This regulates the processing of your personal data by Walk VZW (hereinafter: “Walk”, “we”, “us”) when you:
a) visit our website (https://www.walkingent.be, hereinafter referred to as: “Website”);
b) wish to communicate with us via e-mail, telephone and social media (hereinafter: “social media channels”, e.g. Facebook);
c) join us as a guide or participate in our activities.
d) make a reservation with us and pay online.
1. GENERAL
1.1 Your data will be processed by Walk VZW, Slootwede 15, 9050 Gentbrugge, Belgium, with company number 1004.174.880. You can contact us by e-mail at contact@walkingent.be.
1.2 What is ‘personal data’? Personal data is defined in the GDPR (General Data Protection Regulation) as ‘any information relating to an identifiable person who can be identified, directly or indirectly’. Personal data is, in simpler terms, any information about you that makes it possible to identify you.
1.3 Where reference is made to certain laws or regulations, such reference shall also include any amendment, replacement or annulment of said laws or regulations, including any related implementing decrees.
1.4 Walk reserves the right to change or modify the Privacy Policy at its sole discretion. Any such change or modification will be communicated via the website.
2. TYPES OF PERSONAL DATA WE PROCESS
2.1 When you use our website and social media channels, we may collect the following personal data:
– technical information about the device you are using, such as your IP address, browser type, geographic location, and operating system;
– information about your browsing habits, such as how long you visit the page, which links you click on, which pages you visit and how often you visit the page.
2.2 When you contact us via email, telephone or social media channels, we collect:
– the basic identity information you provide to us, such as name, email address, mailing address, telephone number;
– the content of your communication and the technical details of the communication itself (with which of us you correspond, the date, time, etc.);
– your preferences regarding receiving our email communications, such as information about our activities, etc.;
– any other personal data you provide to us.
2.3 When you become a guide with us, we collect and process the following personal data about you:
– the basic identity information you provide to us, such as name, email address, postal address, telephone number, date of birth;
– financial information, in particular your account number;
– portfolio data (languages and topics guided);
– your photo.
2.4 When you make a reservation with us via the website, email, telephone or social media channels, we collect:
– the basic identity information you provide to us, such as name, email address, mailing address, telephone number;
– the content of your communication and the technical details of the communication itself (with which of us you correspond, the date, time, etc.);
– your preferences regarding receiving our email communications, such as information about our activities, etc.;
– any other personal data you provide to us.
3. PURPOSES FOR WHICH WALK USES YOUR PERSONAL DATA
3.1 Walk uses your personal data to provide you with the information you request via email, telephone or social media channels in an appropriate and efficient manner.
3.2 We will also process your personal data when you apply to us to become a guide, as part of the normal membership administration of our organisation. If you wish to participate in our activities, we will process the personal data indicated above in order to facilitate your participation. We also process your personal data in order to be able to inform you and the other participants about the past activities afterwards, for example by means of atmospheric images.
3.3 We process your personal data to comply with legal obligations or to comply with any reasonable request from authorised agents or representatives of law enforcement, judicial authorities, public authorities or bodies, including competent data protection authorities. Walk may also, on its own initiative, transmit your personal data to the police or to the judicial authorities as evidence or if there is a justified suspicion of an unlawful act or crime when using our website, social media channels or other communications with us, in the context of your participation in our activities.
3.4 Walk may process your personal data to protect Walk’s legitimate interests, in particular to safeguard our evidence in preparation for or during a dispute settlement or legal proceedings as well as to keep our website, social media channels and activities secure.
3.5 Walk may process personal data of customers who have purchased a tour from us within the past 2 years in order to keep them informed of new tours in Ghent.
3.6 Walk may send an e-mail with an evaluation form after the end of a tour in order to check whether the tour meets expectations and to be able to evaluate and improve our services.
4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
4.1 You give your explicit consent to the processing of your personal data for the purpose described in Article 3.1 when you submit your request for information.
4.2 The processing of your personal data for the purpose described in Article 3.2 is necessary for the performance of the agreement we have with you as a guide or participant in our activities.
4.3 The processing of your personal data for the purposes mentioned in article 3.3 is necessary to enable Walk to comply with its legal obligations.
4.4 The processing of your personal data for the purpose referred to in Article 3.4 is necessary for Walk’s legitimate interest, namely to:
– enable us to defend ourselves in judicial and out-of-court proceedings;
– Protect our website, social media channels and activities from abuse and illegal activities
4.5 The processing of personal data as referred to in 3.5. is based on our legitimate interest, namely to be able to keep recent customers of ours informed of new tours or activities.
