General Data Protection regulation

PRIVACY POLICY

Updated on 3 May 2021

1. Parties and Purpose

Les Filles du Baobab SPRL (hereinafter “Les Filles du Baobab” or the “Data Controller“)

Avenue de la Floride 10, 1180 Uccle

ECB / VAT : BE 0688.554.203

Mail: info@lesfillesdubaobab.com

Telephone: +32 (0)478 76 74 75

Les Filles du Baobab has drawn up this Privacy Policy with the aim of informing the Users of the website hosted at the following address: https://www.lesfillesdubaobab.com/, (hereinafter the “Site“), in a transparent manner, of the way in which personal data is collected and processed by Les Filles du Baobab.

The term “User” refers to any user, i.e. any natural or legal person, who visits or interacts in any way with the Site.

In this respect, Les Filles du Baobab determines all the technical, legal and organisational means and purposes of the processing of Users’ personal data. To this end, Les Filles du Baobab undertakes to take all necessary measures to ensure that the processing of personal data complies with the Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data (hereinafter, “the Law“) and the European Regulation of 26 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter, “the Regulation“).

Les Filles du Baobab is free to choose any natural or legal person who processes users’ personal data at its request and on its behalf (hereinafter the “Processor“). Where applicable, Les Filles du Baobab undertakes to select a Subcontractor offering sufficient guarantees as to the technical and organisational security measures for the processing of personal data, with regard to the Law and the Regulation.

2. Processing of personal data

The use of the Site by Users may involve the communication of personal data. The processing of such data by Les Filles du Baobab, in its capacity as Data Controller, or by service providers acting in the name of and on behalf of Les Filles du Baobab, shall be in accordance with the Law and the Regulation.

Personal data will be processed by Les Filles du Baobab, in accordance with the purposes mentioned below, via

– The contact form

– The newsletter registration form

– The customer database (after registration)

– The use of cookies

3. Purpose of processing of personal data

In accordance with Article 13 of the Regulation, the purposes of the processing of personal data are communicated to the User and are as follows

• 1. To ensure the execution of the services offered and agreed upon on the site;
  2. To ensure the control of the execution of the services offered;
  3. To carry out marketing activities and promotional information with the prior consent of the User and until such consent is revoked, for example, the sending of promotions on the products and services of the Data Controller;
  4. To answer the User’s questions;
  5. To carry out statistics in order to improve the Website, the services offered and the internal organisation of its operation;
  6. To improve the quality of the Website and the products and/or services offered by the Data Controller;
  7. To enable better identification of the User’s interests.

4. Personal data likely to be processed

The User consents, when visiting and using the Site, that Les Filles du Baobab collects and processes, according to the methods and principles described in this Privacy Policy, the following personal data :

• 1. The information of the Users that they give for contractual purposes and to allow the good execution of the reciprocal obligations, namely the name, first name, address (of invoicing and delivery), e-mail address; and more generally, any information voluntarily given by the User.
  2. The information of the Users by filling in forms or by contacting by telephone, e-mail or any other means, for example the name, address, e-mail address and telephone number of the Users.
  3. With respect to each of the Users’ visits to the Site, the information automatically collected is :

                        – IP address

                        – Browser type and model

                        – Time zone

                        – The operating system

                        – All information concerning the pages that the User has consulted on the Site, in particular the URL and the time spent browsing.

5. Consent

By accessing and using the Site, the User declares that he/she is aware of and gives his/her free, specific, informed and unequivocal consent to the processing of his/her personal data. This agreement relates to the content of this Privacy Policy.

Consent is given by the positive act by which the User has ticked the box offering the Privacy Policy as a hyperlink. This consent is an indispensable condition for carrying out certain operations on the Site or for allowing the User to enter into a contractual relationship with Les Filles du Baobab. Any contract between Les Filles du Baobab and a User concerning the services and goods offered on the Site is subject to the User’s acceptance of the Privacy Policy.

The User consents to the Data Controller processing and collecting, in accordance with the methods and principles included in this Privacy Policy, his/her personal data that he/she communicates on the Site or on the occasion of the services offered by Les Filles du Baobab, for the purposes indicated above.

The User has the right to withdraw his/her consent at any time. The withdrawal of consent does not compromise the lawfulness of the processing based on the consent previously given.

6. Duration of storage of Users’ personal data

In accordance with Article 13 §2 of the Regulation and of the Law, the Data Controller shall keep personal data only for as long as is reasonably necessary for the purposes for which they are processed.

This period is in any case less than : 2 years

7. Recipients of the data and disclosure to third parties

Personal data may be transmitted to employees, collaborators, subcontractors or suppliers of Les Filles du Baobab who offer adequate data security guarantees and who collaborate with Les Filles du Baobab in the context of marketing products or providing services. They act under the direct authority of Les Filles du Baobab, and are in particular responsible for collecting, processing or subcontracting such data.

