Pursuant to Article 13 and 14 of 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 personal data and the free movement of such (in English “GDPR“), any time personal data are processed (e.g. surname, first name, photo, email address, IP address, etc.), the user must be informed thereof.

The privacy policy contains the mandatory information relating to the protection of your users’ personal data. It is thanks to this document that you will be able to supervise, in complete security, the processing of your users’ personal data.

This document is adaptable, and it should be tailored according to your website (website showcase/informational site or e-commerce site) and your processing activities.

It is broken down into two separate and related parts – the first linking to the second. The first part (Appendix 1) is a simplified version of the “privacy policy” in the form of questions and answers, and the second (Appendix 2) is a detailed version.

 

PRIVACY POLICY

EFHCO aisbl

Effective since:  01.01.2020

We make it a matter of pride to respect the privacy of our users and to treat their personal data in the strictest confidentiality and in accordance with the legislation in force.

The privacy policy is intended to inform you, in a transparent manner, about the data we collect, the purpose for collecting it, the way we use, how long we store it, it and the rights you have regarding the processing of such data.

On this page, we provide you with a simplified version of our privacy policy in the form of questions and answers. We invite you to also read the detailed version available here.

We draw your attention to the need to read this privacy policy carefully. If you have any other questions, do not hesitate to contact us at the following address: info@efhco.eu .

1  WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

EFHCO aisbl is the controller of your personal data.

Here is our contact information:

EFHCO aisbl
to the attention of the Data Officer
Drève du Pressoir
1190 Brussels / Belgium
Email: info@efhco.eu  

2  WHAT DATA DO WE COLLECT?

We collect your data – personal or otherwise – for various reasons which are defined in the following point (see point 3). It includes the following data:

  • your identifying information (surname, first name, e-mail address, date of birth and country);
  • our communications (by email or other);
  • the type of domain with which you connect to the Internet;
  • the IP address assigned to you;
  • the date and time of your access to our website;
  • location data or other data relating to the communication;
  • the pages you viewed on our website;
  • the type of browser, platform and/or operating system you are using;
  • the search engine and the keywords used to find the website;
  • your browsing preferences;
  • If applicable: Date of your participation at an event organized by EFHCO aisbl in Europe;
  • any other data that you would communicate to us.

 

3  WHY DO WE COLLECT YOUR DATA?

We collect your data mainly to respond to your inquiry about Healthcare Clowning, to enable you to register and participate to one of our EFHCO events, provide you with our best information about Healthcare Clowning in Europe and, more generally, to develop our associations services and build a better understanding of what our users’ interests are in our topics. Finally, your data also allow us to improve and facilitate your navigation on our website. The legal bases for processing your data are listed in the full version of the Privacy Policy.

4  HOW DO WE COLLECT YOUR DATA?

Most of your data is communicated to us by your active intervention.  Other data, such as the date and time of your access to our website, the pages you have viewed, or your location data, are collected automatically through servers consulted and “cookies” placed on our website. For more information on what a cookie is, how it is used and the exact data it collects, visit our page concerning our cookie policy.

5  IS YOUR DATA PROTECTED?

We take pride in respecting the privacy of our users. We maintain a strict privacy policy and take all appropriate measures to ensure that our servers prevent, to the extent possible, any unauthorized leak, destruction, loss, disclosure, use, access or modification of your data.

6  HOW LONG DO WE STORE YOUR DATA?

We keep your data for the time necessary to accomplish the objectives pursued (see point 3). Once this goal is achieved, we delete them or anonymize them.

7  WHAT ARE YOUR RIGHTS AND HOW CAN THEY BE EXERCISED?

You may, at any time, request to verify, access, rectify, delete, transfer and object to the use of your data, as well as request the limitation of such use of your data. To do so, simply send us an email to info@efhco.eu titled ‘REVIEW MY DATA”.  We will then make every effort to take the necessary action as soon as possible.

8  WHO HAS ACCESS TO YOUR DATA AND TO WHOM IS IT COMMUNICATED?

Our employees and EFHCO aisbl members have access to your data only to the extent necessary for fulfilling the objectives pursued (see point 3). Each of them is subject to a strict obligation of confidentiality. The categories of recipients are listed in the full version of the Privacy Policy.

9  DO WE TRANSFER YOUR DATA ABROAD?

We only transfer your data to a non-EU country if it provides a level of protection equivalent to what you can find in your country of residence.

