Sench values the handling of your personal data and recognizes the significance of protecting your privacy. Any personal data we receive from you will be processed in accordance with applicable data protection regulations, in particular with the General Data Protection Regulation 2016/679 of 27 April 2016 (“GDPR”), Belgian data protection legislation, as well as with this Privacy Policy (referred to as the “Policy”).

This Policy outlines how Sench SRL (referred to as “Sench”, “we”, “us”, and/or “our”) gathers, uses, shares, stores and protects your personal information. It includes details on the types of data collected by Sench, the reasons for processing it, and how you can exercise your rights regarding your personal data. 

“You” refers to our (potential) members, vendors, service providers or other suppliers, individuals with whom we have business relationships with, a visitor or user of our digital platforms/website or of our activities. 

In this Policy, “personal data” refers to any information that relates to an identifiable natural person. The term “process” means any activity relating to personal data, including, by way of example, collection, storage, use, consultation and transmission.

If you have any questions, comments, or concerns regarding personal data protection, or if you wish to exercise your rights, you can reach Sench at privacy@sench.be.

DATA CONTROLLER 
Sench is collaborative community of ecopreneurs & eco-conscious citizens working together to build a more sustainable and equitable world through conscious business & consumption practices. A forward-thinking eco-friendly club for eco-conscious citizens, brands and craftsman which brings economic prosperity while achieving social and ecological impact. We hereby collect and use personal data to manage our services and achieve our purposes.

For the purpose of this Policy, Sench – whose registered office is located at Avenue de Floréal 118, 1180 Brussels, with company number [BE0805162752] – is the “controller” in relation to its use of your personal data. This is a legal term – it means that we make decisions about how and why we process your personal data and, because of this, we are responsible for making sure it is used in accordance with data protection laws. 

PRIVACY COMMITMENT 
Sench is dedicated to protecting personal data that it has access to, handling it with care, and being transparent in its practices. Sench places a high value on the trust that it receives, and therefore abides by the following principles:

• Providing personal data is optional, but if certain data is not provided, Sench may not be able to provide some services or products. 
• Sench only collects and processes personal data for the purposes described in this Policy or for specific purposes that have been communicated to and/or consented to by the individual. 
• Sench adopts the principle of minimal data collection and processing, only collecting and processing the minimum amount of data necessary for our purposes. 
• Sench strives to keep personal information accurate and up-to-date, and offers the ability to modify it at any time through the member’s area of our website or through sending an e-mail to privacy@sench.be (see below under the title “Your Rights” for more information).
• Personal data will be deleted, destroyed, or anonymized if it is no longer needed and there is no legal obligation to retain it. 
• Personal data will not be sold or rented and will only be shared or disclosed for purposes related to this Policy, unless disclosure is required by law or government authorities.

PERSONAL DATA COLLECTED 
The personal data collected by Sench varies depending on the purpose and service provided. 

Sench may collect the following categories of personal data by collecting data through the use of our (or other) websites or social networks; by sharing content on social networks, websites, or applications related to our products or services; when you contact or request information from us; when you engage in our services or a as a result of your relationship with one or more of our staff and members:

• Contact information, such as (first) name, e-mail address(es), postal address(es), signature and contact details including phone number(s);
• Personal information, such as information about family members or friends for special events, and job application information (previous work experience, education, and references);
• User information, such as username and password;
• Communication with Sench, such as the content of the e-mail exchanges or social media messages to us and the technical details of interactions with us (e.g. with whom you communicate, the date, the time, etc.);
• Personal information for customization, such as date of birth, gender, lifestyle preferences, marketing/communication preferences, business interests and social circumstances;
• Technical information, such as information on surfing behavior (e.g. webpages visited, how often and when you visit a particular webpage, the amount of time you spend on a webpage, what links you click on), geographical location of your electronic device, and Internet Protocol (IP) address, browser plug-in types and versions, operating system, login data, time zone setting, technical data when visiting other websites using our cookies;
• Photographs, visual images and video recordings (for instance taken on Sench events, workshops, training and our conscious experiences);
• Any other information relating to you which you may provide to us. 

