The attached Privacy Statement serves as the Standard Privacy Statement. All members agree to it upon Member Registration or Member Activation.
Clubs - Privacy Statement - https://demo.klubs.be/myprivacy
Privacy Statement
1. Why this privacy statement?
Each user of this application (hereinafter "User") discloses a certain amount of personal data to various parties.Because you are a natural person who is uniquely identifiable based on this data, an explicit consent must be given before being allowed to process this data, both for the club and for KLUBS, the software behind this application.
We process this data in accordance with the privacy legislation of 8 December 1992 and by extension the amended GDPR legislation of 27 April 2016 regarding the further protection of personal data.
By using this application, you consent to the processing of data as described in this privacy statement. Your club has the right to modify this privacy statement at any time. Any substantial modification will be communicated to the Users and will require an explicit consent via the software.
2. Who is responsible for processing personal data?
2.1. Controller
The club acts as controller of the processing of personal data. If you want to change your data, you can always do so via your contact persons within the club or via your own profile. The club has the capabilities necessary within the GDPR legislation to delete your data, export it from the platform and change it if necessary.
2.2. Processors
KLUBS acts as a processor of the data and cannot itself modify anything in profiles without the express consent of the controller.KLUBS acts as a technical party to maintain the software and consequently collects on its servers the necessary personal data to keep the platform running. Also in case of direct access to certain data,KLUBS will always ask for the approval of the controller.
3. Ground of processing
We process your data on the basis of explicit consent (opt-in after registration or account creation). If the person responsible for the club changes or adds data to your profile, they do so solely on their own responsibility and on the basis of the User's consent. If, for example, an official membership with terms of use exists between the club and the User, this can additionally be seen as grounds for processing to enable club management.
4. What data will be processed?
KLUBS itself will process only the necessary data to guarantee your access to the platform. These are the following fields:email address, name & first name, password. All additional information in the profile can be completed by the Controller and the User. As the club itself can create unlimited profile fields, this can include all kinds of information. However, the data controller undertakes to request only the data necessary for processing the User's membership data (e.g. contact details, company data, date of birth, gender, nationality, profile picture, etc.).
Personal data can only be retrieved after the express approval requested when using the platform for the first time.
5. For what purposes is my data processed
KLUBS and the processing manager collect your personal data solely for the purpose of optimizing membership management, providing insight into member profiles and registering for activities or memberships. This processing is therefore considered essential to ensure the optimal functioning of the club.
Your data will be processed for the following purposes:
- To grant the User access to the platform
- To manage and configure the User's memberships and accesses
- For the User to register opactivities
- For the User to interact with other Users
- To ensure the efficient and smooth operation of the club
When using the application, user logs can be registered which indicate when and how the User has used the application. These are only used for statistical purposes and are in no way used to confront Users with their surfing behavior.
6. Who processes your personal data assubprocessor
Your data is processed for internal use only. However, KLUBS may use sub-processors for the optimal operation of the application. For this, however, it is ensured that your data is not sent to unknown processors outside the EU. By approving this privacy statement, you also agree to the processing by the following sub-processors:
- Combell - hosting of database & application.Retention unlimited as long as KLUBS engages this party for hosting.
- Mailgun - transactional mailing, obtainskel mail address + html mail, with a maximum retention of 3 days.
- Yuki / Treasurer / Mollie - if there are links through the APIs, please refer to the processing terms of these parties as the club always enters into a direct agreement with them
KLUBS takes the necessary legal and technical precautions to avoid unauthorized use of the application. In the event of a data breach, KLUBS will do everything in its power to protect the data as quickly and effectively as possible and to prevent further misuse. As a user, you will be informed immediately as required by law.
7. How long will your data be kept?
Your data will be processed as long as deemed necessary for the operation of the Club. When the user is no longer a member, he/she may choose to delete the data immediately, otherwise the data will be kept by default for 1 year for marketing and reactivation purposes.
8. What rights do I have as a User?
8.1 Legitimate processing and data protection
Your data are always processed lawfully and legitimately as defined in Article 5. They are processed in a secure and relevant environment and are not kept in the application longer than necessary.
8.2 Right to access data
If you wish, a User can request the right to access his/her data. Of course, this can be done via the profile where the data can be managed and copied by the User. In addition, the User also has the right to request an overview of all processed data from the Controller. The latter will consequently provide an overview of all processed data, including memberships and attendance at activities. The Controller undertakes to process such requests within a reasonable period (1 week).
8.3 Right to correct data
Incorrectly processed data can be corrected in the application both by the User and the Controller.
8.4 Right to be forgotten
Every user always has the right to be forgotten in the application and database. Various rules apply to this, whereby such a request must always be approved by the club manager. The processing of data may be necessary to continue a membership. Under the following assumptions a user can have his data deleted:
- There is no further legal basis for the processing of data, e.g. upon expiration of membership or deregistration from declub
- Revoking the express consent previously given on this privacy notice
- When the data has been unlawfully processed or obtained
- When the law requires the deletion of data
In case of deletion of data, KLUBS reserves the right to reduce the names of individuals to initials and limit demail addresses to the format a@g*.c(being alexander@gmail.com) in order to provide statistics and evidence of deletion. All other personal data will not be anonymized but will be deleted.
9. How can I exercise my rights?
In the platform, the user can exercise their rights through the profile / Privacy Toolboxdiens. If this fails, you can also contact the club administrator at any time.
10. Complaints
In the event of complaints regarding the processing of personal data by KLUBS or the club itself, the User may file a complaint with the data protection authority at https://www.privacycommission.be
11. Data Protection Officer
KLUBS is assisted in this by a certified DataProtection Officer. He can also be consulted at any time at dpo@klubs.be. The processing of data has also been declared to the Data Protection Authority of Belgium.