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Last modification : 19/10/2021

Whereas

The purpose of this privacy and cookies policy is to inform visitors of the “Aliénor” website (PC and mobile version) of the processing of their personal data that are being carried out via the Website.

Personal data (“data”) is all information on the basis of which you can be identified or on the basis of which you are identifiable, such as your name, your identification number, your location data, an identifier, one or more elements that may be characteristic of your physical, physiological, genetic, psychic, economic, cultural or social identity.

A “processing” is any operation or set of operations using or not using automated processes (manual) and applied to personal data, from its collection to its erasure.

Article 1 : The controller

  1. The company AliénorEU SPRL with its registered headquarters located at 11 rue de l’industrie B-1000 Brussels Belgium, known at the so-called Belgian Crossroads bank for companies under the number BE0508690863 is responsible for the processings described hereafter. Hereafter “Aliénor”.
  2. Aliénor processes the personal data of the visitors of the websitein accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of data personal data and the free movement of this data which repealed Directive 95/46 / EC (Hereinafter the General Data Protection Regulation or “GDPR”) as well as the belgian law of July 31, 2018 related to the protection of individuals with regard to the processing of their personal data.

Article 2 : Application and communication of data by visitors

  1. By visiting the “Aliénor” Website, “visitors” are presumed to have read and accepted that this privacy and cookies policy is applicable to them for all the processing (of their personal data) described hereafter.
  2. This privacy and cookies policy may be extended or adapted in the future. For example if new developments occur in terms of processings performed or in terms of services offered. For this reason, Aliénor recommends that visitors / users regularly consult this privacy and cookie policy.
  3. Visitors of the websitealso acknowledge that they are responsible for the accuracy of the personal data they communicate via the websiteor by email through a contact request.
  4. If personal data concerning third parties are communicated by visitors via the websiteor when contacting the controller by e-mail, visitors guarantee to Aliénor that they have previously obtained the explicit consents of these third parties. If this is not the case, the concerned visitors / users accept that they are fully responsible for any direct or indirect damage incurred by Aliénor following this (Or these) unauthorized communication(s).
  5. Visitors understand that Aliénor can never be held responsible for the content of third party websites to which the websitesite may refer (via integrated content, for example youtube video), or for the products or services which are possibly offered (on these third party websites). This type of content is solely governed by the privacy and cookie policies of the third party sites concerned.
  6. In case of discrepancies between the linguistic versions of the privacy policy and Aliénor’s cookies, the French language version will prevail.

Article 3 : Data processed, legal bases and purposes of the processing

  1. Via functional cookies
  • Data collected : When you visit the Website, without registration (only via functional cookies): Aliénor may have access with your IP address, search terms and possibly the type of errors encountered.
  • Purpose & Legal basis of the processing : Maintenance and improvement of the websitebased on the legitimate interests of the controller to continuously improve the websiteand its services.
  1. Via analytical cookies
  • Data collected : The IP address of users can be collected in order to produce semi-anonymous statistics.
  • Purpose & Legal basis of the processing : The company Aliénor uses Google analytics statistics to collect anonymous information regarding the use of its services. Aliénor has only access to this data in the form of semi-anonymous statistics.
  • Aliénor always requests the consent of the visitor before implementing analytical cookies via the cookie banner. The use of analytical cookies is also justified by the legitimate interest of the company Aliénor in optimizing the performance of the websiteand fulfilling its social objective.
  • For more information on how Google processes your data we recommend that you consult the Google privacy & cookies policy.
  1. Contact request(s) sent by e-mail to info@alienor.eu
  • Data collected : Last name, first name, email address.
  • Purpose & Legal basis of the processing : In order to allow Aliénor to respond to a request for information initiated by the user or visitor concerned.
  • The data collected meet the legitimate interest of the company Aliénor to answer the requests of its users / potential users (visitors). This processing is also carried out on the basis of the execution of a service initiated by the visitor / user himself.

Article 4 : Duration of data storage

  1. Via functional cookies
    These types of cookies are always deleted at the end of the session.
  2. Via analytical cookies
    Aliénor does not store personal data via this type of cookie, but only access semi-anonymous statistics. The IP addresses of users / visitors are stored by Google for the periods indicated in Google’s privacy & cookies policy and via the following link: https://marketingplatform.google.com/about/analytics/terms/us/.
  3. Contact request(s) sent by e-mail to info@alienor.eu
    The data communicated by a visitor / user during a contact are kept until explicit revocation by the user himself. If no contact is made by the data subject within one year, the data is deleted by Aliénor.

