Privacy statement

Who is responsible

The controller is Orion-Solution CommV, Oude Keiemweg 12, 8600 Diksmuide, Belgium, company number BE 1015.276.135. The manager is Jasper Vande Moortel.

Send questions or requests about your data to jaspervandemoortel@orion-solution.net. We have not appointed a data protection officer.

What we collect, and why

We collect only what you enter yourself in one of the four forms on this website. For each form, this purpose and legal basis (Article 6 GDPR) apply:

• Sign-up for the second brain course: name, email address, optionally organisation or company, and your answers to the five intake questions. We use them to answer your sign-up and prepare your invoice. Legal basis: steps taken before entering into a contract, at your request (Article 6(1)(b)).
• Bootcamp interest: name, email address, school, role and optionally your idea for an application. Purpose and legal basis are the same as for the course.
• Waitlist for Hablar: name, email address and optionally school and subject. We use them to tell you when a place opens or when there is news about Hablar. Legal basis: your consent (Article 6(1)(a)), which you give by sending the form.
• Contact form: name, email address and your message. We use them to reply to you. Legal basis: your consent (Article 6(1)(a)), which you give by sending the form.
• Invoicing: if you book a course or bootcamp, we process your invoice details in our accounting and in Billit, the invoicing platform we use. Legal basis: a legal obligation (Article 6(1)(c)).
• Preventing abuse: to limit too many submissions from one address, the form stores your IP address only as a salted hash, an unreadable abbreviation made with a secret key. We delete that hash after one hour. Legal basis: our legitimate interest in protecting the forms and the mailbox (Article 6(1)(f)).
• With every submission we also store the form type, the time, the language of the page and whether the fill-time check passed (yes, or not available for a form used without JavaScript). We do not store how long filling it in took.

What you had better not enter

Do not write sensitive data (such as health information) or data about pupils in the free text fields. We do not need it.

Who receives your data

We do not sell your data and we do not use it for anyone else’s advertising. These providers process data on our behalf:

• Microsoft Azure (App Service, region West Europe), our web hosting. Each submission is stored there as one line in a log file, outside the publicly reachable folder of the website. Azure also keeps its usual web server logs, with IP addresses, for security. How long those are kept follows from the App Service log retention.
• Microsoft: Azure Communication Services (data location Europe) sends the notification of your submission, and it arrives as an email in the Orion-Solution mailbox in Microsoft 365. Every submission is therefore also stored there.
• Billit, for invoicing, when you book a course or bootcamp.

Transfers outside the European Economic Area

We choose services with their data location in the European Union. If a provider or a company in its group can still access data from outside the EEA, the transfer relies on an adequacy decision of the European Commission or on standard contractual clauses (Articles 45 and 46 GDPR). You can get a copy of those clauses on request.

How long we keep data

• A message through the contact form, or a sign-up that does not lead to a booking: at most 13 months after receipt. The log file is deleted one month at a time, which is why we say at most 13 months.
• A sign-up that leads to a booking: the copy in the log file follows the same 13 months. The invoice details stay in Billit for the legal accounting period, 7 years.
• The Hablar waitlist: at most 25 months after receipt. If you want off the list sooner, email me and I will delete your details by hand.
• The email with your submission in the Orion-Solution mailbox (Microsoft 365): I delete those emails by hand, on the same periods as above.
• The salted hash of your IP address at the form: 1 hour.
• The App Service web server logs in Azure, with IP addresses: the period follows from the App Service log retention.

Cookies and measuring

This website uses no cookies and does not measure your visit with analytics tools or other third-party tracking. That is why there is no cookie banner. The website loads no fonts or scripts from external services, so your browser does not fetch anything for them from another party.

Do you have to provide data

We need the fields marked as required to answer you or to register you. Without them we cannot process the form. The other fields are voluntary.

Your rights

You can ask us for:

• access to your data and a copy (Article 15);
• correction of inaccurate data (Article 16);
• erasure of your data, where the law allows it (Article 17);
• restriction of the processing (Article 18);
• your data in a usable format, when the processing rests on consent or a contract (Article 20);
• an end to the processing where it rests on our legitimate interest (Article 21).

Withdrawing your consent

Where the processing rests on your consent (the waitlist and the contact form), you can withdraw it at any time by emailing jaspervandemoortel@orion-solution.net. We then stop the processing and delete the data, unless a legal retention duty prevents it. What happened before the withdrawal stays lawful.

Making a request

Email jaspervandemoortel@orion-solution.net. We reply within one month. If your request is complex, that period can be extended by up to two months; we tell you within the first month. It costs you nothing. We may ask you to show who you are.

Making a complaint

If you are not satisfied with our answer, you can complain to the Belgian Data Protection Authority, Drukpersstraat 35, 1000 Brussels, contact@apd-gba.be, www.dataprotectionauthority.be. You can also go to court.

Automated decisions

We make no decisions about you that rest only on automated processing, and we do not build profiles.

Changes

If we change this statement, the new version appears here with a new date at the top.