We understand that your trust in us, is JA Europe’s most important asset (hereinafter referred to as "JA Europe", "we" or "us"). As such, your privacy is essential for us.
This privacy statement (hereinafter referred to as the "Privacy Statement") is applicable, inter alia, to (i) our website http://entrepreneurialskillspass.eu/ (hereinafter referred to as the "Website") and (ii) all relations between JA Europe and its visitors of the Website. This privacy Statement is effective from 9 August 2019.
This Privacy Statement includes information about the personal data collected by JA Europe, as well as the manner in which JA Europe uses and processes this personal data.
JA Europe wishes to emphasize that it always attempts to act in accordance with (i) the Belgian Privacy Law of 30 July 2018 concerning the protection of individuals with regards to the processing of personal data, (ii) the EU Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC and/or (iii) all (future) Belgian laws regarding the implementation of this Regulation (hereinafter referred to as the “Privacy Legislation”).
Visiting the Website implies your explicit approval (through disclosure of your personal information and/or opt-in) of the Privacy Statement and consequently how we collect, use and process your personal data.
Please read this Privacy Statement in conjunction with JA Europe’s Legal Disclaimer.
I. Types of personal data
JA Europe can collect and process the following personal data (non-limitative):
- E-mail address
- Company name
- Telephone number (landline and/or mobile phone)
- Other personal data voluntarily provided to JA Europe (e.g. through completing the contact form)
JA Europe also automatically collects anonymous information regarding your use of the Website. As such, JA Europe shall, for example, automatically log which sections of the Website you visit, which web browser you use and which website you were visiting prior to obtaining access to the Website. We cannot identify you through these data, but it allows JA Europe to draw up statistics regarding the use of the Website.
II. Sensitive Information
JA Europe does not seek any sensitive information from our visitors to the Website, unless legally required to do so. Sensitive information includes a number of types of personal data relating to: race or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual life or criminal record, or genetic or biometric data. We suggest that you do not provide sensitive information of this nature. However, if you do provide such information, JA Europe accepts your explicit consent to use these personal data, as requested by us and disclosed by you, as described in this Privacy Statement or as described under the topic where such sensitive personal data is disclosed.
III. Methods of personal data collection
These personal data are collected in the context of:
- Visiting the Website
- Completing the contact form
- Incoming and outgoing correspondence with JA Europe (via email and/or telephone)
- Subscribing as volunteer
- Subscribing to newsletters
- Registering for the ESP project
- Submitting blogs for publication on the Website
- Commenting on blogs, published on the Website
All personal data, collected by JA Europe, are thus expressly and voluntarily provided by you.
Providing certain personal data is (sometimes) a requirement to be able to enjoy certain services (e.g. to communicate with JA Europe via contact form). In this respect, it shall be indicated which data must be provided mandatory and which data is optional.
IV. Use of personal data
JA Europe can use your personal data for the following purposes:
- Incoming and outgoing correspondence with JA Europe (via email and/or telephone)
- Responding to questions (whether or not received through the contact form)
- Optimizing the quality, management and content of the Website
- Confirmation of your subscription as a volunteer and any communication in this respect
- Confirmation of your registration for the ESP project and any communication in this respect
- Sending newsletters, updates and promotional offers based on your communication preferences and – where applicable – upon explicit consent
- Promotion of the ESP project
- Uploading your blog on the ESP website
Processing takes place on the following legal grounds, as the case may be:
- U have given consent to the processing of your personal data for one or more specific purposes
- Processing is necessary for the performance of the agreement with JA Europe or in order to take steps at your request prior to entering into an agreement
- Processing is necessary for compliance with a legal obligation to which JA Europe is subject
- Processing is necessary for the purposes of the legitimate interests pursued by JA Europe or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data (in particular when you are a child).
V. Disclosure of personal data to third parties
JA Europe shall not disclose your personal data to third parties unless it is necessary in the context of performing the agreement and optimization thereof (including but not limited to (local) support/assistance, maintenance of the Website, promotion of the project, for the delivery of services to JA Europe (i.e. in light of subcontracting)). In this respect, your personal data may be disclosed to:
- Payment providers
- Website developer and/or hosting partner
- Software providers and cloud partners
- JA Europe’s partners
- JA Europe’s sponsors
- JA local organizations. All current JA local organizations are located both within the European Economic Area (‘EEA’) and outside the EEA, as further described under the topic ‘Cross-border processing of personal data’.
If it is necessary that JA Europe discloses your personal data to third parties, the third party concerned is required to use your personal data in accordance with the provisions of this Privacy Statement. Furthermore, such transfer shall also be covered by a data processing agreement.