When sharing information outside EFHCO aisbl and with your direct permission (e.g. non-EU event hosts, third-parties in professional services), we ensure that your data is protected as far as reasonably possible.

10  HOW TO RECEIVE INFORMATION ABOUT US ?

We only use your email address to send you information about EFHCO aisbl and our activities.

With your consent or based on our legitimate interest based on our existing relationship, we will subscribe you to our newsletter and provide you with information that may interest you. You can unsubscribe and withdraw your consent to these communications at any time by sending an email to info@efhco.eu .

11 WHAT IS OUR POLICY ON DATA CONCERNING MINORS?

Our website is not targeted to children under the age of 18. If you learn that your minor child has provided us with their personal data without your consent, contact us at the following address: info@efhco.eu .

12  WHAT HAPPENS IN THE EVENT OF A CHANGE TO THE PRIVACY POLICY?

If we had to make any changes to this privacy policy, you would be notified through our website.

13  WHAT TO DO IN THE EVENT OF A DISPUTE?

Lengthy trials do not benefit anyone. In the event of a dispute between us, we commit to give priority to dialogue and openness in search of an amicable solution. You can also contact the Data Protection Authority.

_____________________________________________________

PRIVACY POLICY EFHCO aisbl

Effective since: 01.01.2020

1  GENERAL WARNING

1.1         EFHCO aisbl (hereinafter, « EFHCO aisbl») respects the privacy of its users (hereinafter, the “Users“).

1.2         EFHCO aisbl 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“).

1.3         Access to the website www.invest-in-usa.org (hereinafter, the “Website”) implies the User’s full understanding of this Privacy Policy (hereinafter the “Policy”) as well as the acceptance of the cookie policy (hereinafter, the “Cookie Policy”) and the general terms of use (hereinafter the “Terms”).

1.4         The User acknowledges having read the information below and authorizes EFHCO aisbl to process, in accordance with the provisions of the Policy, the personal data that he/she communicates on the Website EFHCO aisbl on its Website (hereinafter, the “Service“).

1.5         The Policy is valid for all pages hosted on the Website and for the registrations of this Website. It is not valid for the pages hosted by third parties to which EFHCO aisbl may refer and whose privacy policies may differ. EFHCO aisbl cannot therefore be held responsible for any data processed on these websites or by them.

 

2  DATA CONTROLLER AND DATA PROTECTION OFFICER

2.1         Simply visiting the Website shall take place without requiring you to manually provide any personal data, such as first name, surname, postal address, e-mail address, etc.

2.2         As part of the Service, the User may be required to provide certain personal data. In this case, the data controller is:

EFHCO aisbl
to the attention of the Data Officer
Drève du Pressoir
1190 Brussels
Belgium
Email: info@efhco.eu  

2.3         Any question regarding the processing of this data may be sent to the following address: info@efhco.eu .


3  DATA COLLECTED

3.1         By using the Website, the User understands that EFHCO aisbl records and stores, for the purposes mentioned in point 4, the following information:

  • identifying data, such as the first name and surname, e-mail address, date of birth and country;
  • Date and reason of your inquiry and date of our 1st reply
  • communications between the User and EFHCO aisbl;
  • If applicable: Date of your participation at an event in Europe;
  • The User also acknowledges that EFHCO aisbl records and stores the following data for the purposes mentioned in point 4:
  • information voluntarily provided by the User for a purpose specified in the Policy, the Terms, the Cookie Policy, on the Website or on any other instrument of communication used by EFHCO aisbl
  • additional information requested by EFHCO aisbl to the User in order to identify him or to prevent him from violating any of the provisions of the Policy.

3.3         In order to facilitate browsing the Website as well as to optimize technical management, the Website may use “cookies”. These “cookies” record, in particular:

  • the User’s browsing preferences;
  • the date and time of access to the Website and other data related to traffic;
  • the pages visited;
  • the users country, approximate age and gender breakdown;
  • the type of computer or device used.

All information relating to “cookies” is included in EFHCO aisbl Cookie Policy.

3.4         When the User accesses the Website, the servers consulted automatically record certain data, such as:

  • the type of domain with which the User connects to the Internet;
  • the IP address assigned to the User (when connected);
  • the date and time of access to the Website and other data related to traffic;
  • location data or other data relating to the communication;
  • the pages visited;
  • the type of browser used;
  • the platform and/or operating system used;
  • the search engine as well as the keywords used to find the Website.