Article 5 : Data transfer

  1. Aliénor may give access to your personal data to its employees who are contractually bound by a confidentiality obligation and are also bound to process your data in accordance with the instructions given by Aliénor.
  2. Aliénor may also in certain cases call on subcontractors (processors) whom are bound by an obligation of confidentiality as well as to provide sufficient security guarantees for the processing and who only process your data in accordance with Aliénor’s instructions.
    If your data is communicated or stored with a subcontractor established in a country which is not a Member State of the European Union, the communication or transfer will only take place if a so-called adequacy decision applies to the country concerned. Aliénor also verifies that sufficient contractual guarantees are provided by the subcontractor as to the security of processing.
  3. In the event of reorganization or the total or partial sale of Aliénor’s activities, or in the event of bankruptcy, Aliénor may transfer the personal data it processes to new entities or new third parties carrying out all or part of the professional activities of Aliénor.
  4. If applicable, Aliénor will make reasonable efforts to inform data subjects before transferring their data to a third party, but data subjects understand that this is not technically or commercially feasible in all situations.
  5. In exceptional cases, Aliénor may be compelled to disclose personal data by virtue of a court order or to comply with imperative regulations or legislation. Aliénor will make reasonable efforts to inform those concerned beforehand, subject to the limits provided by law.
  6. Aliénor does not in any case sell the personal data it processes, nor does it rent databases or make them commercially available to third parties, unless you give Aliénor your prior consent.

Article 6 : Technical and organizational security measures adopted by Aliénor

  1. Aliénor has developed technical and organizational security measures to prevent destruction, loss, falsification, modification, unauthorized access or accidental notification to third parties of your personal data (as well as any other unauthorized processing).
  2. With regard to your use of the Website, visitors/users must at all times follow the security instructions, in particular by preventing unauthorized access to their username and password.
    Visitors / users are solely responsible for the use of the websiteand access to their user account from their computer or on the basis of their IP address and their identification data.
  3. Aliénor can in no way be held liable for any direct or indirect damage arising from the improper or unlawful use of personal data by a third party.

Article 7 : Rights of data subjects

  1. Access, rectification and erasure of your data
  • Visitors / users have the right to request access to their data, rectification of incorrect or incomplete data or subject to legitimate reasons for the deletion of their data (processed by Aliénor).
  • Such erasure of data is not possible if the processing of the data is necessary for the justification of or the defense in the context of a legal action.
  • Visitors / users also recognize that in the event of a request to erase their personal data, certain products and services can no longer be provided to them.
  1. Restriction of the processing
  • Visitors / users have the right to request the restriction of processing, in particular if they dispute the accuracy of the data, if the processing is illegitimate and they oppose the erasure of the data.
  • Visitors / users acknowledge that in the event of refusal to communicate their personal data, (if applicable) certain products and services can no longer be provided to them.
  1. Data Portability
  • Visitors / users have the right to obtain data concerning them (or to ask Aliénor to transmit it to another data controller) in a structured, customary and computer-usable form.
  • Such reception or transmission is not possible if the processing of the data is necessary for the exercise of or defense in the context of a legal action.
  1. Automated decisions and profiling
  • Visitors / users have the right not to be subject to individual decisions based on automated processing if this entails significant legal or personal consequences for them. Visitors / users can also object to profiling.
  • Aliénor does not make any automated decisions or profiling with regards to your personal data. Third-party Websites such as Facebook may possibly create profiles on the basis of data collected via cookies implemented on the Website. In this case, it is up to visitors / users to contact the Websites/social media concerned.
  1. Right to object
  • Visitors / users can object to the processing of their personal data for serious and legitimate reasons. As far as processing is based on their prior consent, Visitors / users have the right to withdraw this consent.
  • Visitors / users also have the right to object to the use of their personal data for direct marketing purposes. Where applicable, visitors / users must not state any reason.
  1. Exercise of your rights
  • Visitors / users can exercise their rights by contacting the controller for this purpose either by email to the email address info@alienor.eu or by postal mail to Aliénor, 11 rue de l’industrie B-1000 Brussels Belgium, or by browsing in the “Contact us” section of the Website.
  • If Aliénor believes that you are not authorized to exercise one or more of these rights on legitimate grounds, or that it needs additional time to respond to the request, Aliénor will notify you in writing within 30 days upon receipt of your request.