Notwithstanding the foregoing, it is however possible that JA Europe discloses your personal data:
- To the competent authorities (i) if JA Europe is obliged to do so under the law or under legal or future legal proceedings and (ii) to safeguard and defend our rights.
- If JA Europe, or the majority of its assets, are taken over by a third party, in which case your personal data – which JA Europe has collected – shall be one of the transferred assets
In all other cases, JA Europe will not sell, hire out or pass on your personal data to third parties, except when it (i) has obtained your permission to this end and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your personal data.
We may also share information with third parties in an aggregated or non-personally identifiable form.
VI. Cross-border processing of personal data
Any transfer of personal data outside EEA to a recipient whose domicile or registered office is in a country which does not fall under the adequacy decision enacted by the European Commission, shall be subject of one or more of the listed EU-approved safeguards:
- Closing a data transfer agreement with such recipient, which shall contain (i) the standard contractual clauses, as referred to in the 'European Commission decision of 5 February 2010 (Decision 2010/87/EC)', or (ii) any other mechanism pursuant to privacy legislation, or any other regulations pertaining to the processing of personal data; and/or
- Binding corporate rules; and/ or
- Certification mechanisms (such as but not limited to the EU-US Privacy Shield).
As mentioned under the previous topic, JA Europe closely cooperates with JA local organizations in the framework of its activities, who will provide local support/assistance. To do so, it might be necessary that JA Europe transfers your personal data outside the EEA. The transfer from JA Europe to the JA local organizations outside the EEA is covered by at least one of the EU-approved privacy safeguards, as mentioned above.
By accepting this Privacy Statement, you provide your explicit consent for these transfers, including cross-border processing of personal data.
VII. Storage of personal data
Unless a longer storage period is required or justified (i) by law or (ii) through compliance with another legal obligation, JA Europe shall only store your personal data for the period necessary to achieve and fulfil the purpose in question, as specified in the Privacy Statement under 'Use of personal data'.
VIII. Your privacy rights
In light of the processing of your personal data, you enjoy the following privacy rights:
- Right of access to your personal data
- Right to rectification, completion or update of your personal data
- Right to delete your personal data ('right to be forgotten'). (JA Europe wishes to point out that in this context certain services will no longer be accessible and/or can no longer be provided if you delete resp. request deletion of certain required personal data)
- Right to limit the processing of your personal data
- Right to transferability of your personal data
- Right to object to/oppose the processing of your personal data
In principle, you can exercise these rights free of charge via the above-mentioned form. In addition, you can always, via your personal account, update, modify and/or verify your personal data, which you were required to submit when creating your account.
If you no longer wish to receive newsletters, information about our services/programmes/projects and/or future promotional email communications, you can unsubscribe at any time by clicking the "unsubscribe" button underneath each of JA Europe’ emails.
IX. Security of personal data
JA Europe undertakes to take reasonable, physical, technological and organisational precautions in order to avoid (i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data.
JA Europe shall store all personal data, which it has collected, in the cloud with a data center located in the European Union.
Notwithstanding JA Europe’ Legal Disclaimer, the checks it carries out and the actions it proposes in this context, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the internet, or any method of electronic storage is 100% secure, JA Europe is, in this context, not in a position to guarantee absolute security.
X. Update Privacy Statement
JA Europe is entitled to update this Privacy Statement by posting a new version on the Website whereby JA Europe will indicate the revision data at the top of the front page of the Privacy Statement. As such, it is strongly recommended to regularly consult the Website and the page displaying the Privacy Statement of the Website, to make sure that you are aware of any changes.
XI. Other websites
The Website may potentially contain hyperlinks to other websites. When you click on one of these links, you may be redirected to another website or internet source that could collect information about you through cookies or other technologies. JA Europe does not bear any responsibility, liability or control authority over these other websites or internet resources, nor about their collection, use and disclosure of your personal data. You must check the privacy statements of these other websites and internet sources in order to be able to judge whether they act in accordance with the Privacy Legislation.
XII. Contact JA Europe
If you have questions and/or remarks about this Privacy Statement or the manner in which JA Europe collects, uses and/or processes your personal data, please contact JA Europe’s Data Privacy Office:
- Via mail: Rue Montoyer 46, 1000 (Brussels), Belgium.
In case you are not satisfied with the way JA Europe handled your questions and/or remarks or have any complaints about the way JA Europe collects, uses and and/or processes your personal data, note that you have the right to lodge a complaint with the Data Protection Authority.