PRIVACY CHARTER

The present Charter is established by SPRL Dokeos whose registered office is located at rue Provinciale, 264, 1301, Bierges, which can be contacted at the following email address: info@dokeos.com, registered at the ECB under the number: BE 0862 938 031 (hereinafter referred to as “Dokeos” or “we”). This Charter applies to the website referring to the url: https://www.dokeos.com (hereinafter referred to as the “website”) as well as to all instances of Dokeos software hosted on behalf of our clients. The purpose of this charter is to inform you about how we collect and process your personal data. Dokeos attaches great importance to your privacy and the security of your personal data. We act in full transparency, in compliance with the law of 8 December 1992 on the protection of privacy with regard to the processing of personal data and Regulation (EU) 2016/679 of the European Parliament and of the Council of the 27th of April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the “General Data Protection Regulation” or “GDPR”). If you wish to respond to any of the practices described below, you may contact us at privacy@dokeos.com of the present Charter.

 

Consent

 

By accessing and using the website, you declare that you have read the information described below, accept this Charter and expressly consent to our collecting and processing, in accordance with the terms and principles described below, of your personal data that you communicate to us through the website or the software, for the purposes indicated below.

 

You have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of the processing based on the consent previously given.

 

What data do we collect?

 

By visiting and using the website or browsing the Dokeos software, you expressly consent to our collection and processing of your personal data as described below:

 

your home domain (dynamic IP address), which is automatically detected by the server on each visit to the website;
if applicable, your e-mail address if you have voluntarily communicated it to us, for example via the contact form or request for access to a free portal;
information concerning the pages you have consulted on the website;
any other information you have voluntarily provided to us; information collected on your Dokeos LMS portal by the portal manager in your organisation. For example: your performance in the quizzes, your progress in the training courses and the training courses you have taken. This information is entrusted to us by your manager, managed by us and by our subcontractors for hosting purposes only, and we do not exploit it. Our subcontractors are subject to the same obligations to respect the confidentiality of your data;
We may also collect non-personal data. These data are qualified as non-personal data because they do not allow the direct or indirect identification of a particular person. It may therefore be used for any purpose, for example to improve the website or the software and the information it contains.

 

In the event that non-personal data is combined with personal data in such a way that identification of the persons concerned is possible, such data will be treated as personal data until such time as it is impossible to link it with a specific person.

 

How do we collect your data?

 

We collect your personal data as follows:

 

when you contact us via the contact form on the website;
when you fill in the form to request access to a test portal;
when you use the Dokeos software;
by one or more cookie(s).

 

What purposes do we pursue?

 

Your personal data are only collected and processed for the purposes mentioned below:

answer your questions or comments (for example questions about our software);
provide you with a test portal that meets your needs;
inform you about our products and services;
improve the quality of the website and the information it contains.

 

What is the shelf life of your data?

 

We only store your personal data for the time reasonably necessary for the purposes pursued and in accordance with legal and regulatory requirements, for a maximum of two years.

 

What are your rights and how can you exercise them?

 

By means of a written, dated and signed request sent to the address referred to privacy@dokeos.com of the present Charter and by justifying your identity (by attaching a copy of your identity card/passport) you can ask us to :

 

obtain a free of charge written communication or a copy of your personal data that has been collected. The copy of your data will be communicated to you at the latest within one month after receiving your written request;
obtain, as soon as possible and at the latest within one month, free of charge correction of your personal data which would be inaccurate, incomplete or irrelevant, as well as supplementing them if they prove to be incomplete;
limit the processing of your personal data, in particular in the following cases:

 

1) when you dispute the accuracy of a data and only for the time that we can control it;

 

2) when, although no longer necessary for the pursuit of the purposes of the treatment, you need it for the purpose of exercising or defending your rights in court;

 

obtain the deletion of your personal data, in particular when one of the following reasons applies:

 

1) your data are no longer necessary for the purposes of the treatment;

 

2) you have withdrawn your consent to have your data processed and there is no other legal basis for the processing.

 

Who has access to your data?

 

Your data is only accessible to Dokeos employees and its subcontractors within the strict framework of their working relationship with Dokeos and for which they have committed to respect this charter.

 

We do not disclose your personal information to any third party without your prior consent, unless it is necessary to respond to your requests or we are legally required to do so.

 

Do we use cookies?

 

The website uses cookies to make navigation more useful and reliable. Some of these cookies are necessary for the website to function, others are used to improve your experience.

 

Most web browsers are configured to accept cookies automatically. If you wish to customise the way they are managed, you should change your browser settings. Further information on this can be found below.

 

By visiting and using the website, you expressly agree with the cookie management described below.

 

Definition: A “cookie” is a file of data or texts that the server of a website temporarily or permanently records on the user’s equipment (hard disk of the computer, tablet, smartphone, or any other similar device) through its browser.