Article 8 : Cookies

  1. A “cookie” is a small file sent by Aliénor’s server and installed on your computer’s hard drive. The information it contains may be sent back to our servers or those of the third parties concerned during a subsequent visit.
  2. There are different categories of cookies :
    • Functional cookies are cookies that ensure the proper functioning of all elements of a website. These are cookies for website protection, cookies for load balancing (i.e. distributing requests to a server on a number of computers) and cookies for adaptation the user interface (in particular the choice of language and the display of search results). Aliénor may place these cookies without your consent for this purpose.
    • Non-functional cookies are placed for statistical, social and commercial purposes and do not meet the conditions to be exempt from the consent requirement. Your explicit consent is required for the placement of these cookies:
    • Technical cookies (non-functional) allow Aliénor to keep your user preferences in memory. By placing these types of functional cookies, Aliénor facilitate your visits to the Website. In this way, for example, you should not systematically enter the same information when you visit the Website.
    • Analytical cookies collect general information about how the website is used. Based on this information, we can perform a statistical analysis of the website usage. Based on this analysis, we can make the structure, navigation and content of the website more user-friendly and improve it.
    • Marketing cookies are used to personalize online advertisements. This gives us (and third parties) an overview of the benefits of a campaign. This is done using a profile, in particular drawn up on the basis of your clicks and your navigation on our website.
    • There are also social media cookies. These cookies offer the possibility of including buttons from social networking sites. The buttons work via a code from these sites. These type of buttons are a handy tool for promoting web pages such as “like” and “pins”.
  3. In practice, Aliénor processes on the one hand personal data which is collected and processed through cookies which are strictly necessary for the proper functioning of the website(functional cookies). The processing of the information collected by these cookies is based on Aliénor’s legitimate interest in offering a functional website to visitors / users.
  4. With regard to cookies which are not essential for the proper functioning of the website and which are placed by Aliénor or by a third party, Aliénor always collects the explicit and prior consent of visitors / users (via its “cookies banner”) before their implementation.
  5. If social networking sites or other third parties: (For example, Facebook, Google+, Whatsapp, Instagram, YouTube, LinkedIn, Disqus and Twitter) use the Aliénor website to place cookies in order to collect (your) data, Aliénor has no influence on the use and the way in which they process this data.
  • You can find more information in the privacy statements (policies) of the social networking sites. Please note that these privacy statements may be changed at any time by social networking sites.
  1. Visitors/users may through their Internet browser delete cookies automatically or manually and may also decide whether certain cookies can be placed or not. They can also configure their Internet browser to notify them when a cookie is placed. Visitors/users can find more information on these possibilities in the instructions of their browser’s help function.
  • Warning ! If some cookies are disabled, the website may not work optimally. After deletion in your browser, cookies will be placed (with your permission) again on your next visit to the Website.
  1. The website exclusively allows the following cookies :
    • Functional cookies :
             Name              Category              Duration              Purpose
             osano_consentmanager*              Fonctional cookie implemented by Aliénor              1 year              These cookies are used by Osano to store your cookie preferences on our website.
             wp-settings-1              Fonctional cookie implemented by Aliénor              1 year              WordPress uses this cookie to customize your view of admin interface, and possibly also the main site interface.
  • Non-functional cookies :
             Name              Category              Duration              Purpose
             _gid*, _gat_gtag*, _ga*,              Analytics cookies from Google              1 year              This cookie works via Google Analytics (a statistical analysis tool that allows us to improve your browsing experience on the Aliénor Website. Google Analytics provides Aliénor, among others, the following data about the number of (unique) users of the site, their visitation sessions and how they use the site in the form of semi-anonymous statistics. Then (Google Analytics gives us an in-depth view of this data by a analysis report.)

Article 9 : Contact and complaints

  1. Visitors / users can exercise their rights, by contacting the controller (Aliénor) by sending an email to the address info@alienor.eu or alternatively by sending a postal letter to the address indicated below and attaching it a copy of his identity card: Aliénor, info@alienor.eu.
  • If Aliénor has reasons to believe that the visitor / user is not authorized to exercise one or more of these rights on legitimate grounds, or that it needs additional time to respond to the request, Aliénor will inform you in writing within 30 days of receiving your request.
  1. Visitors may also (in case of violation of their rights) lodge a complaint with the Data Protection Authority.
  • Contact information
    Rue de la presse, 35, 1000, Brusels
    Tel : +32 (0)2 274 48 00
    contact@apd-gba.be
  • According to Article 77 of the GDPR, data subjects who do not live in Belgium but in another Member State of the European Union can also file a complaint with their own data protection authority.
  1. A complaint to the data protection authority does not prejudice the initiation (if any) of proceedings before a civil court (in the event of damage suffered as a result of a violation of the rights of the data subject).
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