Vie privée

Preamble

This Privacy Policy concerns all Personal Data that are collected and used by the "Data Controller", i.e. SPRL FORTUNOO, whose operational headquarters are located in Silversquare, Rue Arnaud Fraiteur 15/23, 1050 Brussels in Belgium and registered at the ECB under the number 0649.718.470.

FORTUNOO SPRL is the Belgian publisher of the NAOJO solidarity platform (naojo.com, naojo.be, naojo.eu, ....).

It is active in the new economy, and particularly in a current that is called "the benevolent economy". FORTUNOO intends to act in total respect with all its partners.

Your privacy is important to us. This is not just rhetoric. It is our duty to all our partners to respect the rights related to your Data in a transparent manner and to allow everyone to easily exercise these rights.

FORTUNOO and its NAOJO Platform respect the privacy of individuals and appreciate the trust of its customers, employees, suppliers, contractors, business partners and generous donor-participants.

FORTUNOO strives to collect and use Personal Data in a manner that complies and optimally complies with the laws of the countries in which it operates.

FORTUNOO is in full compliance with the Belgian Privacy Law and with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 applicable as from 25 May 2018, the so-called European Data Protection Regulation (hereinafter, "DPR").

It should be noted that FORTUNOO did not wait for the new European DPR regulation to guarantee the protection of its users' data. Indeed, as regards the Processing of Personal Data, FORTUNOO had made a declaration to the Commission de la Protection de la Vie Privée (Rue Haute, 139 in 1000 Brussels, Belgium) at the time of the first launch of its platform in test mode under the commercial name "FORTUNOO".

FORTUNOO's management recognizes the importance of identifying and protecting the organization's information assets to prevent the destruction, improper disclosure, inappropriate modification or unauthorized use of any information relating to its customers, employees and its generous donor-participants.

FORTUNOO is therefore committed to developing, implementing, maintaining and continuously improving its information security management system to ensure the confidentiality, availability and integrity of personal data and information in general.

This Privacy Policy concerns the information we collect on our NAOJO solidarity platform and in offline marketing activities. It explains precisely what Personal Data we collect and how we use it.

1. Definitions

Control Authority: A control authority designated by the Member State under Article 51 of the DPR. In Belgium this is the Data Protection Authority.

Personal Data (or Data): Any information relating to an identified or identifiable natural person (hereinafter referred to as "Concerned Person"). An "identifiable natural person" is 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 elements specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

Sensitive Data: Personal data related to sensitive aspects such as racial or ethnic identity, political opinions, religion or any other belief, health or any medical condition, criminal history, trade union membership or sexual orientation. Sensitive data may be processed with the consent of the concerned person. If the concerned person communicates sensitive data, he or she consents to the processing of such data by the Controller.

Internet user: The natural or legal person who visits the web page https://www.naojo.com/ ;
Notification: The information of the Authority by the Data Controller, in accordance with Article 33 of the DPR, in case of Violation of Personal Data.

Platform: "NAOJO" fundraising platform for the associative world managed by the Data Controller, FORTUNOO.

Privacy Policy: This policy concerns the protection of Personal Data.
Data Controller: the legal entity that determines the purposes and means of the Processing, i.e. the SPRL FORTUNOO whose registered office is located at 4280 HANNUT, Rue du Straux, 1 and registered with the Crossroads Bank for enterprises (CBE) under the number 0649.718.470.

Subcontractor: the natural or legal person, public authority, service or any other body that processes Personal Data on behalf of the Data Controller.

Processing: Any operation or set of operations, whether or not carried out by automated means and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, communication by transmission, dissemination or otherwise making available, alignment or combination, limitation, erasure or destruction.

User: The natural or legal person who creates an account on the Platform of the Data Controller.

Violation: A breach of security resulting, accidentally or unlawfully, in the destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to, personal data transmitted, stored or otherwise processed.

2. What information is collected ?

2.1 Users

2.1.1. Personal identification data
Your Personal Identification Data is collected when you register as a User on the FORTUNOO Platform.

In particular, FORTUNOO collects the following Data:
- Name ;
- First Name ;
- Date of Birth;
- Spoken Language ;
- Phone number ;
- E-mail address ;
- Address.

2.1.2 Financial identification data
When financial transactions take place on the platform, the following Financial Identification Data can be collected:
- Identification and bank account numbers ;
- Credit or debit card numbers;
- Secret codes.

2.1.3 Electronic Identification Data
The following Data may also be collected via the FORTUNOO website:
- Location ;
- IP address assigned at the time of connection ;
- Connection time ;
- Pages viewed;
- Type of browser used;
- Platform and/or operating system installed and used;
- Device used to connect (computer, tablet, smartphone, ...) ;
- Search engine and keywords used to access the website.

2.2 Internet users
The following Electronic Identification Data is collected when an Internet user visits the website:
- Location;
- IP address assigned at the time of connection;
- Connection time;
- Pages viewed;
- Type of browser used;
- Platform and/or operating system installed and used;
- Device used to connect (computer, tablet, smartphone, ...) ;
- Search engine and keywords used to access the website.