 

Cookies retain a certain amount of information, such as the language preferences of visitors. Other cookies collect statistics about the users of a website or ensure that graphics appear correctly and that applications work properly on the website.

 

What types of cookies do we use?

 

On the website, we use the following cookies:

 

Essential or technical cookies: these cookies are essential for the operation of the website, allowing good communication and intended to facilitate navigation;

 

Statistical or analytical cookies: these cookies are used to recognise and count the number of visitors and to see their browsing behaviour when they visit the website. This improves the user’s browsing experience and makes it easier for him to find what he is looking for;

 

Functional cookies: these cookies enable specific features on the website to improve usability and user experience, including remembering the user’s preference choices (e.g. language);

 

Performance cookies: these cookies collect information about how visitors use the website. They allow us to evaluate and improve the content and performance of the website (e.g. by counting the number of visitors, identifying the most popular pages or clicks), and to better match the content of the website to the user’s personal preferences;

 

Tracking cookies: The website uses tracking cookies via Google Analytics, in order to help us measure the ways in which users interact with the content of the website, and which generates visit statistics in a strictly anonymous way. These statistics continually improve the website and provide the user with relevant content. We use Google Analytics to get an overview of the traffic to the website, the origin of this traffic and the pages visited. This means that Google acts as a subcontractor. The information collected by Google Analytics is generated as anonymously as possible. For example, it is not possible to identify the people who visit the website. For further information, the user is invited to consult the Google data protection policy, available at the following address: https://www.google.nl/intl/en_uk/policies/privacy/

 

The retention period for cookies varies according to their type: essential cookies are generally retained until the browser is closed, while functional cookies remain valid for 1 year and performance cookies for 4 years.

 

We allow public search engines to visit the website via the ‘spiders’ with the sole purpose of making the access and the content of the website accessible through their search engines, without granting the right to archive the website. We reserve the right to withdraw the permission as stated in this article at any time.

 

How can you manage / disable cookies?

 

Most browsers are set to automatically accept cookies, but all allow you to customise the settings according to your preferences.

 

If you do not want the website to place cookies on your computer/mobile device, you can easily manage or delete them by changing your browser settings. You can also set your browser to notify you when you receive a cookie, so you can decide whether or not to accept it.

 

If you want to block and/or manage certain cookies, you can do so by following the link linked to your browser:

 

Internet Explorer:
https://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

 

Chrome:
https://support.google.com/accounts/answer/61416?hl=en

 

Firefox:
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

 

Safari:
https://support.apple.com/kb/PH5042

 

If you do not want to accept cookies from Google Analytics, you can indicate this via the message about cookies that appears on your first visit to the website or by customising your browser settings so that you refuse cookies.

 

To stop being tracked by Google Analytics on any website, you are invited to visit the following website
https://tools.google.com/dlpage/gaoptout

 

In the event that you deactivate certain cookies, it is possible that certain parts of the website will not be accessible and/or usable or only partially.

 

How do we secure your personal data?

 

We implement the appropriate technical and organizational measures to guarantee a level of security of data collecting and processing in relation to the risks presented by the treatment and the nature of the data to be protected. We take into account the state of knowledge, the costs of implementation and the nature, scope, context and purpose of the processing as well as the risks to your rights and freedoms.

 

We always use encryption technologies that are recognised as industry standards within the IT sector when transferring or receiving data on the website.

 

We have implemented appropriate security measures to protect and prevent the loss, misuse or alteration of information received on the website.

 

File a complaint ?

 

If you wish to respond to any of the practices described in this Charter, you can contact us at privacy@dokeos.com.

 

You can submit a complaint to the Belgian Commission for the Protection of Privacy at the following address:

 

Commission for the Protection of Privacy

 

Rue de la Presse, 35

 

1000 Bruxelles

 

Phone number: + 32 2 274 48 00

 

Fax: + 32 2 274 48 35

 

commission@privacycommission.be

 

You can also submit a complaint to the court of first instance in your place of residence.

 

For more information on complaints and possible remedies, you are invited to consult the following address of the Belgian Commission for the Protection of Privacy:
https://www.privacycommission.be/de/node/19254

 

How to contact us ?

 

If you have any questions and/or complaints, particularly about the clarity and accessibility of this Charter, you can contact us at the following addresses:

 

Via email:
privacy@dokeos.com

 

By post : Dokeos SPRL, Rue Provinciale, 264, 1301 BIERGES

 

Modification of this Charter

 

We reserve the right to modify the provisions of this Charter at any time. The modifications will be published with a notice as to their entry into force.

 

Applicable law and jurisdiction

 

This Charter is governed by Belgian law.

 

Any dispute relating to the interpretation or execution of the present Charter will be subject to Belgian law and will fall under the exclusive competence of the courts of the judicial district of Brabant Wallon, Belgium.

 

Last update: May 7, 2018