1. PURPOSE

The purpose of this data protection policy is to inform you about the commitments and practical measures taken by VATEL to ensure respect for your personal data.

This privacy policy may evolve depending on the legal and regulatory context and the recommendations and/or guidelines of the Belgian Data Protection Authority (DPA).

 

2. SCOPE

This privacy policy applies in particular when you visit our websites, when you access our products and services (school enrollment, hotel, restaurant, or spa reservations) or when you participate in VATEL events (hereinafter collectively referred to as the "Service(s)").

VATEL acts in its capacity as data controller.

This privacy policy may be supplemented by additional elements specified in all or part of a provided Service.

 

3. TYPES OF DATA COLLECTED

VATEL ensures that it only collects and processes data that is strictly necessary for the purpose for which it is processed, in accordance with the data minimization principle.

When you access one of our Services, you may be required to provide personal data by filling out registration forms: we indicate there which types of data are required. You may choose not to submit the requested data, but this may limit your access to the Service.

Personal data is collected in three ways:

• what you provide;
• what we obtain from third-party sources;
• and finally, through your use of our Services.

3.1. Data you provide to us

The data collected directly from you depends on your relationship with the Service and may include:

• Contact data: last name, first name, email address, postal address, phone number, mobile number;
• Comments and other information you provide to us, including search queries, questions, and information you send to the requested service.

3.2. Data collected from other sources

We may also obtain your contact details and other personal information from our subsidiaries and other third parties, including:

• Vatel group companies with which we offer joint services; and/or
• Publicly accessible sources and partners from whom we obtain data to validate and supplement the information we hold.

3.3. Service usage data, including cookies

A Service may automatically collect information about how you interact with it, including:

• Information about the computer and connection environment, namely the IP address, browser type and version, operating system and other software installed in your environment, mobile platform, technical identifier(s), error reports, and execution data;
• Usage data such as the functions you used, configurations you selected, data you clicked on, including the date and time, and pages viewed, terms searched, and pages visited and searched within the Service;
• Geographic information from Services based on user location, to provide you with more relevant content based on your geographic location wherever you are in the world.

We collect this data through our servers, the use of cookies, and various technologies.

Cookies are small text files that can be read by a web server in the VATEL domain that placed the cookie on your device. In accordance with applicable Belgian regulations, cookies that are not strictly necessary (in particular analytics and advertising cookies) are only placed with your prior consent, which you may withdraw at any time via [link to cookie manager / cookie policy].

You can also control cookies through your browser settings. However, if you block certain strictly necessary cookies, you will no longer be able to register, log in, access certain parts, or fully use the Services.

 

4. PURPOSES OF PROCESSING

Depending on the relationship established with VATEL, we use your personal data to:

• Provide, activate, and manage your access to and use of the Service;
• Process and respond to a school enrollment application or a brochure request;
• Improve the Service and our other products and events, and develop new ones;
• Offer personalized content to make the Service more relevant based on your interests and geographic location;
• Respond to your requests, searches, comments, and concerns;
• Notify you of changes, updates, and other announcements relating to the Service and our other products and services;
• Send you promotional messages and other information about our products, events, services, and all new developments related to VATEL;
• Invite you to participate in surveys regarding the use of the Service;
• Identify usage trends and carry out data analysis, including for research, auditing, reporting, and other business operations, which include measuring the effectiveness of our promotional campaigns and evaluating business performance;
• Comply with our legal obligations, resolve potential disputes, and enforce our contracts.

If you are the manager of an entity registered for one of our Services, we will use your data to communicate with you about your organization's subscription.

If you provide us with information about users within your entity, you warrant that you have obtained their consent for us to use their personal data to provide them with the Services.

Processing is based on the performance of a contract, consent, VATEL's legitimate interest, or a legal obligation, as the case may be.

 

5. DATA RECIPIENTS

VATEL only communicates your personal data to authorized and specified recipients:

• Competent internal departments of VATEL;
• Vatel group companies, to the extent necessary for the purposes described above;
• Technical service providers acting as processors, bound by contractual obligations compliant with the GDPR.

No personal information of the user is published without the user's knowledge, exchanged, transferred, assigned, or sold on any medium to third parties. Only in the event of the acquisition of the website [www.vatel.be] and its rights could said information be transmitted to the potential purchaser, who would in turn be bound by the same obligation of data conservation and modification with respect to the website user.

 

6. DATA RETENTION PERIOD

VATEL only retains your data for as long as necessary for the operations for which it was collected, and in compliance with applicable legislation. This is for the purpose of providing the Service and fulfilling the obligations you have requested, or for other essential purposes such as complying with our legal obligations (in particular accounting and tax obligations), maintaining commercial and financial archives, settling disputes, maintaining security, detecting and preventing fraud and abuse, and performing the contract binding us.

 

7. PROCESSING LOCATIONS

Your personal data is stored and processed in Belgium, in France, and within the European Union.

VATEL takes measures, including contractual ones, to ensure that the information remains protected wherever it is located, fully consistent with the protection standards required by applicable law.

 

8. TRANSFER OF PERSONAL DATA

VATEL refrains from processing, hosting, or transferring the collected information to a country outside the European Economic Area that does not benefit from an adequacy decision of the European Commission without prior notification to the data subject.

When such transfers are necessary, VATEL implements appropriate safeguards, including:

• European Commission Standard Contractual Clauses;
• Additional security measures.

 

9. DATA SECURITY

VATEL ensures the security of your personal data by implementing enhanced protection through physical and logistical security measures.

To ensure the security and confidentiality of personal data, including health-related data, VATEL uses networks protected by standard devices such as firewalls, pseudonymization, encryption, and passwords.

When processing data, VATEL takes all reasonable measures to protect it against loss, misuse, unauthorized access, disclosure, alteration, or destruction.

10. CHILDREN'S PRIVACY PROTECTION

VATEL does not knowingly collect information from children under 16, and as a rule, VATEL's websites are not directed at children under 16.

 

11. YOUR RIGHTS

In accordance with the GDPR, you have the following rights, which you can exercise free of charge:

• Access to your personal data;
• Rectification or erasure of your data;
• Restriction of the processing of your data;
• Objection to processing, including at any time and without justification for direct marketing purposes;
• Withdrawal of your consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before its withdrawal;
• The right to obtain a copy of the data concerning you provided to VATEL, in a structured, commonly used, and machine-readable format, where this right applies in accordance with Article 20 of the GDPR (right to data portability).

You can exercise these rights over your own data by writing to: [name of the Belgian entity – postal address in Belgium] or rgpd@vatel.com, specifying "GDPR" in the subject line. We may ask you for proof of identity if there is reasonable doubt as to your identity.

You also have the right to lodge a complaint with the Data Protection Authority (DPA): Rue de la Presse 35, 1000 Brussels – contact@apd-gba.be – www.dataprotectionauthority.be.

 

12. LANGUAGES

The original version of this policy was drafted in the French language.

Thus, the French version will be considered the official version. In the event of a dispute concerning this policy, the French version will prevail over any translated version, in particular the Dutch or English version.

 

13. CHANGES

We will update this privacy policy regularly. Any changes will be posted on this page with an updated revision date.

 

14. CONTACT

If you have any comments, questions, or requests regarding this policy or the processing of your data, please contact us in writing at: Vatel Bruxelles, Avenue de la Toison d'Or 80, 1060 Saint-Gilles – Belgium or rgpd@vatel.com, specifying "GDPR" in the subject line.