3. Who Collects the Data ?

The Data is collected by the Data Controller, either FORTUNOO SPRL or by STRIPE in the case of Financial Identification Data.

4. How is the Data collected ?

4.1. Personal Identifying Data
The Data is collected on the basis of the information that you provide to FORTUNOO, in particular when you register on the Platform as a User or when you complete your User profile.

4.2. Financial identification data
Concerning your financial data, NAOJO has chosen to trust STRIPE for all payment services by bank card and direct debit denominated in euros. STRIPE is a well-known and highly reputable solution for crowdfunding type payments, for which it is a worldwide reference.

By using the credit card payment system offered by NAOJO, you accept the Special Conditions of Use (SCU) of STRIPE. These SCU can be consulted in our General Conditions of Use here.

4.3. Electronic identification data
Data may also be collected via cookies.
The optimization of the use of the site indeed requires the implementation of text files ("cookies"), stored by your web browser on your hard disk, containing information on your Personal Data or your course on the site.
The use of cookies is intended to offer you a pleasant browsing experience and, where appropriate, adapted to your interests. If you wish, you have the right to oppose the recording of these "cookies" by configuring your computer according to the indications provided by the help of your browser.
If you disable cookies, the performance or use of the website may be affected.

5. Why do we collect your Data ?

Data is collected mainly for the purpose of the proper execution of the contractual relationship between the parties.

The Data may in particular be used for the following purposes
- The management of user accounts;
- The management of the website;
- The improvement of FORTUNOO's products and services;
- Sending newsletters for marketing and promotional purposes.

The sending of newsletters for marketing and promotional purposes is subject to your approval. You must give your consent when you register on the Platform ("opt-in" system).

You can unsubscribe from these newsletters at any time.

The Data can also be used for :
- Responding to and following up on requests for information
- Inform about possible changes in the services offered and/or the applicable texts (such as the general terms and conditions or the privacy policy)

The Data is also collected in order to meet legal obligations, in particular with respect to accounting, to comply with a court decision, to respond to a request from public authorities, to protect the interests of FORTUNOO, as well as those of its partners and customers and to protect its services, to enforce the Terms and Conditions, the Privacy Policy and any applicable text, to formulate a possible recourse or to limit any prejudice that FORTUNOO may suffer.

Data relating to the connection and use of the Website are collected for statistical purposes only.

Specific data concerning the winning participants: by winning a unique experience and taking possession of the winning experience to raise funds for a social organization on our NAOJO platform, the winning Participant agrees that we may use his/her first name, surname, image (photo or video) to communicate about the won experience and how it was carried out with him/her. The objective is to show the unique and very real side of the experiences that we offer on our platform. This includes that we may include the winning participant in the promotional materials of our platform, regardless of the medium (paper or online) and without compensation, in order to promote our NAOJO platform and continue to impact the world. This will be done in strict compliance with current legislation.

6. With whom will the Data be shared ?

The Data may possibly be communicated to third parties directly related to FORTUNOO, when necessary and in particular to the entities listed below:
- The Associations organizing the drawing operations on the Platform as " responsible organizer for the drawing operation";
- The service providers selected by FORTUNOO, which are in charge of hosting the Website and the Platform, the provision of infrastructure, IT services, e-mail services, auditing services and any other similar services in order to enable them to provide the said services or the service providers selected by FORTUNOO in charge of the security of the IT systems;
- To a potential buyer, in the event of a transfer (total or partial) of FORTUNOO's activities (merger, sale, transfer of assets, judicial reorganization, etc.).
- In the event of a dispute, the Data may be transmitted to a third party in charge of managing disputes (law firm, debt collection agency, etc.), which will also ensure compliance with the applicable legislation with respect to such information
- Accountant, public authority, etc., in order to comply with FORTUNOO's legal obligations (communicating Data to its accountant, responding to a request from public authorities, complying with a court decision, etc.).

The list of these service providers can be communicated upon request.

7. How do we secure the Data ?

FORTUNOO attaches particular importance to the protection and security of the Personal Data of its Users.

FORTUNOO makes every effort to ensure the integrity and protection of such Data against any form of damage, loss, intrusion, disclosure, alteration or destruction by means of appropriate technical and organizational measures such as, as required :
- means to ensure the constant confidentiality, integrity, availability and resilience of the Processing systems and services such as cryptography ;
- means to restore the availability of and access to Personal Data within appropriate time frames in the event of a physical or technical incident;
- the awareness and training of personnel in security policies and their implementation.

The details of the security measures are kept confidential to avoid any risk of intrusion and hacking of the Data.

8. How long will we keep the Data ?

The personal Data collected are stored and kept for the duration strictly necessary to achieve the purposes referred to above.

8.1 When you are registered on the Platform
Your Data is kept as long as you are registered on the site. This registration period is not limited. You can unsubscribe whenever you wish and in a very simple way, except if you participate in an ongoing operation.

