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Effective since: 18 November 2018
1.1 The Academic Cooperation Association (ACA), an AISBL/VZW according to Belgian law seated in Brussels, respects the privacy of its users and member organisations.
1.2 ACA processes the personal data transmitted to it in accordance with the legislation in force, and, in particular, Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, applicable from 25 May 2018 (hereinafter the “General Data Protection Regulation”).
1.4 The user acknowledges having read the information below and authorises ACA to process, in accordance with the provisions of the policy, the personal data that s/he communicates on the website.
1.5 The policy is valid for all pages hosted on the ACA website and for the registrations of the latter. It is not valid for the pages hosted by third parties to which ACA may refer and whose privacy policies may differ. Therefore, ACA be held responsible for any data processed on these websites or by them.
2.1 Simply visiting the website shall take place without having to provide any personal data, such as first name, surname, postal and/or email address, for example.
2.2 As part of the service, the user may be required to provide certain personal data. In this case, the data controller is:
Academic Cooperation Association, AISBL/VZW (ACA)
15, rue d’Egmontstraat
Tel: +32 2 513 22 41
Fax: +32 2 513 1776
Belgian registry number: BE0451.407.415
2.3 Questions relating to the processing of said data should be sent to this address: firstname.lastname@example.org.
3 Data collected
3.1 By using the service and/or completing the registration form on the website, the user allows ACA to record and store, for the purposes mentioned under 4, the following information: data for identifications, such as surname, first name, function, organisation or institution, email address, postal address; invoicing information; communications between the user and ACA.
3.2 Further, the user authorises ACA to record and store the following data for the purposes mentioned under 4:
3.3 In order to facilitate browsing the website as well as to optimise technical management, the website may use “cookies”. These “cookies” record, in particular:
3.4 When the website is accessed by the user, the servers involved automatically record certain data, such as:
3.5 No nominative data identifying the user is collected through the cookies used and servers involved. This information is kept for statistical purposes only and to improve the website.
4 Purposes of data processing
4.1 The Website collects, stores and uses its users’ data for the following purposes in particular:
5 Rights of the person concerned
5.1 In compliance with the regulations on the processing of personal data, the user has the following rights:
5.2 The User may, at any time, request access to his/her personal data, verify them, transfer them, and, in some cases, as mentioned above, limit their processing and rectify them, by writing to the following email address secretariat(at)aca-secretariat.be or the postal address: 15, rue d’Egmonstraat, B-1000 Brussels, Belgium.
5.3 The user may also, free of charge, request rectification and, where applicable, the deletion of all his/her personal data from ACA’s database – except such which ACA is legally obliged to keep on record – and object to the use and, where appropriate, request the limitation thereof by sending a written request, accompanied by a copy of his/her identity card or passport, to the data controller under the addresses mentioned in 5.2.
5.4 ACA will take the necessary measures to satisfy such requests as soon as any possible.
6 Duration of data storage
6.1 ACA will keep the personal data of its users for the duration necessary to achieve the objectives pursued (see under 4).
6.2 ACA may also continue to keep personal data concerning the de-registered user, including all correspondence or requests for assistance sent to ACA in order to be in a position to reply to all questions or complaints that may be sent to it, and in order to comply with all applicable laws.
7 Complaint to the supervisory authority
The user is informed that s/he has the right to lodge a complaint with the Belgian Commission for the Protection of Privacy.
8.1 ACA has taken the appropriate technical and organisational measures to ensure a level of security commensurate with the risk and that, to the extent possible, the servers hosting the personal data processed prevent:
8.2 In this respect, employees of ACA who have access to these data are subject to a strict confidentiality obligation. This notwithstanding, ACA may in no way be held liable in the event that the data are stolen or hijacked by a third party despite the security measures adopted.
9 Communication to third parties
9.1 ACA treats personal data as confidential information. It will not communicate them to third parties under any condition other than those specified in the policy, such as to achieve the objectives set out and defined under 4, or under the conditions in which the law requires it to do so.
9.2 ACA may communicate its users’ personal information to third parties to the extent that such information is necessary for the performance of a contract with its users. In such case, these third parties will not communicate this information to other third parties, except in one of the two following situations:
9.3 The communication of this information to the above-mentioned persons shall, under any circumstances, be limited to what is strictly necessary or required by the applicable regulations.
10 Transfer of data to a non-EU country or company
ACA transfers data to a non-EU country or company only when the country in question provides an adequate level of protection within the meaning of the legislation in force, and, in particular, the Law of 8 December 1992 on protection of privacy and its executive orders, and Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, applicable from 25 May 2018 (hereafter called the “General Data Protection Regulation”), or within the limits permitted by the legislation in force, for example by ensuring the protection of data by appropriate contractual provisions.
11 Direct marketing
11.1 Personal data will not be used for direct marketing purposes for information or services other than those to which the user has already subscribed.
11.2 Despite of this, the user has the right to object to such use at any time, upon request and free of charge. The user may use the unsubscribe link provided in all ACA emails or simply communicate his/her request by writing to the following address: email@example.com.
12.1 Persons under the age of 18 and persons who do not have full legal capacity are not permitted to use the website. ACA asks them not to provide their personal data.
13 Changes to and updates of the policy
13.1 By informing users via the website or email, ACA may modify and adapt the policy, in particular to comply with any new legislation and/or regulations applicable (such as the General Data Protection Regulation applicable from 25 May 2018), the recommendations of the Belgian Privacy Commission as well as the guidelines, recommendations and best practices of the European Data Protection Board and the decisions of the courts and tribunals on this issue.
14 Validity of the contractual clauses
14.1 Failure of ACA to invoke – at any given time – a provision of this policy, may not be interpreted as a waiver to subsequently make use of its rights under the said provision.
14.2 The invalidity, expiration or the unenforceable nature of all or part of one of the above or below mentioned provisions shall not give rise to the invalidity of the entire policy. Any fully or partially invalid, lapsed or unenforceable provision shall be deemed not to have been written. ACA undertakes to substitute this provision with another which, to the extent possible, fulfils the same objective.
15 Applicable law and competent court
15.1 The validity, interpretation and/or implementation of the policy are subject to Belgian law, to the extent permitted by the provisions of applicable private international law.
15.2 In the event of a dispute relating to the validity, interpretation or implementation of the policy, the courts and tribunals of Brussels have exclusive jurisdiction, to the extent permitted by the provisions of applicable private international law.
15.3 Before taking any step towards the judicial resolution of a dispute, the user and ACA undertake to attempt to resolve it amicably. To this end, they shall first contact each other before resorting, where appropriate, to mediation, arbitration, or any other alternative method of dispute resolution.
16 Final note
16.1 ACA bases its data rationale on the notion of legitimate interest in the sense of the GDPR.
16.2 ACA’s members and users have a legitimate interest to receive ACA products, which help them improve their practice in internationalisation in higher education, ACA’s core business. Among these products are the ACA Newsletter Education Europe, ACA research results in the form of publications, as well as ACA seminars and conferences of interest to them.
16.3 Likewise, ACA, as an association created to promote and to improve internationalisation in tertiary education, has a legitimate interest to be visible. It must have the right to showcase its knowledge, skills and experience to its target audience, the academic community.