A complaint before the data protection authority is without prejudice to the institution (if applicable) of proceedings before a court in the manner provided by law.
Confidentiality and privacy policy
Last modification: 04/21/2024.
ARTICLE 1: DEFINITIONS
“Personal data” means: any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); is deemed to be an “identifiable natural person” a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to their physical, physiological, genetic, psychological, economic, cultural or social identity;
“Processing” means: any operation or set of operations, whether or not carried out using automated processes and applied to personal data or sets of data, such as collection, recording, organization, structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection , limitation, erasure or destruction;
“Controller” means: the natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of the processing; where the purposes and means of such processing are determined by Union law or the law of a Member State, the controller may be designated or the specific criteria applicable to its designation may be provided for by the law of the processing party. Union or by the law of a Member State;
“Processor” means: the natural or legal person, public authority, service or other body which processes personal data on behalf of the controller.
ARTICLE 2: CONTROLLER
“VICITRA” refers to the limited liability company whose head office is located at 1050 Ixelles, rue de Washington 107 and which is registered in the Register of the Banque Carrefour des Entreprises under number BE 0701.673.749 which is responsible for processing your personal data with regard to the processing described below.
VICITRA is concerned about the protection of your personal data and undertakes to process your personal data in accordance with this privacy policy in compliance with the legal provisions applicable to the protection of personal data, including the General Regulation 2016/679 relating to data protection (hereinafter the “GDPR”) as well as the national provisions which supplement it.
VICITRA may at any time, for various reasons, make corrections, additions or modifications to this privacy policy. The most current version can always be consulted on our websites. The last modification date is always indicated before the preamble.
ARTICLE 3: WHEN IS YOUR DATA COLLECTED BY VICITRA?
This privacy policy applies to the processing of your personal data carried out by VICITRA in its capacity as data controller when you visit or place an order on our site www.vicitra.us (hereinafter “the Website” ) or if you participate in one of VICITRA's discussion groups on Telegram.
Attention ! When you visit the Telegram platform or any other third party site, this privacy policy only applies to the extent that VICITRA determines the processing of your personal data.
The privacy policies of our service providers are available online on their respective websites. Here you will find external links which will redirect you to their dedicated platforms:
– https://stripe.com/fr/privacy#Presentation
– https://mailchimp.com/fr/gdpr/
– https://telegram.org/privacy
ARTICLE 4: WHAT CATEGORIES OF PERSONAL DATA PROCESSED BY VICITRA AND WHEN ARE THEY COLLECTED?
The following categories of personal data may be processed by VICITRA when you visit our Website (via cookies) or when you engage in the ordering process on our Website and where applicable if you participate in our group Telegram chat or subscribe to our newsletter:
• Your IP address and browsing behaviors may be collected by cookies placed on our Website.
• Your identification data: name, first name, private address, email address, telephone number.
• Banking data and data relating to orders: account number, billing address delivery address, means of payment when you place an order, order history.
• Your communications addressed to VICITRA;
• Your publications in our discussion group on Telegram;
• In certain cases, your photos and videos (for example: with your authorization to illustrate written testimonies, as part of interviews or if photos and videos are taken during a face-to-face training course);
ARTICLE 5: WHAT ARE THE PURPOSES OF THE PROCESSING?
VICITRA processes your personal data to meet the following purposes:
• In order to be able to carry out the services you have ordered via our Website;
• In order to be able to respond to your request for membership in our Affiliation program and then in order to be able to fulfill and execute the conditions thereof towards our Affiliates;
• In order to be able to answer your questions relating to our activities or our services;
• In order to guarantee the proper functioning of our Website;
• To promote our activities;
• In order to be able to offer you targeted content that better meets your expectations;
• In order to meet our legal obligations, particularly in matters of accounting or taxes;
• In order to be able to defend ourselves in court if our liability were to be incurred;
ARTICLE 6: WHAT ARE THE LEGAL BASES FOR PROCESSING?
Depending on the purpose pursued for each processing, we process your data based on the following legal bases:
• Based on our contractual or pre-contractual obligations towards you;
• Based on our legitimate interest;
• In order to comply with our legal obligations. (The same goes for our accounting or tax obligations.)
• Based on your prior, free, specific and explicit consent. (For example for our newsletter or for sending free videos);
• Based on the applicable provisions of the “E-privacy” directive (directive 2002/58/EC) transposed into national law combined with one of the aforementioned legality bases of the GDPR (example: placement of non-functional cookies with your consent or sending of information relating to services similar to those you ordered if you do not object).
ARTICLE 7: WHO DOES VICITRA SHARE YOUR DATA WITH?
VICITRA may have to transmit the personal data collected to the authorities or entities established by law, decree or any regulatory provision that is applicable.
VICITRA may also share certain data with its co-contractors, qualified as "subcontractors" within the meaning of the legislation, to the extent strictly necessary for the operation of computerized or non-computerized applications or management systems to which VICITRA has subscribed in particular in order to be able to provide you with offer a high-performance Site and online services.
The list of subcontractors, their field of activity, the purpose pursued and, where applicable, the country in which the data is processed and hosted are available on request.
Transfers of personal data to a country which is not part of the Union will only be authorized by VICITRA if and only if:
– The European Commission has issued an adequacy decision granting an adequate level of protection equivalent to that provided for by European legislation. Personal data will then be transferred on this basis.