3.5         No nominative data directly identifying the User is collected through the cookies and servers consulted. This information is kept for statistical purposes only and to improve the Website.

 

4  PURPOSES OF PROCESSING THE DATA

4.1         We process your data for various purposes. For each purpose, only the data relevant to the pursuit of the purpose in question are processed. The processing consists of any operation (manual or automated) on a personal data. EFHCO aisbl collects, stores and uses its Users’ data for the following purposes, in particular:

  • to establish, carry out and conduct the contractual relationship with the User;
  • to analyse, adapt and improve the content of the Website;
  • to provide the best ‘Healthcare Clowning in Europe’ information;
  • to respond to the User’s inquiry about EFHCO’s topics;
  • to develop our business and build a better understanding of what our Users’ interests are in ‘Healthcare Clowning’
  • to enable you to register and participate to one of EFHCO’s events,
  • to allow the User to receive messages;
  • to facilitate the availability and use of the Website; 
  • to personalize the User’s experience on the Website;
  • to respond to requests for information;
  • for any communication activities and promotions of EFHCO aisbl activities to Users who have given their consent;
  • to inform them about any changes on the Website and its features;
  • for any other purpose to which the User has expressly consented.

4.2         The legal basis of the processing of your personal data is based on:

– ☒your consent to the reception of direct communications;

– ☒the execution of any request from you;

We do need to collect some of your data to answer any request from you. If you choose not to share this data with us, it may render the performance of the contract impossible.

– ☐ a legal obligation imposed on the controller;

We do need to collect and store some of your data to meet various legal requirements, including tax and accounting.

– ☐ the protection of vital interests;

– ☐ for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or

– ☒ our legitimate interest, provided that it is in accordance with your interests, freedoms and fundamental rights.

We have a legitimate interest in providing you with this information and interacting with you, especially to respond to your requests or improve our services, prevent abuse and fraud, control the regularity of our operations, exercise, defend and preserve our rights, for example in litigation, as well as evidence of a possible violation of our rights, manage and improve our relations with you, continually improve our website and our products/services, unless such interests are supplanted by your interests or your fundamental rights and freedoms requiring the protection of your personal data. We take care in any case to maintain a proportionate balance between our legitimate interest and respect for your privacy.

If the legal basis of our treatment is your consent, you have the right to withdraw it at any time without prejudice to the lawfulness of the processing performed prior to withdrawal.

When you receive information in the context of direct communications, this means that you can unsubscribe at any time from commercial communications from us (e.g. invitations to EFHCO aisbl events). You will be put in “opt-out”. You can unsubscribe by sending us an email to info@efhco.eu . Please note that it may take up to 5 working days to process your opt out request.

 

5  RIGHTS OF THE DATA SUBJECT

5.1         According to the regulations on the processing of personal data, the User has the following rights:

  • Right to be informed about the purposes of the processing (see above) and the identity of the data controller.
  • Right of access: the User may at any time have access to the data that EFHCO aisbl has on him or check if it is included in the database of EFHCO aisbl
  • Right to rectification: we take all reasonable steps to ensure that the data we hold is up to date. We encourage you from time to time to access your account (if applicable) or to consult us to check that your data is up to date. If you find that your data is inaccurate or incomplete, you have the right to ask us to correct it.
  • Right to object: the User may, at any time, object to the use of his data by EFHCO aisbl and by other EFHCO members.
  • Right to erasure: the user may, at any time request the deletion of his personal data, except those which EFHCO aisbl has a legal obligation to keep on record.
  • Right of limitation of processing: the User may, in particular, obtain a limitation of processing when he has objected to the processing, when he disputes the accuracy of the data, or when he considers that the processing is illegal.
  • Right of portability: The User has the right to receive the personal data that he has communicated to EFHCO aisbl and may also ask said company to send this data to another data controller.

5.2         In order to exercise his rights, the User sends a written request, accompanied by a copy of his

identity card or his passport, to the data controller by e-mail to info@efhco.eu 

5.3         EFHCO aisbl will then take the necessary steps to satisfy this request as soon as possible and in any case within one month of receipt of the application. If necessary, this period can be extended by two months, given the complexity and the number of requests.

6  PERIODE OF STORAGE

6.1         EFHCO aisbl will keep the personal data of its Users for the duration necessary to achieve the objectives pursued (see point 4).