4.6 The processing of personal data as referred to in 3.6. is based on our legitimate interest, namely to verify that our tours meet customer expectations and to be able to evaluate and improve our services for customers.
5 RECIPIENTS AND TRANSFERS
5.1 In principle, Walk will only send your personal data to yourself and other participants in an identifiable manner insofar as this is part of the reporting of past activities. We may also transfer your personal data to the third parties described below and to competent governmental and judicial authorities if they request us to do so. However, you understand that if you use our social media channels, your personal data will also be processed by the social media providers. You can find more information about how these social media providers process your personal data in their respective privacy policies.
5.2 We work with a third party processor to provide you with the Website and to facilitate payments.
6 QUALITY GUARANTEES
6.1 Walk does its utmost to only process the personal data that is necessary to achieve the objectives as described above.
6.2 Your personal data will only be kept for the purpose of achieving the purposes described above until the moment you withdraw your consent to its processing. We will de-identify your personal data when it is no longer needed for the purposes described above, unless:
– there is an overriding interest of Walk or another third party in keeping your personal data identifiable;
– there is a legal or regulatory obligation or a judicial or administrative order that prevents us from de-identifying them.
6.3 We will take the appropriate technical and organisational measures to protect your personal data against unauthorised access or theft, as well as accidental loss, falsification or destruction. However, you understand that safety and security are best efforts commitments and can never be guaranteed.
7. YOUR RIGHTS
7.1 Some rights are complex and not all details are included here. Therefore, please read the relevant provisions and guidelines of supervisory authorities for a full explanation of these rights.
7.2 You have the right to request access to all your personal data processed by Walk, which relate to you. Walk reserves the right to charge an administrative fee for multiple successive access requests, which are clearly intended to cause inconvenience or damage to Walk.
7.3 You have the right to request that all personal data relating to you that is inaccurate be corrected free of charge. You also have the right to request that your personal data be completed if it is incomplete.
7.4 You have the right to request that personal data relating to you be deleted, if
– the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
– you withdraw your consent to processing based on consent;
– you object to processing in accordance with certain rules of applicable data protection law (the GDPR);
– the processing is used for direct marketing purposes;
– the personal data has been unlawfully processed;
– the personal data has been collected in the case of a direct offer of services to a child and the processing is carried out on the basis of consent;
– the personal data must be erased in order to comply with a legal obligation to which we are subject.
However, there are exclusions from the right to erasure of data. The general exclusions include where processing is necessary:
– To exercise the right to freedom of expression and information;
– To comply with a legal obligation to which we are subject;
– To establish, exercise or defend legal claims;
– For archiving in the public interest, scientific or historical research or statistical purposes;
– For reasons of public interest in the field of public health.
7.5 Instead of erasure, you can also request that Walk restrict the processing of your personal data if and when
a) you contest the accuracy of that data,b) the processing is unlawful,c) you exercise your right to object or d) the data is no longer necessary for the purposes described above,
but you need this data to defend yourself in court.
7.6 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease processing the personal data, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or that the processing is for the establishment, exercise or defence of legal claims. In addition, you have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you object to this, we will cease processing your personal data for this purpose. Furthermore, you have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes for reasons relating to your particular situation, unless the processing is necessary for the performance of a task carried out in the public interest.
7.7 You have the right to receive your personal data from us in a structured, commonly used and machine-readable format to the extent that the legal basis for our processing of your personal data is based on:
a) Consent
b) The processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request before entering into a contract; or
c) This processing is carried out by automated means;
This right does not apply where it would encroach on the rights and freedoms of others.
7.8 If you wish to submit a request to exercise one or more of the above-mentioned rights, you can send an e-mail to contact@walkingent.be. Walk will respond to your request within one month of receiving your request. Normally, we aim to provide a complete answer within that timeframe. However, in some cases, especially if your request is more complex, more time may be required, up to a maximum of three months from the date we receive your request. You will be kept fully informed of the progress.
If you believe that our processing of your personal data violates the General Data Protection Regulation (GDPR), you have the right to lodge a complaint with a supervisory authority responsible for data protection. In Belgium, the supervisory authority is the Data Protection Authority (DPA).
Contact: Data Protection Authority (DPA)Drukpersstraat 35, 1000 Brussels+32 (0)
2 274 48 00 contact@apd-gba.be
https://www.gegevensbeschermingsautoriteit.be
Data subjects from other Member States have the right to lodge a complaint with their own national supervisory authority.
7.9 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw this consent at any time. Revocation does not affect the lawfulness of the processing prior to the revocation.
Version 03/01/2024