Updated on July 21, 2022
1. Parties and Purpose
Aude Mirerekano (hereinafter “Yoroshe” or the “Data Controller”)
6 place de Bastogne 1081 koekelberg
BCE / VAT : 0767574856
Register of legal persons: Brussels
Mail : Mirerekano.email@example.com
Telephone : 0470658701
The term “User” refers to any user, i.e. any natural or legal person, who visits or interacts in any way with the Site.
As such, Yoroshe determines all the technical, legal and organizational means and purposes of the processing of Users’ personal data. To this end, Yoroshe undertakes to take all necessary measures to ensure that the processing of personal data complies with the Law of 30 July 2018, on the protection of natural persons with regard to the processing of personal data (hereinafter, “the Law”) and the European Regulation of 26 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter, “the Regulation”).
Yoroshe is free to choose any natural or legal person that processes the personal data of users at its request and on its behalf (hereinafter the “Processor”). Where applicable, Yoroshe undertakes to select a Processor offering sufficient guarantees as to the technical and organisational security measures for the processing of personal data, with regard to the Law and the Regulation.
2. Processing of personal data
The use of the Site by the Users may lead to the communication of personal data. The processing of such data by Yoroshe, in its capacity as Data Controller, or by the service providers acting in the name and on behalf of Yoroshe, will be in accordance with the Law and the Regulation.
The personal data will be processed by Yoroshe, in accordance with the purposes mentioned below, through:
- Automated procedure
- Subscription to a newsletter
- Answer to a quiz
- Response to a personalized diagnosis
- Sharing of free content
3. Purpose of the processing of personal dataIn accordance with Article 13 of the Regulation, the purposes of the processing of personal data are communicated to the User and are as follows:
- To ensure the execution of the services offered and agreed upon on the site
- To monitor the execution of the services offered
- To carry out marketing activities and promotional information after the user’s consent and until the revocation of such consent
- To answer the user’s questions
- Carry out statistics to improve the site, the services offered and the internal organization of operation
- To improve the quality of the site and the products and services offered by the responsible
- To allow a better identification of the user’s interests
- The information of the users that they give for contractual purposes and to allow the proper performance of mutual obligations, name, surname, address, IBAN number, bank data all information voluntarily given by the user.
- The information of the users by filling in forms or by contacting by telephone, e-mail or other means for the name, surname, address, e-mail address, telephone number of the users
- With respect to each of the users’ visits to the site, the information automatically collected is: IP address,
- Browser type and model, time zone, operating system.
- All information concerning the pages that the user has consulted on the site, including the URL
The User has the right to withdraw his/her consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on the consent previously given.
6. Duration of retention of Users’ personal dataIn accordance with Article 13 §2 of the Regulation and the Law, the Data Controller shall keep personal data only for as long as is reasonably necessary for the purposes for which they are processed.
This period is in any case less than : 1 year
7. Recipients of the data and disclosure to third partiesPersonal data may be passed on to employees, collaborators, subcontractors or suppliers of Yoroshe who offer adequate data security guarantees, and who collaborate with Yoroshe in the marketing of products or the provision of services. They act under the direct authority of Yoroshe, and are in particular responsible for collecting, processing or outsourcing such data.
In the event that the data is disclosed to third parties for direct marketing or canvassing purposes, the User will be informed beforehand so that he/she may express his/her consent to the use of such personal data.
8. Data Protection Officer (DPO)The following person is appointed Data Protection Officer (hereinafter “DPO”): Aude Marine Beatrice Mirerekano
The role of the DPO is to ensure the proper implementation of national and supranational provisions regarding the collection and processing of personal data.
The DPO can be contacted as follows Mirerekano.firstname.lastname@example.org
9. Users’ rightsAt any time, the User can exercise his rights by sending a message by e-mail to the following address Mirerekano.email@example.com, or a letter by post addressed, enclosing a copy of his identity card to the following address: 6 place de Bastogne 1081 koekelberg
a. Right of accessIn accordance with Article 15 of the Regulation, Yoroshe guarantees the User the right of access to his/her personal data. The User has the right to obtain access to said personal data as well as the following information
- the purposes of the processing ;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular recipients who are established in third countries or international organizations;
- where possible, the period of time for which the personal data will be kept or, where this is not possible, the criteria used to determine this period;
- The existence of automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the Regulation, and, at least in such cases, useful information regarding the underlying logic, as well as the significance and expected consequences of such processing for the data subject
The Controller may require payment of a reasonable fee based on administrative costs for any additional copies requested by the User.