6.2         EFHCO aisbl may also continue to keep personal data concerning the User, including all correspondence or request for assistance sent to EFHCO aisbl in order to be in a position to reply to all questions or complaints that may be sent to it or after an event organized by EFHCO aisbl, and in order to comply with all applicable laws, namely in tax matters or as part of other legal requirements. Once this goal is achieved, we either delete or anonymize the data.

7  COMPLAINT WITH THE SUPERVISORY AUTHORITY

The User is informed that he has the right to lodge a complaint with the Data Protection Authority: https://www.dataprotectionauthority.be/citizen 

8  SECURITY

8.1         In addition, EFHCO aisbl has taken the appropriate organizational and technical measures to ensure a level of security adapted to the risk and that, to the extent possible, the servers hosting the personal data processed prevent:

  • unauthorized access to or modification of this data;
  • improper use or disclosure of such data;
  • unlawful destruction or accidental loss of such data.

8.2         In this respect, employees of EFHCO aisbl and EFHCO aisbl members who have access to this data are subject to a strict confidentiality obligation. Nevertheless, EFHCO aisbl may in no way be held liable in the event that this data is stolen or hijacked by a third party despite the security measures adopted.

8.3         Users undertake not to commit acts that may be contrary to this Policy, the Terms, the Cookie Policy or, in general, the law. Violations of confidentiality, integrity and availability of information systems and data which are stored, processed or transmitted by these systems, or the attempt to commit one of these violations, shall be punishable by imprisonment of between three months and five years and a fine of between twenty-six euros and two hundred thousand euros, or one of these penalties only.

9  COMMUNICATION TO THIRD PARTIES

9.1         EFHCO aisbl 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 in point 4, or under the conditions in which the law requires it to do so.

9.2.        Upon your approval and if deemed applicable, we share your personal information with EFHCO aisbl members (you have the choice to identify which one/s), all of which provide the same high level of security and protection.  When sharing information outside EFHCO aisbl and with your permission, we make sure that your information is protected as far as reasonably possible.

9.3         EFHCO aisbl may communicate its Users’ personal information to third parties to the extent that such information is necessary for providing its Users with the Website or answer Users requests. In such case, these third parties will not communicate this information to other third parties, except in one of the two following situations:

  • the communication of this information by such third parties to their suppliers or subcontractors to the extent necessary for the performance of the contract;
  • where such third parties are obliged by the regulations in force to communicate certain information or documents to the competent authorities in the field of combating money laundering, as well as, in general, to any competent public authority.

9.4         The communication of this information to the aforementioned persons shall, in all circumstances, be limited to what is strictly necessary or required by the applicable regulations.

9.5         We do not sell any data.


10 TRANSFER TO A COUNTRY OUTSIDE OF THE EUROPEAN ECONOMIC AREA

10.1       EFHCO aisbl transfers data to a country outside the European Economic Area only when that country ensures an adequate level of protection within the meaning of the legislation in force and, in particular, within the meaning of the General Data Protection Regulation (for more information on the countries offering an adequate level of protection, check EU Data Protection law), or within the limits permitted by the legislation in force, for example by ensuring the protection of data by appropriate contractual provisions.

10.2       In case of such a necessary data transfer by EFHCO aisbl, those are based on your consent. We use standard contractual clauses approved by the European Commission and we rely on the European Commission’s adequacy decisions concerning certain countries, where appropriate, for data transfers from the European Economic Area to the United States. If you have any questions in this regard, do not hesitate to contact us at the following address: info@efhco.eu .

 

11  DIRECT COMMUNICATION

11.1       The personal data will not be used for direct communication purposes for articles or services that would not be identical or similar to those to which the User has already subscribed, unless the User has previously explicitly consented to such use by ticking the boxes provided for this purpose (“opt-in”).

11.2       When the User has given his consent to the use of this information for direct communication purposes, the User retains the right to object to such use at any time, upon request and free of charge. The User may simply communicate his request by writing to the following address: info@efhco.eu .

12  NOTE CONCERNING MINORS

Persons under the age of 18 and persons who do not have full legal capacity are not allowed to use the Website. EFHCO aisbl asks them not to provide their personal data. Any infringement found in this provision must be reported without delay to the following address: info@efhco.eu .

13  UPDATES AND CHANGES TO THE POLICY

By informing Users through the Website or email, EFHCO aisbl 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), the recommendations of the Belgian Data Protection Authority, 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 by EFHCO aisbl 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 all the Policy. Any fully or partially invalid, lapsed or unenforceable provision shall be deemed not to have been written. EFHCO aisbl 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 EFHCO aisbl 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.