 

WHY IS YOUR PERSONAL DATA COLLECTED AND ON WHICH LEGAL BASIS?
The legal basis for processing your personal data may include:

• Consent: You have given permission for us to process your personal data. The consent will be freely given, clear and easy to withdraw (e.g. by sending an e-mail to privacy@sench.be);

• Contractual obligation: Processing your personal data is necessary in order for us to enter into a contract with you and/or to implement a contract;
• Legal obligation: Processing your personal data is necessary for us to (i) comply with our legal and regulatory obligations or (ii) respond to any reasonable requests from competent law enforcement agencies or representatives, courts and public bodies or organizations, including competent data protection authorities (e.g. providing your personal data to the police as evidence in relation to investigation of illegal acts or crimes when using our websites);
• Legitimate interest: Processing your personal is necessary for our legitimate interests or those of third parties. It constitutes a processing activity that is normally expected from our company. If the processing activity does not outweigh any risks to your rights and freedoms, we will refrain from processing your personal data for our own business purposes;

• Protecting your vital interests (or those of someone else).

Sench collects and processes your personal data for the following purposes:

• Membership administration and services

This includes the management of our membership (such as the administration of the member benefits); understanding our members’ interests; ensuring the quality of our services, providing you with personalized services and products that meet your expectations.

Our legal basis is the conclusion and performance of an agreement with you for providing our services/products as a member, or, if you are a third party, our legitimate interest in providing our services to our members.

• Communication services

This includes keeping you informed about our services, products and activities; managing communication services (such as newsletters and registration); and providing you tailored communications.

Our legal basis is our legitimate interest to promote our products, services and activities to our members and other third parties. Newsletters will be received by you only if you have given your consent. You are free to unsubscribe at any time for our newsletters and other forms of communications. 

• Activities

This includes organizing and developing our activities (such as our events (e.g. Storysharing, business speeddating and conferences), workshops, trainings and conscious experiences (e.g. diner, ecotrip, ecoactions, etc.)); the participation in contests and promotions.

Our legal basis is the conclusion and performance of an agreement with you as a participant of one of our activities. We will ask for your consent: (i) if we take targeted images of you during our activities, (ii) if we use content created by you; and are planning to share these images / content on our website, our social media and/or any other marketing campaign.

• Contact 

This includes responding to inquiries and contact you; authenticating the identity of individuals who contact us; and responding when you use our contact form on our website.

The legal basis for this processing is the consent you have given by providing your personal data when contacting us. 

• Web performance enhancement and security

This includes the processing of personal technical data when you visit our website www.sench.club, improving our website/application functionality, enhance your website browsing experience by customizing it to your preferences, while also safeguarding it against spam.

Our legal basis for essential and functional cookies is our legitimate interest, whereas the legal basis for analytical, advertising and social media cookies will be your explicit (see also our Cookie Policy for more details).

• Business-to-business administration

This includes conducting pre-contractual discussions and finalizing agreements with suppliers and business partners; communicating with them; managing orders and handling payments.

Our legal basis is the conclusion and performance of an agreement with you, or, if we do not have a contractual relationship, our legitimate interest in administering our B2B operations.

• Invoicing and accounting 

This includes processing payments if you purchase our products or services; and general invoicing and accounting purposes. 

Our legal basis is the legal obligation, as contained in Articles I.1, III.82, III.89 and III.90 of the Belgian Code of Economic Law, the Royal Decree of the Code of Companies and Associations (“CCA”), and article 3:1 CCA.

• Dispute management 

This includes the possible management of legal disputes. 

Our legal basis is to defend our legitimate interests in all forms of dispute resolution and to administer it.

HOW LONG IS YOUR PERSONAL DATA RETAINED BY SENCH? 
Sench retains the above mentioned personal data only for as long as necessary to fulfill the purpose for which it was collected. This includes the time to respond to your inquiries and completing any transactions, plus the period required for legal accounting and archiving obligations. If there is a claim or legal dispute, the retention period may be extended to defend our rights.

More specifically, if we base our processing activities on a contractual obligation, we will retain your personal data for ten (10) years as this is the maximum time period to file a contractual claim. If we process your personal data for invoicing and accounting purposes, we will retain it for seven (7) years. If we base our processing activities on your consent, we will retain your personal data until you withdraw such consent. We will renew your consent in appropriate intervals.