Where the User makes such a request electronically (e.g. through the e-mail address), the information shall be provided in a commonly used electronic form, unless the User requests otherwise.
The User will be provided with a copy of his data within one month of receiving the request.
b. Right of rectificationYoroshe guarantees the right of rectification and erasure of personal data to the user.
In accordance with Article 16 of the Regulation, incorrect, inaccurate or irrelevant data can be corrected or deleted at any time. The User shall first make the necessary changes himself/herself from his/her user/other account, unless these cannot be made independently, in which case the request can be made to Yoroshe.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom personal data have been disclosed of any rectification of personal data, unless such disclosure proves impossible or requires disproportionate efforts. The Controller shall provide the data subject with information about such recipients if he or she so requests.
c. Right to erasureThe User has the right to obtain the erasure of his personal data as soon as possible in the cases listed in Article 17 of the Regulation.
Where the Controller has made the personal data public and is required to erase it pursuant to the preceding paragraph, the Controller shall, taking into account the available technologies and the costs of implementation, take reasonable steps, including technical steps, to inform the other controllers processing such personal data that the data subject has requested the erasure by such controllers of any link to such personal data, or any copy or reproduction thereof.
The two preceding paragraphs shall not apply to the extent that such processing is necessary:
- to exercise the right to freedom of expression and information;
- to comply with a legal obligation requiring the processing laid down by Union law or by the law of the Member State to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller
- for the establishment, exercise or defence of legal claims.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom personal data have been disclosed of any erasure of personal data or restriction of processing carried out, unless such disclosure proves impossible or would require disproportionate effort. The controller shall provide the data subject with information about such recipients upon request.
d. Right to limit processingThe User has the right to obtain the limitation of the processing of his/her personal data in the cases listed in article 19 of the Regulation.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data have been communicated of any restriction of the processing carried out, unless such communication proves impossible or requires disproportionate efforts. The Controller shall provide the data subject with information about such recipients if he or she so requests.
e. Right to data portabilityIn accordance with Article 20 of the Regulation, Users have the right to receive from Yoroshe personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transmit such data to another controller without Yoroshe hindering this in the cases provided for by the Regulation.
When the User exercises the right to data portability pursuant to the previous paragraph, she has the right to obtain that the personal data be transmitted directly from one data controller to another, where technically possible.
The exercise of the right to data portability is without prejudice to the right to erasure. This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
The right to data portability does not affect the rights and freedoms of third parties.
f. Right to object and automated individual decision makingThe User has the right at any time to object to the processing of his or her personal data due to his or her particular situation, including the automation of data carried out by Yoroshe. In accordance with Article 21 of the Regulation, Yoroshe will no longer process personal data unless there are compelling legitimate grounds for the processing that override the interests and rights and freedoms of the User, or for the establishment, exercise or defence of legal claims.
Where personal data are processed for the purpose of canvassing, the User has the right to object at any time to the processing of personal data concerning him or her for such canvassing purposes, including profiling insofar as it is related to such canvassing.
Where the data subject objects to the processing for canvassing purposes, the personal data shall no longer be processed for such purposes.
g. Right of complaintThe User has the right to lodge a complaint regarding the processing of his/her personal data by Yoroshe with the Data Protection Authority, competent for the Belgian territory. More information can be found on the website: https://www.autoriteprotectiondonnees.be.
Complaints can be submitted to the following addresses:
- Data Protection Authority
- Rue de la Presse 35, 1000 Brussels
- Phone + 32 2 274 48 00
- Fax: + 32 2 274 48 35
- E-mail: firstname.lastname@example.org
The User may also file a complaint with the court of first instance of his residence.
10. Limitation of liability of the data controllerThe website may contain links to other websites owned by third parties not related to Yoroshe. Yoroshe is not responsible for the content of these sites and their compliance with the Law and the Regulations.
The holder of parental authority must give his or her express consent for a minor under the age of 16 to disclose personal information or data on the website. Yoroshe strongly advises persons exercising parental authority over minors to promote responsible and secure use of the Internet. The Data Controller cannot be held responsible for collecting and processing information and personal data from minors under 16 years of age whose consent is not effectively covered by that of their legal parents, or for incorrect data -including data regarding age- entered by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he/she is under 16 years of age.
Yoroshe is not responsible for the loss, corruption or theft of personal data caused by viruses or computer attacks.
11. SecurityThe Data Controller implements organizational and technical measures to ensure a level of security appropriate to the processing and collection of data. These security measures depend on the costs of implementation with regard to the nature, context and purposes of the processing of personal data.
The Data Controller uses standard encryption technologies within the IT sector when transferring or collecting data on the Site.