose of the datr cookie is to identify the web browser being used to connect to Facebook independent of the logged in user.
_fbp facebook.com 3 months Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers

 

4. How can I manage/delete cookies?

4.1. Browser settings

You can refuse the installation of cookies via your browser settings. More information about disabling cookies or managing the cookie settings for your browser can be found in the following list:

Google ChromeFirefoxInternet ExplorerSafari (iOS)Safari (macOS)

Are you using a different browser? Then check whether the procedure for your browser is mentioned on this website.

 

4.2. Deleting cookies

You can also delete already installed cookies from your computer or mobile device at any time.

 

4.3. Disabling marketing cookies

If you want to disable or refuse marketing cookies (from Google and so on), you can do so via this website.  

If you do not want to receive advertising based on your surfing behaviour and remarketing cookies, such as those from Google, you can change the settings of the Google Ads Preferences Manager. Google also recommends installing the Google Analytics Opt-out Browser Add-on.  

This link contains additional information about how you can manage what information is shared by your web browser when you interact with Google services on third-party websites and apps.

 

4.4. More information

Here you can find more information on cookies. Do you wish to receive more information on privacy and online advertising?

YouTubeVimeoSpotifyGoogleMailchimpSoundcloudFacebookInstagram.

 

4.5. Changes to this Cookie Policy

We can change this Cookie Policy at any moment. We advise you to check this Cookie Policy regularly, so you are aware of the most recent version.

Contact

If you have any questions or concerns about our privacy policy, please contact Subbacultcha’s DPO (Data Protection Officer) via:

Email: Info@subbacultcha.be

Mail: VZW WE PROMISED - DPO Spinmolenplein 264, B-9000 Ghent

 

This Cookie Policy was last updated on the 1st of July 2020.

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