– The transfer is covered by an adequate measure granting a level of protection equivalent to that provided for by European legislation, such as binding company rules, standard Commission clauses, a code of conduct allowing transfers previously accepted by the subcontractors concerned or on the basis of an exemption provided for in Article 49 of the GDPR or another appropriate measure set out in Article 46 of the GDPR.
If VICITRA relies on one of the above-mentioned adequate measures, VICITRA will also have previously carried out a risk analysis of the envisaged transfer and will, if necessary, have taken additional measures to limit any risk that the authorities of the importing country could compromise the safety and security. confidentiality of this data under applicable law.
ARTICLE 8: HOW LONG DOES VICITRA KEEP YOUR DATA?
The personal data that VICITRA must process in the context of placing an order are kept by VICITRA for the period necessary for the execution of the order and then the necessary data will still be kept by VICITRA for a maximum period of 10 years after the end of this order in order to allow us to meet our legal obligations (for example: accounting and tax) and possibly defend ourselves in court if our liability were to be incurred.
The data of prospects (persons who have expressed an interest in our activities or who have engaged in an ordering process without having placed an order) are kept for a period of 1 year after their last contact.
Whether you are a customer or a prospect, your email address may be processed by VICITRA for a longer period (within the limits of what is reasonable) for sending emails concerning similar services or as part of our newsletter as well. that you have not expressed your opposition to the processing or withdrawn your consent (via the unsubscribe link provided in each mailing).
The photos and videos for which you have granted authorization for use to VICITRA are kept as long as you do not revoke this authorization and in any case for a reasonable period.
ARTICLE 9: TECHNICAL AND ORGANIZATIONAL SECURITY MEASURES
VICITRA has adopted security measures adapted on a technical and organizational level, in order to avoid the destruction, loss, falsification, modification, unauthorized access or accidental notification to third parties of your personal data ( as well as any other unauthorized processing). The list of these measures is available on request.
ARTICLE 10: WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE THEM?
Unless a legal provision in force in Belgium does not allow it, including the GDPR, you have the following rights:
Access, rectification and erasure of your data: You have the right (at reasonable intervals) to request from VICITRA access to your data processed by it, the rectification of incorrect or incomplete data or subject to a legitimate reason (provided for in article 17.1 of the GDPR) the erasure of your data.
Limitation of the processing of your data: In certain cases (provided for in article 18.1 of the GDPR) you have the right to request the limitation of processing, in particular if you contest the accuracy of the data, if the processing is illegitimate yes if you object to the erasure of data.
Opposition to the processing of your data: if your data is processed on the basis of our legitimate interests, you can inform us of your opposition to this processing by providing specific reasons (article 21 of the GDPR). If the purpose of the processing is marketing or prospecting, in this case you can object at any time without particular justification).
Withdrawal of your consent: for personal data processed on the basis of your consent, you can inform VICITRA at any time that you wish to withdraw your consent. VICITRA will then take the necessary measures within a reasonable time to delete this data.
Data portability and transfer: If your data is processed by VICITRA as part of the execution of its contractual obligations or on the basis of your consent (article 20 GDPR), you have the right to obtain the data that concerns you (or depending on the legal basis of the processing, ask VICITRA to transmit them to another data controller) in a structured, usual and computer-usable form.
Exercise of your rights: You can exercise your rights or send us any request related to the processing of your personal data by contacting us either by email at privacy@vicitra.yoga or by post addressed to VICITRA SRL , Rue de Washington, 107, 1050 Ixelles.
It is important that you also communicate to us in your request your identity and, if applicable, your customer number.
If VICITRA is in doubt about your identity, it reserves the right to ask you for a front copy of your identity card which will be processed by VICITRA for identification purposes only and destroyed/deleted immediately thereafter.
VICITRA will inform you of the outcome of your request within one month after receipt of the request (if the request requires more time to be able to respond, VICITRA will let you know within one month and will make use of the additional period of two months provided for this purpose by the GDPR.)
ARTICLE 11: COOKIES
VICITRA may in certain cases place “cookies” on your server via its website: www.vicitra.us (hereinafter “the Website”) when you visit it or when you place an order. A cookie is a code in the form of a file stored on your computer. During a subsequent visit to the site, these cookies can then be recognized.
VICITRA's cookie policy containing all the cookies present on our site is available in its entirety via the following link: https://www.vicitra.yoga/politique-de-cookies-ue/
Regarding the use of cookies which are not essential for the proper functioning of the Site (non-functional cookies) and which would be placed by VICITRA, we always obtain your specific, explicit, free and prior consent via our “cookie banner” which appears during each visit before implementing them.
If social media sites or other third parties: (For example, Facebook, Google+, WhatsApp, Instagram, YouTube, LinkedIn and Twitter) were to use our Website to place cookies to collect (your) data, you understand that VICITRA will not has no influence on the use and manner in which these third parties process this data. You will find further information on this subject in the Privacy policies of the third parties concerned.
Please note that through your Internet browser you can also delete/block cookies automatically or manually and you can decide whether or not certain types of cookies can be placed on your server. You can also configure your Internet browser to notify you when a cookie is placed.
ARTICLE 12: COMPLAINTS
If you believe that your rights have been violated you can always send a Complaint to the Data Protection Authority:
www.autoriteprotectiondonnees.be
Rue de la Presse, 35, 1000 Brussels
Tel.: +32 (0)2 274 48 00
Fax: +32 (0)2 274 48 35
E-mail : contact@apd-gba.be
Éric Laudière is a practitioner and trainer in the field of psychogenealogy and family constellations.
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