YOUR RIGHTS 
When Sench processes your personal data, you have certain rights that you can exercise at any time. To exercise these rights, you can send an email to the dedicated address: privacy@sench.be

• Right of access and information: You can receive information about how your personal data is processed and obtain a copy of that data. It suffices to send a detailed and signed application to us or the data processor (in the event we do not process the data ourself) with proof of identity and mentioning the processed data to which access is requested. Note that your request may not impact the rights and freedoms of other people (for example, the privacy and confidentiality rights of other members). We (or the data processor) do not have to comply with the request in the event no reasonable term has expired since your previous application which has been complied with or since the date on which you have been informed about this data.
• Right to correction: If you believe your personal data is inaccurate or incomplete, you can request that it be corrected or completed. You have a responsibility to help us to keep your personal information accurate and up to date. We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details. 
• Right to erasure: Under the conditions outlined in Article 17 of the General Data Protection Regulation (GDPR), you can request the deletion of your personal data (also known as the “right to be forgotten”). This is possible, for example, where your personal data is no longer needed for the purposes it was collected for, or where the relevant processing is unlawful. We may not be in a position to erase your personal data, if for example, we need it to (i) comply with a legal obligation, or (ii) exercise or defend legal claims. 
• Right to restrict processing: Under the conditions outlined in Article 18 of the GDPR, you can request that the processing of your personal data be restricted.
• Right to object: You have the right to object to the processing of your personal data based on your specific situation, if the processing is based on Sench’s legitimate interests. You have the absolute right to object to the processing of your personal data for direct marketing purposes.
• Right to withdraw consent: If the processing of your personal data is based on your consent, you can withdraw that consent at any time, free of charge. If you withdraw your consent, this will only take effect for future processing.
• Right to data portability: Under the conditions outlined in Article 20 of the GDPR, you have the right to receive your personal data which you have provided to us and which is processed by us by automated means (i.e. not for paper records), in a structured, commonly used machine-readable format, and if technically feasible, to have it transmitted directly to a third party. If you exercise this right, you should specify the type of information you would like to receive (and where we should send it), where possible, to ensure that our disclosure is meeting your expectations. The exercise of this right is only possible if the processing is based on your consent or on our contract with you. It covers only the personal data that has been provided to us by you. 
• Right to file a complaint with a Supervisory Authority: You have the right to file a complaint with a supervisory authority regarding our processing of your personal data. In Belgium, the supervisory authority is the Belgian Data Protection Authority (“Autorité de protection des données“/”Gegevensbeschermingsautoriteit”) (“BDPA”). 

Please find the contact details of the BDPA:
Address: Drukpersstraat 35, 1000 Brussels
Telephone number: +32 (0)2 274 48 00 or +32 (0)2 274 48 35
E-mail: contact@apd-gba.be 

For more information, please consult the website of the BDPA (in Dutch / French).

HOW DOES SENCH PROTECT YOUR PERSONAL DATA? 
Sench recognizes the significance of safeguarding your personal data and implemented appropriate technical and organizational measures to ensure the confidentiality of your personal data and to protect against accidental or unlawful destruction, loss, misuse, interference, harm, unauthorized access, alteration, or disclosure. The company has implemented several security measures, including access controls, firewalls, and secure servers, to ensure the protection of your personal data.

Sench could share your personal data with other organizations, (such as, i.a., IT service providers, marketing agencies, insurers, third parties involved in hosting or organizing the activities and our ecopreneurs);and where required by law or government authorities or in the context of legal proceedings. These third parties are carefully selected and contractually obliged to ensure the integrity of your personal data and put appropriate security standards in place to make sure your personal data is protected. 

International Transfers of your personal data may be processed outside the European Economic Area (EEA) in countries that have received an adequacy decision from the European Commission, meaning they offer a level of protection for personal data similar to the GDPR or we will ensure EU standard contractual clauses are in place between Sench and the entity with whom we transfer data to.

UPDATES TO THIS NOTICE 
We may update this notice from time to time to reflect changes to the type of personal data that we process and/or the way in which it is processed. We will update you on material changes to this notice. We also encourage you to check this notice on a regular basis.

CONTACT US 
If you have any questions, comments, or complaints regarding this Policy or the processing of your personal data, you can reach Sench through the e-mail address privacy@sench.be.