In all cases, the recipients of the data and those to whom the data has been disclosed shall comply with the contents of this Privacy Policy. Les Filles du Baobab assures that they will process such data only for the purposes intended, in a discreet and secure manner.

In the event that the data is disclosed to third parties for direct marketing or canvassing purposes, the User will be informed beforehand so that he/she can express his/her consent to the use of this personal data.

8. Data Protection Officer (DPO)

The following person is appointed Data Protection Officer (hereinafter “DPO“): Véronique Schermant

The role of the DPO is to ensure the proper implementation of national and supranational provisions regarding the collection and processing of personal data.

The DPO can be contacted as follows

+32 478 76 74 75

veronique@lesfillesdubaobab.com

9. Users’ rights

At any time, the User may exercise his rights by sending a message by e-mail to the following address: info@lesfillesdubaobab.com, or a letter by post addressed, enclosing a copy of his identity card to the following address Avenue de la Floride 10, 1180 Uccle

• 1. Right of access

In accordance with Article 15 of the Regulations, Les Filles du Baobab guarantees the User the right of access to his/her personal data. The User has the right to obtain access to said personal data as well as the following information:

• the purposes of the processing ;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients who are established in third countries or international organisations;
• where possible, the period for which the personal data are to be kept or, where this is not possible, the criteria used to determine that period
• the existence of automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the Regulation, and, at least in such cases, relevant information concerning the underlying logic and the significance and intended consequences of such processing for the data subject

The Controller may require payment of a reasonable fee based on administrative costs for any additional copies requested by the User.

Where the User makes such a request electronically (e.g. via the e-mail address), the information is provided in a commonly used electronic form, unless the User requests otherwise.

The copy of the data will be communicated to the User at the latest within one month after the receipt of the request.

• 2. Right to rectify

Les Filles du Baobab guarantees the user the right to rectify and delete personal data.

In accordance with Article 16 of the Regulation, incorrect, inaccurate or irrelevant data can be corrected or deleted at any time. The User shall first make the necessary changes himself/herself from his/her user/other account, unless these cannot be made independently, in which case the request can be made to Les Filles du Baobab.

In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom personal data have been disclosed of any rectification of the personal data, unless such disclosure proves impossible or would require disproportionate effort. The controller shall provide the data subject with information about such recipients on request.

• 3. Right to deletion

The User has the right to obtain the erasure of his/her personal data as soon as possible in the cases listed in Article 17 of the Regulation.

Where the Controller has made the personal data public and is required to erase them pursuant to the preceding paragraph, the Controller shall, taking into account the available technology and the costs of implementation, take reasonable steps, including technical steps, to inform the other controllers processing such personal data that the data subject has requested the erasure by such controllers of any link to, or any copy or reproduction of, such personal data.

The two preceding paragraphs shall not apply to the extent that such processing is necessary:

• to exercise the right to freedom of expression and information;
• to comply with a legal obligation requiring the processing laid down by Union law or by the law of the Member State to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller
• for the establishment, exercise or defence of legal claims.

In accordance with Article 19 of the Regulation, the controller shall notify each recipient to whom personal data have been disclosed of any erasure of personal data or restriction of processing carried out, unless such disclosure proves impossible or would require disproportionate effort. The controller shall provide the data subject with information about such recipients on request.

• 4. Right to restrict processing

The User has the right to obtain the restriction of the processing of his/her personal data in the cases listed in Article 19 of the Regulation.

In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom personal data have been disclosed of any restriction on processing, unless such disclosure proves impossible or would require disproportionate effort. The controller shall provide the data subject with information about such recipients on request.

• 5. Right to data portability

In accordance with Article 20 of the Regulation, Users have the right to receive from Les Filles du Baobab personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transmit this data to another data controller without Les Filles du Baobab preventing this in the cases provided for by the Regulation.

When the User exercises her right to data portability in application of the previous paragraph, she has the right to have her personal data transmitted directly from one data controller to another, where technically possible.

The exercise of the right to data portability is without prejudice to the right to erasure. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The right to data portability shall not affect the rights and freedoms of third parties

• 6. Right of opposition and automated individual decision making

The User has the right at any time to object to the processing of his/her personal data due to his/her particular situation, including the automation of data carried out by Les Filles du Baobab. In accordance with Article 21 of the Regulation, Les Filles du Baobab will no longer process personal data unless there are compelling legitimate grounds for the processing which override the interests and rights and freedoms of the User, or for the establishment, exercise or defence of legal claims.

Where personal data are processed for the purpose of canvassing, the User shall have the right to object at any time to the processing of personal data concerning him or her for such canvassing purposes, including profiling insofar as it is related to such canvassing.

Where the data subject objects to the processing for canvassing purposes, the personal data shall no longer be processed for such purposes.

• 7. Right to complain

The User has the right to lodge a complaint concerning the processing of his/her personal data by Les Filles du Baobab with the Data Protection Authority, which is competent for the Belgian territory. More information can be found on the website: https://www.autoriteprotectiondonnees.be.