8.2 When you have unsubscribed from the Platform
At the date of your unsubscription, the Data is kept for one year (to ensure a reasonable buffer zone between the end of your registration and any commitments made during your registration). If you are involved in an ongoing operation, you will only be able to unsubscribe 2 months after the end of the operation so that the entire normal process of an operation can be completed normally.

9. What rights do you have ?

A. Right to Information
You have a right to information concerning the collected Data. It is notably through this Privacy Policy that FORTUNOO wishes to fill in this information.

B. Right of Access
You have a right of access to your Personal Data.

In order to do so, you must make a request to FORTUNOO so that FORTUNOO can provide you with details of the specific Data it holds about you, subject to the rights and freedoms of others which cannot be infringed upon.

A response must be provided within one month of your request. However, this time limit may be extended by an additional month depending on the complexity and number of requests. In the latter case, you will be informed within one month of your request for access.

FORTUNOO is entitled to demand the payment of "reasonable fees" based on the administrative costs incurred to edit these documents in the event that the request is excessively recurrent, unfounded or manifestly intended to abuse this right of access.

C. Right of rectification
You have the right to obtain from FORTUNOO, as soon as possible, the rectification of the Personal Data concerning you that are inaccurate. You may also request that incomplete Data be completed, in particular by providing an additional declaration.

FORTUNOO will notify you of the completion of this process.

In addition, you may at any time access your account and edit your personal information, including your address in the "My Account" section of the Website or by contacting the relevant department at [email protected]
You may also delete credit card details at any time, and/or register a new card.

D. Right to Delete
You can claim the right to the deletion of your Data as soon as one of the following reasons arise:
- The Data is no longer necessary for the purposes for which it was collected or processed by FORTUNOO ;
- You wish to withdraw your consent and there is no other legal basis for such Processing;
- The Data has been the subject of unlawful Processing;
- The Data must be erased to comply with a legal obligation which is provided for by the law of the Union or by the law of the Member State to which FORTUNOO is subject;

In the event of such a request, FORTUNOO will take reasonable steps to delete such Data within one month of the request and will notify you of the completion of such action.

In the event that FORTUNOO does not wish to comply with such request, reasons will be given for its refusal. The right of deletion does not apply to the extent that the Processing of such Data is necessary:
- for the exercise of the right to freedom of expression and information ;
- to comply with a legal obligation which requires the Processing as provided for by the law of the European Union or by the law of the Member State to which FORTUNOO is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in FORTUNOO ;
- the establishment, exercise or defence of legal rights.

E. Right to Limitation of Treatment
You have the right to obtain from FORTUNOO the limitation of the Treatment when one of the following applies:
- the accuracy of your Personal Data is disputed, for a period of time that allows FORTUNOO to verify the accuracy of the Personal Data ;
- the Processing is unlawful and you object to their deletion and instead require the limitation of their use ;
- FORTUNOO no longer needs the Personal Data for the purposes of the Processing but they are still necessary for you to establish, exercise or defend your rights in court;
- You have objected to the Processing by virtue of your right to object, during the verification as to whether the legitimate reasons pursued by FORTUNOO prevail over yours.

This request for limitation implies that the Personal Data may, with the exception of conservation, only be processed with your consent, or for the establishment, exercise or defence of legal rights, or for the protection of the rights of another natural or legal person, or for important reasons of public interest of the European Union or of a Member State.

FORTUNOO will notify you of the completion of this procedure.

F. Right to portability
Where the Processing of your Personal Data is based on the consent you have given, or on a contract, and this Processing is carried out using automated processes, you may request to receive this Data in a structured, commonly used and machine-readable format.

You may pass on such Data to another data controller, without FORTUNOO being able to prevent this.

G. Right of opposition
You have the right to object at any time, for reasons relating to your particular situation, to any Processing of your Personal Data based on the public interest or the legitimate interest of FORTUNOO, including profiling based on such interests.

FORTUNOO will no longer process such Data, unless it demonstrates that there are legitimate and compelling reasons for the Processing that prevail over your interests and your rights and freedoms, or for the establishment, exercise or defence of legal rights.

10. Modification of the privacy policy

We will update this Privacy Policy when necessary to reflect customer feedback and changes to our products or services.
When we post changes to this statement, we will revise the "last updated" date at the bottom of the statement.

If material changes are made to this Statement or to the way FORTUNOO uses your Personal Information, we will notify you by posting a notice of such changes before they take effect or by sending you a notice directly to you.
We encourage you to periodically review this Privacy Statement to learn how FORTUNOO protects your information.

11. How can you enforce your rights ?

You can submit your request internally to the Data Controller, via the e-mail address [email protected] or by post to the Data Controller's head office.

In the event that the follow-up given to your complaint is not appropriate, you can always exercise one of the rights provided for above, or lodge a complaint with the Data Protection Authority. You can contact the Data Protection Authority as follows:
- By phone : (+32) (0)2 274 48 00
- E-mail: [email protected]
- Online contact form: https://www.privacycommission.be/en/contact-form
- By mail: Commission de la protection de la vie privée, Rue de la Presse 35, 1000 Brussels, Belgium
- Fax: (+32) (0)2 274 48 35

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