 

INFORMATION FOR EFHCO aisbl:

Pursuant to Article 129 of the Law of 13 June 2005 on electronic communications, each user must be informed about the use of cookies and their consent must be obtained before placing them.

The cookie policy contains information about the use of cookies by the website. This document contains information on what a cookie is, the type of cookie(s) used, the purposes of such use and the management of cookies.

It is recommended to separate your cookie policy from your privacy policy.

In addition, we strongly recommend that you make the “cookie policy” accessible in the header or footer on all pages of the website.

 

COOKIE POLICY

EFHCO aisbl

Effective since: 01.01.2020

This policy relating to cookies (hereinafter, the “Cookie Policy“) describes the different types of cookies that we use on our www.efhco.eu website (hereinafter, the “Website“) and the manner in which you can configure these cookies.

We maintain a strict privacy policy and we are committed to being transparent about the technologies that are used on our Website.

Insofar as the information collected using cookies constitutes personal data, the provisions of the Privacy Policy shall apply and supplement this Cookie Policy.

 

1  WHAT IS A COOKIE?

A “cookie” is a small text file containing information saved by a website on a computer or by a mobile application on a user’s smartphone.

Cookies offer the possibility to identify you and to memorize various information in order to facilitate your navigation on a website/a mobile application, to ensure the smooth functioning of these or to make them more effective, for example by memorizing your language preferences.

2  WHAT COOKIES ARE USED ON OUR WEBSITE AND WHY?

We use different types of cookies for different reasons.

COOKIE PURPOSE

ESSENTIAL COOKIES

(STRICTLY NECESSARY)

These cookies are essential for browsing our Website or strictly necessary for the provision of a service specifically requested by a user.

The removal of this type of cookies can lead to navigation difficulties and is therefore strongly discouraged.

PREFERENCE COOKIES

 

(PERFORMANCE)

These cookies collect information about your choices and preferences and make your navigation more pleasant and personalized.

These cookies make it possible to memorize the language chosen during your first visit to our Website in order to personalize it accordingly.

 ANALYTICS COOKIES

 

(STATISTICS)

These cookies are used to gather information about your use of the Website, in order to improve the content of the Website, make it more suitable to your needs and increase its usability.

For example, these cookies show us the most visited pages of the Website or help to identify difficulties that may be encountered during navigation.

THIRD-PARTY / SHARING COOKIES

(SOCIAL NETWORKS)

These cookies allow you to share the content of the Website with other people via social networks. Some sharing buttons are integrated via third-party applications that can issue this type of cookies. This is particularly the case with the buttons [“Facebook”, “Twitter”, “Google +” and “Pinterest”].

Social networks providing such a sharing button are likely to identify you with this button, even if you did not use this button when visiting our Website. We invite you to consult the privacy policy of these social networks, by visiting their respective websites, to learn the purpose of using the information collected through these sharing buttons.
THIRD-PARTY / ADVERTISING COOKIES These cookies are used for marketing purposes, in particular to display targeted advertising, conduct market research and evaluate the effectiveness of an advertising campaign.

3  HOW TO CONFIGURE THE COOKIES?

You can easily delete, disable or accept cookies from our Website at any time by configuring your browser settings.

Each browser (Internet Explorer, Safari, Firefox, Google Chrome, etc.) has its own cookie configuration mode. To learn about the procedure to follow concerning your navigator, visit the site: http://www.allaboutcookies.org/manage-cookies/.

If you wish to refuse these commercial cookies (among others Google, Criteo or Facebook), you can do it using the following website: http://www.youronlinechoices.com.

If you use different computers, smartphones and/or tablets, do not forget to configure each device so that each of them corresponds to your preferences regarding cookies.

You can change your cookie preferences at any time here:

 

4  WILL OUR WEBSITE STILL WORK WITHOUT COOKIES?

You will still be able to view our Website, but some interactions may not work normally.

For example, we have a cookie that saves your language preference. If you disable this cookie, the selected products will disappear with each new login session.

 

5  OTHER QUESTIONS?

If you have other questions, contact us:

  • by writing to the following postal address:

 EFHCO aisbl
to the attention of the Data Officer
Drève du Pressoir
1190 Brussels / Belgium
Email: info@efhco.eu  

[1] A cookie is a file that contains information saved by your website on the consumer’s computer and allows you to recognize the consumer and his preferences during a subsequent visit.