VIVEL VZW – PRIVACY STATEMENT VIVEL LEER- EN SHARING PLATFORM

Date of last modification: 15/12/2022

1. Introduction

The Flemish Institute for Primary Care, with registered office at Rue de Laeken 76 1000 Brussels, company number 0720.947.550 (hereinafter referred to as "VIVEL", "we" or "us") undertakes, as a data controller, to comply with the applicable legislation on the protection of personal data, including but not limited to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of personal data natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC ("GDPR"), as well as any applicable national legislation implementing it ("Applicable Privacy Laws").

In this privacy statement (hereinafter referred to as the "Privacy Statement") we explain how VIVEL processes personal data in the context of the collaboration, the platform of the VIVEL Academy (hereinafter referred to as "VIVEL Academy") and the sharing platform that VIVEL makes available. It also sets out your rights and how you can exercise them.

If you still have questions after reading this Privacy Statement, you can contact us via [email protected].

For the purposes of this Privacy Statement, terms such as "personal data", "processing", "processor" and "controller" shall have the meanings ascribed to them in the Applicable Privacy Legislation.

Our websites sometimes contain links to third-party sites. The use of your personal data by these third parties is not covered by this Privacy Statement; Please read the third party's privacy statement carefully to learn more about their use and protection of your personal data.

2. Overview of the processing of personal data by VIVEL

Below we provide an overview of the types of personal data we process, the purposes for which we process it and the applicable legal basis.

2.1. Personal data

In the context of VIVEL Academy, VIVEL collects the following personal data from Users:

  • Identification and contact details (name, telephone number, (e-mail) address, etc.);
  • Professional data (first-line zone, profession, place of employment, etc.);
  • Data relating to courses taken (participation, learning statistics, etc.)
  • Personal data via the contact form on the website www.vivelacademie.be
  • Personal data collected through functional and analytical cookies.

In the context of the sharing platform, which includes hosting an environment in Microsoft, Yammer, Teams, SharePoint, OneDrive and other Microsoft tools for storing documents and creating channels, VIVEL processes the following data regarding the use of the platform: 

  • Date, time and location; 
  • Affected application;
  • IP address; 
  • Form of authentication. 

2.2. Purposes and legal basis

We collect and process the above-mentioned personal data of Users for the following purposes:

  • The management and organisation of VIVEL Academy and the sharing platform: these processing operations are carried out on the basis of our legitimate interest.
  • Informing members by means of newsletters about the activities of VIVEL and VIVEL Academy: this processing is done on the basis of consent. 
  • The follow-up of training courses and activities followed and the issuing of certificates: these processing operations are carried out on the basis of the necessity for the execution of the agreement;
  • Monitoring trends and analysis results with regard to training courses: these processing operations are carried out on the basis of our legitimate interest;
  • Sharing the generic e-mail addresses of the 60 care councils via Excel on the website wordpress-386464-4302613.cloudwaysapps.com. This processing is carried out on the basis of consent.  
  • In accordance with the applicable legislation, we process the personal data collected through the use of cookies in this context, either on the basis of your prior consent (i.e. for non-strictly necessary/functional cookies) or on the basis of our legitimate interest (i.e. for strictly necessary/functional cookies). For more information about our use of cookies, please read our Cookie Statement.

Please note that where the processing of personal data is a legal or contractual requirement, the refusal or inability to provide this personal data may prevent us from participating in VIVEL Academy and/or the Sharing Platform.

3. Who do we share your personal data with? 

When you register as a participant of VIVEL Academy or the VIVEL sharing platform, we will share your personal data with third parties who provide services to us with a view to VIVEL's provision of the Academy and the sharing platform. This includes the following categories of third parties:

  • Third parties that maintain VIVEL Academy or the Sharing Platform;
  • Third parties who are responsible for the analysis of personal data in order to improve VIVEL Academie and the sharing platform;
  • Third parties who are responsible for the follow-up of attendance;
  • External trainers and trainers of VIVEL Academie with whom we share your personal data in the performance of their assignment. We agree with them that this personal data cannot be used for commercial purposes.

VIVEL enters into processing agreements with these third parties in accordance with the Applicable Privacy Legislation, so that we can guarantee that they also take the necessary measures to guarantee the protection of your personal data.

4. International Transfers

In the event that we transfer your personal data to a third country or international organisation (i.e. outside the EEA), we will ensure that your personal data is in principle only transferred to third countries that are deemed by the European Commission to provide an "adequate" level of protection (a list of adequate countries is available on the European Commission's website), or if your personal data is not transferred to a country that provides an adequate level of protection, we will put in place appropriate safeguards with the entity receiving your personal data (for example, the EU Standard Contractual Clauses or Binding Corporate Rules) to ensure that your personal data remains protected in accordance with the Applicable Privacy Laws.

If you would like to receive more information or a copy of these safeguards, please contact us at the following email address: [email protected].

5. How long do we keep your personal data? 

In accordance with the Applicable Privacy Legislation, your personal data will be retained for as long as we have a legitimate business need to process it, for example, for certain personal data, a maximum retention period of 10 years after enrolment in VIVEL Academie or for a reasonable period of time in accordance with our legitimate interests for retention. When we no longer have a legitimate business need to process your personal data, we will anonymise or delete it, or if this is not possible, we will securely store your personal data and isolate it from further processing until deletion is possible. If we wish to keep your data for a longer period of time, we will ask for your explicit permission to do so.

For more information about the retention periods that apply to the processing of your personal data, please contact us using the contact details in Section 9 below.

6. How do we protect your personal data?

VIVEL makes every effort to protect your personal data at all times. Various functions within VIVEL oversee compliance with the Applicable Privacy Legislation and the security of your personal data, our infrastructure and systems.

Moreover, the number of employees within vzw VIVEL who have access to your data is limited and carefully selected. These employees are bound by strict confidentiality obligations and are trained to handle your personal data correctly. Moreover, these employees will only be granted access to your personal data insofar as they need it to properly perform their tasks within the framework of VIVEL Academy or VIVEL's sharing platform.

7. Your rights and how to exercise them 

To the extent applicable and in accordance with the Applicable Privacy Legislation, you can exercise the following rights with regard to the processing of your personal data by VIVEL in the context of VIVEL Academy and the sharing platform:

  • You can request access to and obtain a copy of any personal data we have processed about you;
  • You can also request that any personal data that is inaccurate or incomplete be corrected or completed;
  • You can ask for your personal data to be erased;
  • You can object to the processing of your personal data, ask us to restrict the processing of your personal data, or request portability of your personal data.
  • You can also object to the processing of your personal data for direct marketing purposes free of charge by contacting VIVEL at the email address below (Section 9) or by using the unsubscribe link in any direct marketing communication.
  • If we collect and process your personal data with your consent, you can withdraw your consent at any time. However, the withdrawal of your consent will not affect the lawfulness of any processing based on your consent before the withdrawal.
  • You have the right to lodge a complaint with a supervisory authority.

You can exercise these rights by sending an e-mail to the following address [email protected]. We will handle your request in accordance with the Applicable Privacy Laws.

8. Modifications

We may update this Privacy Statement from time to time to comply with business, legal, or technical developments. The date of last modification can always be found at the top of this Privacy Statement. When we update our Privacy Notice, we will take appropriate steps to inform you, depending on the significance of the changes and the legal requirements in this regard.

Contact

If you have any questions about this Privacy Notice, for complaints, or to exercise your rights, please contact us at [email protected].

You can contact our Data Protection Officer (DPO) via the same e-mail address.