Privacy policy

This privacy policy discloses the privacy practices for Subbacultcha Belgium. We are responsible for the processing of personal data as described in this policy. If you have any questions regarding our privacy policy please contact us via

Contact information

Subbacultcha Belgium (VZW We Promised)
Spinmolenplein 264
9000 Ghent

+32 479 83 02 18

Processing of personal data
Subbacultcha Belgium processes the data you’ve provided when registering to become a Subbacultcha member and / or data captured by Google Analytics when you use our website(s).

Below is an overview of the personal data we process and store if you’re a Subbacultcha member or have indicated that you are interested in becoming a Subbacultcha member:

  • First and last name
  • Email address
  • Date of birth (if provided)
  • Address information (if provided)
  • Phone number (if provided)
  • IBAN (if provided)

This is the data we process if you’re a visitor of, or

  • Login information: we store some data in server logs that include, but are not limited to:
    • Internet protocol address
    • Browser-information
    • The external website that referred you
    • The pages you visited on our website
    • Time and date of each page visited by you
    • Details on how you use our services
  • Device information: we can collect device-specific information e.g. hardware type, version, etc.
  • Local storage: using browser web storage, application data caches, and other mechanisms on your device, we can collect and store your data (including personal data)
  • Cookies: we use cookies to identify our visitors, to remember your custom preferences (e.g. language), … (for further information on what cookies are and their use, we refer you to our Cookies Policy).

We do not have Subbacultcha members younger than 16 years and we have no intention to collect and process data of visitors to our website who are younger than 16 years unless we have the explicit permission of a parent or guardian. However, we cannot check the age of visitors to our website. If you’re convinced that we’ve collected data of a minor without the consent of a parent or a guardian, please contact us via

Subbacultcha Belgium processes your personal data for the following purposes:

  • The execution of your Subbacultcha membership. Registration, processing and general functioning of your membership which includes but is not limited to: the monthly payment transaction, mailing your membership card and newsletters, informing you about changes in our service or membership, … These processing activities are all done for the purpose of executing your contract with Subbacultcha and in our legitimate commercial interests.
  • For prospective Subbacultcha members: emailing newsletters and general marketing based on your explicit consent, which can be withdrawn at all times.

Subbacultcha Belgium doesn’t make any decisions based on automated processing.


Duration of storage of personal data
Subbacultcha Belgium does not store your personal data longer than is strictly necessary to realize the purposes for which your data is collected. We use the following retention periods:

Personal data (with exception of your email address): duration of your membership.

Email address: 2 years after cancellation when you’re a member or, when you’re just a newsletter subscriber, 1 year after your unsubscription.


Transfer of personal data
Subbacultcha Belgium never sells your information to third parties.

Subbacultcha Belgium only provides your personal data to a third party if this is necessary for the execution of our agreement with you or to comply with a legal obligation. We choose our partners carefully to ensure the same level of security and confidentiality of your data with the companies who process your data commissioned by us. Subbacultcha Belgium remains responsible for these transactions. If a business needs to process your data on our behalf, we always require a Data Processing Agreement from the third party.

Our current work process includes a transfer of data with the following parties:

  • ING
  • Mailchimp and Mandrill
  • Dreamhost
  • Dropbox

Your personal data rights
You have the right to request Subbacultcha Belgium:

  • for information about the processing of your personal data and obtain access to your personal data in case you have additional questions after reading this privacy policy.
  • to correct incorrect, inaccurate or incomplete personal data. Should any of your personal data change during your membership, please inform us as soon as possible.
  • that personal data shall be erased when it’s no longer needed, if the processing of it is unlawful or – in case the processing is based (solely) on your consent – if you revoke your consent.
  • to stop processing your personal data for marketing purposes or on grounds relating to your particular situation or restriction the processing of your personal data in specific cases.

You can send your request to To ensure that the request has been made by you, we ask you to send a copy of your ID with the request. This is to protect your privacy. We respond as quickly as possible to your request (within the required month) and free of costs.

Please note that being a Subbacultcha member is impossible without us processing and storing your data.


Protection of your personal data
Subbacultcha Belgium takes the protection of your data seriously and takes the appropriate measures to prevent misuse, loss, unauthorized access, unwanted publication, and unauthorized modification.

Should you have any complaints on how we process your personal data or if there are any indications of abuse, please contact us via We will make every effort to reply as soon as possible and take into consideration any suggestions from your end. If you feel that we do not sufficiently assist you, you can lodge a complaint with the Belgian data protection authority.


Cookies Policy
Subbacultcha Belgium uses analytical and tracking cookies. A cookie is a small text file that is stored in the browser of your computer, tablet, or smartphone when you first visit a website. We place cookies that keep track of your browsing on our site so we can offer you customized content and advertisements. On your first visit to our website we have already informed you about these cookies and asked permission for their placement. You can opt out of cookies by setting your internet browser so that it doesn’t store cookies anymore. In addition, you can also delete all information previously saved via the settings of your browser. Cookies are also placed by third parties. These are e.g. advertisers and / or social media companies. Below an overview:

Google Analytics
Name: _dc_gtm_UA-68078902-1 Function: Analytical cookie, used by Google Tag Manager to distinguish users and events on the website and analyze how users interact with our website. User data tracked is anonymous. Retention period: 10 minutes
Name: _ga Function: Analytical cookie, Used to distinguish users. Retention period: 26 months
Name: _gid Function: Analytical cookie, Used to distinguish users. Retention period: 24 hours

Name / ID: 1880485145526004 Function: Analytical cookie, used to track conversions from Facebook ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads. Retention period: up to 180 days


Subbacultcha Belgium reserves the right to make changes to their privacy statement without prior notice at any time. Any changes will be automatically published on this page. Current version: May 2018