Complaints can be submitted to the following address:
Autorité de Protection des Données
Rue de la Presse 35, 1000 Brussels
Phone + 32 2 274 48 00
Fax: + 32 2 274 48 35
E-mail: contact@apd-gba.be

10. Cookies

The Site uses cookies to distinguish between Users of the Site. This allows us to provide Users with a better browsing experience and to improve the Site and its content. The purposes and terms of cookies are contained in this section.

• 1. General approach

A “Cookie” is a file deposited temporarily or permanently on the User’s hard disk when consulting the Website, with a view to a subsequent connection. Thanks to cookies, the server recognises the User’s computer.

Cookies may also be installed by third parties with whom Les Filles du Baobab collaborates.

Some of the cookies used by Les Filles du Baobab are necessary for the proper functioning of the Site, while others are used to improve the User’s experience.

The User can personalise or deactivate cookies by configuring their browser.

By using the Website, the User expressly agrees to the management of cookies as described in this article.

• 2. Type of cookies and purpose

Different types of cookies are used by Les Filles du Baobab on the Site:

• Technical cookies: these are necessary for the operation of the Website, allow the communication of data entered and are intended to facilitate the User’s navigation;
• Statistical and audience measurement cookies: these cookies allow the recognition of the User and are used to count the number of Users of the Website over a certain period. Since they also indicate browsing behaviour, they are an effective means of improving the User’s browsing experience, by displaying proposals and offers likely to interest him/her. They also allow Les Filles du Baobab to identify possible bugs on the Website and to correct them.
• Functional cookies: these cookies facilitate the use of the Website by retaining certain choices entered (for example, the user name or language);
• Tracking cookies: Les Filles du Baobab uses tracking cookies via Google Analytics, to measure the interaction of Users with the content of the Website and to produce anonymous statistics. These statistics allow Les Filles du Baobab to improve the Website. Google supports the explanation of these cookies at the following address: http://www.google.nl/intl/en_uk/policies/privacy/

• 3. Cookie storage duration

Cookies are kept for the time necessary to achieve the purpose for which they are intended. The cookies likely to be stored on the User’s hard disk and their retention period are as follows :

ga: 1 year

gid: 24 hours

Maximum 1 for all others.

• 4. Cookie management

If the User does not want the Website to place cookies on his/her hard drive, he/she can easily manage or delete them by modifying his/her browser settings. Browser programming also allows the User to receive a notice or notification when a Website is using cookies and to decide whether to accept or reject them.

If the User disables certain cookies, the User accepts that the Website may not function optimally. Some parts of the Website may not be usable, or may be partially usable.

If the User wishes to manage and/or delete certain cookies, he/she can do so by using the following link(s):

For Users using the following browsers :

• Internet Explorer : http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
• Microsoft Edge : http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq
• Chrome : https://support.google.com/accounts/answer/61416?hl=fr
• Firefox : https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
• Safari : https://support.apple.com/kb/ph21411?locale=fr_CA

If the User does not want Google Analytics cookies to be used, he/she is invited to set his/her browser to this effect at the following website: http://tools.google.com/dlpage/gaoptout.

11. Limited liability of the data controller

The website may contain links to other websites owned by third parties not related to Les Filles du Baobab. Les Filles du Baobab is not responsible for the content of these sites or their compliance with the Law and Regulations.

The holder of parental authority must give his or her express consent for a minor under the age of 16 to disclose personal information or data on the website. Les Filles du Baobab strongly advises persons exercising parental authority over minors to promote responsible and secure use of the Internet. The Data Controller cannot be held responsible for collecting and processing information and personal data from minors under the age of 16 whose consent is not effectively covered by that of their legal parents or for incorrect data – particularly regarding age – entered by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he or she is under 16 years of age.

Les Filles du Baobab is not responsible for the loss, corruption or theft of personal data caused in particular by the presence of viruses or following computer attacks.

12. Security

The Data Controller implements organisational and technical measures to guarantee an appropriate level of security for the processing and collection of data. These security measures depend on the costs of implementation with regard to the nature, context and purposes of the processing of personal data.

The Data Controller uses industry standard encryption technologies when transferring or collecting data on the Site.

13. Changes to the Privacy Policy

Les Filles du Baobab reserves the right to modify this Privacy Policy in order to comply with legal obligations in this area. The user is therefore invited to consult the Privacy Policy regularly in order to take note of any changes and adaptations. Any such modification will be posted on the Site or sent by e-mail for the purpose of enforceability.

14. Applicable law and jurisdiction

This Privacy Policy is governed exclusively by Belgian law. Any dispute shall be brought before the courts of the judicial district of the registered office of Les Filles du Baobab.

15. Contact information

For any questions or complaints relating to this Privacy Policy, the User may contact the Data Controller via the following address: info@lesfillesdubaobab.com